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Filing # 127930791 E-Filed 06/02/2021 11:11:18 AM
IN THE CIRCUIT COURT OF THE 17,TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
IRMA QURESHI AND GEORGE GUERRERO,
CASE NO.: CACE21-007238
Plaintiff,
VS.
UNIVERSALPROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
NOTICE OF SERVING INTERROGATORIES TO PLAINTIFFS
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by
and through undersigned counsel, propounds the attached Interrogatories to Plaintiffs, IRMA
QURESHI AND GEORGE GUERREO, to be answered under oath within thirty (30) days from
rece*t hereof in accordance with the applicable Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correctcopy ofthe foregoingwas furnishedvia E-Service
to: Amy E. Ruiz, Esq., I Taylor Espino Vega & Touron, PLLC.,
aruiz@tevtlaw.com; avrey@tevtlaw.com)on this 2nd day of June, 2021.
AttorneysMDefendant
Universal Property& Casualty Ins. Co.
P.O. Box 9388
Fort Lauderdale FL 33310
Telephone: 1-833-658-8594
Facsimile: 954-958-1262
By-- /s/ JoshuaD. Strudwick. Esq.
Joshua D. Strudwick,Esq.
Florida Bar No. 95761
For Service of Court Documents onlv:
Primary:
Secondary:
Tertiary:
For Scheduling Matters:
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/02/2021 11:11:18 AM.****
Irma Qureshiand George Guerrero vs. UPCIC
CASE NO. CACE21-007238
Page 2 of 9
INTERROGATORIES
In accordance with Rule 1.340(e) of the Fla. R. Civ. P., sufficient space has been provided
after each interrogatory for the answer to be inserted. However, if more space is needed,
you should append the answer to the interrogatory,making reference to such attachmentin
the space providedfor the answer. The Rule does not provide for placing all the answers on
a single, separate page.
1.
Please state the name and address of the person answering these Interrogatories and the
name and address of any person assisting in preparing responses to these Interrogatories.
ANSWER:
2.
Please state all facts upon which you base the contention that the damage(s) sustained to
the Plaintiffs' property is covered under the subject insurance policy.
ANSWER:
3
Please state the name and address of all persons who are believed or known by you, your
agents or your attorneys to have any knowledge concerning any issues in this lawsuit;
please specify the subject matter about which each witness has knowledge.
ANSWER:
Irma Qureshiand George Guerrero vs. UPCIC
CASE NO. CACE21-007238
Page 3 of 9
4.
Please state the name and address of every person known to you, your agents or your
attorneys, who have knowledge about or possession, custody or control of any model, plat,
map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue
involved in this controversy; please describe as each what items such individual(s) have,
the name and address of the party who took or prepared it and the date it was taken or
prepared.
ANSWER:
5.
Please state the name and address of every individualwho has conducted an investigation,
adjustment or evaluation ofthe Plaintiffs' residence to determine the cause ofthe alleged
damage to which Plaintiffs are seeking insurance coverage.
ANSWER:
6.
Please state each item of damage to the dwelling, contents or for additional living expenses
that you are claiming and/or other damages that you are claiming and provide an
explanation for the computationof each item of damage.
ANSWER:
Irma Qureshiand George Guerrero vs. UPCIC
CASE NO. CACE21-007238
Page 4 of 9
7.
Please provide a detailed description of each item of or area of damage you personally
witnessed to the dwelling, contents or for additional living expenses.
ANSWER:
8
Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other
than the present matterand, ifso, please state whether you were plaintiffs or defendant, the
nature of the action and the date and court in which suit was filed.
ANSWER:
9-
Please indicate whether you have filed any insurance claims in the last ten years prior to
the claim allegedly occurring on October 14, 2020 or any claims subsequent to the
aforementioned dates. If so, please identify the nature of the claims, the insurer and the
date of the claims.
ANSWER:
Irma Qureshiand George Guerrero vs. UPCIC
CASE NO. CACE21-007238
Page 5 of 9
10.
Please indicate if the dwelling, contents, additional living expenses, etc. with respect to
661 Alabama Ave, Fort Lauderdale,FL. 33312 were insured by you pursuantto any other
insurance policies prior to the issuance ofthe Universalpolicy at issue. If so, please name
the insurance carrier and the applicablepolicy periods.
ANSWER:
11.
Please identify the initial date and time that the alleged damages claimed in the lawsuit
occurredto the property located at 661 Alabama Ave, Fort Lauderdale,FL. 33312 and the
nature of the damage.
ANSWER:
12.
Please list all damages discovered on the date referenced in Interrogatory 11 and identify
the individualthat discoveredthe damages.
ANSWER:
Irma Qureshiand George Guerrero vs. UPCIC
CASE NO. CACE21-007238
Page 6 of 9
13.
Please identify any and all repairs made to the areas ofthe home located at 661 Alabama
Ave, Fort Lauderdale,FL. 33312 that you are claimingwere damaged, within five (5) years
prior to the loss at issue or anytime subsequent to the claim at issue, as well as the nature
ofthe repair(s) and the party making the repair.
ANSWER:
14.
Please state any and all actions taken by you or anyone on your behalfto protect the
alleged damagedproperty from further damage.
ANSWER:
15.
Please identify all persons/companies that inspected and/or appraised the property located
at 661 Alabama Ave, Fort Lauderdale,FL. 33312 at the time of or prior to your purchase
of the property.
ANSWER:
Irma Qureshiand George Guerrero vs. UPCIC
CASE NO. CACE21-007238
Page 7 of 9
16.
Please state the date the property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312
was purchasedas well as the purchase price and the name of the seller of the property.
ANSWER:
17.
Within the year prior to the loss, had you considered renovating the property that was
damaged? Ifso, describe the intendedrenovations and list the names and addresses of any
persons, contractors, or entities that were contacted, interviewed, or otherwise asked to
prepare a proposal or bid for the renovation.
ANSWER:
18.
State the date any repairs were completed to the property as a result of the loss alleged in
Plaintiffs' Complaint.
ANSWER:
Irma Qureshiand George Guerrero vs. UPCIC
CASE NO. CACE21-007238
Page 8 of 9
IRMA QURESHI
STATE OF FLORIDA
S.S.)
COUNTY OF
BEFORE ME, the foregoing instrumentwas acknowledgedby
who is personally known to me or has produced identificationin the form of
and who executed the foregoing instrumentfor the purposes therein expressed.
IN WITNESS WHEREOF, I have hereto set my hand and official seal this
dayor
,2021.
Signature ofNotaryPublic
Name ofNotaryTyped, Printed or Stamped
CommissionNumber
Irma Qureshiand George Guerrero vs. UPCIC
CASE NO. CACE21-007238
Page 9 of 9
GEORGE GUERRERO
STATE OF FLORIDA
S.S.)
COUNTY OF
BEFORE ME, the foregoing instrumentwas acknowledgedby
who is personally known to me or has produced identificationin the form of
and who executed the foregoing instrumentfor the purposes therein expressed.
IN WITNESS WHEREOF, I have hereto set my hand and official seal this
dayor
,2021.
Signature ofNotaryPublic
Name ofNotaryTyped, Printed or Stamped
CommissionNumber
Preview
Filing # 127930791 E-Filed 06/02/2021 11:11:18 AM IN THE CIRCUIT COURT OF THE 17,TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IRMA QURESHI AND GEORGE GUERRERO, CASE NO.: CACE21-007238 Plaintiff, VS. UNIVERSALPROPERTY & CASUALTY INSURANCE COMPANY, Defendant. NOTICE OF SERVING INTERROGATORIES TO PLAINTIFFS Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by and through undersigned counsel, propounds the attached Interrogatories to Plaintiffs, IRMA QURESHI AND GEORGE GUERREO, to be answered under oath within thirty (30) days from rece*t hereof in accordance with the applicable Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correctcopy ofthe foregoingwas furnishedvia E-Service to: Amy E. Ruiz, Esq., I Taylor Espino Vega & Touron, PLLC., aruiz@tevtlaw.com; avrey@tevtlaw.com)on this 2nd day of June, 2021. AttorneysMDefendant Universal Property& Casualty Ins. Co. P.O. Box 9388 Fort Lauderdale FL 33310 Telephone: 1-833-658-8594 Facsimile: 954-958-1262 By-- /s/ JoshuaD. Strudwick. Esq. Joshua D. Strudwick,Esq. Florida Bar No. 95761 For Service of Court Documents onlv: Primary: Secondary: Tertiary: For Scheduling Matters: *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/02/2021 11:11:18 AM.**** Irma Qureshiand George Guerrero vs. UPCIC CASE NO. CACE21-007238 Page 2 of 9 INTERROGATORIES In accordance with Rule 1.340(e) of the Fla. R. Civ. P., sufficient space has been provided after each interrogatory for the answer to be inserted. However, if more space is needed, you should append the answer to the interrogatory,making reference to such attachmentin the space providedfor the answer. The Rule does not provide for placing all the answers on a single, separate page. 1. Please state the name and address of the person answering these Interrogatories and the name and address of any person assisting in preparing responses to these Interrogatories. ANSWER: 2. Please state all facts upon which you base the contention that the damage(s) sustained to the Plaintiffs' property is covered under the subject insurance policy. ANSWER: 3 Please state the name and address of all persons who are believed or known by you, your agents or your attorneys to have any knowledge concerning any issues in this lawsuit; please specify the subject matter about which each witness has knowledge. ANSWER: Irma Qureshiand George Guerrero vs. UPCIC CASE NO. CACE21-007238 Page 3 of 9 4. Please state the name and address of every person known to you, your agents or your attorneys, who have knowledge about or possession, custody or control of any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this controversy; please describe as each what items such individual(s) have, the name and address of the party who took or prepared it and the date it was taken or prepared. ANSWER: 5. Please state the name and address of every individualwho has conducted an investigation, adjustment or evaluation ofthe Plaintiffs' residence to determine the cause ofthe alleged damage to which Plaintiffs are seeking insurance coverage. ANSWER: 6. Please state each item of damage to the dwelling, contents or for additional living expenses that you are claiming and/or other damages that you are claiming and provide an explanation for the computationof each item of damage. ANSWER: Irma Qureshiand George Guerrero vs. UPCIC CASE NO. CACE21-007238 Page 4 of 9 7. Please provide a detailed description of each item of or area of damage you personally witnessed to the dwelling, contents or for additional living expenses. ANSWER: 8 Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other than the present matterand, ifso, please state whether you were plaintiffs or defendant, the nature of the action and the date and court in which suit was filed. ANSWER: 9- Please indicate whether you have filed any insurance claims in the last ten years prior to the claim allegedly occurring on October 14, 2020 or any claims subsequent to the aforementioned dates. If so, please identify the nature of the claims, the insurer and the date of the claims. ANSWER: Irma Qureshiand George Guerrero vs. UPCIC CASE NO. CACE21-007238 Page 5 of 9 10. Please indicate if the dwelling, contents, additional living expenses, etc. with respect to 661 Alabama Ave, Fort Lauderdale,FL. 33312 were insured by you pursuantto any other insurance policies prior to the issuance ofthe Universalpolicy at issue. If so, please name the insurance carrier and the applicablepolicy periods. ANSWER: 11. Please identify the initial date and time that the alleged damages claimed in the lawsuit occurredto the property located at 661 Alabama Ave, Fort Lauderdale,FL. 33312 and the nature of the damage. ANSWER: 12. Please list all damages discovered on the date referenced in Interrogatory 11 and identify the individualthat discoveredthe damages. ANSWER: Irma Qureshiand George Guerrero vs. UPCIC CASE NO. CACE21-007238 Page 6 of 9 13. Please identify any and all repairs made to the areas ofthe home located at 661 Alabama Ave, Fort Lauderdale,FL. 33312 that you are claimingwere damaged, within five (5) years prior to the loss at issue or anytime subsequent to the claim at issue, as well as the nature ofthe repair(s) and the party making the repair. ANSWER: 14. Please state any and all actions taken by you or anyone on your behalfto protect the alleged damagedproperty from further damage. ANSWER: 15. Please identify all persons/companies that inspected and/or appraised the property located at 661 Alabama Ave, Fort Lauderdale,FL. 33312 at the time of or prior to your purchase of the property. ANSWER: Irma Qureshiand George Guerrero vs. UPCIC CASE NO. CACE21-007238 Page 7 of 9 16. Please state the date the property located at 661 Alabama Ave, Fort Lauderdale, FL. 33312 was purchasedas well as the purchase price and the name of the seller of the property. ANSWER: 17. Within the year prior to the loss, had you considered renovating the property that was damaged? Ifso, describe the intendedrenovations and list the names and addresses of any persons, contractors, or entities that were contacted, interviewed, or otherwise asked to prepare a proposal or bid for the renovation. ANSWER: 18. State the date any repairs were completed to the property as a result of the loss alleged in Plaintiffs' Complaint. ANSWER: Irma Qureshiand George Guerrero vs. UPCIC CASE NO. CACE21-007238 Page 8 of 9 IRMA QURESHI STATE OF FLORIDA S.S.) COUNTY OF BEFORE ME, the foregoing instrumentwas acknowledgedby who is personally known to me or has produced identificationin the form of and who executed the foregoing instrumentfor the purposes therein expressed. IN WITNESS WHEREOF, I have hereto set my hand and official seal this dayor ,2021. Signature ofNotaryPublic Name ofNotaryTyped, Printed or Stamped CommissionNumber Irma Qureshiand George Guerrero vs. UPCIC CASE NO. CACE21-007238 Page 9 of 9 GEORGE GUERRERO STATE OF FLORIDA S.S.) COUNTY OF BEFORE ME, the foregoing instrumentwas acknowledgedby who is personally known to me or has produced identificationin the form of and who executed the foregoing instrumentfor the purposes therein expressed. IN WITNESS WHEREOF, I have hereto set my hand and official seal this dayor ,2021. Signature ofNotaryPublic Name ofNotaryTyped, Printed or Stamped CommissionNumber