On October 15, 2019 a
Request for Production - to Defendant United Property and Casualty Insurance CompanyParty: Plaintiff Cayobit, Ricardo Plaintiff Cayubit, Roland
was filed
involving a dispute between
Cayobit, Ricardo,
Cayubit, Roland,
and
United Property And Casualty Insurance Company,
for Contract and Indebtedness
in the District Court of Broward County.
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Case Number: CACE-19-021361 Division: 25
Filing # 97313220 E-Filed 10/15/2019 03:22:33 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY,
FLORIDA
RICARDO CAYOBIT AND ROLAND CAYUBIT,
Plaintiffs,
v.
UNITED PROPERTY AND CASUALTY INSURANCE
COMPANY,
Defendant. Case No.:
REQUEST FOR PRODUCTION
COMES NOW, Plaintiff(s) by and through the undersigned attorneys and pursuant to the applicable
Florida Rules of Civil Procedure, hereby requests the Defendant to produce the following items for inspection
and/or copying at the offices of the undersigned attomeys:
1. The original and/or a true and correct certified copy of the insurance policy described in the
Complaint including declaration page and all addendums, if any.
2. All correspondence or written communications from Defendant to Plaintiff regarding the subject
loss alleged in the Complaint.
3. Any and all written estimates of repairs created by and/or on behalf of the Defendant regarding
any and all damages to the subject premises allegedly occurring as a result of the subject loss.
4. Copies of all checks issued by Defendant and payable to or on behalf of Plaintiff representing
insurance proceeds for the subject loss alleged in the Complaint.
5. Copies of Plaintiff's recorded statement(s) taken by Defendant or their agents regarding the subject
loss alleged in the Complaint.
6. Copies of Plaintiff's Examination Under Oath Transcript(s) regarding the subject loss alleged in
the Complaint.
7. All delivery receipts, written proof of mailing and all other records evidencing in any manner the
date and/or dates that the entire policy of insurance described in the complaint/Complaint was mailed or delivered
to Plaintiff.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/15/2019 03:22:30 PM.****8. Any and all field notes and/or all other documentation of any sort relating to any investigation
undertaken with regard to the Plaintiff’s claim prior to Defendant’s reasonably anticipated litigation.
9. Any and all photographs, video, diagrams, or other documentation depicting the subject loss and/or
relating to the Plaintiff's subject property.
10. The underwriting file relating to the Plaintiff's subject property.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon Defendant
by the Insurance Commissioner of the State of Florida.
LEVY & PARTNERS, PLLC
Attorneys for Plaintiff
3230 Stirling Road, Suite 1
Hollywood, Florida 33021
(954) 727-8570 - Telephone
Robin@lawlp.com - E-Mail
Maritza@lawlp.com - Secondary Service
By: /s/ Robin A. Richison
ROBIN A. RICHISON, Esq.
Florida Bar No.: 42009
Preview
Case Number: CACE-19-021361 Division: 25 Filing # 97313220 E-Filed 10/15/2019 03:22:33 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RICARDO CAYOBIT AND ROLAND CAYUBIT, Plaintiffs, v. UNITED PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. Case No.: REQUEST FOR PRODUCTION COMES NOW, Plaintiff(s) by and through the undersigned attorneys and pursuant to the applicable Florida Rules of Civil Procedure, hereby requests the Defendant to produce the following items for inspection and/or copying at the offices of the undersigned attomeys: 1. The original and/or a true and correct certified copy of the insurance policy described in the Complaint including declaration page and all addendums, if any. 2. All correspondence or written communications from Defendant to Plaintiff regarding the subject loss alleged in the Complaint. 3. Any and all written estimates of repairs created by and/or on behalf of the Defendant regarding any and all damages to the subject premises allegedly occurring as a result of the subject loss. 4. Copies of all checks issued by Defendant and payable to or on behalf of Plaintiff representing insurance proceeds for the subject loss alleged in the Complaint. 5. Copies of Plaintiff's recorded statement(s) taken by Defendant or their agents regarding the subject loss alleged in the Complaint. 6. Copies of Plaintiff's Examination Under Oath Transcript(s) regarding the subject loss alleged in the Complaint. 7. All delivery receipts, written proof of mailing and all other records evidencing in any manner the date and/or dates that the entire policy of insurance described in the complaint/Complaint was mailed or delivered to Plaintiff. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/15/2019 03:22:30 PM.****8. Any and all field notes and/or all other documentation of any sort relating to any investigation undertaken with regard to the Plaintiff’s claim prior to Defendant’s reasonably anticipated litigation. 9. Any and all photographs, video, diagrams, or other documentation depicting the subject loss and/or relating to the Plaintiff's subject property. 10. The underwriting file relating to the Plaintiff's subject property. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon Defendant by the Insurance Commissioner of the State of Florida. LEVY & PARTNERS, PLLC Attorneys for Plaintiff 3230 Stirling Road, Suite 1 Hollywood, Florida 33021 (954) 727-8570 - Telephone Robin@lawlp.com - E-Mail Maritza@lawlp.com - Secondary Service By: /s/ Robin A. Richison ROBIN A. RICHISON, Esq. Florida Bar No.: 42009