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Filing # 127655882 E-Filed 05/27/2021 11:08:30 AM
21-10668
ACA
IN THE CIRCUIT COURT OF THE 17”
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JIMMY NOEL, CASE NO. CACE 21-006186 (25)
(Judge Carol-Lisa Phillips)
Plaintiff,
v.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
/
DEFENDANT, CITIZENS PROPERTY INSURANCE CORPORATION’S
NOTICE OF SERVING ITS FIRST SET OF INTERROGATORIES TO PLAINTIFF
COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION
(hereinafter “Citizens”), a Florida Governmental Entity, by and through its undersigned counsel,
hereby files its Notice of Serving its First Set of Interrogatories to Plaintiff, Jimmy Noel.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
sent by e-mail on this the 27th day of May, 2021, to Kenneth R. Duboff, Esq., Duboff Law
Firm, Attorneys for Plaintiff, courtdocument@dubofflawfirm.com.
BRONSTEIN & CARMONA, P.A.
Attorneys for Defendant
8000 Peters Road, Suite A-200
Fort Lauderdale, FL 33324
(954) 358-0444 — Phone
(954) 358-0445 — Fax
service@bronstein-carmona.com
By:_/s/ Ana C. Arenas, Esq.
Ana C. Arenas
Florida Bar No.: 1020219
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/27/2021 11:08:29 AM.****Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
DEFINITIONS AND INSTRUCTIONS
L GENERAL GUIDELINES
These interrogatories shall be considered to be continuing and Plaintiff's answers,
therefore, should be modified or supplemented if information requested in these
interrogatories is obtained at a later date by Plaintiff or its counsel.
These interrogatories seek all information that is known or available to Plaintiff, its
agents, representatives, investigators and, unless privileged, its attorneys and its
attomey’s agents, servants, employees, representatives or investigators.
Il DEFINITIONS
As used throughout these Interrogatories, the following terms are defined as follows:
The terms “you,” “your,” and “Plaintiff,” refers to Plaintiff, Jimmy Noel, his agents,
attomneys, representatives, and all other individuals acting, or purporting to act, on its
behalf.
The word “Insured” refers to Jimmy Noel, his agents, his attorneys, representatives, and
all other individuals acting or purporting to act on his behalf.
“All” shall be understood to include and encompass “all.”
“Any” shall be understood to include and encompass “any”.
“Or” shall be understood to include both “or” and “and”.
“Defendant,” “CPIC” refers to CITIZENS PROPERTY INSURANCE CORPORATION,
its agents, attorneys and/or representatives.
The word “document” as used herein means all written, graphic and audio or visually
recorded matter of every kind and description, however produced or reproduced, whether
draft or final, original or reproduction, in the actual or constructive possession, custody or
control of Plaintiff, Jimmy Noel including, but not limited to: plans, drawings, graphs,
deeds, title policies, commitments or abstracts, writings, letters, correspondence,
memoranda, notes, films, photographs, audio recordings, transcripts, contracts,
agreements, covenants, permits, licenses, memoranda of telephone or personal
conversations or communications, microfilm, microfiche, telegrams, books, magazines,
advertisements, periodicals, bulletins, circulars, pamphlets, written communications,
minutes or notes of meetings, interoffice communications, reports, financial statements,
ledgers, books of account, proposals, prospectuses, offers, receipts, working papers, desk
calendars, appointment books, diaries, time sheets, logs, movies, tapes for visual audio
reproduction, recordings, or materials similar to any of the foregoing, however,
denominated by Plaintiff. The term “document” shall also include all copies of each10.
11.
12.
13.
14.
15.
16.
Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
document if the copies contain additional matter, or are not identical copies of the
originals.
The word “communication” means any transmission or exchange of information between
two or more persons, orally or in writing, and includes, without limitation, any
conversations or discussion, whether face-to-face or by means of any telephone,
telegraph, telecopies, electron or other media.
“Identity” shall have the following meanings:
a. With regard to individuals, state the name and last known employment,
employment title, employment address and telephone number, and home address
and telephone number.
b. With regard to business entities, state the name, type of entity, state of
corporation, and principal business address.
c. With regard to documents: state the author(s) and recipient(s), all individuals or
entities having possession or the right to possession of original(s) or copies
thereof, and state the date, number of pages, and type of each document.
“Person” refers to any natural person, individual, proprietorship, partnership, corporation,
association, organization, joint venture, firm, other business enterprise, government body,
group or natural persons, or other entity.
“Property” refers to the Property located at 1652 SW 70th Avenue, North Lauderdale, FL
33068-4356.
“Repairs” or “replacements” refer to any major restoration made to the Property to
restore it to its former condition. This does not include minimal restoration such as
painting or cleaning.
“Policy” refers to Policy No. 04004007-1.
The word “date” means the exact day, month and year, if ascertainable or, if not, the best
approximate thereof, including relationship to other events.
“Third party” refers to any person and/or entity other than the Plaintiff.
“Closing documents” refers to any documents involved in the real estate closing of the
Property, including but not limited to completed loan application form, mortgage
insurance application, promissory note pledging to pay the amount in full and with
interest, mortgage document(s), payment letter stating the amount and due date of the
first payment, truth in lending form, affidavit that the buyer’s various names refer to one
and the same person, survey form that accurately describe the Property, termite and/or
other inspection form(s), RESPA form, proration agreements, affidavit signifying the17.
18.
19.
20.
Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
purchase price and the source of the price, deed which transfers title from the buyer to the
seller, bill of sale transferring ownership, affidavit of title/search of abstract title, title
insurance, affidavit relating to mechanic’s liens, if any.
“Date of loss” refers to November 10, 2020, the date the Insureds alleged the damage that
is subject of the Complaint occurred.
“Claimed loss” refers to any and all damage that the Insureds alleged occurred on
November 10, 2020, at the Property and is the subject of the Complaint.
“Complaint” as used herein refers to the Complaint entitled, Jimmy Noel v. Citizens
Property Insurance Corporation, filed in the Circuit Court of the 17" Judicial Circuit in
and for Broward County, Florida, Case Number CACE 21-006186 (25).
Whenever you are asked in these interrogatories to “state”, “explain” or “describe” a fact,
event, phenomenon or allegation, you should explain or describe such fact, event,
phenomenon or allegation in detail, giving reasons therefore.
ill INSTRUCTIONS
Unless a different meaning is stated or obvious from its context, all terms used herein
shall have the same meaning as in the Defendant’s Answer and Affirmative Defenses.
The use of the singular herein shall include the plural and that of masculine shall include
the feminine as appropriate in the context.
With respect to any answers called for by these interrogatories, but withheld due to a
claim of privilege, list for each such answer the paragraph to which it is responsive and
the nature of the privilege claimed.
Unless otherwise indicated, all words and terms used in these requests shall have the
same meaning as in the Defendant’s Answer and Affirmative Defenses filed in this
action.
If objection is taken to any of the following interrogatories or if Plaintiff fails to fully
respond to any interrogatory, state the specific grounds therefore and respond to such
interrogatory to the extent which there is no obligation. If privilege is asserted as to any
of the interrogatories, fully identify for each: (a) its date; (b) the type of document (e.g.,
letter, memo, etc.); (c) the author; (d) the recipient; and the general subject matter.
The term “all” means “any and all”.Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
FIRST SET OF INTERROGATORIES TO PLAINTIFF
1. Please state the name, address and telephone number of all persons who are assisting you
in providing responses to these Interrogatories, and include the nature of the relationship
between you and that person.
2. Please describe in detail what events transpired at the subject property on or about
November 10, 2020 that caused or contributed to the alleged loss that is the subject
matter of this cause of action against Citizens, including how the loss was discovered and
who discovered the loss.
3. Please state the date that any of the damages being claimed, as alleged in the Complaint
for damages, were first reported to Citizens and state how the damages were reported as
well as the name of the person to whom the damages were reported.Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
4. Please describe in detail, what efforts, if any, where made to mitigate any damage(s) to
the Property after the loss as alleged in the Complaint for Damages.
5. Please state with specificity the dollar amount you are claiming that you are entitled to be
paid with respect to your claim for damage to the Property, as a result of the alleged loss
which occurred on or about November 10, 2020, as alleged in the Complaint.
Additionally, please include the following:
a. The date that the damage was first noticed.
b. Describe where within the Property the damage was located.
c. Describe all damage to the Property which occurred on November 10, 2020 as a
result of the alleged loss.
d. As to each item of damage claimed, please describe the status of the damage (whether
repaired or pending).
e. If the damage claimed has been repaired, please state the names and addresses of the
individual or contractor that made repairs, when the repairs were made, and the costs
of the repairs.
f. State whether any photographs were taken of damage to the Property prior to any
repairs. If so, identify who took the photos.
g. If additional repairs are necessary, state what repairs need to be completed.Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
6. Please identify with specificity, including name, address, telephone number, company
name and job title, all contractors, sub-contractors, engineers, plumbers, architects, tile
companies, handymen, material men, and all other entities and/or individuals with whom
you have consulted with, and/or retained to inspect, repair, and/or provide estimate(s) for
the repair and/or replacement of any damages which occurred at the Property from the
November 10, 2020 loss, up _to the date of service of your responses _to_these
interrogatories upon Citizens.
7. Identify with specificity, all supporting documents (and attach said documents pursuant
to Rule 1.350, Fla. R. Civ. P) evidencing the observations, inspections,
repairs/replacements, and the related involvement of the entities, professionals or
individuals identified in Interrogatory No. 6, including, but not limited to plans,
estimates, reports, diagrams, field notes, illustrations, photographs, invoices, videos,
records of payment, correspondence and/or repair records.
8. Please indicate whether you had the Property inspected prior to purchasing it on the date
listed in Interrogatory No. 18, and include the date of the inspection, the name of the
company, corporation, entity, business, or person that performed said inspections, and the
address and/or telephone number for said company, corporation, entity, business, or
person that performed said inspections.Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
9. Please state whether you, or your agents, allowed for Citizens to perform an inspection of
the home subsequent to the loss and if so, state who was present for Citizens’ inspection,
the date Citizens was able to inspect the alleged loss, and who from Citizens inspected
the alleged loss.
10. Please provide the name, address and telephone number of all persons who have, or may
have knowledge of the facts set forth within the Complaint. Include the facts that each
person has knowledge of and the source of that knowledge.
11. Were any repairs, improvements, modifications or replacements made to the Property as
the result of any prior homeowner insurance claims?
Additionally, please also state:
a. Who made any such repairs, improvements, modifications or replacements;
b. When such repairs, improvements, modifications or replacements were made;
c. What parts of the home were repaired, improved, modified or replaced; and
d. The costs of such repairs, improvements, modifications or replacements.Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
12. Please describe in detail the nature of any repair(s), renovations, or construction to the
Property from the date of purchase to the present time. Additionally, please identify the
name(s) and current address(es) of the individual(s) and entity(ies) who participated in
such repairs, renovations, or construction, or whom you have retained to conduct such
Tepairs, renovations or construction.
13. Do any individual(s) and/or entity(ies), other than yourself, have an ownership interest in
the Property? If so, please provide each person or entity’s name, address and telephone
number, as well as, the nature and scope of each person or entity's ownership interest,
when that interest was acquired or obtained, and your relationship to each person or
entity holding such ownership interest.
14. Please describe with specificity any losses to the Property that occurred before and
after November 10, 2020, including the cause of such damages and who made such a
determination. Additionally, please state the name(s) and current address(es) of any
individual(s) and entity(ies) who participated in the repair or whom you have retained to
repair or replace any of the damages you identified.15.
16.
17.
18.
Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
Describe with specificity any additional living expenses that you allege you incurred as a
result of the subject loss to the Property.
Describe with specificity any personal property damage that you allege you incurred as a
result of the subject loss to the Property including the amount of damage, the original
date of purchase, the amount the property was purchased, etc.
Please state with specificity each fact the Plaintiff is relying on, with regard to each item
of damage being claimed, as referenced in the Complaint.
Please state the date that you purchased the Property and from whom you purchased it.
10Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
JURAT PAGE
Jimmy Noel
STATE OF FLORIDA )
) SS:
COUNTY OF )
The foregoing instrument was acknowledged before me _ this day of
2021 by Jimmy Noel, who is ( ) personally known to me or who has ( )
produced the following identification , and, who, after first being
duly sworn, deposes and states that the above Answers to Interrogatories are true and correct to
the best of Affiant’s knowledge and belief.
Swom and subscribed before me this day of. 2021.
Notary Public
Print
Seal
11
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Filing # 127655882 E-Filed 05/27/2021 11:08:30 AM 21-10668 ACA IN THE CIRCUIT COURT OF THE 17” JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JIMMY NOEL, CASE NO. CACE 21-006186 (25) (Judge Carol-Lisa Phillips) Plaintiff, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / DEFENDANT, CITIZENS PROPERTY INSURANCE CORPORATION’S NOTICE OF SERVING ITS FIRST SET OF INTERROGATORIES TO PLAINTIFF COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION (hereinafter “Citizens”), a Florida Governmental Entity, by and through its undersigned counsel, hereby files its Notice of Serving its First Set of Interrogatories to Plaintiff, Jimmy Noel. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been sent by e-mail on this the 27th day of May, 2021, to Kenneth R. Duboff, Esq., Duboff Law Firm, Attorneys for Plaintiff, courtdocument@dubofflawfirm.com. BRONSTEIN & CARMONA, P.A. Attorneys for Defendant 8000 Peters Road, Suite A-200 Fort Lauderdale, FL 33324 (954) 358-0444 — Phone (954) 358-0445 — Fax service@bronstein-carmona.com By:_/s/ Ana C. Arenas, Esq. Ana C. Arenas Florida Bar No.: 1020219 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/27/2021 11:08:29 AM.****Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) DEFINITIONS AND INSTRUCTIONS L GENERAL GUIDELINES These interrogatories shall be considered to be continuing and Plaintiff's answers, therefore, should be modified or supplemented if information requested in these interrogatories is obtained at a later date by Plaintiff or its counsel. These interrogatories seek all information that is known or available to Plaintiff, its agents, representatives, investigators and, unless privileged, its attorneys and its attomey’s agents, servants, employees, representatives or investigators. Il DEFINITIONS As used throughout these Interrogatories, the following terms are defined as follows: The terms “you,” “your,” and “Plaintiff,” refers to Plaintiff, Jimmy Noel, his agents, attomneys, representatives, and all other individuals acting, or purporting to act, on its behalf. The word “Insured” refers to Jimmy Noel, his agents, his attorneys, representatives, and all other individuals acting or purporting to act on his behalf. “All” shall be understood to include and encompass “all.” “Any” shall be understood to include and encompass “any”. “Or” shall be understood to include both “or” and “and”. “Defendant,” “CPIC” refers to CITIZENS PROPERTY INSURANCE CORPORATION, its agents, attorneys and/or representatives. The word “document” as used herein means all written, graphic and audio or visually recorded matter of every kind and description, however produced or reproduced, whether draft or final, original or reproduction, in the actual or constructive possession, custody or control of Plaintiff, Jimmy Noel including, but not limited to: plans, drawings, graphs, deeds, title policies, commitments or abstracts, writings, letters, correspondence, memoranda, notes, films, photographs, audio recordings, transcripts, contracts, agreements, covenants, permits, licenses, memoranda of telephone or personal conversations or communications, microfilm, microfiche, telegrams, books, magazines, advertisements, periodicals, bulletins, circulars, pamphlets, written communications, minutes or notes of meetings, interoffice communications, reports, financial statements, ledgers, books of account, proposals, prospectuses, offers, receipts, working papers, desk calendars, appointment books, diaries, time sheets, logs, movies, tapes for visual audio reproduction, recordings, or materials similar to any of the foregoing, however, denominated by Plaintiff. The term “document” shall also include all copies of each10. 11. 12. 13. 14. 15. 16. Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) document if the copies contain additional matter, or are not identical copies of the originals. The word “communication” means any transmission or exchange of information between two or more persons, orally or in writing, and includes, without limitation, any conversations or discussion, whether face-to-face or by means of any telephone, telegraph, telecopies, electron or other media. “Identity” shall have the following meanings: a. With regard to individuals, state the name and last known employment, employment title, employment address and telephone number, and home address and telephone number. b. With regard to business entities, state the name, type of entity, state of corporation, and principal business address. c. With regard to documents: state the author(s) and recipient(s), all individuals or entities having possession or the right to possession of original(s) or copies thereof, and state the date, number of pages, and type of each document. “Person” refers to any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, government body, group or natural persons, or other entity. “Property” refers to the Property located at 1652 SW 70th Avenue, North Lauderdale, FL 33068-4356. “Repairs” or “replacements” refer to any major restoration made to the Property to restore it to its former condition. This does not include minimal restoration such as painting or cleaning. “Policy” refers to Policy No. 04004007-1. The word “date” means the exact day, month and year, if ascertainable or, if not, the best approximate thereof, including relationship to other events. “Third party” refers to any person and/or entity other than the Plaintiff. “Closing documents” refers to any documents involved in the real estate closing of the Property, including but not limited to completed loan application form, mortgage insurance application, promissory note pledging to pay the amount in full and with interest, mortgage document(s), payment letter stating the amount and due date of the first payment, truth in lending form, affidavit that the buyer’s various names refer to one and the same person, survey form that accurately describe the Property, termite and/or other inspection form(s), RESPA form, proration agreements, affidavit signifying the17. 18. 19. 20. Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) purchase price and the source of the price, deed which transfers title from the buyer to the seller, bill of sale transferring ownership, affidavit of title/search of abstract title, title insurance, affidavit relating to mechanic’s liens, if any. “Date of loss” refers to November 10, 2020, the date the Insureds alleged the damage that is subject of the Complaint occurred. “Claimed loss” refers to any and all damage that the Insureds alleged occurred on November 10, 2020, at the Property and is the subject of the Complaint. “Complaint” as used herein refers to the Complaint entitled, Jimmy Noel v. Citizens Property Insurance Corporation, filed in the Circuit Court of the 17" Judicial Circuit in and for Broward County, Florida, Case Number CACE 21-006186 (25). Whenever you are asked in these interrogatories to “state”, “explain” or “describe” a fact, event, phenomenon or allegation, you should explain or describe such fact, event, phenomenon or allegation in detail, giving reasons therefore. ill INSTRUCTIONS Unless a different meaning is stated or obvious from its context, all terms used herein shall have the same meaning as in the Defendant’s Answer and Affirmative Defenses. The use of the singular herein shall include the plural and that of masculine shall include the feminine as appropriate in the context. With respect to any answers called for by these interrogatories, but withheld due to a claim of privilege, list for each such answer the paragraph to which it is responsive and the nature of the privilege claimed. Unless otherwise indicated, all words and terms used in these requests shall have the same meaning as in the Defendant’s Answer and Affirmative Defenses filed in this action. If objection is taken to any of the following interrogatories or if Plaintiff fails to fully respond to any interrogatory, state the specific grounds therefore and respond to such interrogatory to the extent which there is no obligation. If privilege is asserted as to any of the interrogatories, fully identify for each: (a) its date; (b) the type of document (e.g., letter, memo, etc.); (c) the author; (d) the recipient; and the general subject matter. The term “all” means “any and all”.Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) FIRST SET OF INTERROGATORIES TO PLAINTIFF 1. Please state the name, address and telephone number of all persons who are assisting you in providing responses to these Interrogatories, and include the nature of the relationship between you and that person. 2. Please describe in detail what events transpired at the subject property on or about November 10, 2020 that caused or contributed to the alleged loss that is the subject matter of this cause of action against Citizens, including how the loss was discovered and who discovered the loss. 3. Please state the date that any of the damages being claimed, as alleged in the Complaint for damages, were first reported to Citizens and state how the damages were reported as well as the name of the person to whom the damages were reported.Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) 4. Please describe in detail, what efforts, if any, where made to mitigate any damage(s) to the Property after the loss as alleged in the Complaint for Damages. 5. Please state with specificity the dollar amount you are claiming that you are entitled to be paid with respect to your claim for damage to the Property, as a result of the alleged loss which occurred on or about November 10, 2020, as alleged in the Complaint. Additionally, please include the following: a. The date that the damage was first noticed. b. Describe where within the Property the damage was located. c. Describe all damage to the Property which occurred on November 10, 2020 as a result of the alleged loss. d. As to each item of damage claimed, please describe the status of the damage (whether repaired or pending). e. If the damage claimed has been repaired, please state the names and addresses of the individual or contractor that made repairs, when the repairs were made, and the costs of the repairs. f. State whether any photographs were taken of damage to the Property prior to any repairs. If so, identify who took the photos. g. If additional repairs are necessary, state what repairs need to be completed.Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) 6. Please identify with specificity, including name, address, telephone number, company name and job title, all contractors, sub-contractors, engineers, plumbers, architects, tile companies, handymen, material men, and all other entities and/or individuals with whom you have consulted with, and/or retained to inspect, repair, and/or provide estimate(s) for the repair and/or replacement of any damages which occurred at the Property from the November 10, 2020 loss, up _to the date of service of your responses _to_these interrogatories upon Citizens. 7. Identify with specificity, all supporting documents (and attach said documents pursuant to Rule 1.350, Fla. R. Civ. P) evidencing the observations, inspections, repairs/replacements, and the related involvement of the entities, professionals or individuals identified in Interrogatory No. 6, including, but not limited to plans, estimates, reports, diagrams, field notes, illustrations, photographs, invoices, videos, records of payment, correspondence and/or repair records. 8. Please indicate whether you had the Property inspected prior to purchasing it on the date listed in Interrogatory No. 18, and include the date of the inspection, the name of the company, corporation, entity, business, or person that performed said inspections, and the address and/or telephone number for said company, corporation, entity, business, or person that performed said inspections.Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) 9. Please state whether you, or your agents, allowed for Citizens to perform an inspection of the home subsequent to the loss and if so, state who was present for Citizens’ inspection, the date Citizens was able to inspect the alleged loss, and who from Citizens inspected the alleged loss. 10. Please provide the name, address and telephone number of all persons who have, or may have knowledge of the facts set forth within the Complaint. Include the facts that each person has knowledge of and the source of that knowledge. 11. Were any repairs, improvements, modifications or replacements made to the Property as the result of any prior homeowner insurance claims? Additionally, please also state: a. Who made any such repairs, improvements, modifications or replacements; b. When such repairs, improvements, modifications or replacements were made; c. What parts of the home were repaired, improved, modified or replaced; and d. The costs of such repairs, improvements, modifications or replacements.Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) 12. Please describe in detail the nature of any repair(s), renovations, or construction to the Property from the date of purchase to the present time. Additionally, please identify the name(s) and current address(es) of the individual(s) and entity(ies) who participated in such repairs, renovations, or construction, or whom you have retained to conduct such Tepairs, renovations or construction. 13. Do any individual(s) and/or entity(ies), other than yourself, have an ownership interest in the Property? If so, please provide each person or entity’s name, address and telephone number, as well as, the nature and scope of each person or entity's ownership interest, when that interest was acquired or obtained, and your relationship to each person or entity holding such ownership interest. 14. Please describe with specificity any losses to the Property that occurred before and after November 10, 2020, including the cause of such damages and who made such a determination. Additionally, please state the name(s) and current address(es) of any individual(s) and entity(ies) who participated in the repair or whom you have retained to repair or replace any of the damages you identified.15. 16. 17. 18. Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) Describe with specificity any additional living expenses that you allege you incurred as a result of the subject loss to the Property. Describe with specificity any personal property damage that you allege you incurred as a result of the subject loss to the Property including the amount of damage, the original date of purchase, the amount the property was purchased, etc. Please state with specificity each fact the Plaintiff is relying on, with regard to each item of damage being claimed, as referenced in the Complaint. Please state the date that you purchased the Property and from whom you purchased it. 10Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) JURAT PAGE Jimmy Noel STATE OF FLORIDA ) ) SS: COUNTY OF ) The foregoing instrument was acknowledged before me _ this day of 2021 by Jimmy Noel, who is ( ) personally known to me or who has ( ) produced the following identification , and, who, after first being duly sworn, deposes and states that the above Answers to Interrogatories are true and correct to the best of Affiant’s knowledge and belief. Swom and subscribed before me this day of. 2021. Notary Public Print Seal 11