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Filing # 58193613 E-Filed 06/23/2017 03:02:17 PM
IN THE CIRCUIT COURT OF THE 11™
JUDICIAL CIRCUIT IN AND FOR
MIAMI DADE COUNTY, FLORIDA
OTTO ESPINO and ADELFA ESPINO GENERAL JURISDICTION DIV.
CASE NO.: 2017-014528-CA-01
Plaintiff(s),
vs.
UNIVERSAL PROPERTY and CASUALTY INSURANCE COMPANY
Defendant,
a
PLAINTIFFS’ FIRST SET OF INTERROGATORIESTO DEFENDANT
COMES NOW the Plaintiffs OTTO ESPINO and ADELFA ESPINO, by and through
their undersigned counsel, and propounds the attached Interrogatories to Defendant,
UNIVERSAL PROPERTY and CASUALTY INSURANCE COMPANY and requests
Defendant to answer in writing, under oath, pursuant to the applicable Florida Rules of Civil
Procedure.
Dated this day of May 2017.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and a correct copy of the foregoing First Set of
Interrogatories and the attachments were served on the Defendant along with the Summons and
Complaint.
/s/ Senen Garcia
SENEN GARCIA, ESQ
Attorney for Plaintiffs
SG Law Group
3400 Coral Way, Suite 603
Coral Gables, Florida 33145
Telephone No.: 305-285-3042
Facsimile No.: 305-285-3043
SG Law Group
Property Claims Division
3400 Coral Way Suite 603 Coral Gables , Florida 33145
Telephone No.: (305) 285-3042 - Facsimile No.: (305) 285-3043KINDLY ATTACH ADDITIONAL SHEETS AS REQUIRED IDENTIFYING THE NUMBERED
INTERROGATORY BEING ANSWERED
(Definitions: “You” as used in these Interrogatories means your corporation, company or
partnership, or anyone who handles operations on its behalf.)
we
Please state the full name, occupation/title, present residence, and business address of the
person answering these interrogatories and anyone who assisted in answering the same
Please state the basis and/or the provision in the Defendant’s denial of coverage for the
claim at issue presented by the Plaintiffs.
Please describe each document upon which the Defendant relies on for its denial of
coverage for the loss at issue with sufficient particularity to allow a description in a
Request for Production.
Please describe with detail and specificity all facts and circumstances giving rise to the
Defendant’s defense(s) and any affirmative defense(s) raised in this matter.
Please identify, including the full legal names, present business address and residential
address, of each and every individual at the insurance company who was involved in the
subject claim and the extent of their involvement.
YOU HAVE A CONTINUING OBLIGATION TO UPDATE THE INFORMATION IN THESE
INTERROGATORIES AS YOU ACQUIRE NEW INFORMATION. IF NO SUCH UPDATE IS
PROVIDED IN A REASONABLE PERIOD OF TIME FROM THE TIME YOU ACQUIRED SUCH
INFORMATION, IT MAY BE EXCLUDED AT TRIAL OR HEARINGKINDLY ATTACH ADDITIONAL SHEETS AS REQUIRED IDENTIFYING THE NUMBERED
INTERROGATORY BEING ANSWERED
6. Please state the name, professional address and home address of each person who may or
is expected by you, your attorney or any representative of yours, to testify as an expert
witness during trial in this matter.
A. Please list each expert’s profession and occupation and the specialty field in which
he/she is alleged an expert.
B. Please state all qualifications of the subject expert which enables him/her to render an
opinion in this cause.
C. Please state the subject matter upon which each expert is expected to testify
Please list any and all opinions the expert has in regard to the subject matter of this
litigation outlining each fact or facts determined, the substance of the facts relied upon,
and a summary for the grounds of each opinion.
7. Please list the names and addresses of all persons who are believed or known by you,
your agents; or attorneys, to have any knowledge concerning any of the issues raised by
the pleadings and all facts pertaining to the loss, claim, investigation, evaluation, and
coverage decision on the claim and specify the subject matter about which the witness
has knowledge and provide the person’s employer, all phone numbers and other contact
information.
8. Please list each and every witness whose statements have been taken pertaining to any
issue raised by the Complaint filed herein, indicating each person’s full legal name,
resident addresses, and telephone numbers in regard to the subject matter of this
litigation
YOU HAVE A CONTINUING OBLIGATION TO UPDATE THE INFORMATION IN THESE
INTERROGATORIES AS YOU ACQUIRE NEW INFORMATION. IF NO SUCH UPDATE IS
PROVIDED IN A REASONABLE PERIOD OF TIME FROM THE TIME YOU ACQUIRED SUCH
INFORMATION, IT MAY BE EXCLUDED AT TRIAL OR HEARINGKINDLY ATTACH ADDITIONAL SHEETS AS REQUIRED IDENTIFYING THE NUMBERED
INTERROGATORY BEING ANSWERED
9. If applicable, please provide the last known address for each individual the Defendant or
anyone on its behalf who assisted with the handling, adjusting, investigating, evaluating
and decision making of the claim and is no longer employed with the Defendant and/or
the entity in which they were employed at the time of the loss and claim
10 Please identify all inspections conducted by the Defendant and/ or on the Defendant’ s
behalf, relative to the subject loss and claim. Please identify the date of the inspection and
the name, entity, and address of the individual who conducted the inspection(s).
By:
STATE OF FLORIDA)
)Ss
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared, ;
who is personally known to me or who produced
as identification and who after first being duly sworn,
States that the above and foregoing answers to Interrogatories are true and correct.
SWORN TO AND SUBSCRIBE this day of 2017
NOTARY PUBLIC, at large
My Commission Expires:
YOU HAVE A CONTINUING OBLIGATION TO UPDATE THE INFORMATION IN THESE
INTERROGATORIES AS YOU ACQUIRE NEW INFORMATION. IF NO SUCH UPDATE IS
PROVIDED IN A REASONABLE PERIOD OF TIME FROM THE TIME YOU ACQUIRED SUCH
INFORMATION, IT MAY BE EXCLUDED AT TRIAL OR HEARING
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Filing # 58193613 E-Filed 06/23/2017 03:02:17 PM IN THE CIRCUIT COURT OF THE 11™ JUDICIAL CIRCUIT IN AND FOR MIAMI DADE COUNTY, FLORIDA OTTO ESPINO and ADELFA ESPINO GENERAL JURISDICTION DIV. CASE NO.: 2017-014528-CA-01 Plaintiff(s), vs. UNIVERSAL PROPERTY and CASUALTY INSURANCE COMPANY Defendant, a PLAINTIFFS’ FIRST SET OF INTERROGATORIESTO DEFENDANT COMES NOW the Plaintiffs OTTO ESPINO and ADELFA ESPINO, by and through their undersigned counsel, and propounds the attached Interrogatories to Defendant, UNIVERSAL PROPERTY and CASUALTY INSURANCE COMPANY and requests Defendant to answer in writing, under oath, pursuant to the applicable Florida Rules of Civil Procedure. Dated this day of May 2017. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and a correct copy of the foregoing First Set of Interrogatories and the attachments were served on the Defendant along with the Summons and Complaint. /s/ Senen Garcia SENEN GARCIA, ESQ Attorney for Plaintiffs SG Law Group 3400 Coral Way, Suite 603 Coral Gables, Florida 33145 Telephone No.: 305-285-3042 Facsimile No.: 305-285-3043 SG Law Group Property Claims Division 3400 Coral Way Suite 603 Coral Gables , Florida 33145 Telephone No.: (305) 285-3042 - Facsimile No.: (305) 285-3043KINDLY ATTACH ADDITIONAL SHEETS AS REQUIRED IDENTIFYING THE NUMBERED INTERROGATORY BEING ANSWERED (Definitions: “You” as used in these Interrogatories means your corporation, company or partnership, or anyone who handles operations on its behalf.) we Please state the full name, occupation/title, present residence, and business address of the person answering these interrogatories and anyone who assisted in answering the same Please state the basis and/or the provision in the Defendant’s denial of coverage for the claim at issue presented by the Plaintiffs. Please describe each document upon which the Defendant relies on for its denial of coverage for the loss at issue with sufficient particularity to allow a description in a Request for Production. Please describe with detail and specificity all facts and circumstances giving rise to the Defendant’s defense(s) and any affirmative defense(s) raised in this matter. Please identify, including the full legal names, present business address and residential address, of each and every individual at the insurance company who was involved in the subject claim and the extent of their involvement. YOU HAVE A CONTINUING OBLIGATION TO UPDATE THE INFORMATION IN THESE INTERROGATORIES AS YOU ACQUIRE NEW INFORMATION. IF NO SUCH UPDATE IS PROVIDED IN A REASONABLE PERIOD OF TIME FROM THE TIME YOU ACQUIRED SUCH INFORMATION, IT MAY BE EXCLUDED AT TRIAL OR HEARINGKINDLY ATTACH ADDITIONAL SHEETS AS REQUIRED IDENTIFYING THE NUMBERED INTERROGATORY BEING ANSWERED 6. Please state the name, professional address and home address of each person who may or is expected by you, your attorney or any representative of yours, to testify as an expert witness during trial in this matter. A. Please list each expert’s profession and occupation and the specialty field in which he/she is alleged an expert. B. Please state all qualifications of the subject expert which enables him/her to render an opinion in this cause. C. Please state the subject matter upon which each expert is expected to testify Please list any and all opinions the expert has in regard to the subject matter of this litigation outlining each fact or facts determined, the substance of the facts relied upon, and a summary for the grounds of each opinion. 7. Please list the names and addresses of all persons who are believed or known by you, your agents; or attorneys, to have any knowledge concerning any of the issues raised by the pleadings and all facts pertaining to the loss, claim, investigation, evaluation, and coverage decision on the claim and specify the subject matter about which the witness has knowledge and provide the person’s employer, all phone numbers and other contact information. 8. Please list each and every witness whose statements have been taken pertaining to any issue raised by the Complaint filed herein, indicating each person’s full legal name, resident addresses, and telephone numbers in regard to the subject matter of this litigation YOU HAVE A CONTINUING OBLIGATION TO UPDATE THE INFORMATION IN THESE INTERROGATORIES AS YOU ACQUIRE NEW INFORMATION. IF NO SUCH UPDATE IS PROVIDED IN A REASONABLE PERIOD OF TIME FROM THE TIME YOU ACQUIRED SUCH INFORMATION, IT MAY BE EXCLUDED AT TRIAL OR HEARINGKINDLY ATTACH ADDITIONAL SHEETS AS REQUIRED IDENTIFYING THE NUMBERED INTERROGATORY BEING ANSWERED 9. If applicable, please provide the last known address for each individual the Defendant or anyone on its behalf who assisted with the handling, adjusting, investigating, evaluating and decision making of the claim and is no longer employed with the Defendant and/or the entity in which they were employed at the time of the loss and claim 10 Please identify all inspections conducted by the Defendant and/ or on the Defendant’ s behalf, relative to the subject loss and claim. Please identify the date of the inspection and the name, entity, and address of the individual who conducted the inspection(s). By: STATE OF FLORIDA) )Ss COUNTY OF ) BEFORE ME, the undersigned authority, personally appeared, ; who is personally known to me or who produced as identification and who after first being duly sworn, States that the above and foregoing answers to Interrogatories are true and correct. SWORN TO AND SUBSCRIBE this day of 2017 NOTARY PUBLIC, at large My Commission Expires: YOU HAVE A CONTINUING OBLIGATION TO UPDATE THE INFORMATION IN THESE INTERROGATORIES AS YOU ACQUIRE NEW INFORMATION. IF NO SUCH UPDATE IS PROVIDED IN A REASONABLE PERIOD OF TIME FROM THE TIME YOU ACQUIRED SUCH INFORMATION, IT MAY BE EXCLUDED AT TRIAL OR HEARING