On April 22, 2021 a
Party Discovery
was filed
involving a dispute between
Biscayne Friendly Llc,
and
Westchester Surplus Lines Insurance Company,
for CONTRACT & DEBT
in the District Court of Palm Beach County.
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Filing # 131482874 E-Filed 07/27/2021 12:40:37 PM
IN THE CIRCUIT COURT OF THE 15!
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 50-2021-CA-005140
BISCAYNE FRIENDLY, LLC,
Plaintiff,
v.
WESTCHESTER SURPLUS LINES
INSURANCE COMPANY,
Defendant.
/
DEFENDANT, WESTCHESTER SURPLUS LINES INSURANCE COMPANY’S
FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
Defendant, Westchester Surplus Lines Insurance Company (“Defendant”) serves its First
Request for Production upon Plaintiff, Biscayne Friendly, LLC (“Plaintiff”). The documents shall
be produced to undersigned counsel within the time limits required by law.
INSTRUCTIONS
If you object to fully identifying a document or oral communication because of a
privilege, you are requested to provide a privilege log of the following information as to each
document, unless divulging the information would disclose the privilege information.
(1) The nature of the privilege claimed (including work product);
(2) If the privilege is being asserted in connection with a claim or defense governed
by state law, the state privilege rule being invoked;
() The date of the document or oral communication;
(4) Ifa document: its type (correspondence, memorandum, facsimile, etc.), custodian,
location, and such other information sufficient to identify the document for a
subpoena duces tecum or a document request, including where appropriate the
author, the addressee, and if not apparent, the relationship between the author and
addressee;
LEGAL(S2861536\1
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 07/27/2021 12:40:37 PM ***(5)
(6)
If an oral communication: the place where it was made, the names of the persons
present while it was made, and if not apparent, the relationship of the persons
present and the declarant; and
The general subject matter of the document or oral communication.
REQUEST TO PRODUCE
1. Please produce true and correct copies of all estimates, sworn proof(s) of loss, and/or
invoices supporting Plaintiff's claim for damages as a result of the loss described in the
Complaint.
LEGAL(S2861536\1
By: _/s/ Alexandra J. Schultz
John David Dickenson
Florida Bar No. 575801
jdickenson@cozen.com
Alexandra J. Schultz
Florida Bar No. 122100
aschultz@cozen.com
One North Clematis Street, Suite 510
West Palm Beach, Florida 33401
Telephone: (561) 515-5250
Facsimile: (561) 515-5230
Counsel for Defendant, Westchester Surplus
Lines Insurance CompanyCERTIFICATE OF SERVICE
I HERBY CERTIFY that a true and correct copy of the foregoing was filed and served via
the Court’s e-Filing Portal this 27th day of July, 2021 on All Counsel listed on the following
Service List.
/s/_ Alexandra J. Schultz
Alexandra J. Schultz
SERVICE LIST
Counsel for Plaintiff
Ashley M. Allison, Esq.
Brett L. Schlacter, Esq.
SCHLACTER LAW
1108 Kane Concourse, Suite 305
Bay Harbor Islands, FL 33154
Telephone: (305) 999-1111
Email: bls@schlacterlaw.com
aallison@schlacterlaw.com
michelle@schlacterlaw.com
LEGAL(S2861536\1
Document Filed Date
July 27, 2021
Case Filing Date
April 22, 2021
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Filing # 131482874 E-Filed 07/27/2021 12:40:37 PM IN THE CIRCUIT COURT OF THE 15! JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 50-2021-CA-005140 BISCAYNE FRIENDLY, LLC, Plaintiff, v. WESTCHESTER SURPLUS LINES INSURANCE COMPANY, Defendant. / DEFENDANT, WESTCHESTER SURPLUS LINES INSURANCE COMPANY’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF Defendant, Westchester Surplus Lines Insurance Company (“Defendant”) serves its First Request for Production upon Plaintiff, Biscayne Friendly, LLC (“Plaintiff”). The documents shall be produced to undersigned counsel within the time limits required by law. INSTRUCTIONS If you object to fully identifying a document or oral communication because of a privilege, you are requested to provide a privilege log of the following information as to each document, unless divulging the information would disclose the privilege information. (1) The nature of the privilege claimed (including work product); (2) If the privilege is being asserted in connection with a claim or defense governed by state law, the state privilege rule being invoked; () The date of the document or oral communication; (4) Ifa document: its type (correspondence, memorandum, facsimile, etc.), custodian, location, and such other information sufficient to identify the document for a subpoena duces tecum or a document request, including where appropriate the author, the addressee, and if not apparent, the relationship between the author and addressee; LEGAL(S2861536\1 *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 07/27/2021 12:40:37 PM ***(5) (6) If an oral communication: the place where it was made, the names of the persons present while it was made, and if not apparent, the relationship of the persons present and the declarant; and The general subject matter of the document or oral communication. REQUEST TO PRODUCE 1. Please produce true and correct copies of all estimates, sworn proof(s) of loss, and/or invoices supporting Plaintiff's claim for damages as a result of the loss described in the Complaint. LEGAL(S2861536\1 By: _/s/ Alexandra J. Schultz John David Dickenson Florida Bar No. 575801 jdickenson@cozen.com Alexandra J. Schultz Florida Bar No. 122100 aschultz@cozen.com One North Clematis Street, Suite 510 West Palm Beach, Florida 33401 Telephone: (561) 515-5250 Facsimile: (561) 515-5230 Counsel for Defendant, Westchester Surplus Lines Insurance CompanyCERTIFICATE OF SERVICE I HERBY CERTIFY that a true and correct copy of the foregoing was filed and served via the Court’s e-Filing Portal this 27th day of July, 2021 on All Counsel listed on the following Service List. /s/_ Alexandra J. Schultz Alexandra J. Schultz SERVICE LIST Counsel for Plaintiff Ashley M. Allison, Esq. Brett L. Schlacter, Esq. SCHLACTER LAW 1108 Kane Concourse, Suite 305 Bay Harbor Islands, FL 33154 Telephone: (305) 999-1111 Email: bls@schlacterlaw.com aallison@schlacterlaw.com michelle@schlacterlaw.com LEGAL(S2861536\1