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Filing # 129728423 E-Filed 06/29/2021 02:16:46 PM
IN THE CIRCUIT COURT IN AND FOR THE
17TH
JUDICIAL
CIRCUIT
IN
AND
FOR
BROWARD COUNTY, FLORIDA
Case No. CACE-21-010671
IRMA HIDALGO AND JUAN HIDALGO,
Plaintiffs,
VS.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
The
Defendant, CITIZENS
PROPERTY
INSURANCE CORPORATION,
in
accordance with the applicable Rules of Civil Procedure, requiresthe Plaintiffs, Irma Hidalgo
and Juan Hidalgo to produce, within the time prescribed by law, at the offices of the
undersignedattorneys, the folkwing:
1.
Copies of all receipts, invoices, estimates, bills or other documents related to
expenses incurred to repair or replace any item of damage to the home located at
2205 NW 170th Ave, Pembroke Pines FL 33028 as a result of the loss as alleged
in the Complaint.
RESPONSE:
2.
Any roofing reports, invoices, contracts, estimates and/or proposals related to the
loss asserted in this action.
RESPONSE:
3.
Copies of all receipts, bills, invoices, estimates or other documents related to
expenses incurred to repair or replace any item of damage to the residence located
at 2205 NW 170th Ave, Pembroke Pines FL 33028 as result of any loss claimed
over the last 7 years.
RESPONSE:
4.
Copies of all leases for the subject property since 2008.
RESPONSE:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/29/2021 02:16:46 PM.****
5.
Copies of all policies of insurance which have provided or provide dwelling
coverage to the residence located at 2205 NW 170th Ave, Pembroke Pines FL
33028 from the time you purchased the residence to the present.
RESPONSE:
6.
Copies of all documentation reflecting any payment made to the Plaintiff by or on
behalf of any entity for any reason as a result of Plaintiffsclaim for property damage
alleged in the Complaint.
RESPONSE:
7.
Copies of all bank statements, withdrawal slips, ATM receipts or other bank
documents related to any cash payment made necessary as a result of repair or
replacement of any item of damage sustained as alleged in the Complaint.
RESPONSE:
8.
Copies of all correspondence or other documents related to communication with
any municipal, governmental or building official or office related to building permits,
repairs, renovations and/orremodelingfor the residencelocated at 2205 NW 170th
Ave, Pembroke Pines FL 33028 from the time Plaintiff owned the property to the
present.
RESPONSE:
9.
Copies of any and all correspondence by or between the Plaintiff and her agents or
representatives, and the Defendant or any agent or representativeof the Defendant.
RESPONSE:
10.
Color copies of all photographs,video, or other pictorial documentation related to
damage to the home or to the contents of the residence located at 2205 NW 170th
Ave, Pembroke Pines FL 33028 as a result of the loss alleged in the Complaint.
RESPONSE:
11.
Copies of any communication relating to the loss claimed for the property located
at 2205 NW 170th Ave, Pembroke Pines FL 33028.
RESPONSE:
12.
Copies of any and all correspondence by or between the Plaintiffand her agent or
representativeand any third party related to the loss claimed to the residence located
at 2205 NW 170th Ave, Pembroke Pines FL 33028.
RESPONSE:
13.
Copies of all reports, correspondence, notes, memoranda, or other communication
or recommendation from any experts retained to testify at trial.
RESPONSE:
14.
Any and all correspondenceby or between the Plaintiffand/or anyone acting on her
behalf and the Defendant or any agent or representativeof the Defendant.
RESPONSE:
15.
All reports from any and all experts retained for any reason concerning any item of
damage asserted in this matter.
RESPONSE:
16.
All reports, estimatesor other analysisfrom any and all individual(s) or entity(ies)who
inspected any item of damage asserted in this matter.
RESPONSE:
17.
All documentation concerning the ownership of the subject residence where the
alleged loss took place, including but not limited to mortgage documents, vouchers,
coupons, or other documentation identifying all ownership interests in the subject
property.
RESPONSE:
18.
Color copies of all photographs, video, or other pictorial documentation related to
damage to the home or to the contents of the residence located at 2205 NW 170th
Ave, Pembroke Pines FL 33028 as of the date of the loss alleged, prior to the repair
or removal of any building materials.
RESPONSE:
19.
Copies of any and all documents relating to and/or referring to any and all
maintenance, renovation, repairs, or work performed on any portion of the
residence, including the roof, which Plaintiff is claiming was damaged as alleged
in the Complaint from the time Plaintiff purchased the residence through the date
of loss which is the subject of this litigation.
RESPONSE:
20.
Copies of all notes, memos and/or recordings of any conversation with
representatives of the Defendant and/or the Defendant'semployees or agents.
RESPONSE:
21.
Copies of all materials you claim were submitted to the Defendant in support of
Plaintiff's claim.
RESPONSE:
22.
Any and all documents relating to Plaintiffs replacement or repair of any item of
damage Plaintiff is claiming in this matter.
RESPONSE:
23.
Any and all documents defining, explaining, relating to or referring to the cause of
Plaintiff's loss or date of Plaintiffs loss as identified in the Complaint.
RESPONSE:
24.
Any and all documents relating to, referringto and/or supporting any allegation that
Plaintiff complied with the conditions precedent to this action.
RESPONSE:
25.
Any and all documents relating to, referringto and/or supporting any allegation that
the conditions precedent to this action have been waived.
RESPONSE:
26.
Any and all documents relating to, referring to and/or supporting Plaintiffs
allegation that the damaged asserted in connection with Plaintiffs claim are
covered under the subject policy.
RESPONSE:
27.
A picture identification of the Plaintiff named in the Complaint.
RESPONSE:
28.
Copies of any and all documentation concerning any presence on the subject roof
including but not limited to repairmen, roof cleaners, pressure washers, etc., and/or
any other presence on the roof from the time of purchase to the present.
RESPONSE:
This production is necessary for the proper defense of this case, since certain
claims have been made by Plaintiffwhich places these items at issue.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by E-
Mail to Dennis N. Urbano, Esq., Greenberg Ramon Alonso & Urbano, 11440 North Kendall
Drive,
Penthouse 400,
Miami, FL
33176, 305-595-2400, durbano@sgqlaw.com,
mail@sgglaw.com,this 29th day of June, 2021.
By /s/ Cliff Klein
CLIFF KLEIN
Florida Bar # 84394
PETERSON BERNARD
Attorneysfor Defendant
707 S.E. 3rd Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
faythe.
com
ck.fpv
945.38025
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Filing # 129728423 E-Filed 06/29/2021 02:16:46 PM IN THE CIRCUIT COURT IN AND FOR THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE-21-010671 IRMA HIDALGO AND JUAN HIDALGO, Plaintiffs, VS. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF The Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, in accordance with the applicable Rules of Civil Procedure, requiresthe Plaintiffs, Irma Hidalgo and Juan Hidalgo to produce, within the time prescribed by law, at the offices of the undersignedattorneys, the folkwing: 1. Copies of all receipts, invoices, estimates, bills or other documents related to expenses incurred to repair or replace any item of damage to the home located at 2205 NW 170th Ave, Pembroke Pines FL 33028 as a result of the loss as alleged in the Complaint. RESPONSE: 2. Any roofing reports, invoices, contracts, estimates and/or proposals related to the loss asserted in this action. RESPONSE: 3. Copies of all receipts, bills, invoices, estimates or other documents related to expenses incurred to repair or replace any item of damage to the residence located at 2205 NW 170th Ave, Pembroke Pines FL 33028 as result of any loss claimed over the last 7 years. RESPONSE: 4. Copies of all leases for the subject property since 2008. RESPONSE: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/29/2021 02:16:46 PM.**** 5. Copies of all policies of insurance which have provided or provide dwelling coverage to the residence located at 2205 NW 170th Ave, Pembroke Pines FL 33028 from the time you purchased the residence to the present. RESPONSE: 6. Copies of all documentation reflecting any payment made to the Plaintiff by or on behalf of any entity for any reason as a result of Plaintiffsclaim for property damage alleged in the Complaint. RESPONSE: 7. Copies of all bank statements, withdrawal slips, ATM receipts or other bank documents related to any cash payment made necessary as a result of repair or replacement of any item of damage sustained as alleged in the Complaint. RESPONSE: 8. Copies of all correspondence or other documents related to communication with any municipal, governmental or building official or office related to building permits, repairs, renovations and/orremodelingfor the residencelocated at 2205 NW 170th Ave, Pembroke Pines FL 33028 from the time Plaintiff owned the property to the present. RESPONSE: 9. Copies of any and all correspondence by or between the Plaintiff and her agents or representatives, and the Defendant or any agent or representativeof the Defendant. RESPONSE: 10. Color copies of all photographs,video, or other pictorial documentation related to damage to the home or to the contents of the residence located at 2205 NW 170th Ave, Pembroke Pines FL 33028 as a result of the loss alleged in the Complaint. RESPONSE: 11. Copies of any communication relating to the loss claimed for the property located at 2205 NW 170th Ave, Pembroke Pines FL 33028. RESPONSE: 12. Copies of any and all correspondence by or between the Plaintiffand her agent or representativeand any third party related to the loss claimed to the residence located at 2205 NW 170th Ave, Pembroke Pines FL 33028. RESPONSE: 13. Copies of all reports, correspondence, notes, memoranda, or other communication or recommendation from any experts retained to testify at trial. RESPONSE: 14. Any and all correspondenceby or between the Plaintiffand/or anyone acting on her behalf and the Defendant or any agent or representativeof the Defendant. RESPONSE: 15. All reports from any and all experts retained for any reason concerning any item of damage asserted in this matter. RESPONSE: 16. All reports, estimatesor other analysisfrom any and all individual(s) or entity(ies)who inspected any item of damage asserted in this matter. RESPONSE: 17. All documentation concerning the ownership of the subject residence where the alleged loss took place, including but not limited to mortgage documents, vouchers, coupons, or other documentation identifying all ownership interests in the subject property. RESPONSE: 18. Color copies of all photographs, video, or other pictorial documentation related to damage to the home or to the contents of the residence located at 2205 NW 170th Ave, Pembroke Pines FL 33028 as of the date of the loss alleged, prior to the repair or removal of any building materials. RESPONSE: 19. Copies of any and all documents relating to and/or referring to any and all maintenance, renovation, repairs, or work performed on any portion of the residence, including the roof, which Plaintiff is claiming was damaged as alleged in the Complaint from the time Plaintiff purchased the residence through the date of loss which is the subject of this litigation. RESPONSE: 20. Copies of all notes, memos and/or recordings of any conversation with representatives of the Defendant and/or the Defendant'semployees or agents. RESPONSE: 21. Copies of all materials you claim were submitted to the Defendant in support of Plaintiff's claim. RESPONSE: 22. Any and all documents relating to Plaintiffs replacement or repair of any item of damage Plaintiff is claiming in this matter. RESPONSE: 23. Any and all documents defining, explaining, relating to or referring to the cause of Plaintiff's loss or date of Plaintiffs loss as identified in the Complaint. RESPONSE: 24. Any and all documents relating to, referringto and/or supporting any allegation that Plaintiff complied with the conditions precedent to this action. RESPONSE: 25. Any and all documents relating to, referringto and/or supporting any allegation that the conditions precedent to this action have been waived. RESPONSE: 26. Any and all documents relating to, referring to and/or supporting Plaintiffs allegation that the damaged asserted in connection with Plaintiffs claim are covered under the subject policy. RESPONSE: 27. A picture identification of the Plaintiff named in the Complaint. RESPONSE: 28. Copies of any and all documentation concerning any presence on the subject roof including but not limited to repairmen, roof cleaners, pressure washers, etc., and/or any other presence on the roof from the time of purchase to the present. RESPONSE: This production is necessary for the proper defense of this case, since certain claims have been made by Plaintiffwhich places these items at issue. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by E- Mail to Dennis N. Urbano, Esq., Greenberg Ramon Alonso & Urbano, 11440 North Kendall Drive, Penthouse 400, Miami, FL 33176, 305-595-2400, durbano@sgqlaw.com, mail@sgglaw.com,this 29th day of June, 2021. By /s/ Cliff Klein CLIFF KLEIN Florida Bar # 84394 PETERSON BERNARD Attorneysfor Defendant 707 S.E. 3rd Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile faythe. com ck.fpv 945.38025