Preview
Filing# 145202807 E-Filed 03/07/2022 02:50:35 PM
In The Circuit Court Of The 17th Judicial Circuit
In And For Broward County, Florida
Peter and Monica Treppeda,
Case No.: CACE-21-007431
Plaintiff(s),
VS.
Universal Property & CasualtyInsurance Coinpany,
Defendant.
AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM
PLEASE TAKE NOTICE that the undersignedattorneys will take the video deposition
Ofi
Name Date and Time Location
Defendant's Corporate June 13, 2022 Zoom Meeting Link
Representative 10:00 A.M. ET https://app.parrothq.com/d/65187491
This is a videotapeddepositionthat will occur before
Notary Public,or any officer authorized bylaw
a
in the State of Florida,via Zoom. This deposition
to take depositions will be videotapedby Parrot,
LLC. This videotapedexamination will continue from day to day until completed.This videotaped
is being taken
deposition for the purpose of for the use
discovery, at trial or for such other purposes
as are and governingrules of Court.
permittedunder the applicable
In accordance with the Americans with Disabilities Act of 1990, persons needing special
accommodation to participatein this proceedingshould contact the within-named attorney at no later
than seven days priorto the proceeding.
Please see the attached Subpoena which will be served upon the deponent, attached
hereto as Exhibit A, including document requests.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/07/2022 02:50:35 PM.****
submitted,
Respectfully
The Property People FL, P.A.
forPlaintiff
-Attorneys
80 SW 8th Street,Suite 2590
Miami, FL 33130
Telephone:844.776.7364
E-Service: Service@PropertyPeopleLaw.com
By: /s / Daniel M. Ilani
Daniel M. Ilani,Esq.
Florida Bar No. 116189
Email: Danny(*PropertyPeopleLaw.com
Nicole S. Houtnan, Esq.
Florida Bar No. 1013527
Email: Nicole@PropertyPeopleLaw.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this March 7,2022, a true and correct copy of the foregoing
was served via Florida's portalto Joseph P Henn, Esq.,Lindsay C. Tropnas, Esq.,Attorney's
e-filing
for Defendant at is0601@universalproperty.coin,
upciceservice01@universalproperty.com,
jh0518@universalproperty.coin,
lt0223@universalproperty.coin.
/s/ Daniel M. Ilani
Daniel M. Ilani
In The Circuit Court Of The 17th Judicial Circuit
In And For Broward County, Florida
Peter and Monica Treppeda,
Case No.: CACE-21-007431
Plaintiff(s),
VS.
Universal Property & CasualtyInsurance Coinpany,
Defendant.
SUBPOENA DUCES TECUM
STATE OF FLORIDA
TO: Defendant's Corporate Representative
YOU ARE HEREBY COMMANDED to appear via Zoom Video Conference on June
13, 2022 at 10:00 A.M. ET, and, at least ten davspnor to Deposition, shall produce all items
regardinga loss at 16425 SAPPHIRE PLA-CE, WESTON, FL, 33331, with assignedClaim Number
FL20-0153899E420, as well as:
Definitions and Instructions
A. The terms "Peter and Monica Treppeda " mean Plaintiff(s),
or "Plaintiff(s)" Peter and
Monica Treppeda, includingall of their past and present partners, employees,agents, representatives,
attorneys, and any other person actingor purportingto act on their behalf.
B. The term "Insurance Companf' means Defendant, Universal Property & Casualty
Insurance Company, includingall of its past and present affiliates, and parent, and
subsidiaries, all
their respectiveofficers, directors, shareholders, partners, employees, agents, representatives,
attorneys, and any other person actingor purportingto act on any of its behalf.
C. The term "Property" shall mean the property concerning the subject
Plaintiff(s)'
lawsuit.
D. The term"Claim" means claim number, for the loss to Plaintiff(s)'
the subject Property
concerningthe subjectlawsuit.
E. "You" or"Your" shall mean Defendant, the Insurance Company, includingits agents,
employees or other servants (includingindependent contractors and subcontractors),
attorneys,
outside advisors or consultants,investigators, of any kind and any other person acting
representatives
on its behalf or for its or indirectly.
benefit,either directly
F. The term "communication" means the convey-ance of information or knowledge by
orallyor otherwise and includes, but
writing, is not limited to, letters,memoranda, reports,
writings,
notes, interoffice communication
telegratns, electronic mail, audiotapes, and
videotapes, computer
programs and any form of electromagnetic
storage.
G. The term "document" means and includes any kind of written, typed,electronically
produced or recorded or otherwise recorded and any graphic matter, however produced or
whether sent or received, and every record of
reproduced,of any kind or description, every- type,
non-identical copies and drafts,and both
includingoriginals, sides of any documentation where
information appears on both sides, and including but not limited to: letters, correspondence,
or minutes, publicfilings
memoranda, meeting transcripts or tax returns, papers, books, telegratns,
bulletins,notices,announcements, instructions,charts,manuals, brochures, schedules, cables,telex
messages, notes, notations, accountants' working papers, transcriptions,agendas,reports, recordings
oftelephone or other conversations, ofinterviews, of conferences or of meetings,telephonemessages,
diaries,indices, books, reports, ledgers,
working papers, invoices, worksheets, receipts,
computer
printouts,financial statements, schedules affidavits,contracts, canceled checks, statements,
magazine or newspaper articles,
transcripts, releases and any and
periodicals, all drafts,alterations and
modifications, changes and amendments of any of the foregoing,whether handwritten, printedor
prepared,filed or stored, affidavits,statements, summaries, opinions,reports, studies,
electronically
statistical records,calendars,appointmentbooks,
evaluations,contracts, agreements, journals,
analysis,
tabulations,sound recordings,
diaries,lists, computer print-outs, data processing input and output,
or press releases,includinginformation stored
newspapers, magazines,books, periodicals
tnicrofiltns,
on any electromagnetic
storage device, any written, printed,typed, recorded, or graphic matter,
however produced or reproduced or stored to which you have or had access. If any responsive
information or documentation is stored on computer, then printout a hard or paper copy of such
information or documentation or download such information or documentation to a floppy disk.
"Document" shall also be deemed to include copiesof documents even though the originals
are not
in your custodyor control; every- copy of a document which contains handwritten or other
possession,
notations or which otherwise does not duplicate of any other copy; and all attachments to
the original
any document. "Document" shall also be deemed to include any summary of a document or
documents called for hereafter.
H. As used shall include the
herein the singular the plural
plural, shall include the singular,
and the tnasculine,feminine, and neutral shall include each of the other genders.
I. The terms "and" as well as "or" shall be construed disjunctively
as well as conjunctively
as necessary to make the request inclusive rather than exclusive. The term "all" means " any and all."
The term "each" means "each and every,"and the term "every"means "each and every."
J. The terms "refer" or 'relate to" mean setting forth, pertainingto, memorializing,
constituting,
einbodying,discussing,
analyzing, or otherwise concerning.
reflecting
K. "Relatingto" means embodying, pertainingto, concerning, involving,
constituting,
comprising,reflecting,
discussing,
evidencing,referring of, or having any logicalor
to, consisting
factual connection whatever with the subjectmatter in question.
L. If you claim that the attorney-client or attorneys'work product
or other privilege
doctrine is applicable
to any document the identification of which is sought by these requests, then
with respect to each such document, state its date, author(s), present and
recipient(s), all previous
custodians, location, subjectmatter, and sufficient additional information to explainthe claim of
and to enable adjudication
privilege of the proprietyof that claim.
M. or other
If you claim that the attorney-client work product
or the attorneys'
privilege
to any event, occurrence, or communications, including
doctrine is applicable any oral coininunication,
the identification of which is sought by these requests, then with respect to each such event or
occurrence, state its date, place and length,identify
all
persons present at all or any part of the event
or occurrence; identifyall documents that record, refer,or relate to the event or occurrence; state the
subjectmatter of the event or occurrence; and providesufficient additional information to explainthe
and to enable adjudication
claim of privilege of the proprietyof that claim.
N. If any document the identification of which is sought by these requests has been
destroyed,then state the date and circumstances of its destruction, and identifythe person who
destroyedthe documents and the person who ordered its destruction.
SCHEDULE A
1. The identity,
by full name and company title, of all those persons who participated
in making
the decisionon behalf of the Insurance Company to withhold, deny or authorize payments;
The assessment, evaluation, and valuation of damages;
2. The terms, limitations,exclusions,and conditions within the Insurance Companfs insurance
policyit contends applyto exclude or limit coverage;
3. The terms, limitations,exclusions, and conditions within the Insurance Companfs insurance
policywhich it contends applyto exclude or limit damages;
4. The allegations
in the most recent version of the Complaint;
5. The Insurance Companfs Responses, Objections,and Answers to discovery requests,
includingany basis,factual or otherwise, for its Answers,
Objections, and Responses;
6. The Plaintiff(s)'Responses, Objections,and Answers to discoveryrequests;
7. The factual basis for any and all denials and affirmative defenses raised by the Insurance
Company in the most recent version of the Answer;
8. The Insurance Companfs investigation, adjustment,and handlingof the Claim from the date
of loss to present date;
9. The date and circumstances which gave rise to the Insurance Company's reasonable
would ensue, result,or arise regardingthe Claim;
expectationor belief that litigation
10. The terms, conditions, limitations and exclusions within the Insurance Companfs insurance
policywhich it contends it has complied with in adjustingthe Claim;
11. Any actions or omissions which the Insurance Company claims voided or excluded coverage;
12. The identityof the person or persons who participated in retainingany of the engineersor
damage repairexperts to evaluate the Claim and the results,findings,work, tests, surveys, and
evaluations done by the engineersor damage repairexperts.
13. The pre-losscondition of the Property as memorialized in the underwritingfile,includingany
pre-loss inspections, inspectionreports, and pre-loss
pre-loss photographs.
14. Prior property damage insurance claims on the Property and the damage sustained.
SCHEDULE B
DUCES TECUM
Items to be Produced
1. A certified copy of the Policy.
2. All statements taken of Plaintiff(s).
3. All statements takenof all independentwitnesses or other persons by the Insurance Company
to coverage for
relating Claim.
Plaintiff(s)'
4. All documents reflecting communications between you and Plaintiff(s) relatingto the Claim.
5. All photographs of the Property relating to the Claim, includingany thermal imagery.With
JPEG or TIFF digital
respect to this request, pleasealso include the original files,or digital
image files converted directlyfrom the native digital
format, includingall metadata.
6. All video recordingsin originaldigital format, includingany drone footage,along with all
metadata, of the to
Propertyrelating the Claim.
7. All documents submitted to you by Plaintiff(s) to the Claim.
relating
8. All diagrams,sketches and other drawingsdepicting
the Property relating
to the Claim.
9. All reports and estimates relatingto the damage to the Property.
10. All documents relating to assessments as to the damage to the Property.
11. All documents reflecting for payment(s) of money relating
negotiations to damage to the
Property.
12. All documents relating
to the coverages the Policyaffords to Plaintiff(s).
13. All documents relating
to your decision not to fullycompensate Plaintiff for their Claim.
14. All documents to and from adjusters and/or appraisers relatingto coverage for Plaintiff(s)'
Claim.
15. All photographs, inspection reports, or other documents relatingto the condition of
Property priorto Plaintiff(s)'
Plaintiff(s)' Claim, includingall inspectionreports prepared by
the Insurance Company before decidingto insure Plaintiff(s)' Property.With respect to
photographs,pleasealso include all originalJPEG or TIFF format digital or digital
files, image
files converted directlyfrom the native digital
format, including all metadata.
16. All photographs, inspectionreports, or other documents relatingto the condition of
Plaintiff(s)'Property subsequentto Plaintiff(s)' Claim. With respect to photographs,please
also include all originalJPEG or TIFF format digitalfiles,or digital image files converted
directly from the native digital
format, includingall metadata.
17. All documents confirmingthe dates and times that you inspectedPlaintiff(s)' Property within
the past 5 years.
18. All documents reflecting
the areas of Plaintiff(s)'
Property inspectedwithin the past five years.
19. All documents reflecting Property on your behalf
the individuals that inspectedPlaintiff(s)'
within the past five years.
20. The underwritingfile for the Policy.
21. Any and all statements that be attributed to Plaintiff(s),
call including,but not limited to, any
claim log notes or entries memorializing,summarizing,transcribing, and/or documenting any
statements made by Plaintiff(s) during pre-suit in accordance with Florida Rule of Civil
Procedure 1.280. Defendant may produce claim log notes redacted to exclude all other
information.
privileged
You have the rightto make a legalobjectionto the productionof these materials under Florida
Rules of Civil Procedure 1.410. If you fail to comply,you may be held in contempt of Court.
You may request reasonable costs of preparingthese copiesin advance by making written
request within five (5)days.
A copy of this Subpoena has been furnished to all counsel of record.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this March 7,2022, a true and correct copy of the foregoing
was served via Florida's portalto Joseph P Henn, Esq.,Lindsay C. Tropnas, Esq.,Attorney's
e-filing
for Defendant at upciceservice01@universalproperty.com,
is0601@universalproperty.coin,
jh0518@universalproperty.coin,
lt0223@universalproperty.coin.
/s/ Daniel M. Ilani
Daniel M. Ilani
Preview
Filing# 145202807 E-Filed 03/07/2022 02:50:35 PM In The Circuit Court Of The 17th Judicial Circuit In And For Broward County, Florida Peter and Monica Treppeda, Case No.: CACE-21-007431 Plaintiff(s), VS. Universal Property & CasualtyInsurance Coinpany, Defendant. AMENDED NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersignedattorneys will take the video deposition Ofi Name Date and Time Location Defendant's Corporate June 13, 2022 Zoom Meeting Link Representative 10:00 A.M. ET https://app.parrothq.com/d/65187491 This is a videotapeddepositionthat will occur before Notary Public,or any officer authorized bylaw a in the State of Florida,via Zoom. This deposition to take depositions will be videotapedby Parrot, LLC. This videotapedexamination will continue from day to day until completed.This videotaped is being taken deposition for the purpose of for the use discovery, at trial or for such other purposes as are and governingrules of Court. permittedunder the applicable In accordance with the Americans with Disabilities Act of 1990, persons needing special accommodation to participatein this proceedingshould contact the within-named attorney at no later than seven days priorto the proceeding. Please see the attached Subpoena which will be served upon the deponent, attached hereto as Exhibit A, including document requests. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/07/2022 02:50:35 PM.**** submitted, Respectfully The Property People FL, P.A. forPlaintiff -Attorneys 80 SW 8th Street,Suite 2590 Miami, FL 33130 Telephone:844.776.7364 E-Service: Service@PropertyPeopleLaw.com By: /s / Daniel M. Ilani Daniel M. Ilani,Esq. Florida Bar No. 116189 Email: Danny(*PropertyPeopleLaw.com Nicole S. Houtnan, Esq. Florida Bar No. 1013527 Email: Nicole@PropertyPeopleLaw.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this March 7,2022, a true and correct copy of the foregoing was served via Florida's portalto Joseph P Henn, Esq.,Lindsay C. Tropnas, Esq.,Attorney's e-filing for Defendant at is0601@universalproperty.coin, upciceservice01@universalproperty.com, jh0518@universalproperty.coin, lt0223@universalproperty.coin. /s/ Daniel M. Ilani Daniel M. Ilani In The Circuit Court Of The 17th Judicial Circuit In And For Broward County, Florida Peter and Monica Treppeda, Case No.: CACE-21-007431 Plaintiff(s), VS. Universal Property & CasualtyInsurance Coinpany, Defendant. SUBPOENA DUCES TECUM STATE OF FLORIDA TO: Defendant's Corporate Representative YOU ARE HEREBY COMMANDED to appear via Zoom Video Conference on June 13, 2022 at 10:00 A.M. ET, and, at least ten davspnor to Deposition, shall produce all items regardinga loss at 16425 SAPPHIRE PLA-CE, WESTON, FL, 33331, with assignedClaim Number FL20-0153899E420, as well as: Definitions and Instructions A. The terms "Peter and Monica Treppeda " mean Plaintiff(s), or "Plaintiff(s)" Peter and Monica Treppeda, includingall of their past and present partners, employees,agents, representatives, attorneys, and any other person actingor purportingto act on their behalf. B. The term "Insurance Companf' means Defendant, Universal Property & Casualty Insurance Company, includingall of its past and present affiliates, and parent, and subsidiaries, all their respectiveofficers, directors, shareholders, partners, employees, agents, representatives, attorneys, and any other person actingor purportingto act on any of its behalf. C. The term "Property" shall mean the property concerning the subject Plaintiff(s)' lawsuit. D. The term"Claim" means claim number, for the loss to Plaintiff(s)' the subject Property concerningthe subjectlawsuit. E. "You" or"Your" shall mean Defendant, the Insurance Company, includingits agents, employees or other servants (includingindependent contractors and subcontractors), attorneys, outside advisors or consultants,investigators, of any kind and any other person acting representatives on its behalf or for its or indirectly. benefit,either directly F. The term "communication" means the convey-ance of information or knowledge by orallyor otherwise and includes, but writing, is not limited to, letters,memoranda, reports, writings, notes, interoffice communication telegratns, electronic mail, audiotapes, and videotapes, computer programs and any form of electromagnetic storage. G. The term "document" means and includes any kind of written, typed,electronically produced or recorded or otherwise recorded and any graphic matter, however produced or whether sent or received, and every record of reproduced,of any kind or description, every- type, non-identical copies and drafts,and both includingoriginals, sides of any documentation where information appears on both sides, and including but not limited to: letters, correspondence, or minutes, publicfilings memoranda, meeting transcripts or tax returns, papers, books, telegratns, bulletins,notices,announcements, instructions,charts,manuals, brochures, schedules, cables,telex messages, notes, notations, accountants' working papers, transcriptions,agendas,reports, recordings oftelephone or other conversations, ofinterviews, of conferences or of meetings,telephonemessages, diaries,indices, books, reports, ledgers, working papers, invoices, worksheets, receipts, computer printouts,financial statements, schedules affidavits,contracts, canceled checks, statements, magazine or newspaper articles, transcripts, releases and any and periodicals, all drafts,alterations and modifications, changes and amendments of any of the foregoing,whether handwritten, printedor prepared,filed or stored, affidavits,statements, summaries, opinions,reports, studies, electronically statistical records,calendars,appointmentbooks, evaluations,contracts, agreements, journals, analysis, tabulations,sound recordings, diaries,lists, computer print-outs, data processing input and output, or press releases,includinginformation stored newspapers, magazines,books, periodicals tnicrofiltns, on any electromagnetic storage device, any written, printed,typed, recorded, or graphic matter, however produced or reproduced or stored to which you have or had access. If any responsive information or documentation is stored on computer, then printout a hard or paper copy of such information or documentation or download such information or documentation to a floppy disk. "Document" shall also be deemed to include copiesof documents even though the originals are not in your custodyor control; every- copy of a document which contains handwritten or other possession, notations or which otherwise does not duplicate of any other copy; and all attachments to the original any document. "Document" shall also be deemed to include any summary of a document or documents called for hereafter. H. As used shall include the herein the singular the plural plural, shall include the singular, and the tnasculine,feminine, and neutral shall include each of the other genders. I. The terms "and" as well as "or" shall be construed disjunctively as well as conjunctively as necessary to make the request inclusive rather than exclusive. The term "all" means " any and all." The term "each" means "each and every,"and the term "every"means "each and every." J. The terms "refer" or 'relate to" mean setting forth, pertainingto, memorializing, constituting, einbodying,discussing, analyzing, or otherwise concerning. reflecting K. "Relatingto" means embodying, pertainingto, concerning, involving, constituting, comprising,reflecting, discussing, evidencing,referring of, or having any logicalor to, consisting factual connection whatever with the subjectmatter in question. L. If you claim that the attorney-client or attorneys'work product or other privilege doctrine is applicable to any document the identification of which is sought by these requests, then with respect to each such document, state its date, author(s), present and recipient(s), all previous custodians, location, subjectmatter, and sufficient additional information to explainthe claim of and to enable adjudication privilege of the proprietyof that claim. M. or other If you claim that the attorney-client work product or the attorneys' privilege to any event, occurrence, or communications, including doctrine is applicable any oral coininunication, the identification of which is sought by these requests, then with respect to each such event or occurrence, state its date, place and length,identify all persons present at all or any part of the event or occurrence; identifyall documents that record, refer,or relate to the event or occurrence; state the subjectmatter of the event or occurrence; and providesufficient additional information to explainthe and to enable adjudication claim of privilege of the proprietyof that claim. N. If any document the identification of which is sought by these requests has been destroyed,then state the date and circumstances of its destruction, and identifythe person who destroyedthe documents and the person who ordered its destruction. SCHEDULE A 1. The identity, by full name and company title, of all those persons who participated in making the decisionon behalf of the Insurance Company to withhold, deny or authorize payments; The assessment, evaluation, and valuation of damages; 2. The terms, limitations,exclusions,and conditions within the Insurance Companfs insurance policyit contends applyto exclude or limit coverage; 3. The terms, limitations,exclusions, and conditions within the Insurance Companfs insurance policywhich it contends applyto exclude or limit damages; 4. The allegations in the most recent version of the Complaint; 5. The Insurance Companfs Responses, Objections,and Answers to discovery requests, includingany basis,factual or otherwise, for its Answers, Objections, and Responses; 6. The Plaintiff(s)'Responses, Objections,and Answers to discoveryrequests; 7. The factual basis for any and all denials and affirmative defenses raised by the Insurance Company in the most recent version of the Answer; 8. The Insurance Companfs investigation, adjustment,and handlingof the Claim from the date of loss to present date; 9. The date and circumstances which gave rise to the Insurance Company's reasonable would ensue, result,or arise regardingthe Claim; expectationor belief that litigation 10. The terms, conditions, limitations and exclusions within the Insurance Companfs insurance policywhich it contends it has complied with in adjustingthe Claim; 11. Any actions or omissions which the Insurance Company claims voided or excluded coverage; 12. The identityof the person or persons who participated in retainingany of the engineersor damage repairexperts to evaluate the Claim and the results,findings,work, tests, surveys, and evaluations done by the engineersor damage repairexperts. 13. The pre-losscondition of the Property as memorialized in the underwritingfile,includingany pre-loss inspections, inspectionreports, and pre-loss pre-loss photographs. 14. Prior property damage insurance claims on the Property and the damage sustained. SCHEDULE B DUCES TECUM Items to be Produced 1. A certified copy of the Policy. 2. All statements taken of Plaintiff(s). 3. All statements takenof all independentwitnesses or other persons by the Insurance Company to coverage for relating Claim. Plaintiff(s)' 4. All documents reflecting communications between you and Plaintiff(s) relatingto the Claim. 5. All photographs of the Property relating to the Claim, includingany thermal imagery.With JPEG or TIFF digital respect to this request, pleasealso include the original files,or digital image files converted directlyfrom the native digital format, includingall metadata. 6. All video recordingsin originaldigital format, includingany drone footage,along with all metadata, of the to Propertyrelating the Claim. 7. All documents submitted to you by Plaintiff(s) to the Claim. relating 8. All diagrams,sketches and other drawingsdepicting the Property relating to the Claim. 9. All reports and estimates relatingto the damage to the Property. 10. All documents relating to assessments as to the damage to the Property. 11. All documents reflecting for payment(s) of money relating negotiations to damage to the Property. 12. All documents relating to the coverages the Policyaffords to Plaintiff(s). 13. All documents relating to your decision not to fullycompensate Plaintiff for their Claim. 14. All documents to and from adjusters and/or appraisers relatingto coverage for Plaintiff(s)' Claim. 15. All photographs, inspection reports, or other documents relatingto the condition of Property priorto Plaintiff(s)' Plaintiff(s)' Claim, includingall inspectionreports prepared by the Insurance Company before decidingto insure Plaintiff(s)' Property.With respect to photographs,pleasealso include all originalJPEG or TIFF format digital or digital files, image files converted directlyfrom the native digital format, including all metadata. 16. All photographs, inspectionreports, or other documents relatingto the condition of Plaintiff(s)'Property subsequentto Plaintiff(s)' Claim. With respect to photographs,please also include all originalJPEG or TIFF format digitalfiles,or digital image files converted directly from the native digital format, includingall metadata. 17. All documents confirmingthe dates and times that you inspectedPlaintiff(s)' Property within the past 5 years. 18. All documents reflecting the areas of Plaintiff(s)' Property inspectedwithin the past five years. 19. All documents reflecting Property on your behalf the individuals that inspectedPlaintiff(s)' within the past five years. 20. The underwritingfile for the Policy. 21. Any and all statements that be attributed to Plaintiff(s), call including,but not limited to, any claim log notes or entries memorializing,summarizing,transcribing, and/or documenting any statements made by Plaintiff(s) during pre-suit in accordance with Florida Rule of Civil Procedure 1.280. Defendant may produce claim log notes redacted to exclude all other information. privileged You have the rightto make a legalobjectionto the productionof these materials under Florida Rules of Civil Procedure 1.410. If you fail to comply,you may be held in contempt of Court. You may request reasonable costs of preparingthese copiesin advance by making written request within five (5)days. A copy of this Subpoena has been furnished to all counsel of record. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this March 7,2022, a true and correct copy of the foregoing was served via Florida's portalto Joseph P Henn, Esq.,Lindsay C. Tropnas, Esq.,Attorney's e-filing for Defendant at upciceservice01@universalproperty.com, is0601@universalproperty.coin, jh0518@universalproperty.coin, lt0223@universalproperty.coin. /s/ Daniel M. Ilani Daniel M. Ilani