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Filing # 135665322 E-Filed 09/30/2021 01:54:12 PM
ELLEN ARENBERG and
IN THE CIRCUIT COURT OF THE 17rTH
SCOTT ARENBERG,
JUDICIAL
CIRCUIT
IN
AND
FOR
BROWARD COUNTY, FLORIDA
Plaintiffs,
CASE NO.: CACE-20-017316
V
AUTO CLUB INSURANCE COMPANY OF
FLORIDA,
Defendant.
I
PLAINTIFFS' RESPONSES TO DEFENDANT'S FIRST REQUEST FOR
PRODUCTION
COME NOW, the Plaintiffs, ELLEN ARENBERG and SCOTT ARENBERG, by and
through the undersigned counsel, pursuantto the Florida Rules of Civil Procedure, and hereby file
these Responses to Defendant, AUTO CLUB INSURANCE COMPANY OF FLORIDA'S,
Request for Production and state as follows:
1.
Any and all documents used or referenced in formulating Plaintiffs' responses to
Defendant's First Set of Interrogatories to Plaintiffs.
RESPONSE: See attached.
2.
All pictures, photographs, video recordings, or other documentary evidence depicting all
physical damages to property Plaintiffs are claiming as a result of the loss referred to in
Plaintiffs' Complaint.
RESPONSE: See attached.
3. Any and all documentsrelatedto services performed,maintenance,remediationperformed,
mitigation performed, repairs commenced, repairs completed, replacement of parts,
systems or building materials, service calls or other work commenced or completed at the
property located at 412 Mallard Road, Fort Lauderdale, Florida 33327, from January 1,
2009 through the present.
RESPONSE: See attached.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/30/2021 01:54:11 PM.****
4.
Any and all receipts, invoices, credit card statements, canceled checks, bank slips, bank
statements
evidencing debit card transactions and/or cash withdrawals, or other
documentationreflectingany and all expenses already incurredby or on behalfofPlaintiffs
as a result of the loss referred to Plaintiffs' Complaint.
RESPONSE: See attached.
5.
Any and all proposals,contracts,work orders, change orders, permit applications,permits,
noticesof commencement, receipts, invoices, creditcard statements, canceledchecks, bank
slips, bank statements evidencing debit card transactionsand/or cash withdrawals,or other
documentation reflecting any and all expenses incurred as a result of any and all roof
damage, roof failures, roof leaks, window leaks and/or other water intrusion that occurred
prior to the loss referenced in Plaintiffs' Complaint.
RESPONSE: Objection, this request is not reasonably limited in time or scope.
6.
Any and all receipts, estimates, service agreementsor other documentsreflecting any and
all repairs, renovations,professionalcleaning or painting, mitigation services,roofrepairs,
plumbing repairs or work and upgrades that were commenced or completed at the subject
property following the loss referred to in Plaintiffs' Complaint.
RESPONSE: Objection, this request is not reasonably limited in scope and seeks
information
that
is
not
relevant
to
the
subject litigation.
Notwithstanding and without waiving said objection, please see
attached.
7.
Copies of any other insurance policies in effect on the date of the loss referred to in
Plaintiffs' Complaint that pertain to the property located at 412 Mallard Road, Fort
Lauderdale, Florida 33327.
RESPONSE: Plaintiffs state that they had Ilood insurance through USAA.
8.
All documents, including but not limited to, correspondences, memoranda, invoices,
receipts, estimates/scopes,reports,appraisals,proofs ofloss, etc., which supportyour claim
for all damages to the property located at 412 Mallard Road, Fort Lauderdale, Florida
33327, as a result ofthe loss referred to in Plaintiffs' Complaint.
RESPONSE: See attached.
9.
Copies of receipts, invoices, bills, credit card charges, and other related documents
evidencingrepairs or renovations of any nature made to any part of the property located at
412 Mallard Road, Fort Lauderdale,Florida 33327 or evidencing the replacement of any
property and/or building materials, from January 1,2009 through September 10,2017.
RESPONSE: Objection, this request is not reasonably limited in scope.
10. Copies of receipts, invoices, bills, credit card charges, and other related documents
evidencingrepairs or renovations of any nature made to any part of the property located at
412 Mallard Road, Fort Lauderdale,Florida 33327 or evidencing the replacement of any
property and/or building materials, from September 10,2017 through present.
RESPONSE: See attached.
11. Copies of receipts, invoices, bills, canceled checks, credit card charges, bank slips, bank
statements evidencing debit card transactions and/or cash withdrawals,and other related
documentationevidencing expenses incurred for repairs or renovations ofany nature made
to any part ofthe propertylocated at 412 Mallard Road, Fort Lauderdale,Florida 33327 or
evidencingthe replacement ofany property and/or building materialsat the aforementioned
propertypriorto the date of loss referred to in Plaintiffs' Complaint.
RESPONSE: Objection, this request is not reasonably limited in time or scope.
12. Copies of receipts, invoices, bills, canceled checks, credit card charges, bank slips, bank
statements evidencing debit card transactions and/or cash withdrawals,and other related
documentationevidencing expenses incurred for repairs or renovations ofany nature made
to any part ofthe property located at 412 Mallard Road, Fort Lauderdale,Florida 33327or
evidencingthe replacement ofany property and/or building materialsat the aforementioned
property subsequent to the date of loss referred to in Plaintiffs' Complaint.
RESPONSE: See attached.
13. Any and all correspondence, including but not limited to, e-mails and letters, by and
between the Plaintiffs and/or anyone on their behalf, and the Defendant and/or Defendant's
agent(s), regarding the loss(es) described in Plaintiffs' Complaint
RESPONSE: All requested documentation should be in Defendant's possession.
14. Any and all estimates that were prepared by an individual, entity, loss consultant, public
adjuster, roofer, general contractor, mold assessor, mold remediator, water mitigation
company, mold tester, or law firm, retainedby the Plaintiffs,reflecting damages sought as
a result ofthe loss referred to in Plaintiffs' Complaint.
RESPONSE: See attached.
15. Any and all Sworn Proof ofLoss Statementswith the supporting documentsand estimates
that were submitted by or on behalfof Plaintiffs to Defendantin support of loss referred to
in Plaintiffs' Complaint.
RESPONSE: None.
16. Copies of any documentsprovided by any third party (other than Plaintiffs' legal counsel)
to Plaintiffs or Plaintiffs' agents and/or representatives regarding the damage to the
property located at 412 Mallard Road, Fort Lauderdale, Florida 33327 in relation to the
loss referred to in Plaintiffs' Complaint.
RESPONSE: See attached.
17. Any and all estimates or estimates for repair or replacement related to the damages alleged
in the Complaint, prepared for or on behalf of Plaintiffs, or Plaintiffs' agents or
representatives.
RESPONSE: See attached.
18. Any and all photographs or videos which show the condition ofthe property located at 412
Mallard Road, Fort Lauderdale, Florida 33327 prior to the loss referenced in Plaintiffs'
Complaint, which depict the condition of the subject premises prior to Plaintiffs' alleged
loss.
RESPONSE: None.
19. Any and all photographs or videos which show the condition ofthe property located at 412
Mallard Road, Fort Lauderdale,Florida 33327 before repairs were performed as a result of
Plaintiffs' alleged loss.
RESPONSE: None.
20. Any and all photographs or videos which show repairs made to the property located at 412
Mallard Road, Fort Lauderdale, Florida 33327, after the loss referred to in Plaintiffs'
Complaint.
RESPONSE: None.
21. Any and all photographs or videos which show the property after the loss referred to in the
Complaint was first discoveredbut prior to reportingthe alleged loss to Defendant.
RESPONSE: None.
22. Any and all photographsor videos which identifythe date(s) on which any and all damages
to the subject property occurred and/or were discovered, in relation to the loss alleged in
Plaintiffs' Complaint.
RESPONSE: None.
23. All correspondences, memoranda, notes, etc., between and among Plaintiffs and any third
party (excluding attorneys retained by Plaintiffs), including, but not limited to, public
adjusters, contractors, roofers, water mitigation companies, mold remediation companies,
and/or mold assessors, pertaining to the insurance claim presented by Plaintiffs to
Defendant, for the loss referred to in the Complaint, and any other issues relevantto this
cause.
RESPONSE: None.
24. Copies ofany and all documentsrelatedto prior insurance claimspertainingto the property
located at 412 MallardRoad, Fort Lauderdale,Florida 33327, including but not limited to,
correspondence, estimates, payments, proofs of loss, public adjuster contracts, dry logs,
inspectionreports, and photographs.
RESPONSE: None.
25. Any and all documentation evidencing the date on which Plaintiffs first discovered any
damage to the property located at 412 Mallard Road, Fort Lauderdale, Florida 33327 in
relation to the loss referred to in Plaintiffs' Complaint.
RESPONSE: None.
26. Any and all documents reflecting the name(s) of the insurance carriers to whom you
reported any prior insurance claims
RESPONSE: None.
27. Copies of any and all documents related to repairs or renovations made following each and
every prior claim you have submitted on the subject property but prior to the date of loss
alleged in the Complaint.
RESPONSE: None.
28. Copies of all inspection reports, appraisals, and home inspection reports, concerning the
property located at 412 Mallard Road, Fort Lauderdale, Florida 33327, relating to
Plaintiffs'purchase ofthe aforementioned property or at any time thereafter.
RESPONSE: See attached.
29. Any and all assignments of benefits entered into by Plaintiffs with any public adjuster,
contractor, handyman, plumber, roofer, water mitigation company, mold assessor and/or
mold remediation company for the loss(es)referred to in Plaintiffs' Complaint.
RESPONSE: None.
30. Any and all documentation, including inspection reports, cause and origin reports, mold
assessment reports, laboratoryanalysis reports, weather/climatedata reports, photographs,
video recordings, etc., evidencing the cause of damage(s) for which Plaintiffs seek
insurance coverage in the instant litigation.
RESPONSE: See attached. Plaintiffs reserve their right to amend this response as
discovery is ongoing.
31. Copies of any and all documents evidencing or related to any and all bankruptcies and/or
foreclosuresfiled in the past five (5) years by or against Plaintiffs.This includes but is not
limited to documents, emails and notificationsregarding loan modifications for the subject
property.
RESPONSE: The documents requestedare public record and equally available to the
Defendant.
32. A copy of Plaintiffs' current driver's license or other current form of government-issued
photo identificationshould Plaintiffs not currently possess a driver's license.
RESPONSE: See attached.
33. Copies of any and all permit applications, permits, or records related to permits for the
property located at 412 Mallard Road, Fort Lauderdale, Florida 33327 from January 1,
2009 through the present.
RESPONSE: The documents requestedare public record and equally available to the
Defendant.
34. A copy of any and all agreements or contracts between Plaintiffs and any public adjusters,
loss consultants, roofers, contractors, mold assessor, mold tester, mitigation company, or
other remediation company in relation to the loss referenced in Plaintiffs' Complaint.
RESPONSE: See attached.
35. All documentationreceived by Plaintiffs and/or Plaintiffs' representativesfrom any mold
assessor, mold tester, mitigation company, mold remediation company and/or other
remediation company, in relationto the loss referred to in Plaintiffs' Complaint.
RESPONSE: See attached.
36. All statements obtained by Plaintiffs, or Plaintiffs' counsel, of Defendant, its agents or
representatives,or any other party, whether recorded or written,pertainingto any issues in
this cause, whether prior to or subsequent to Plaintiffs' submission ofthe instantinsurance
claims to Defendant.
RESPONSE: None.
37. All documents, correspondences, bills, invoices, receipts, papers, etc. that evidence
Plaintiffs'purchase or Plaintiffs' ownershipofany item ofpersonal property that Plaintiffs
contend was damaged or destroyed as a result of the loss referred to in Plaintiffs'
Complaint.
RESPONSE: N/A.
38. All documents evidencing or substantiating the replacement cost of any personal property
that Plaintiffs contend was damaged or destroyed as a result of the loss referred to in
Plaintiffs' Complaint.
RESPONSE: N/A.
39. All documents, correspondences,bills, invoices, receipts, papers, etc., that evidence any
additional living expenses incurred by Plaintiffs as a result of the loss referred to in
Plaintiffs' Complaint.
RESPONSE: N/A.
40. All documents, correspondences,bills, invoices, receipts, papers, etc., that evidence any
loss of rental proceeds incurred by Plaintiffs as a result of the loss referred to in Plaintiffs'
Complaint.
RESPONSE: N/A.
41. All documents, correspondences,bills, invoices, receipts, papers, etc., that evidence any
loss to contents/personalproperty claimed by Plaintiffs as a result ofthe loss referred to in
Plaintiffs' Complaint.
RESPONSE: N/A.
42. Copies ofall documents relatingto any other insurance claim presented by Plaintiffs to any
insurance company within the past ten (10) years, including
sent
to and received from any insurance company, coverage determination letters, payment
issued by any insurance company for any insurance claim, photographs,estimates, proofs
of loss, and reports.
RESPONSE: None.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via ePortal
Filing to: Linda M. Berns, Esq. and Hope C. Zelinger, Esq., Bressler, Amery & Ross, P.C., Counsel
for Defendant, 200 East Los Olas Boulevard, Suite 1500, Fort Lauderdale, Florida 33301, on this 30/h
day of September 2021.
By:/s/ Robin A. Rios
ROBIN A. RIOS, ESQ.
FBN: 1004208
JESSE N. BERNHEIM, ESQ.
FBN: 525421
REBEKAH C. MOLASKY, ESQ.
FBN: 1024720
BERNHEIM KELLEY BATTISTA & BLISS, LLC
Attorneys for Plaintiffs
110 SE 6?-th St., Suite 1719
Fort Lauderdale,FL 33301
Telephone: (954) 866-1111
Facsimile: (954) 252-4532
RRios@bkbblaw.com
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Filing # 135665322 E-Filed 09/30/2021 01:54:12 PM ELLEN ARENBERG and IN THE CIRCUIT COURT OF THE 17rTH SCOTT ARENBERG, JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Plaintiffs, CASE NO.: CACE-20-017316 V AUTO CLUB INSURANCE COMPANY OF FLORIDA, Defendant. I PLAINTIFFS' RESPONSES TO DEFENDANT'S FIRST REQUEST FOR PRODUCTION COME NOW, the Plaintiffs, ELLEN ARENBERG and SCOTT ARENBERG, by and through the undersigned counsel, pursuantto the Florida Rules of Civil Procedure, and hereby file these Responses to Defendant, AUTO CLUB INSURANCE COMPANY OF FLORIDA'S, Request for Production and state as follows: 1. Any and all documents used or referenced in formulating Plaintiffs' responses to Defendant's First Set of Interrogatories to Plaintiffs. RESPONSE: See attached. 2. All pictures, photographs, video recordings, or other documentary evidence depicting all physical damages to property Plaintiffs are claiming as a result of the loss referred to in Plaintiffs' Complaint. RESPONSE: See attached. 3. Any and all documentsrelatedto services performed,maintenance,remediationperformed, mitigation performed, repairs commenced, repairs completed, replacement of parts, systems or building materials, service calls or other work commenced or completed at the property located at 412 Mallard Road, Fort Lauderdale, Florida 33327, from January 1, 2009 through the present. RESPONSE: See attached. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/30/2021 01:54:11 PM.**** 4. Any and all receipts, invoices, credit card statements, canceled checks, bank slips, bank statements evidencing debit card transactions and/or cash withdrawals, or other documentationreflectingany and all expenses already incurredby or on behalfofPlaintiffs as a result of the loss referred to Plaintiffs' Complaint. RESPONSE: See attached. 5. Any and all proposals,contracts,work orders, change orders, permit applications,permits, noticesof commencement, receipts, invoices, creditcard statements, canceledchecks, bank slips, bank statements evidencing debit card transactionsand/or cash withdrawals,or other documentation reflecting any and all expenses incurred as a result of any and all roof damage, roof failures, roof leaks, window leaks and/or other water intrusion that occurred prior to the loss referenced in Plaintiffs' Complaint. RESPONSE: Objection, this request is not reasonably limited in time or scope. 6. Any and all receipts, estimates, service agreementsor other documentsreflecting any and all repairs, renovations,professionalcleaning or painting, mitigation services,roofrepairs, plumbing repairs or work and upgrades that were commenced or completed at the subject property following the loss referred to in Plaintiffs' Complaint. RESPONSE: Objection, this request is not reasonably limited in scope and seeks information that is not relevant to the subject litigation. Notwithstanding and without waiving said objection, please see attached. 7. Copies of any other insurance policies in effect on the date of the loss referred to in Plaintiffs' Complaint that pertain to the property located at 412 Mallard Road, Fort Lauderdale, Florida 33327. RESPONSE: Plaintiffs state that they had Ilood insurance through USAA. 8. All documents, including but not limited to, correspondences, memoranda, invoices, receipts, estimates/scopes,reports,appraisals,proofs ofloss, etc., which supportyour claim for all damages to the property located at 412 Mallard Road, Fort Lauderdale, Florida 33327, as a result ofthe loss referred to in Plaintiffs' Complaint. RESPONSE: See attached. 9. Copies of receipts, invoices, bills, credit card charges, and other related documents evidencingrepairs or renovations of any nature made to any part of the property located at 412 Mallard Road, Fort Lauderdale,Florida 33327 or evidencing the replacement of any property and/or building materials, from January 1,2009 through September 10,2017. RESPONSE: Objection, this request is not reasonably limited in scope. 10. Copies of receipts, invoices, bills, credit card charges, and other related documents evidencingrepairs or renovations of any nature made to any part of the property located at 412 Mallard Road, Fort Lauderdale,Florida 33327 or evidencing the replacement of any property and/or building materials, from September 10,2017 through present. RESPONSE: See attached. 11. Copies of receipts, invoices, bills, canceled checks, credit card charges, bank slips, bank statements evidencing debit card transactions and/or cash withdrawals,and other related documentationevidencing expenses incurred for repairs or renovations ofany nature made to any part ofthe propertylocated at 412 Mallard Road, Fort Lauderdale,Florida 33327 or evidencingthe replacement ofany property and/or building materialsat the aforementioned propertypriorto the date of loss referred to in Plaintiffs' Complaint. RESPONSE: Objection, this request is not reasonably limited in time or scope. 12. Copies of receipts, invoices, bills, canceled checks, credit card charges, bank slips, bank statements evidencing debit card transactions and/or cash withdrawals,and other related documentationevidencing expenses incurred for repairs or renovations ofany nature made to any part ofthe property located at 412 Mallard Road, Fort Lauderdale,Florida 33327or evidencingthe replacement ofany property and/or building materialsat the aforementioned property subsequent to the date of loss referred to in Plaintiffs' Complaint. RESPONSE: See attached. 13. Any and all correspondence, including but not limited to, e-mails and letters, by and between the Plaintiffs and/or anyone on their behalf, and the Defendant and/or Defendant's agent(s), regarding the loss(es) described in Plaintiffs' Complaint RESPONSE: All requested documentation should be in Defendant's possession. 14. Any and all estimates that were prepared by an individual, entity, loss consultant, public adjuster, roofer, general contractor, mold assessor, mold remediator, water mitigation company, mold tester, or law firm, retainedby the Plaintiffs,reflecting damages sought as a result ofthe loss referred to in Plaintiffs' Complaint. RESPONSE: See attached. 15. Any and all Sworn Proof ofLoss Statementswith the supporting documentsand estimates that were submitted by or on behalfof Plaintiffs to Defendantin support of loss referred to in Plaintiffs' Complaint. RESPONSE: None. 16. Copies of any documentsprovided by any third party (other than Plaintiffs' legal counsel) to Plaintiffs or Plaintiffs' agents and/or representatives regarding the damage to the property located at 412 Mallard Road, Fort Lauderdale, Florida 33327 in relation to the loss referred to in Plaintiffs' Complaint. RESPONSE: See attached. 17. Any and all estimates or estimates for repair or replacement related to the damages alleged in the Complaint, prepared for or on behalf of Plaintiffs, or Plaintiffs' agents or representatives. RESPONSE: See attached. 18. Any and all photographs or videos which show the condition ofthe property located at 412 Mallard Road, Fort Lauderdale, Florida 33327 prior to the loss referenced in Plaintiffs' Complaint, which depict the condition of the subject premises prior to Plaintiffs' alleged loss. RESPONSE: None. 19. Any and all photographs or videos which show the condition ofthe property located at 412 Mallard Road, Fort Lauderdale,Florida 33327 before repairs were performed as a result of Plaintiffs' alleged loss. RESPONSE: None. 20. Any and all photographs or videos which show repairs made to the property located at 412 Mallard Road, Fort Lauderdale, Florida 33327, after the loss referred to in Plaintiffs' Complaint. RESPONSE: None. 21. Any and all photographs or videos which show the property after the loss referred to in the Complaint was first discoveredbut prior to reportingthe alleged loss to Defendant. RESPONSE: None. 22. Any and all photographsor videos which identifythe date(s) on which any and all damages to the subject property occurred and/or were discovered, in relation to the loss alleged in Plaintiffs' Complaint. RESPONSE: None. 23. All correspondences, memoranda, notes, etc., between and among Plaintiffs and any third party (excluding attorneys retained by Plaintiffs), including, but not limited to, public adjusters, contractors, roofers, water mitigation companies, mold remediation companies, and/or mold assessors, pertaining to the insurance claim presented by Plaintiffs to Defendant, for the loss referred to in the Complaint, and any other issues relevantto this cause. RESPONSE: None. 24. Copies ofany and all documentsrelatedto prior insurance claimspertainingto the property located at 412 MallardRoad, Fort Lauderdale,Florida 33327, including but not limited to, correspondence, estimates, payments, proofs of loss, public adjuster contracts, dry logs, inspectionreports, and photographs. RESPONSE: None. 25. Any and all documentation evidencing the date on which Plaintiffs first discovered any damage to the property located at 412 Mallard Road, Fort Lauderdale, Florida 33327 in relation to the loss referred to in Plaintiffs' Complaint. RESPONSE: None. 26. Any and all documents reflecting the name(s) of the insurance carriers to whom you reported any prior insurance claims RESPONSE: None. 27. Copies of any and all documents related to repairs or renovations made following each and every prior claim you have submitted on the subject property but prior to the date of loss alleged in the Complaint. RESPONSE: None. 28. Copies of all inspection reports, appraisals, and home inspection reports, concerning the property located at 412 Mallard Road, Fort Lauderdale, Florida 33327, relating to Plaintiffs'purchase ofthe aforementioned property or at any time thereafter. RESPONSE: See attached. 29. Any and all assignments of benefits entered into by Plaintiffs with any public adjuster, contractor, handyman, plumber, roofer, water mitigation company, mold assessor and/or mold remediation company for the loss(es)referred to in Plaintiffs' Complaint. RESPONSE: None. 30. Any and all documentation, including inspection reports, cause and origin reports, mold assessment reports, laboratoryanalysis reports, weather/climatedata reports, photographs, video recordings, etc., evidencing the cause of damage(s) for which Plaintiffs seek insurance coverage in the instant litigation. RESPONSE: See attached. Plaintiffs reserve their right to amend this response as discovery is ongoing. 31. Copies of any and all documents evidencing or related to any and all bankruptcies and/or foreclosuresfiled in the past five (5) years by or against Plaintiffs.This includes but is not limited to documents, emails and notificationsregarding loan modifications for the subject property. RESPONSE: The documents requestedare public record and equally available to the Defendant. 32. A copy of Plaintiffs' current driver's license or other current form of government-issued photo identificationshould Plaintiffs not currently possess a driver's license. RESPONSE: See attached. 33. Copies of any and all permit applications, permits, or records related to permits for the property located at 412 Mallard Road, Fort Lauderdale, Florida 33327 from January 1, 2009 through the present. RESPONSE: The documents requestedare public record and equally available to the Defendant. 34. A copy of any and all agreements or contracts between Plaintiffs and any public adjusters, loss consultants, roofers, contractors, mold assessor, mold tester, mitigation company, or other remediation company in relation to the loss referenced in Plaintiffs' Complaint. RESPONSE: See attached. 35. All documentationreceived by Plaintiffs and/or Plaintiffs' representativesfrom any mold assessor, mold tester, mitigation company, mold remediation company and/or other remediation company, in relationto the loss referred to in Plaintiffs' Complaint. RESPONSE: See attached. 36. All statements obtained by Plaintiffs, or Plaintiffs' counsel, of Defendant, its agents or representatives,or any other party, whether recorded or written,pertainingto any issues in this cause, whether prior to or subsequent to Plaintiffs' submission ofthe instantinsurance claims to Defendant. RESPONSE: None. 37. All documents, correspondences, bills, invoices, receipts, papers, etc. that evidence Plaintiffs'purchase or Plaintiffs' ownershipofany item ofpersonal property that Plaintiffs contend was damaged or destroyed as a result of the loss referred to in Plaintiffs' Complaint. RESPONSE: N/A. 38. All documents evidencing or substantiating the replacement cost of any personal property that Plaintiffs contend was damaged or destroyed as a result of the loss referred to in Plaintiffs' Complaint. RESPONSE: N/A. 39. All documents, correspondences,bills, invoices, receipts, papers, etc., that evidence any additional living expenses incurred by Plaintiffs as a result of the loss referred to in Plaintiffs' Complaint. RESPONSE: N/A. 40. All documents, correspondences,bills, invoices, receipts, papers, etc., that evidence any loss of rental proceeds incurred by Plaintiffs as a result of the loss referred to in Plaintiffs' Complaint. RESPONSE: N/A. 41. All documents, correspondences,bills, invoices, receipts, papers, etc., that evidence any loss to contents/personalproperty claimed by Plaintiffs as a result ofthe loss referred to in Plaintiffs' Complaint. RESPONSE: N/A. 42. Copies ofall documents relatingto any other insurance claim presented by Plaintiffs to any insurance company within the past ten (10) years, including sent to and received from any insurance company, coverage determination letters, payment issued by any insurance company for any insurance claim, photographs,estimates, proofs of loss, and reports. RESPONSE: None. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via ePortal Filing to: Linda M. Berns, Esq. and Hope C. Zelinger, Esq., Bressler, Amery & Ross, P.C., Counsel for Defendant, 200 East Los Olas Boulevard, Suite 1500, Fort Lauderdale, Florida 33301, on this 30/h day of September 2021. By:/s/ Robin A. Rios ROBIN A. RIOS, ESQ. FBN: 1004208 JESSE N. BERNHEIM, ESQ. FBN: 525421 REBEKAH C. MOLASKY, ESQ. FBN: 1024720 BERNHEIM KELLEY BATTISTA & BLISS, LLC Attorneys for Plaintiffs 110 SE 6?-th St., Suite 1719 Fort Lauderdale,FL 33301 Telephone: (954) 866-1111 Facsimile: (954) 252-4532 RRios@bkbblaw.com