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Filing # 125142206 E-Filed 04/19/2021 10:44:40 AM
STEVEN R. VALENTINE, IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
Plaintiff, FOR
vs. BROWARD COUNTY, FLORIDA
PROGRESSIVE PROPERTY INSURANCE CASE NO.: CACE-21-003854
COMPANY,
Defendant.
DEFENDANT’S FIRST REQUEST FOR PRODUCTION
The Defendant, PROGRESSIVE PROPERTY INSURANCE COMPANY
(“Progressive”), by and through undersigned counsel, and pursuant to Florida Rule of
Civil Procedure 1.350, requests Plaintiff, STEVEN R. VALENTINE (‘Plaintiff’), to
produce for inspection and copying each of the following within thirty (30) days:
1 All correspondence sent between Plaintiff and any third party concerning
this matter, including but not limited to all correspondences between the Plaintiff and
their public adjuster, contractors, experts, or any other person.
2 All documents, including all invoices, estimates, and/or receipts, for any
and all damages claimed by the Plaintiff.
3. All documents, including all invoices, estimates, proposals, contracts,
and/or receipts, for any and all damages claimed by the Plaintiff for their breach of
contract lawsuit including but not limited to any documents that support your claim for
breach of contract damages relating to the underlying incident.
4 All documentation, including all invoices, estimates, proposals, contracts,
and receipts, for any and all repairs and renovations performed to the Plaintiffs property
in the last five (5) years.
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/19/2021 10:44:39 AM.*###*
5. All documents which support any of Plaintiffs allegations in Plaintiff's
lawsuit against Defendant.
6. All documents used to answer Defendant's First Set of Interrogatories.
7. All documents which show that Plaintiff mitigated damages in this matter.
8. All documents which Plaintiff intends to introduce at trial.
9. Any and all photographs of the Plaintiffs property that show any and all
damage being claimed by the Plaintiff in the above-referenced lawsuit.
10. All statements, correspondence, depositions or other written materials
authored by the Defendant or any of its agents or employees which are in Plaintiffs
possession.
11. All diaries, correspondence, email, notes or journals prepared by Plaintiff
and/or any agents and/or representatives of the Plaintiffs relating to the claim.
12. All diaries, correspondence, email, notes or journals prepared by Plaintiff
and/or any agents and/or representatives of the Plaintiff relating to their lawsuit against
the Defendant.
13. All building permits requested and/or issued for the Plaintiffs property
since the date of loss.
14. All documents relating to any repairs to Plaintiff's property beginning five
years before the date of loss and spanning to the present.
15. All correspondences sent between the Plaintiff and the Defendant.
Certificate of Service included on the following page.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was
furnished via the e-portal to: Daniel Rosenbaum, Esq., 2601 East Oakland Park
Boulevard, Suite 503, Fort Lauderdale, Florida 33306;
(DRosenbaum@HLLawgroup.com; Service@HLLawgroup.com;
SJames@HLLawGroup.com) on April 6, 2021.
BECK LAW, P.A.
901 Clint Moore Road, Suite C
Boca Raton, FL 33487
Tel: (561) 990-1647
Fax: (561) 717-9673
By: /s/ NATHAN WEINBAUM, ESQ.
Florida Bar No.: 1025784
Primary E-Mail: pleadings@becklawpa.com
Secondary E-Mail: weinbaum@becklawpa.com
beck@becklawpa.com
Attorney for Defendant
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Filing # 125142206 E-Filed 04/19/2021 10:44:40 AM STEVEN R. VALENTINE, IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND Plaintiff, FOR vs. BROWARD COUNTY, FLORIDA PROGRESSIVE PROPERTY INSURANCE CASE NO.: CACE-21-003854 COMPANY, Defendant. DEFENDANT’S FIRST REQUEST FOR PRODUCTION The Defendant, PROGRESSIVE PROPERTY INSURANCE COMPANY (“Progressive”), by and through undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, requests Plaintiff, STEVEN R. VALENTINE (‘Plaintiff’), to produce for inspection and copying each of the following within thirty (30) days: 1 All correspondence sent between Plaintiff and any third party concerning this matter, including but not limited to all correspondences between the Plaintiff and their public adjuster, contractors, experts, or any other person. 2 All documents, including all invoices, estimates, and/or receipts, for any and all damages claimed by the Plaintiff. 3. All documents, including all invoices, estimates, proposals, contracts, and/or receipts, for any and all damages claimed by the Plaintiff for their breach of contract lawsuit including but not limited to any documents that support your claim for breach of contract damages relating to the underlying incident. 4 All documentation, including all invoices, estimates, proposals, contracts, and receipts, for any and all repairs and renovations performed to the Plaintiffs property in the last five (5) years. #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/19/2021 10:44:39 AM.*###* 5. All documents which support any of Plaintiffs allegations in Plaintiff's lawsuit against Defendant. 6. All documents used to answer Defendant's First Set of Interrogatories. 7. All documents which show that Plaintiff mitigated damages in this matter. 8. All documents which Plaintiff intends to introduce at trial. 9. Any and all photographs of the Plaintiffs property that show any and all damage being claimed by the Plaintiff in the above-referenced lawsuit. 10. All statements, correspondence, depositions or other written materials authored by the Defendant or any of its agents or employees which are in Plaintiffs possession. 11. All diaries, correspondence, email, notes or journals prepared by Plaintiff and/or any agents and/or representatives of the Plaintiffs relating to the claim. 12. All diaries, correspondence, email, notes or journals prepared by Plaintiff and/or any agents and/or representatives of the Plaintiff relating to their lawsuit against the Defendant. 13. All building permits requested and/or issued for the Plaintiffs property since the date of loss. 14. All documents relating to any repairs to Plaintiff's property beginning five years before the date of loss and spanning to the present. 15. All correspondences sent between the Plaintiff and the Defendant. Certificate of Service included on the following page. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the e-portal to: Daniel Rosenbaum, Esq., 2601 East Oakland Park Boulevard, Suite 503, Fort Lauderdale, Florida 33306; (DRosenbaum@HLLawgroup.com; Service@HLLawgroup.com; SJames@HLLawGroup.com) on April 6, 2021. BECK LAW, P.A. 901 Clint Moore Road, Suite C Boca Raton, FL 33487 Tel: (561) 990-1647 Fax: (561) 717-9673 By: /s/ NATHAN WEINBAUM, ESQ. Florida Bar No.: 1025784 Primary E-Mail: pleadings@becklawpa.com Secondary E-Mail: weinbaum@becklawpa.com beck@becklawpa.com Attorney for Defendant