135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33156

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-CV-22671-ALTONAGA/TORRES

DELIO BATISTA,

CARLOS LOPEZ,

MARIANA LOPEZ, and

RAFAELA VALIENTE,

Plaintiffs,

vs.

AVANT ASSURANCE INC., 

REINIER CORTES, AND 

ANDREA GONZALEZ QUINTERO,

Defendants.

______________________________/

NAME: The Corporate Defendant with knowledge of the claims and 

defenses raised in this lawsuit, its general business operations, and 

matters relevant to the pleadings, and the matters identified in 

Exhibit “A” hereto.

DATE AND TIME: April 11, 2023 commencing at 10:00 a.m

PLACE: Via Zoom. (link will be provided day before)

Upon oral examination before a court reporting service, a Notary Public, or any other 

notary public or officer authorized by law to take depositions in the State of Florida. This 

deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as 

are permitted under the Rules of Court. The deposition will continue from hour to hour and from 

day to day until completed.

[Certificate of Service on the Following Page]

Case 1:22-cv-22671-CMA Document 56-1 Entered on FLSD Docket 05/04/2023 Page 1 of 3
135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33156

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing document was served 

on March 29, 2023 to Santiago Cueto, Esq. at sc@cuetolawgroup.com, and Davy A. Karkason, 

Esq. at dk@cuetolawgroup.com, as Counsels for Defendants.

FAIRLAW FIRM

Counsel for Plaintiff

135 San Lorenzo Avenue

Suite 770

Coral Gables, FL 33146

Tel: 305.230.4884

Fax: 305.230.4844

s/Toussaint Cummings, Esq.

Toussaint Cummings, Esq.

Fla. Bar No. 119877

toussaint@fairlawattorney.com

Case 1:22-cv-22671-CMA Document 56-1 Entered on FLSD Docket 05/04/2023 Page 2 of 3
135 San Lorenzo Avenue, Suite 770, Coral Gables, FL 33156

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

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EXHIBIT A: AREAS OF INQUIRY

1. All employees of Defendant, and other persons known to Defendant with knowledge of any 

issues or discoverable matter in this lawsuit, including knowledge of the claims and defenses 

asserted.

2. The factual basis for denying every paragraph that Defendant denied of the Complaint 

filed by Plaintiff, in whole or in part, in its respective Answer to same.

3. The factual basis for every affirmative defense raised by Defendant in its Answer to the 

Complaint filed by Plaintiff.

4. The bonus and commission agreements in force during each Plaintiff’s time working for 

Avant.

5. All commission payments made to each Plaintiff by Avant Assurance, Inc. (“Avant”), and 

the basis for those payments.

6. All bonus payments made to each Plaintiff by Avant, and the basis for those payments.

7. All contracts between Avants and each Plaintiff. 

8. Work schedules for each Plaintiff and other people working at/for Avant from 2020 to 

2022.

9. Process for signing up customers/clients to Avant form procuring leads to client obtaining 

insurance. 

10. All requests by each Plaintiff for payment of commissions and bonuses. 

Case 1:22-cv-22671-CMA Document 56-1 Entered on FLSD Docket 05/04/2023 Page 3 of 3