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Filing# 142505114 E-Filed 01/24/2022 12:29:43 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
VALLI LENTINI,
Plaintiff.
V CASE NO.: CACE-21-003799
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.,
Defendant.
i
RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION TO PLAINTIFF
COME NOW, Plaintiff,
VALLI LENTINI, by and through the undersigned counsel,and
file this,her response to Defendant's Request for Production and as such would state as follows:
1. All documents and communications relatingto payment to plumbers, public adjusters,
engineers,consultants, construction experts, inspectors,experts of any kind, repair
personnel,and/or contractors in connection with the insurance claim or the prosecutionof
this action.
ANSWER: All documents in possessionof the Plaintiff are as follows:
a) Homeowners estimate for repairswith sketch of property;
b) Correspondence from Homeowners dated November 28,2020;
c) Correspondence from Homeowners dated December 23,2020;
d) Correspondence from Homeowners dated January 18, 2021;
e) Check to Insured dated December 16,2020;
f) Measurement notes;
g) Pinnacle Claim Service, Inc agreement for Public Adjustingservices;
h) Pinnacle Claim Service,Inc. welcome letter to Insured;
i) Pinnacle Claim Service, Inc. estimate for repairs;
j) Pinnacle Claim Service, Inc photographreport with eighteen(18)color photographsof
the loss;
k) Twenty (20) color photographs of the loss;
1) Sworn Proof of Loss;
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/24/2022 12:29:42 PM.****
CASE NO.: CACE-21-003799
m) Homeowners Insurance policyof insurance,policynumber HCPC-HO6-253273-8;
2. All documents and communications relatingto damage to the property associated with the
claim at issue in this lawsuit.
ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
3. All invoices, receipts, to repairsperformed or to be performed to the
or estimates relating
property followingthe date of loss.
ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
4. All documents and communications relatingto the terms and conditions upon which the
receiptof financial income, includingdamages in this action,will be divided between you
and any public adjuster,appraiser,attorney, contractor, expert, repairpersonnel and/or
anyone else.
ANSWER: Objection,unduly burdensome, outside the scope of discovery for this claim,
and not likelyto lead to admissible evidence. Please see Plaintiff' PrivilegeLog. Subject
to and without waving said objections, documents in possessionof the
all non-privileged
Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's
Request for Production number 1, above.
5. All documents and communications between you and:
a. to the property which constitutes the basis of this lawsuit,the alleged
Defendant relating
loss which constitutes the basis of this lawsuit, insurance coverage and/or the insurance
claim which constitutes the basis of this lawsuit.
b. Your agents relatingto the property which constitutes the basis of this lawsuit, the
alleged loss which constitutes the basis of this lawsuit, insurance coverage and/or the
insurance claim which constitutes the basis of this lawsuit.
c. Public adjusters, experts of any
engineers,consultants,construction experts, inspectors,
kind, repair personnel,and/or contractors relatingto the property which constitutes the
basis of this lawsuit,the allegedloss which constitutes the basis of this lawsuit,insurance
coverage and/or the insurance claim which constitutes the basis of this lawsuit.
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CASE NO.: CACE-21-003799
d. Government code
including,but not limited to, buildinginspectors,
or publicofficials,
relatingto the property which constitutes the basis ofthis
enforcement and code inspectors,
lawsuit, the alleged loss which constitutes the basis of this lawsuit, insurance coverage
and/or the insurance claim which constitutes the basis of this lawsuit.
ANSWER: Objection,unduly burdensome, outside the scope of discoveryfor this claim,
and not likelyto lead to admissible evidence. Subject to and without waving said
objections,all non-privileged documents in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
6. All permits and applications to repairsassociated with this insurance
for permitsrelating
claim.
ANSWER: None in claim file.
7. All documents and communications relating
to the subjectmatter of this lawsuit (thisdoes
not seek any item which are protectedby attorney client privilegeor the work product
doctrine).
ANSWER: All non-privileged documents in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
8. All documents and communications relating
to contracts or retainers with individuals hired
by you in connection with the insurance claim which constitutes the subjectof this lawsuit.
ANSWER: Objection,unduly burdensome, outside the scope of discoveryfor this claim,
and not likelyto lead to admissible evidence. Please see Plaintiff' PrivilegeLog. Subject
to and without waving said objections, documents in possessionof the
all non-privileged
Plaintiff have been previously produced by way of Plaintiff' Response to Defendant's
Request for Production number 1, above.
9. All documents relied upon in presentingthe insurance claim.
ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
10. All photographs and videotapesrelated to the claimed damage.
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CASE NO.: CACE-21-003799
ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
11. All bills,invoices,receiptsor other documents relating
to additional livingexpenses or
fair rental value loss in connection with the insurance claim which constitutes the subject
of this lawsuit.
ANSWER: All non-privileged documents in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
12. All documents and communications relatingto contents damage in connection with the
insurance claim which constitutes the subjectofthis lawsuit.
ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
13. All documents and communications relatingto any purportedassignment of the insurance
claim.
ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
14. Copies of all correspondence, letters,
notes, memos emails, memoranda and documents
from any individuals or entities who did emergency or mitigation repairs and/or
replacementson the subjectresidence followingthe loss.
ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
15. All plumbing invoices, diagrams, videos, photographs,and reports related to the subject
insurance claim.
ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been
previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production
number 1, above.
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CASE NO.: CACE-21-003799
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished Roye, Esq., Attorneys for Defendant, HOMEOWNERS CHOICE
to: Christina
PROPERTY & CASUALTY INSURANCE COMPANY, INC., using the Florida Courts E-
ith
croye@hcpci.comi and brreid@hcpci.com on this 24? dayor
Filing Portal, at: legal@hcpci.corn:
January, 2022.
By-. /s/ Lora A. Lieb
LORA A. LIEB, ESQ.
Florida Bar No: 123874
WEISSER ELAZAR & KANTOR, PLLC
Attorneys for Plaintiff
800 East Broward Boulevard, Suite 510
Fort Lauderdale, FL 33301
T: (954) 486-2623
F: (954) 572-8695
Email: LL@WEKLaw.com
SG@WEKLaw.com
Service@WEKLaw.com
5
Preview
Filing# 142505114 E-Filed 01/24/2022 12:29:43 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA VALLI LENTINI, Plaintiff. V CASE NO.: CACE-21-003799 HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC., Defendant. i RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION TO PLAINTIFF COME NOW, Plaintiff, VALLI LENTINI, by and through the undersigned counsel,and file this,her response to Defendant's Request for Production and as such would state as follows: 1. All documents and communications relatingto payment to plumbers, public adjusters, engineers,consultants, construction experts, inspectors,experts of any kind, repair personnel,and/or contractors in connection with the insurance claim or the prosecutionof this action. ANSWER: All documents in possessionof the Plaintiff are as follows: a) Homeowners estimate for repairswith sketch of property; b) Correspondence from Homeowners dated November 28,2020; c) Correspondence from Homeowners dated December 23,2020; d) Correspondence from Homeowners dated January 18, 2021; e) Check to Insured dated December 16,2020; f) Measurement notes; g) Pinnacle Claim Service, Inc agreement for Public Adjustingservices; h) Pinnacle Claim Service,Inc. welcome letter to Insured; i) Pinnacle Claim Service, Inc. estimate for repairs; j) Pinnacle Claim Service, Inc photographreport with eighteen(18)color photographsof the loss; k) Twenty (20) color photographs of the loss; 1) Sworn Proof of Loss; *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/24/2022 12:29:42 PM.**** CASE NO.: CACE-21-003799 m) Homeowners Insurance policyof insurance,policynumber HCPC-HO6-253273-8; 2. All documents and communications relatingto damage to the property associated with the claim at issue in this lawsuit. ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 3. All invoices, receipts, to repairsperformed or to be performed to the or estimates relating property followingthe date of loss. ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 4. All documents and communications relatingto the terms and conditions upon which the receiptof financial income, includingdamages in this action,will be divided between you and any public adjuster,appraiser,attorney, contractor, expert, repairpersonnel and/or anyone else. ANSWER: Objection,unduly burdensome, outside the scope of discovery for this claim, and not likelyto lead to admissible evidence. Please see Plaintiff' PrivilegeLog. Subject to and without waving said objections, documents in possessionof the all non-privileged Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 5. All documents and communications between you and: a. to the property which constitutes the basis of this lawsuit,the alleged Defendant relating loss which constitutes the basis of this lawsuit, insurance coverage and/or the insurance claim which constitutes the basis of this lawsuit. b. Your agents relatingto the property which constitutes the basis of this lawsuit, the alleged loss which constitutes the basis of this lawsuit, insurance coverage and/or the insurance claim which constitutes the basis of this lawsuit. c. Public adjusters, experts of any engineers,consultants,construction experts, inspectors, kind, repair personnel,and/or contractors relatingto the property which constitutes the basis of this lawsuit,the allegedloss which constitutes the basis of this lawsuit,insurance coverage and/or the insurance claim which constitutes the basis of this lawsuit. 2 CASE NO.: CACE-21-003799 d. Government code including,but not limited to, buildinginspectors, or publicofficials, relatingto the property which constitutes the basis ofthis enforcement and code inspectors, lawsuit, the alleged loss which constitutes the basis of this lawsuit, insurance coverage and/or the insurance claim which constitutes the basis of this lawsuit. ANSWER: Objection,unduly burdensome, outside the scope of discoveryfor this claim, and not likelyto lead to admissible evidence. Subject to and without waving said objections,all non-privileged documents in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 6. All permits and applications to repairsassociated with this insurance for permitsrelating claim. ANSWER: None in claim file. 7. All documents and communications relating to the subjectmatter of this lawsuit (thisdoes not seek any item which are protectedby attorney client privilegeor the work product doctrine). ANSWER: All non-privileged documents in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 8. All documents and communications relating to contracts or retainers with individuals hired by you in connection with the insurance claim which constitutes the subjectof this lawsuit. ANSWER: Objection,unduly burdensome, outside the scope of discoveryfor this claim, and not likelyto lead to admissible evidence. Please see Plaintiff' PrivilegeLog. Subject to and without waving said objections, documents in possessionof the all non-privileged Plaintiff have been previously produced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 9. All documents relied upon in presentingthe insurance claim. ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 10. All photographs and videotapesrelated to the claimed damage. 3 CASE NO.: CACE-21-003799 ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 11. All bills,invoices,receiptsor other documents relating to additional livingexpenses or fair rental value loss in connection with the insurance claim which constitutes the subject of this lawsuit. ANSWER: All non-privileged documents in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 12. All documents and communications relatingto contents damage in connection with the insurance claim which constitutes the subjectofthis lawsuit. ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 13. All documents and communications relatingto any purportedassignment of the insurance claim. ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 14. Copies of all correspondence, letters, notes, memos emails, memoranda and documents from any individuals or entities who did emergency or mitigation repairs and/or replacementson the subjectresidence followingthe loss. ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 15. All plumbing invoices, diagrams, videos, photographs,and reports related to the subject insurance claim. ANSWER: All non-privilegeddocuments in possession of the Plaintiff have been previouslyproduced by way of Plaintiff' Response to Defendant's Request for Production number 1, above. 4 CASE NO.: CACE-21-003799 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished Roye, Esq., Attorneys for Defendant, HOMEOWNERS CHOICE to: Christina PROPERTY & CASUALTY INSURANCE COMPANY, INC., using the Florida Courts E- ith croye@hcpci.comi and brreid@hcpci.com on this 24? dayor Filing Portal, at: legal@hcpci.corn: January, 2022. By-. /s/ Lora A. Lieb LORA A. LIEB, ESQ. Florida Bar No: 123874 WEISSER ELAZAR & KANTOR, PLLC Attorneys for Plaintiff 800 East Broward Boulevard, Suite 510 Fort Lauderdale, FL 33301 T: (954) 486-2623 F: (954) 572-8695 Email: LL@WEKLaw.com SG@WEKLaw.com Service@WEKLaw.com 5