Preview
Filing # 128521728 E-Filed 06/10/2021 03:38:16 PM
IN
THE
CIRCUIT
COURT OF
THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND
FOR
BROWARD
COUNTY,
FLORIDA
CASE NO.: CACE-21-007460
AMER JERDANA,
Plaintiff,
V
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
NOTICE OF FILING INTERROGATORIES TO PLAINTIFF
COMES NOW Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by
and through their undersigned counsel and filed their Notice of Filing Interrogatories to
Plaintiff, to be answered under oath and in writing within the time permitted by the Florida
Rules of Civil Procedure or within such time as directed by the Court.
-
THIS SPACE IS INTENTIONALLY LEFT BLANK -
Page 1
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/10/2021 03:38:15 PM.****
CASE NO.: CACE-21-007460
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of June 2021, a true and correct copy
of the foregoing was filed with the Clerk of Broward County by using the Florida Courts
e-Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: Teresa Urda, Esq., Law Offices of Marcote &
Marcote
De
Moya,
PLLC,
12595 SW 137th Ave., Miami, Florida
33186, (305) 256-2616/(305) 256-2446 (F), Attorney for Plaintiff, Amer Jerdana.
COLE, SCOTT & KISSANE, P.A.
Counselfor Defendant CITIZENS PROPERTY
NSURANCE CORPORATION
Lakeside Office Center, Suite 500
600 North Pine Island Road
Plantation, Florida 33324
Telephone (954) 703-3706
Facsimile (954) 474-7979
Primary e-mail:
Secondarye-mail:
Alternate e-mail:
By: s/ Jake A. Roth
JOSE F. CAMPOS
Florida Bar No.- 110733
JAKE A. ROTH
Florida Bar No.- 1025881
3228.6626-00
Page 2
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
DEFINITIONS
A.
The term "you" refers to Plaintiff, their agents, representatives, employees,
attorneys and any persons or entities acting principally on behalf of Plaintiff.
B.
The term "documents" refers to any written, recorded or other reproducible
manifestation or communication of language, including but not limited to, the particular
items
Iisted:
correspondence, letters, contracts,
advertisements, agreements,
appointment records, audio recordings, transcriptions of audio recordings, balance
sheets, bills, bills of Iading, blanks, books, books of account, bylaws, cable grams,
certificates, charters, charts, checks, communications, computer programs, computer
printouts, computer readouts, computer tapes, data compilationwhich can be translated
or obtained through detection devices, delivery records, entries, estimated, expense
reports, field notes, film, financial analysis, financial statements, forms, graphs,
handbooks, income statements, indices, instruments, intra-office and inter-office
communications and memoranda, invoices, itemizations, journals, licenses, manuals,
maps, meeting reports, memoranda of all conversations, including telephone calls,
minutes, notes, order forms, orders, opinions, patents, patent applications, payroll
records, permits, photocopies, photographs, planographs, plans, press releases, proofs,
prospectuses, publications, receipts, recordings, records, records of account, reports,
requisitions, resolutions, sketches, specifications, statements, statistical records, studies,
summaries, systems analysis, tapes, telegrams, texts, time records, training manuals,
transcripts, valuations, video recordings, warehouse receipts, writings, or work papers
and all non-identical copies thereof which are in the possession, custody or control of
Page 3
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
Plaintiff, their employees, agents, attorneys, or representatives, or any other person or
entity acting principally on their behalf.
C.
The term "correspondence" refers to any "documents" as that term is
defined above, that have been exchanged from one person or entity to another person or
entity or which were intended to be exchanged or prepared in order to be so
communicatedfrom one person or entity to another, whether or not such correspondence
was actually exchanged, mailed or posted.
D.
The term "subject loss" refers to the alleged Tropical Storm Eta damage
suffered by the Plaintiff on or about 1 1/9/2020 and assigned claim number 001-00-
252764.
Page 4
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
INTERROGATORIES TO PLAINTIFF
1. What is your name, address, date of birth, social security number, and if you are
answering for someone else, your relationship to the Plaintiff and your official
position?
2. Describe the nature and extent of the damage your home sustained on or about
the date of loss referenced in the Complaint/Petition, and whether anyone has
inspected the damage. If so, give a detailed description of every inspection that
was done; the identity of all
involved in the inspection(s);
what each individual/company did to inspect the damage and on what date those
actions were taken; and the results of every inspection.
3. State each and every attempt, whether successful or not, that has been made to
repair/replace the damage your home sustained on or about the date of loss
referenced
in
the
Complaint/Petition.
Provide
a
detailed
description of
the identity of all
involved in the
repair/replacement of the damage; what each individual/company did to
repair/replace the damage and on what date those actions were taken; and the
results of what each individual/company did to repair/replacethe damage.
4. List the names, addresses and telephone numbers of all persons who are believed
or known by you, your agents or attorneys to have any knowledge concerning any
of the issues raised by the claim and pleadings and specify the subject matter
about which the witness has knowledge.
Page 5
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
5. State whether you or your agents have any photographs or videos (whether
analog, digital or any other format) of the property damage you claim you sustained
as a result of the loss alleged in the Complaint/Petition. If so, state the name and
address of the custodian of the photographs or videos, the date the photographs
or videos were taken, as well as the identity of the person(s) who took the
photographs or videos.
6. Describe in detail all actions taken by you to comply with the policy's post-loss
obligations including but not limited to the folkwing:
(a)
Giving prompt notice of the loss;
(b)
Showing the damaged property;
(c)
Providing records and documents requested;
(d)
Keeping an accurate record of repair expenses
(e)
Prepare an inventory of damaged personal property showing the quantity,
description, actual cash value and amount of loss;
(f)
Attaching all bills, receipts and related documents that justify the figures in
the inventory;
(g)
Submitting a signed, sworn proof of loss;
(h)
Protecting the property from further damage; and
(i)
Making reasonable and necessary repairs to the property.
And on what date those actions were taken?
7. If you waited to report the loss to the carrier, advise in detail how long you waited
and why you waited. Additionally, advise in detail your actions to repair, mitigate,
Page 6
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
and protect the home from further damage prior to notifying the carrier of the
loss.
8. After discovering the loss describe with specificity each and every action taken by
you to mitigate any and all alleged damages as a result of subject loss including
anything done by you before calling a repair man, whether you called a repair man,
the name and address of any such repair man, what the repair man did, and how
much you paid the repair man.
9. State with specificity the nature and substance of all communications regarding
this loss between you or your agents and Defendant or its agents, as well as any
communications with anyone associated with Defendant, along with the dates on
which these communications took place.
10. State whether there have ever been any other insurance claims for property
damage of any type or cause to the subject property, either before or after the
subject claim. If so, state the date(s) of the claim(s), the nature and extent of the
damage(s) claimed, the name of the insurer(s), the final result, whether repairs
have been made as a result, and if so what repairs were made and by whom were
they made.
11. Have you heard or do you know about any statement or remark made by or on
behalf of any party to this lawsuit, other than yourself, concerning any issue to this
lawsuit?
If so, state the name and address of each person who made the
Page 7
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
statement or statements, the name and address of each person who heard it, and
the date, time, place and substance of each statement.
12. State the name and address of every person known to you, your agents, or your
attorneys, who has knowledge about, or possession, custody or control of, any
document(s) pertaining to any fact or issue involved in this controversy; and
describe as to each, what items such person has, the name and address of the
person who prepared the document, and the date the document was taken or
prepared
13. State if you have ever been a party to a lawsuit other than the present matter, and,
if so, state the nature of the action, the case number, and the date and court in
which suit was filed, and the final disposition or resolution of each case or
controversy.
14. State the names of all mortgages, equity loans or home loans on the insured
property and provide the current amount due and owing on each. Also, list the
name, address, and individual contact for any and all mortgage brokers or
mortgage providers that you applied to and whether the application was granted
and in what amount.
Also, state whether you are current on your mortgage
payments. If not, state the date your last mortgage payment was made.
Page 8
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
15. State whether any improvements, replacements, remodeling, repairs, renovations
and/or additions of any kind were made to the subject property in the past ten
years.
If so, specify the dates and identity of all individuals and/or companies
involved and the nature and costs of the work performed including a list of all
contractors that provided a bid to the Plaintiffs, even if not selected to perform the
improvements, replacements, remodeling, repairs, renovations and/or additions of
any kind.
16. State with specificity the total amount of damages you claim to have sustained as
a result of the loss referred to in the Complaint/Petition.
17. Do you intend to call any expert witness at the trial of this case? If so, state as to
each such witness the name and business address of the witness, the witnesses'
qualifications as an expert, the subject matter upon which the witness is expected
to testify, the substance of the facts and opinions to which the witness is expected
to testify, and a summary of the grounds for each opinion.
18. If any repairs have been commenced or completed respective to the damage you
alleged your property sustained on or about the date of loss referenced in the
Complaint/Petition,provide a description of all such repairs, the name and address
of the person or entity that performed the repairs, the dates of the repairs and the
costs of the repairs. In the event it was necessary for you to obtain a permit to
commence or conduct any such repairs, state the name of the entity from whom
the permit was obtained, the date of the application for the permit and the name
and address of the person or entity that obtained the permit.
Page 9
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
19. If you performed any repairs to the subject property yourself, please list and
describe in detail what repairs/mitigation efforts you performed. Also, If you
performed any repairs to the subject property yourself, please list and describe
each item you were required to use or purchase in order to make the necessary
repairs, including where you purchased each item and the amount you paid for
each item.
20. If any repairs were made, state whether any damaged walls, flooring, tiles, and/or
other items have been retained for evidence. If so, state the name(s), address(es),
and telephone number(s) of each and every person who has possession of the
damaged item, what the item is, and where it is being held.
21. State the date on which you acquired the subject property, all names in which the
property was acquired (all names included on the title or deed), the name of the
person or entity from which it was acquired, the amount you paid for the subject
property and the name and address of all lien holders on the subject property.
22. State whether or not an inspection of the property was conducted at the time of
your acquisition of the subject property, whether on your behalf or on behalf of
anyone else, and if so, provide the name and address of the person or entity that
conducted the inspection, the date of the inspection and the name and address of
any person or entity in possession of any such inspection report.
Page 10
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
23. List the full names of all current and former residents of the subject property and
identify your relationship to each one of them.
24. State the full names and addresses of each and every individual and/or entity that
current y holds title to the property that is the subject of your claim. If you do not
current y own the subject property, state with specificity the details surrounding the
reasons why you do not currently own the property, including the date the title to
the property was transferred.
25. Is the property that is the subject of your claim currently the subject of a foreclosure
action, or has it ever been the subject of a foreclosure action? If so, state the name
of the party who foreclosed on the subject property and the current status of the
action and your ownership of the property.
26. Specify the name, address and telephone number of the individual who reported
the loss that is the subject of this case. Provide the date the loss was reported
and explain why you or your representative waited to report your claim.
27. Please provide the first date upon which you noticed water damage, water
intrusion, or tile damage to the subject property.
Page 11
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
28. Please provide the name, address, phone number, and any known contact
information for any individuals that observed the alleged damage that is the subject
of this litigation.
Page 12
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
CASE NO.: CACE-21-007460
Signed:
Print Name:
STATE OF
COUNTY OF
Sworn to and subscribed before me by means of u physical presence or u online
notarization, this
day of
2021, who is personally known to me or who
,
has produced
as identification.
NOTARY PUBLIC, State of
My Commission Expires:
Page 13
COLE, SCOTT & KISSANE, P.A.
LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473-
1112 (954) 474-7979 FAX
Preview
Filing # 128521728 E-Filed 06/10/2021 03:38:16 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-007460 AMER JERDANA, Plaintiff, V CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. NOTICE OF FILING INTERROGATORIES TO PLAINTIFF COMES NOW Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by and through their undersigned counsel and filed their Notice of Filing Interrogatories to Plaintiff, to be answered under oath and in writing within the time permitted by the Florida Rules of Civil Procedure or within such time as directed by the Court. - THIS SPACE IS INTENTIONALLY LEFT BLANK - Page 1 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/10/2021 03:38:15 PM.**** CASE NO.: CACE-21-007460 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 10th day of June 2021, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Teresa Urda, Esq., Law Offices of Marcote & Marcote De Moya, PLLC, 12595 SW 137th Ave., Miami, Florida 33186, (305) 256-2616/(305) 256-2446 (F), Attorney for Plaintiff, Amer Jerdana. COLE, SCOTT & KISSANE, P.A. Counselfor Defendant CITIZENS PROPERTY NSURANCE CORPORATION Lakeside Office Center, Suite 500 600 North Pine Island Road Plantation, Florida 33324 Telephone (954) 703-3706 Facsimile (954) 474-7979 Primary e-mail: Secondarye-mail: Alternate e-mail: By: s/ Jake A. Roth JOSE F. CAMPOS Florida Bar No.- 110733 JAKE A. ROTH Florida Bar No.- 1025881 3228.6626-00 Page 2 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 DEFINITIONS A. The term "you" refers to Plaintiff, their agents, representatives, employees, attorneys and any persons or entities acting principally on behalf of Plaintiff. B. The term "documents" refers to any written, recorded or other reproducible manifestation or communication of language, including but not limited to, the particular items Iisted: correspondence, letters, contracts, advertisements, agreements, appointment records, audio recordings, transcriptions of audio recordings, balance sheets, bills, bills of Iading, blanks, books, books of account, bylaws, cable grams, certificates, charters, charts, checks, communications, computer programs, computer printouts, computer readouts, computer tapes, data compilationwhich can be translated or obtained through detection devices, delivery records, entries, estimated, expense reports, field notes, film, financial analysis, financial statements, forms, graphs, handbooks, income statements, indices, instruments, intra-office and inter-office communications and memoranda, invoices, itemizations, journals, licenses, manuals, maps, meeting reports, memoranda of all conversations, including telephone calls, minutes, notes, order forms, orders, opinions, patents, patent applications, payroll records, permits, photocopies, photographs, planographs, plans, press releases, proofs, prospectuses, publications, receipts, recordings, records, records of account, reports, requisitions, resolutions, sketches, specifications, statements, statistical records, studies, summaries, systems analysis, tapes, telegrams, texts, time records, training manuals, transcripts, valuations, video recordings, warehouse receipts, writings, or work papers and all non-identical copies thereof which are in the possession, custody or control of Page 3 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 Plaintiff, their employees, agents, attorneys, or representatives, or any other person or entity acting principally on their behalf. C. The term "correspondence" refers to any "documents" as that term is defined above, that have been exchanged from one person or entity to another person or entity or which were intended to be exchanged or prepared in order to be so communicatedfrom one person or entity to another, whether or not such correspondence was actually exchanged, mailed or posted. D. The term "subject loss" refers to the alleged Tropical Storm Eta damage suffered by the Plaintiff on or about 1 1/9/2020 and assigned claim number 001-00- 252764. Page 4 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 INTERROGATORIES TO PLAINTIFF 1. What is your name, address, date of birth, social security number, and if you are answering for someone else, your relationship to the Plaintiff and your official position? 2. Describe the nature and extent of the damage your home sustained on or about the date of loss referenced in the Complaint/Petition, and whether anyone has inspected the damage. If so, give a detailed description of every inspection that was done; the identity of all involved in the inspection(s); what each individual/company did to inspect the damage and on what date those actions were taken; and the results of every inspection. 3. State each and every attempt, whether successful or not, that has been made to repair/replace the damage your home sustained on or about the date of loss referenced in the Complaint/Petition. Provide a detailed description of the identity of all involved in the repair/replacement of the damage; what each individual/company did to repair/replace the damage and on what date those actions were taken; and the results of what each individual/company did to repair/replacethe damage. 4. List the names, addresses and telephone numbers of all persons who are believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues raised by the claim and pleadings and specify the subject matter about which the witness has knowledge. Page 5 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 5. State whether you or your agents have any photographs or videos (whether analog, digital or any other format) of the property damage you claim you sustained as a result of the loss alleged in the Complaint/Petition. If so, state the name and address of the custodian of the photographs or videos, the date the photographs or videos were taken, as well as the identity of the person(s) who took the photographs or videos. 6. Describe in detail all actions taken by you to comply with the policy's post-loss obligations including but not limited to the folkwing: (a) Giving prompt notice of the loss; (b) Showing the damaged property; (c) Providing records and documents requested; (d) Keeping an accurate record of repair expenses (e) Prepare an inventory of damaged personal property showing the quantity, description, actual cash value and amount of loss; (f) Attaching all bills, receipts and related documents that justify the figures in the inventory; (g) Submitting a signed, sworn proof of loss; (h) Protecting the property from further damage; and (i) Making reasonable and necessary repairs to the property. And on what date those actions were taken? 7. If you waited to report the loss to the carrier, advise in detail how long you waited and why you waited. Additionally, advise in detail your actions to repair, mitigate, Page 6 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 and protect the home from further damage prior to notifying the carrier of the loss. 8. After discovering the loss describe with specificity each and every action taken by you to mitigate any and all alleged damages as a result of subject loss including anything done by you before calling a repair man, whether you called a repair man, the name and address of any such repair man, what the repair man did, and how much you paid the repair man. 9. State with specificity the nature and substance of all communications regarding this loss between you or your agents and Defendant or its agents, as well as any communications with anyone associated with Defendant, along with the dates on which these communications took place. 10. State whether there have ever been any other insurance claims for property damage of any type or cause to the subject property, either before or after the subject claim. If so, state the date(s) of the claim(s), the nature and extent of the damage(s) claimed, the name of the insurer(s), the final result, whether repairs have been made as a result, and if so what repairs were made and by whom were they made. 11. Have you heard or do you know about any statement or remark made by or on behalf of any party to this lawsuit, other than yourself, concerning any issue to this lawsuit? If so, state the name and address of each person who made the Page 7 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 statement or statements, the name and address of each person who heard it, and the date, time, place and substance of each statement. 12. State the name and address of every person known to you, your agents, or your attorneys, who has knowledge about, or possession, custody or control of, any document(s) pertaining to any fact or issue involved in this controversy; and describe as to each, what items such person has, the name and address of the person who prepared the document, and the date the document was taken or prepared 13. State if you have ever been a party to a lawsuit other than the present matter, and, if so, state the nature of the action, the case number, and the date and court in which suit was filed, and the final disposition or resolution of each case or controversy. 14. State the names of all mortgages, equity loans or home loans on the insured property and provide the current amount due and owing on each. Also, list the name, address, and individual contact for any and all mortgage brokers or mortgage providers that you applied to and whether the application was granted and in what amount. Also, state whether you are current on your mortgage payments. If not, state the date your last mortgage payment was made. Page 8 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 15. State whether any improvements, replacements, remodeling, repairs, renovations and/or additions of any kind were made to the subject property in the past ten years. If so, specify the dates and identity of all individuals and/or companies involved and the nature and costs of the work performed including a list of all contractors that provided a bid to the Plaintiffs, even if not selected to perform the improvements, replacements, remodeling, repairs, renovations and/or additions of any kind. 16. State with specificity the total amount of damages you claim to have sustained as a result of the loss referred to in the Complaint/Petition. 17. Do you intend to call any expert witness at the trial of this case? If so, state as to each such witness the name and business address of the witness, the witnesses' qualifications as an expert, the subject matter upon which the witness is expected to testify, the substance of the facts and opinions to which the witness is expected to testify, and a summary of the grounds for each opinion. 18. If any repairs have been commenced or completed respective to the damage you alleged your property sustained on or about the date of loss referenced in the Complaint/Petition,provide a description of all such repairs, the name and address of the person or entity that performed the repairs, the dates of the repairs and the costs of the repairs. In the event it was necessary for you to obtain a permit to commence or conduct any such repairs, state the name of the entity from whom the permit was obtained, the date of the application for the permit and the name and address of the person or entity that obtained the permit. Page 9 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 19. If you performed any repairs to the subject property yourself, please list and describe in detail what repairs/mitigation efforts you performed. Also, If you performed any repairs to the subject property yourself, please list and describe each item you were required to use or purchase in order to make the necessary repairs, including where you purchased each item and the amount you paid for each item. 20. If any repairs were made, state whether any damaged walls, flooring, tiles, and/or other items have been retained for evidence. If so, state the name(s), address(es), and telephone number(s) of each and every person who has possession of the damaged item, what the item is, and where it is being held. 21. State the date on which you acquired the subject property, all names in which the property was acquired (all names included on the title or deed), the name of the person or entity from which it was acquired, the amount you paid for the subject property and the name and address of all lien holders on the subject property. 22. State whether or not an inspection of the property was conducted at the time of your acquisition of the subject property, whether on your behalf or on behalf of anyone else, and if so, provide the name and address of the person or entity that conducted the inspection, the date of the inspection and the name and address of any person or entity in possession of any such inspection report. Page 10 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 23. List the full names of all current and former residents of the subject property and identify your relationship to each one of them. 24. State the full names and addresses of each and every individual and/or entity that current y holds title to the property that is the subject of your claim. If you do not current y own the subject property, state with specificity the details surrounding the reasons why you do not currently own the property, including the date the title to the property was transferred. 25. Is the property that is the subject of your claim currently the subject of a foreclosure action, or has it ever been the subject of a foreclosure action? If so, state the name of the party who foreclosed on the subject property and the current status of the action and your ownership of the property. 26. Specify the name, address and telephone number of the individual who reported the loss that is the subject of this case. Provide the date the loss was reported and explain why you or your representative waited to report your claim. 27. Please provide the first date upon which you noticed water damage, water intrusion, or tile damage to the subject property. Page 11 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 28. Please provide the name, address, phone number, and any known contact information for any individuals that observed the alleged damage that is the subject of this litigation. Page 12 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX CASE NO.: CACE-21-007460 Signed: Print Name: STATE OF COUNTY OF Sworn to and subscribed before me by means of u physical presence or u online notarization, this day of 2021, who is personally known to me or who , has produced as identification. NOTARY PUBLIC, State of My Commission Expires: Page 13 COLE, SCOTT & KISSANE, P.A. LAKESIDE OFFICE CENTER,SUITE 500 - 600 NORTH PINE ISLAND ROAD - PLANTATION, FLORIDA33324 (954)473- 1112 (954) 474-7979 FAX