RESPONSE TO REQ TO PRODUCE - PLTS F/B DFT

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                          Filing # 126516055 E-Filed 05/10/2021 04:55:49 PM

IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT, IN AND FOR PALM

BEACH COUNTY, FLORIDA

Case No. 50-2021-CA-004348-XXXX-MB DIV:
AF

JOSEPH BILOTTI AND CATHERINE
BILOTTI,

Plaintiffs,
vs.

UNITED PROPERTY AND CASUALTY
INSURANCE COMPANY,

Defendant.
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DEFENDANT UNITED PROPERTY & CASUALTY INSURANCE COMPANY’S
RESPONSE TO PLAINTIFF’S REQUEST FOR PRODUCTION

COMES NOW, the Defendant UNITED PROPERTY & CASUALTY INSURANCE
COMPANY (“UNITED”), by and through their undersigned counsel and pursuant to the
Florida Rules of Civil Procedure and files this Response to the Plaintiffs’ First Request for
Production served with the summons and complaint as follows:

OBJECTIONS TO DEFINITIONS
Defendant objects to Plaintiffs’ definitions to the extent they invade the work

product, claim file, or attorney/client privilege. Defendant further objects to the extent that
the definitions seek information from persons or entities not parties to this lawsuit. …