MOTION TO COMPEL

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                          Filing # 134792472 E-Filed 09/17/2021 11:31:42 AM

IN THE CIRCUIT COURT OF THE 15™!

JUDICIAL CIRCUIT IN AND FOR

PALM BEACH COUNTY, FLORIDA

CASE NO.: 50-2021-CA-000551-XXXX-MB
CHRISTOPHER AND BERNADETTE CHIN LEE,

Plaintiffs,

vs.

TOWER HILL SIGNATURE
INSURANCE COMPANY,

Defendant.
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DEFENDANT, TOWER HILL SIGNATURE INSURANCE COMPANY’S,
MOTION TO COMPEL DEPOSITIONS AND SANCTIONS

Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY, by and through
undersigned counsel, hereby files this Motion to Compel Deposition Dates and for Sanctions
and in support states as follows:

Ll. Pursuant to Rule 1.380(2) of the Florida Rules of Civil Procedure, Defendant
TOWER HILL SIGNATURE INSURANCE COMPANY (hereinafter “Tower Hill”) hereby files
a motion to compel deposition dates of Plaintiffs, CHRISTOPHER AND BERNADETTE CHIN
LEE, and their PUBLIC ADJUSTER, AFTERMATH ADJUSTERS & CONSULTING, LLC.

2. Despite requests for the aforementioned depositions, Plaintiffs’ counsel is refusing
to coordinate or a…