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wes CASE NUMBER: 502021CA007553XXXXMB Div: AG ****
Filing # 128992354 E-Filed 06/17/2021 04:31:30 PM
IN THE CIRCUIT COURT OF THE 15™ JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO.:
EMELI MARTINE,
Plaintiff,
Vv.
AMERICAN SECURITY
INSURANCE COMPANY,
Defendant,
/
FIRST REQUEST FOR PRODUCTION TO DEFENDANT
COMES NOW Plaintiff, EMELI MARTINE, by and through the undersigned counsel,
pursuant to Florida Rules of Civil Procedure, Rule 1.350, and files this First Request for Production
to Defendant, AMERICAN SECURITY INSURANCE COMPANY, and requests the Defendant
produce the items listed below to the undersigned counsel in accordance with Rule 1.350:
1. A true and correct copy of any and all statements, whether written, oral, or recorded, in
whatever fashion, taken of the Plaintiff, and/or his agents, servants, employees, etc. and
all independent witnesses or other persons by the Defendant in regard to the subject matter of this
liticatinn
muiganon.
2. A true certified copy of the applicable insurance policy issued to the Plaintiff by the
Defendant, including any and all endorsements in effect on the date of the loss.
3. The underwriting file, including the application of insurance signed by the Plaintiff with
regard to the subject matter of this litigation.
4. Copies of any and all correspondence between the Defendant and the Plaintiff, or anyone
acting on the Plaintiff's behalf, regardless of whether Defendant may believe Plaintiff, and/or his
agents may have same.
5. Copies of any and all correspondence, forms, report or other documents between the
Defendant and Plaintiff's insurance agent regarding the Plaintiff, the subject property or any claims
related thereto.
6. Any and ail surveiliance reports, claims history reports or other investigative reports
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED Nei71INNNA NA.24-2N DMA
Pm. PAL DLA VUUINE TT, PL, JUOL IE mDnNUeey, ULUIAN, Yur cue) ut. tou civprepared by Defendant or anyone acting behalf of the Defendant with regard to the Plaintiff, the
subject property, or any claims related thereof.
7. Any and all documents, papers, or things given to Defendant by Plaintiff or anyone acting
on behalf of Plaintiff prior to the filing of the lawsuit, regardless of whether Defendant may believe
Plaintiff and/or his agents may have same.
8. Any and all estimates and/or appraisal reports relating to Plaintiff's claim which is the
subject of this litigation.
9. Any and all video and photographs within the possession, custody, and control of the
Defendant, their agents or employees, concerning the subject matter of this litigation. As grounds
for this request, the Plaintiff asserts she cannot without undue hardship, obtain a substantial
equivalent of these photographs.
10. Any and all documents of whatever nature and kind submitted by the Plaintiff and/or
Plaintiff's agents, employees, attorneys, etc., to the Defendant, its’ agents, servants, and/or
employees in regard to the subject loss.
11. Any and all bills or estimate for repairs to the property submitted to Defendant by Plaintiff
regarding the subject property.
12. Any and all checks paid to, or on behalf of the Plaintiff, representing insurance coverage
payment(s) for the subject loss.
13. Any and all reports prepared by Defendant relating in any way to the claim at issue,
including but not limited to adjuster reports, examiner reports and any claim handling adjustment
documents used by Defendant.
14. Any and all documentation relied upon by the Defendant, relative to each and every
affirmative defense raised by the Defendant relative to coverage as weil as the amount of ioss.
15. Any and all documents evidencing the name, address, and the position/relationship with
Defendant, of every individual who has visited or plans to visit the subject property on behalf of
Defendant.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the
above-mentioned Defendant along with the Complaint and Summons.
Roger A. Alvarez, P.A.
2207 NW 23" Avenue
Miami, Florida 33142
Telephone: 305-638-1188
Fax: 305-847-2777
Cell: 954-294-4500
roger@raalvarezlaw.com
By: /s/ Roger 4. Muanrez
Roger A. Alvarez, Esq.
Florida Bar No. 53968
Preview
wes CASE NUMBER: 502021CA007553XXXXMB Div: AG **** Filing # 128992354 E-Filed 06/17/2021 04:31:30 PM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: EMELI MARTINE, Plaintiff, Vv. AMERICAN SECURITY INSURANCE COMPANY, Defendant, / FIRST REQUEST FOR PRODUCTION TO DEFENDANT COMES NOW Plaintiff, EMELI MARTINE, by and through the undersigned counsel, pursuant to Florida Rules of Civil Procedure, Rule 1.350, and files this First Request for Production to Defendant, AMERICAN SECURITY INSURANCE COMPANY, and requests the Defendant produce the items listed below to the undersigned counsel in accordance with Rule 1.350: 1. A true and correct copy of any and all statements, whether written, oral, or recorded, in whatever fashion, taken of the Plaintiff, and/or his agents, servants, employees, etc. and all independent witnesses or other persons by the Defendant in regard to the subject matter of this liticatinn muiganon. 2. A true certified copy of the applicable insurance policy issued to the Plaintiff by the Defendant, including any and all endorsements in effect on the date of the loss. 3. The underwriting file, including the application of insurance signed by the Plaintiff with regard to the subject matter of this litigation. 4. Copies of any and all correspondence between the Defendant and the Plaintiff, or anyone acting on the Plaintiff's behalf, regardless of whether Defendant may believe Plaintiff, and/or his agents may have same. 5. Copies of any and all correspondence, forms, report or other documents between the Defendant and Plaintiff's insurance agent regarding the Plaintiff, the subject property or any claims related thereto. 6. Any and ail surveiliance reports, claims history reports or other investigative reports CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED Nei71INNNA NA.24-2N DMA Pm. PAL DLA VUUINE TT, PL, JUOL IE mDnNUeey, ULUIAN, Yur cue) ut. tou civprepared by Defendant or anyone acting behalf of the Defendant with regard to the Plaintiff, the subject property, or any claims related thereof. 7. Any and all documents, papers, or things given to Defendant by Plaintiff or anyone acting on behalf of Plaintiff prior to the filing of the lawsuit, regardless of whether Defendant may believe Plaintiff and/or his agents may have same. 8. Any and all estimates and/or appraisal reports relating to Plaintiff's claim which is the subject of this litigation. 9. Any and all video and photographs within the possession, custody, and control of the Defendant, their agents or employees, concerning the subject matter of this litigation. As grounds for this request, the Plaintiff asserts she cannot without undue hardship, obtain a substantial equivalent of these photographs. 10. Any and all documents of whatever nature and kind submitted by the Plaintiff and/or Plaintiff's agents, employees, attorneys, etc., to the Defendant, its’ agents, servants, and/or employees in regard to the subject loss. 11. Any and all bills or estimate for repairs to the property submitted to Defendant by Plaintiff regarding the subject property. 12. Any and all checks paid to, or on behalf of the Plaintiff, representing insurance coverage payment(s) for the subject loss. 13. Any and all reports prepared by Defendant relating in any way to the claim at issue, including but not limited to adjuster reports, examiner reports and any claim handling adjustment documents used by Defendant. 14. Any and all documentation relied upon by the Defendant, relative to each and every affirmative defense raised by the Defendant relative to coverage as weil as the amount of ioss. 15. Any and all documents evidencing the name, address, and the position/relationship with Defendant, of every individual who has visited or plans to visit the subject property on behalf of Defendant.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the above-mentioned Defendant along with the Complaint and Summons. Roger A. Alvarez, P.A. 2207 NW 23" Avenue Miami, Florida 33142 Telephone: 305-638-1188 Fax: 305-847-2777 Cell: 954-294-4500 roger@raalvarezlaw.com By: /s/ Roger 4. Muanrez Roger A. Alvarez, Esq. Florida Bar No. 53968