Preview
Case Number: CACE-21-007238 Division: 08
Filing # 124683002 E-Filed 04/09/2021 05:46:25 PM
IN THE CIRCUIT COURT OF THE
17th JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
IRMA QURESHI, an individual, and GENERAL JURISDICTION DIVISION
GEORGE GUERRERO, an individual,
CASE NO.:
Plaintiffs,
v.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY, a Florida
corporation,
Defendant.
/
PLAINTIFFS’ FIRST SET OF INTERROGATORIES
Irma Qureshi and George Guerrero (“Plaintiffs”), through undersigned counsel and
pursuant to Florida Rule of Civil Procedure 1.340 propound this First Set of Interrogatories upon
Universal Property & Casualty Insurance Company (“Defendant”) to be answered in writing, and
under oath.
DEFINITIONS AND INSTRUCTIONS
1. Insert your answers in the space provided following each question. If additional
space is needed, so indicate in the space provided, prepare your answers on a separate paper, and
attach the additional paper to your answers.
2. Separately answer each interrogatory, and each subsection of each interrogatory.
The term "you" and "your" means the party or parties to which this request is addressed, including
its divisions, departments, subsidiaries, affiliates, predecessors, present or former officers,
directors, owners, agents, accountants, attorneys, and all other persons acting or purporting to act
on its behalf, as well as each partnership in which it is a partner.
3. The terms “Insurance Company” or “Defendant” means the defendant in this action
to which these Interrogatories are addressed, including its agents, attorneys, accountants, and all
other persons acting or purporting to act on their behalf. The terms “Insurance Company” or
“Defendant” also includes the party's divisions, departments, subsidiaries, affiliates, predecessors,
present or former officers, directors, owners, agents, attorneys, and accountants as well as each
partnership in which it is a partner, and includes any other person, acting or purporting to act on
its behalf.
TAYLOR ESPINO VEGA & TOURON, PLLC
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/09/2021 05:46:22 PM.****4. The terms "you" and "your" mean the party or parties to which these interrogatories
are addressed, including its agents, attorneys, accountants, and all other persons acting or
purporting to act on its behalf.
5. The “Complaint” means the Complaint filed by Plaintiff in the matter entitled,
IRMA QURESHI & GEORGE GUERRERO v. UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY, in Broward County, Florida.
6. The terms "person" or "persons" mean any natural person, individual,
proprietorship, partnership, corporation, association, organization, joint venture, firm, other
business enterprise, governmental body, and group of natural persons or other entity, and includes
any other person acting on behalf of a person.
7. The term “Policy” means the subject policy sued upon.
8. The term “Claim” refers to claim number FL20-0148684.
9. The term “communication” means any information given, whether oral or written;
any oral or written statement, conference, consultation, dialogue, colloquy, discussion,
conversation, agreement, the sharing of knowledge by one with another, bargaining preparatory to
making a contract or any expression of any kind.
10. The term “document” means and includes any kind of written, typed, recorded or
graphic matter, however produced or reproduced, of any kind or description, whether sent or
received, and every record of every type, including originals, non-identical copies and drafts, and
both sides of any documentation where information appears on both sides, and including but not
limited to: letters, correspondence, memoranda, meeting transcripts or minutes, public filings or
tax returns, papers, books, telegrams, bulletins, notices, announcements, instructions, charts,
manuals, brochures, schedules, cables, telex messages, notes, notations, accountants’ working
papers, transcriptions, agendas, reports, recordings of telephone or other conversations, of
interviews, of conferences or of meetings, telephone messages, diaries, indices, books, reports,
ledgers, working papers, invoices, worksheets, receipts, computer printouts, financial statements,
schedules affidavits, contracts, canceled checks, statements, transcripts, magazine or newspaper
articles, periodicals, releases and any and all drafts, alterations and modifications, changes and
amendments of any of the foregoing, whether handwritten, printed or electronically prepared, filed
or stored, affidavits, statements, summaries, opinions, reports, studies, analyses, evaluations,
contracts, agreements, journals, statistical records, calendars, appointment books, diaries, lists,
tabulations, sound recordings, computer print-outs, data processing input and output, microfilms,
newspapers, magazines, books, periodicals or press releases, including information stored 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. “Document” shall also be
deemed to include any summary of a document or documents called for hereafter.
11. The term “all documents" means every document or group of documents as above
defined that are known to you or that can be located or discovered by reasonably diligent efforts.
-2-
TAYLOR ESPINO VEGA & TOURON, PLLC12. As used herein the singular shall include the plural, the plural shall include the
singular, and the masculine, feminine, and neutral shall include each of the other genders.
13. The terms "and" as well as "or" shall be construed disjunctively as well as
conjunctively as necessary to make the interrogatory 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."
14. The term "to date" shall mean the date on which you answer these interrogatories.
15. The term “including” means “including but not limited to”.
16. “Relating to” or “relevant to” means embodying, pertaining to, concerning,
involving, constituting, comprising, reflecting, discussing, evidencing, referring to, consisting of,
or having any logical or factual connection whatever with the subject matter in question.
17. The term “Identify,” when used with reference to a natural person, means state:
a. His or her full name and address (or, if the present address is not known, his or her
last known address).
b. the full name and address of each of his or her employers, each corporation of which
he or she is an officer or director and each business in which he or she is a principal.
c. His or her present (or, if the present is not known, his or her last known) position
and his or her position or positions at the time of the act to which the interrogatory
answer relate, and
d. such other information sufficient to enable Mr. Pittman to identify the person.
18. “Identify,” when used with reference to any entity other than a natural person,
a. state the full name of the entity, the type of entity (e.g., corporation, partnership,
etc.), the address of its principal place of business, its principal business activity,
and if it is a corporation, the jurisdiction under the laws of which it has been
organized and the date of such organization.
19. “Identify,” when used with reference to a document or written communication,
means state:
a. its nature (e.g., letter, telegram, floppy disc, computer printout, memorandum,
chart, report or study), date, author, date and place of preparation and the name and
address of each addressee, if there is an addressee;
the identity of each signer to the document or communication;
the title or heading of the document or communication;
its substance;
its present (or, if the present is not known, the last known) location and custodian;
eaes
-3-
TAYLOR ESPINO VEGA & TOURON, PLLCf. the identity of each person to whom a copy was sent and each date of its receipt and
each date of its transmittal or other disposition by (I) respondent and (ii) any other
person (naming such other person) who, at any time, either received, transmitted or
otherwise disposed of such document or communication and each copy thereof;
g. the circumstances of each such receipt and each transmittal or other disposition,
including identification of the person from whom received and the person to
whom transmitted.
20. “Identify,” when used with reference to an oral transaction or oral communication,
means state:
its nature (e.g., telephone call, conversation in person, etc.);
the date and place thereof;
c. the identity and address of each person participating therein, present during or
witness to any part thereof;
d. identify each document in which such transaction or communication was recorded,
described or referred to.
se
21. “Identify,” when used in any other context that is herein above set forth, means to
describe the act, word, situation, event, etc. (and/or conduct, course of action of any nature
whatsoever, including without limitation any failure to act, to engage in any conduct or to pursue
any course of action), to be identified as fully as possible and identify each document or
communication or act in which such act, word, situation, event, conduct or course of action, etc.,
was recorded, refers or relates to each answer, forms all or part of the basis for an answer; and/or
corroborates and answer.
22. You may, in lieu of identifying any Document or written communication, attach a
true copy of each Document as an exhibit to the answers to these interrogatories. On each occasion
in which you choose to attach a Document as your answer to an interrogatory, identify the portion
of the Document that answers the interrogatory.
23. Identify each Document produced pursuant to an interrogatory by the paragraph
number of the interrogatory in response to which it is produced and by the file from which the
document was produced.
24. — If any of the information furnished in an answer to all or part of an interrogatory is
not within your personal knowledge, identify each person who has personal knowledge of the
information furnished in such answer and each person who communicated to you any part of the
information furnished.
25. — If the answer to all or any part of the interrogatory is not presently known or
available to you, include a statement to that effect, furnish the information now known or otherwise
available to you, and respond to the entire interrogatory by supplemental answer, in writing, under
oath, within ten days from the time the entire answer becomes known or available to you, but in
no event less than five days prior to trial.
4
TAYLOR ESPINO VEGA & TOURON, PLLC26. — If you contend that it would be unreasonably burdensome to obtain and provide all
of the information called for in response to any one of these interrogatories or any subpart thereof,
then in response to the appropriate interrogatory or subpart:
a. set forth all such information that is available to you without undertaking what you
contend to be an unreasonable burden;
b. state with particularity the grounds on which you contend that additional efforts to
obtain such information would be unreasonably burdensome; and
c. describe with particularity the efforts made by you to secure such information,
including, without limitation, the identity of all persons consulted, and files,
records, and documents reviewed, and the identity of each person who participated
in gathering such information, including the duration of time spent and nature of
work done by each person.
27. — Ifall of the information furnished in answer to all or part of an interrogatory is not
within the personal knowledge of the affiant, identify each person to whom all or part of the
information furnished is a matter of personal knowledge and each person who communicated to
the affiant any part of the information furnished.
28. To the extent precise and complete information cannot be furnished, such
information as is available shall be supplied, together with an estimate of the precise and complete
information. Where such an estimate is given, the method employed in making the estimate shall
be described.
-5-
TAYLOR ESPINO VEGA & TOURON, PLLCPLAINTIFFS’ FIR:
ET OF INTERROGATORIES
Ll. Identify the name, email address, physical address, title and company of every
person providing any information used to prepare responses to these interrogatories and identify
for which interrogatory responses their information was used.
2. Identify the date Defendant first received notice from Plaintiffs for the claim of
benefits under the Policy for property damages as described in the Complaint in this lawsuit.
6-
TAYLOR ESPINO VEGA & TOURON, PLLC3. With regard to Defendant’s partial denial of Plaintiffs’ claim for benefits under the
Policy, please identify each fact upon which you rely in forming the basis for your refusal to issue
payment on Plaintiffs’ covered repairs for the subject pipe leak.
4. Identify each person, by name, email address, physical address, phone number and
position, whom, on behalf of Defendant, inspected the subject property in reference to the claim
described in the Complaint and the dates of each inspection.
-7-
TAYLOR ESPINO VEGA & TOURON, PLLC5. Identify all persons (other than Defendant) believed or known by you, your agents
or attorneys, to have knowledge concerning any of the issues raised by the pleadings then specify
the subject matter about which the witnesses have knowledge and state whether you have obtained
any statements (oral, written or recorded) from any of these witnesses. If any witness statements
were taken please list the dates they were taken, by whom any such witness statements were taken
and who has the present possession, custody and control of any such statements.
6. Identify all persons who, on Defendant’s behalf, have participated in the
investigation, evaluation, adjusting or handling of the claim involved hereto and specify the nature
of the participation for each and every such person and give the time period during which they
participated.
-8-
TAYLOR ESPINO VEGA & TOURON, PLLC7. Identify all requests made by Defendant upon Plaintiffs, including but not limited
to, requests for Examination Under Oath, documents, Sworn Statement in Proof of Loss, recorded
statement, and inspections, in reference to the claim described in the Complaint, and the dates each
of the requests were made.
8. Did Plaintiffs comply with all post-loss obligations under the Policy for this claim?
If your answer is no, please specify each and every post-loss obligation Plaintiffs allegedly failed
to comply with, and what prejudice their alleged failure to comply caused on Defendant.
-9-
TAYLOR ESPINO VEGA & TOURON, PLLCCERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was delivered via
Certified Process Server to: Universal Property & Casualty Insurance Company, by and through
the Florida Department of Financial Services, 200 East Gaines Street, Tallahassee, Florida 32399-
4201 on this 9th day of April 2021.
Respectfully submitted,
/s/ Amy E. Ruiz
Francisco Touron, III, FBN: 527319
FTouron@tevtlaw.com
Amy E. Ruiz, FBN: 99129
ARuiz@tevtlaw.com
Antonio Villa de Rey, FBN: 1022522
AVrey@tevtlaw.com
Taylor Espino Vega & Touron, PLLC
201 Alhambra Circle, Suite 801
Coral Gables, Florida 33134
Telephone: 305.443.2043
Telefacsimile: 305.443.2048
Attorneys for Plaintiffs, Irma Qureshi & George
Guerrero
-10-
TAYLOR ESPINO VEGA & TOURON, PLLCIN WITNESS WHEREOF, the Insurance Company has executed the foregoing answers to
interrogatories and states that same are true and correct to the best of the undersigned’s knowledge
and belief.
Name of Insurance Company
yi EES SEE AEE
Title:
STATE OF FLORIDA }
}
COUNTY OF }
BEFORE ME, the undersigned authority, personally appeared
, who is personally known to me or who has produced
as identification, being first duly sworn according to law, deposes and says that he/she executed
the foregoing Answers to this First Set of Interrogatories and that they are true and correct to the
best of his/her knowledge and belief.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of my office;
in the County and State last aforesaid, this day of , 2021.
TAYLOR ESPINO VEGA & TOURON, PLLC
Preview
Case Number: CACE-21-007238 Division: 08 Filing # 124683002 E-Filed 04/09/2021 05:46:25 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IRMA QURESHI, an individual, and GENERAL JURISDICTION DIVISION GEORGE GUERRERO, an individual, CASE NO.: Plaintiffs, v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, a Florida corporation, Defendant. / PLAINTIFFS’ FIRST SET OF INTERROGATORIES Irma Qureshi and George Guerrero (“Plaintiffs”), through undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.340 propound this First Set of Interrogatories upon Universal Property & Casualty Insurance Company (“Defendant”) to be answered in writing, and under oath. DEFINITIONS AND INSTRUCTIONS 1. Insert your answers in the space provided following each question. If additional space is needed, so indicate in the space provided, prepare your answers on a separate paper, and attach the additional paper to your answers. 2. Separately answer each interrogatory, and each subsection of each interrogatory. The term "you" and "your" means the party or parties to which this request is addressed, including its divisions, departments, subsidiaries, affiliates, predecessors, present or former officers, directors, owners, agents, accountants, attorneys, and all other persons acting or purporting to act on its behalf, as well as each partnership in which it is a partner. 3. The terms “Insurance Company” or “Defendant” means the defendant in this action to which these Interrogatories are addressed, including its agents, attorneys, accountants, and all other persons acting or purporting to act on their behalf. The terms “Insurance Company” or “Defendant” also includes the party's divisions, departments, subsidiaries, affiliates, predecessors, present or former officers, directors, owners, agents, attorneys, and accountants as well as each partnership in which it is a partner, and includes any other person, acting or purporting to act on its behalf. TAYLOR ESPINO VEGA & TOURON, PLLC *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/09/2021 05:46:22 PM.****4. The terms "you" and "your" mean the party or parties to which these interrogatories are addressed, including its agents, attorneys, accountants, and all other persons acting or purporting to act on its behalf. 5. The “Complaint” means the Complaint filed by Plaintiff in the matter entitled, IRMA QURESHI & GEORGE GUERRERO v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, in Broward County, Florida. 6. The terms "person" or "persons" mean any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, and group of natural persons or other entity, and includes any other person acting on behalf of a person. 7. The term “Policy” means the subject policy sued upon. 8. The term “Claim” refers to claim number FL20-0148684. 9. The term “communication” means any information given, whether oral or written; any oral or written statement, conference, consultation, dialogue, colloquy, discussion, conversation, agreement, the sharing of knowledge by one with another, bargaining preparatory to making a contract or any expression of any kind. 10. The term “document” means and includes any kind of written, typed, recorded or graphic matter, however produced or reproduced, of any kind or description, whether sent or received, and every record of every type, including originals, non-identical copies and drafts, and both sides of any documentation where information appears on both sides, and including but not limited to: letters, correspondence, memoranda, meeting transcripts or minutes, public filings or tax returns, papers, books, telegrams, bulletins, notices, announcements, instructions, charts, manuals, brochures, schedules, cables, telex messages, notes, notations, accountants’ working papers, transcriptions, agendas, reports, recordings of telephone or other conversations, of interviews, of conferences or of meetings, telephone messages, diaries, indices, books, reports, ledgers, working papers, invoices, worksheets, receipts, computer printouts, financial statements, schedules affidavits, contracts, canceled checks, statements, transcripts, magazine or newspaper articles, periodicals, releases and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing, whether handwritten, printed or electronically prepared, filed or stored, affidavits, statements, summaries, opinions, reports, studies, analyses, evaluations, contracts, agreements, journals, statistical records, calendars, appointment books, diaries, lists, tabulations, sound recordings, computer print-outs, data processing input and output, microfilms, newspapers, magazines, books, periodicals or press releases, including information stored 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. “Document” shall also be deemed to include any summary of a document or documents called for hereafter. 11. The term “all documents" means every document or group of documents as above defined that are known to you or that can be located or discovered by reasonably diligent efforts. -2- TAYLOR ESPINO VEGA & TOURON, PLLC12. As used herein the singular shall include the plural, the plural shall include the singular, and the masculine, feminine, and neutral shall include each of the other genders. 13. The terms "and" as well as "or" shall be construed disjunctively as well as conjunctively as necessary to make the interrogatory 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." 14. The term "to date" shall mean the date on which you answer these interrogatories. 15. The term “including” means “including but not limited to”. 16. “Relating to” or “relevant to” means embodying, pertaining to, concerning, involving, constituting, comprising, reflecting, discussing, evidencing, referring to, consisting of, or having any logical or factual connection whatever with the subject matter in question. 17. The term “Identify,” when used with reference to a natural person, means state: a. His or her full name and address (or, if the present address is not known, his or her last known address). b. the full name and address of each of his or her employers, each corporation of which he or she is an officer or director and each business in which he or she is a principal. c. His or her present (or, if the present is not known, his or her last known) position and his or her position or positions at the time of the act to which the interrogatory answer relate, and d. such other information sufficient to enable Mr. Pittman to identify the person. 18. “Identify,” when used with reference to any entity other than a natural person, a. state the full name of the entity, the type of entity (e.g., corporation, partnership, etc.), the address of its principal place of business, its principal business activity, and if it is a corporation, the jurisdiction under the laws of which it has been organized and the date of such organization. 19. “Identify,” when used with reference to a document or written communication, means state: a. its nature (e.g., letter, telegram, floppy disc, computer printout, memorandum, chart, report or study), date, author, date and place of preparation and the name and address of each addressee, if there is an addressee; the identity of each signer to the document or communication; the title or heading of the document or communication; its substance; its present (or, if the present is not known, the last known) location and custodian; eaes -3- TAYLOR ESPINO VEGA & TOURON, PLLCf. the identity of each person to whom a copy was sent and each date of its receipt and each date of its transmittal or other disposition by (I) respondent and (ii) any other person (naming such other person) who, at any time, either received, transmitted or otherwise disposed of such document or communication and each copy thereof; g. the circumstances of each such receipt and each transmittal or other disposition, including identification of the person from whom received and the person to whom transmitted. 20. “Identify,” when used with reference to an oral transaction or oral communication, means state: its nature (e.g., telephone call, conversation in person, etc.); the date and place thereof; c. the identity and address of each person participating therein, present during or witness to any part thereof; d. identify each document in which such transaction or communication was recorded, described or referred to. se 21. “Identify,” when used in any other context that is herein above set forth, means to describe the act, word, situation, event, etc. (and/or conduct, course of action of any nature whatsoever, including without limitation any failure to act, to engage in any conduct or to pursue any course of action), to be identified as fully as possible and identify each document or communication or act in which such act, word, situation, event, conduct or course of action, etc., was recorded, refers or relates to each answer, forms all or part of the basis for an answer; and/or corroborates and answer. 22. You may, in lieu of identifying any Document or written communication, attach a true copy of each Document as an exhibit to the answers to these interrogatories. On each occasion in which you choose to attach a Document as your answer to an interrogatory, identify the portion of the Document that answers the interrogatory. 23. Identify each Document produced pursuant to an interrogatory by the paragraph number of the interrogatory in response to which it is produced and by the file from which the document was produced. 24. — If any of the information furnished in an answer to all or part of an interrogatory is not within your personal knowledge, identify each person who has personal knowledge of the information furnished in such answer and each person who communicated to you any part of the information furnished. 25. — If the answer to all or any part of the interrogatory is not presently known or available to you, include a statement to that effect, furnish the information now known or otherwise available to you, and respond to the entire interrogatory by supplemental answer, in writing, under oath, within ten days from the time the entire answer becomes known or available to you, but in no event less than five days prior to trial. 4 TAYLOR ESPINO VEGA & TOURON, PLLC26. — If you contend that it would be unreasonably burdensome to obtain and provide all of the information called for in response to any one of these interrogatories or any subpart thereof, then in response to the appropriate interrogatory or subpart: a. set forth all such information that is available to you without undertaking what you contend to be an unreasonable burden; b. state with particularity the grounds on which you contend that additional efforts to obtain such information would be unreasonably burdensome; and c. describe with particularity the efforts made by you to secure such information, including, without limitation, the identity of all persons consulted, and files, records, and documents reviewed, and the identity of each person who participated in gathering such information, including the duration of time spent and nature of work done by each person. 27. — Ifall of the information furnished in answer to all or part of an interrogatory is not within the personal knowledge of the affiant, identify each person to whom all or part of the information furnished is a matter of personal knowledge and each person who communicated to the affiant any part of the information furnished. 28. To the extent precise and complete information cannot be furnished, such information as is available shall be supplied, together with an estimate of the precise and complete information. Where such an estimate is given, the method employed in making the estimate shall be described. -5- TAYLOR ESPINO VEGA & TOURON, PLLCPLAINTIFFS’ FIR: ET OF INTERROGATORIES Ll. Identify the name, email address, physical address, title and company of every person providing any information used to prepare responses to these interrogatories and identify for which interrogatory responses their information was used. 2. Identify the date Defendant first received notice from Plaintiffs for the claim of benefits under the Policy for property damages as described in the Complaint in this lawsuit. 6- TAYLOR ESPINO VEGA & TOURON, PLLC3. With regard to Defendant’s partial denial of Plaintiffs’ claim for benefits under the Policy, please identify each fact upon which you rely in forming the basis for your refusal to issue payment on Plaintiffs’ covered repairs for the subject pipe leak. 4. Identify each person, by name, email address, physical address, phone number and position, whom, on behalf of Defendant, inspected the subject property in reference to the claim described in the Complaint and the dates of each inspection. -7- TAYLOR ESPINO VEGA & TOURON, PLLC5. Identify all persons (other than Defendant) believed or known by you, your agents or attorneys, to have knowledge concerning any of the issues raised by the pleadings then specify the subject matter about which the witnesses have knowledge and state whether you have obtained any statements (oral, written or recorded) from any of these witnesses. If any witness statements were taken please list the dates they were taken, by whom any such witness statements were taken and who has the present possession, custody and control of any such statements. 6. Identify all persons who, on Defendant’s behalf, have participated in the investigation, evaluation, adjusting or handling of the claim involved hereto and specify the nature of the participation for each and every such person and give the time period during which they participated. -8- TAYLOR ESPINO VEGA & TOURON, PLLC7. Identify all requests made by Defendant upon Plaintiffs, including but not limited to, requests for Examination Under Oath, documents, Sworn Statement in Proof of Loss, recorded statement, and inspections, in reference to the claim described in the Complaint, and the dates each of the requests were made. 8. Did Plaintiffs comply with all post-loss obligations under the Policy for this claim? If your answer is no, please specify each and every post-loss obligation Plaintiffs allegedly failed to comply with, and what prejudice their alleged failure to comply caused on Defendant. -9- TAYLOR ESPINO VEGA & TOURON, PLLCCERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was delivered via Certified Process Server to: Universal Property & Casualty Insurance Company, by and through the Florida Department of Financial Services, 200 East Gaines Street, Tallahassee, Florida 32399- 4201 on this 9th day of April 2021. Respectfully submitted, /s/ Amy E. Ruiz Francisco Touron, III, FBN: 527319 FTouron@tevtlaw.com Amy E. Ruiz, FBN: 99129 ARuiz@tevtlaw.com Antonio Villa de Rey, FBN: 1022522 AVrey@tevtlaw.com Taylor Espino Vega & Touron, PLLC 201 Alhambra Circle, Suite 801 Coral Gables, Florida 33134 Telephone: 305.443.2043 Telefacsimile: 305.443.2048 Attorneys for Plaintiffs, Irma Qureshi & George Guerrero -10- TAYLOR ESPINO VEGA & TOURON, PLLCIN WITNESS WHEREOF, the Insurance Company has executed the foregoing answers to interrogatories and states that same are true and correct to the best of the undersigned’s knowledge and belief. Name of Insurance Company yi EES SEE AEE Title: STATE OF FLORIDA } } COUNTY OF } BEFORE ME, the undersigned authority, personally appeared , who is personally known to me or who has produced as identification, being first duly sworn according to law, deposes and says that he/she executed the foregoing Answers to this First Set of Interrogatories and that they are true and correct to the best of his/her knowledge and belief. IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of my office; in the County and State last aforesaid, this day of , 2021. TAYLOR ESPINO VEGA & TOURON, PLLC