Preview
Filing# 145955930 E-Filed 03/18/2022 12:06:46 AM
,TH
IN THE CIRCUIT COURT OF THE 17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
ELORS ETIENNE AND ADJANIE CASE NO: CACE-21-010707
ETIENNE,
Plaintiffs,
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S FIRST REOUEST FOR PRODUCTION TO PLAINTIFF
UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY ("Universal")
." '..
Defendant
through counsel and pursuant to Rule 1.350 ofthe Florida Rules ofCivil Procedure, propounds this Request
for Production upon Plaintiff. Plaintiff is to respond to this Request for Production in writing and to produce
for inspection,copying, and/or photographing certain documents requested within thirty(30) days.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/18/2022 12:06:45 AM.****
Elors Etienne, et al.,v. UPCIC
Case No.: CACE-21-010707 (13)
Page 2 of 7
Defendant's First Request for Production to Plaintiffs
DEFINITIONS
1 "Calendar Year" means that period of time that begins at 12:01 a.m. on January
1 of any given year and ends at 11:59 pm. on December 31 of that year.
2. "Claim" means the insurance claim that Plaintiff (as defined herein) reported to
Defendant (as defined herein) and that serves as a basis for any causes of action asserted against
Defendant in this action.
3. "Claimed Cause of Loss" means the event and/or reason that You (as defined
herein) are claiming that the Insured Property (as defined herein) was damaged.
"
4. "Concerning", "concern," or any other derivative thereof as used herein, shall be
construed as referring to, responding to, relatingto, pertaining to, connected with, comprising,
memorializing, commenting on, substantiating,
regarding, discussing, showing, describing,
analyzing,and constituting.
reflecting,
5. "Control" means having possession of and/or the power and/or authority to
request possession of the subjectmatter or a copy thereof, or direct the possession, movement,
transfer or other dispositionof the subjectproperty or document.
6. "Date" means the exact date (including day, month, and year). If the exact day,
month, and year is not ascertainable, then the best available approximation of the exact day, month,
and year.
7. "Defendant" means Universal Property & Casualty Insurance Company.
8 "Document" or "documents" means anything which may be considered to be a
document or tangiblething within the meaning of Fla. R. Civ. P. 1.350 and means any and all
correspondence,records,reports, memoranda, notes, letters, telegrams,emails, voicemails, telexes,
texts, messages (including,but not limited to, memos, notes and/or reports of telephone
conversations and conferences), studies,analyses, books, magazines, newspapers, publications,
booklets, pamphlets, circulars,bulletins,instructions,minutes, or other communications (including,
but not limited to, interoffice and intra-office communications), questionnaires, surveys, contracts,
memoranda of agreements, assignments, books of account, journals,ledgers,summaries, opinions,
reports, evaluations, financial statementsand all records of or reflecting business operations,
mortgages, evaluations, orders, working papers, bills of lading, shipping lists,load sheets,
warehouse receipts, letters of credit, insurance policies, records of summaries of personal
interviews or conversations, appointment calendars, diaries,schedules, printouts,drawings,
specifications, certificates of registration, applications
patents, patent applications, for registration,
graphs,charts,studies,planning materials,statistical statements and compilations,forecasts,work
papers, invoices, statements, bills,checks, bank books, bank statements, forms, vouchers,
notebooks, data sheets, microfilm, microfiche, photographic negatives, audio tape, video tape,
compact disks, blueprints, specifications,architectural diagrams, schematics, logic diagrams,
timing diagrams, pictures,photographs, microscopically obtained photographs, test results,belts,
tapes, magnetic tapes, paper tapes, plotter output recordings, discs, data cards, films, data
processing files,computer files and other computer readable records or programs and all other
written, printed or recorded matter of any kind, and all other data compilations from which
Elors Etienne, et al.,v. UPCIC
Case No.: CACE-21-010707 (13)
Page 3 of 7
Defendant's First Request for Production to Plaintiffs
information can be obtained, and translated,ifnecessary,and all originals,drafts and copies thereof.
Any documents bearing any marks including,but not limited to, initials,stamped indicia,
comments, or notations, of any kind that are not a part of the originaltext or photographic
reproductionthereof are to be considered and identified as separate documents.
9. "Dwelling" means the physical dwelling located at the Insured Property (as
defined herein).
10. "Insured Property" means the real property specifically
listed on the declarations
page of the Policy (as defined herein).
11. "Other Structures" means any structures located at the Insured Property that are
from and/or not connected to the Dwelling including,but not limited to, those structures
set apart
connected only by a fence, utilityline,ancFor similar connection.
12. "Person" or "Persons" shall mean any natural person or any legal entity
including,but not limited to, a corporation,partnershipand unincorporatedassociation,firm,joint
venture, proprietorship,and/or any other entity or group ofnatural persons or such entities, singular
or plural,male, female, or neuter gender, as the context may require,and any officer.
13. "Plaintiff" means any person and/or entitynamed as a plaintiff
in this action.
14. "Policy" means the insurance policy that serves as a basis for any causes of action
asserted against Defendant in this lawsuit.
15. "Related to", "relating to", and "relate to" shall include pertaining to, referring
to, relevant to, supporting, contradicting, mentioning, evidencing, discussing or otherwise
involving,whether directlyor indirectly,
the subjectmatter of the specifiedrequest.
16. "Universal" means Defendant UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY
17. "Written Communication" or "correspondence" means the conveyance of
information by a writing,whether by letters,e-mails, memoranda, handwritten notes and/or faxes.
18. "Witness Statement" or "Statement" means a statement of any person with
knowledge of relevant facts,regardless of when the statement was made, and is either (i)a written
statement signed or otherwise adopted and/or approved in writing by the person making it;or, (ii)
a stenographic, mechanical, electrical,and/or other type of recording of a person's oral statement
verbatim transcript
and/or any substantially of such recording.
19. "You" or "Your" means the specificparty responding to these requests and/or
any person and/or entitynamed as a Plaintiff in this action.
20. "Your Counsel" means the attorney or attorneys who are representing or have
represented you either with regard to the claim or in this lawsuit.
Elors Etienne, et al.,v. UPCIC
Case No.: CACE-21-010707 (13)
Page 4 of 7
Defendant's First Request for Production to Plaintiffs
PRODUCTION REOUESTS
1. Copies of all reports, drafts,charts, drawings, diagrams, memoranda, and/or testingresults
that show and/or intend to show the cause for the alleged damage to the Insured Property in
connection with the Claim.
2. Copies of all documents evidencing the type ofwindows installed at the Insured Property.
3. Copies of all documents evidencing the type of roof installed at the Insured Property.
4. Copies of any rental agreements and/or lease agreements that You entered into concerning
the Insured Property since the Date that You purchased the Insured Property.
5. Copies of all mold reports, lab results,and/or mold remediation reports concerning and/or
relatingto the Insured Property from the Date that You purchased the Insured Property to the
Date of the Claimed Cause of Loss.
6. Copies of all mold reports, lab results,and/or mold remediation reports concerning and/or
relatingto the Insured Property from the Date of the Claimed Cause of Loss to the Date of
responding to these production requests.
7. Copies of all documents evidencing damages that You are claiming for personal property
as a result of the Claimed Cause of Loss.
8. Copies of all documents evidencing damages that You are claiming for additional living
expenses as a result of the Claimed Cause of Loss.
9. Copies of any documents evidencing damages that You are claiming for loss of use of the
Insured Property as a result of the Claimed Cause of Loss.
10. Copies of all repairestimates,contracts, and invoices related to the allegeddamages to the
Insured Property as a result of the Claimed Cause of Loss.
11. Copies of all photographs and/or video taken of any alleged damages to the Insured
Property as a result of the Claimed Cause of Loss.
12. Copies of all photographs and/or video taken of the Insured Property from the Date that
You purchased the Insured Property to the Date of the Claimed Cause of Loss.
13. Copies of all documents pertainingto all insurance claims that You made and/or filed
concerning and/or relatingto the Insured Property from the Date that You purchased the
Insured Property to the Date of the Claimed Cause of Loss.
14.Copies of all documents pertainingto all insurance claims (otherthan this Claim) that You
made ancFor filed concerning and/or relating to the Insured Property from the Date of the
Claimed Cause of Loss to the Date ofresponding to these production requests.
15. Copies of all correspondences and/or documents that You sent to Universal with regard to
the Claim prior to the initiation of this action.
Elors Etienne, et al.,v. UPCIC
Case No.: CACE-21-010707 (13)
Page 5 of 7
Defendant's First Request for Production to Plaintiffs
16. Copies of any and all correspondences and/or documents exchanged between You and any
third party regarding the damages to the Insured Property as a result of the Claimed Cause of
but not limited to, correspondences and/or documents exchanged between You
Loss, including,
and any friends,family, co-workers, law enforcement, and/or, Local, State, and/or Federal
agencies,programs, and/or departments.
17. A copy of the retainer agreement and/or other agreement for compensation between You
and any attorney that You retained in connection with this action.
18. A copy of the retainer agreement and/or other agreement for compensation between You
and any public adjusterthat You retained in connection with this action.
19. A copy of the retainer agreement and/or other agreement for compensation between You
and any general contractor that You retained in connection with this action.
20. A copy of the retainer agreement and/or other agreement for compensation between You
and any emergency mitigation services individual and/or company that You retained in
connection with this action.
21. A copy of the retainer agreement and/or other agreement for compensation between You
and any mold testing individual and/or company that You retained in connection with this
action.
22. A copy of the retainer agreement and/or other agreement for compensation between You
and any mold remediation individual and/or company that You retained in connection with this
action.
23. A copy of the retainer agreement and/or other agreement for compensation between You
and any expert witness that You retained in connection with this action.
24. Copies of all correspondences an(For documents exchanged between Plaintiff and any
public adjuster;general contractor; mold testingindividual and/or company; mold remediation
individual and/or company; emergency mitigation services individual and/or company; and/or,
expert witness retained to inspect, examine, survey, and/or perform services at the Insured
Property from the Date of the Claimed Cause of Loss to the Date of responding to these
production requests.
25. Copies of all correspondence and/or documents exchanged between You and any person
the cause of the damages in connection with the Claim.
and/or entityidentifying
26. Copies of all inspections, due diligencereports, and/or investigation
estimates,appraisals,
records concerning and/or relatingto the Insured Property priorto the Date that You purchased
the Insured Property.
27. Copies of all inspections,estimates,appraisals,due diligencereports, and/or investigation
records concerning and/or relatingto the Insured Property from the Date that You purchased
the Insured Property to the Date of the Claimed Cause of Loss.
Elors Etienne, et al.,v. UPCIC
Case No.: CACE-21-010707 (13)
Page 6 of 7
Defendant's First Request for Production to Plaintiffs
28. Copies of all inspections,estimates, appraisals,due diligencereports, and/or investigation
records concerning and/or relatingto the Insured Property from the Date of the Claimed Cause
of Loss to the Date of responding to these production requests.
29. Copies of any pennits, pennit applications,architectural drawings and/or renderings,
engineering reports, contracts, change orders, invoices, status updates, and evidence of
payment for any repairs and/or renovations to the Insured Property from the Date that You
purchased the Insured Property to the Date of the Claimed Cause of Loss.
30. Copies of any pennits, pennit applications, architectural drawings and/or renderings,
engineering reports, contracts, change orders, invoices, status updates, and evidence of
payment for any repairs and/or renovations to the Insured Property from the Date of the
Claimed Cause of Loss to the Date ofresponding to these production requests.
31. Copies of any post by You on any social media platform (e.g.Facebook, Instagram,
Twitter, WhatsApp, GroupMe, Snapchat, Pinterest, Reddit, Youtube, Nextdoor, Flickr,
Tumblr, and/or Linke(lIn)concerning and/or relatingto the Claim, the Claimed Cause of Loss,
damage to the Insured Property as a result of the Claimed Cause of Loss, and/or the Defendant.
32. Copies of documents supporting Your claim for damages to the Insured Property or
pursuant to the Policy as a result of the Claimed Cause of Loss that have not already been
produced in response to the aforementioned requests.
33. A PrivilegeLog for any documents withheld because of some asserted privilege.
34. Please produce copies of all documents, including correspondences, sent by You or Your
to Universal at claimshelp@universalproperty.com.
representatives
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
Elors Etienne, et al.,v. UPCIC
Case No.: CACE-21-010707 (13)
Page 7 of 7
Defendant's First Request for Production to Plaintiffs
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
Service to: Carolina Lopez, Esq., Feldman & Lopez, P.A. (service@feldmanandlopez.com),)
on March 17, 2022.
AttorneyMDefendant
Universal Property & CasualtyIns. Co.
PO Box 9388
Fort Lauderdale, Florida 33310
Telephone: 954-958-3319
Toll Free: 1-833-658-8594 (JudgesOnly)
Facsimile: 954-958-1262
By-. /s/ Joseph Henn
Joseph Henn, Esq.
Florida Bar No. 91143
For Service of Court Documents Onlv:
Primary: upciceservice01@universalproperty.com
Secondary: kb0615@universalproperty.com
Tertiary:jh0518@universalproperty.com
For Scheduling Matters:
Is0601@universalproperty.com
Please do not send any inquiriesor scheduling matters to upciceservice@universalpropertv. com
or upciceservice01@universalpropertv.com.
Preview
Filing# 145955930 E-Filed 03/18/2022 12:06:46 AM ,TH IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ELORS ETIENNE AND ADJANIE CASE NO: CACE-21-010707 ETIENNE, Plaintiffs, VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i DEFENDANT'S FIRST REOUEST FOR PRODUCTION TO PLAINTIFF UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY ("Universal") ." '.. Defendant through counsel and pursuant to Rule 1.350 ofthe Florida Rules ofCivil Procedure, propounds this Request for Production upon Plaintiff. Plaintiff is to respond to this Request for Production in writing and to produce for inspection,copying, and/or photographing certain documents requested within thirty(30) days. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/18/2022 12:06:45 AM.**** Elors Etienne, et al.,v. UPCIC Case No.: CACE-21-010707 (13) Page 2 of 7 Defendant's First Request for Production to Plaintiffs DEFINITIONS 1 "Calendar Year" means that period of time that begins at 12:01 a.m. on January 1 of any given year and ends at 11:59 pm. on December 31 of that year. 2. "Claim" means the insurance claim that Plaintiff (as defined herein) reported to Defendant (as defined herein) and that serves as a basis for any causes of action asserted against Defendant in this action. 3. "Claimed Cause of Loss" means the event and/or reason that You (as defined herein) are claiming that the Insured Property (as defined herein) was damaged. " 4. "Concerning", "concern," or any other derivative thereof as used herein, shall be construed as referring to, responding to, relatingto, pertaining to, connected with, comprising, memorializing, commenting on, substantiating, regarding, discussing, showing, describing, analyzing,and constituting. reflecting, 5. "Control" means having possession of and/or the power and/or authority to request possession of the subjectmatter or a copy thereof, or direct the possession, movement, transfer or other dispositionof the subjectproperty or document. 6. "Date" means the exact date (including day, month, and year). If the exact day, month, and year is not ascertainable, then the best available approximation of the exact day, month, and year. 7. "Defendant" means Universal Property & Casualty Insurance Company. 8 "Document" or "documents" means anything which may be considered to be a document or tangiblething within the meaning of Fla. R. Civ. P. 1.350 and means any and all correspondence,records,reports, memoranda, notes, letters, telegrams,emails, voicemails, telexes, texts, messages (including,but not limited to, memos, notes and/or reports of telephone conversations and conferences), studies,analyses, books, magazines, newspapers, publications, booklets, pamphlets, circulars,bulletins,instructions,minutes, or other communications (including, but not limited to, interoffice and intra-office communications), questionnaires, surveys, contracts, memoranda of agreements, assignments, books of account, journals,ledgers,summaries, opinions, reports, evaluations, financial statementsand all records of or reflecting business operations, mortgages, evaluations, orders, working papers, bills of lading, shipping lists,load sheets, warehouse receipts, letters of credit, insurance policies, records of summaries of personal interviews or conversations, appointment calendars, diaries,schedules, printouts,drawings, specifications, certificates of registration, applications patents, patent applications, for registration, graphs,charts,studies,planning materials,statistical statements and compilations,forecasts,work papers, invoices, statements, bills,checks, bank books, bank statements, forms, vouchers, notebooks, data sheets, microfilm, microfiche, photographic negatives, audio tape, video tape, compact disks, blueprints, specifications,architectural diagrams, schematics, logic diagrams, timing diagrams, pictures,photographs, microscopically obtained photographs, test results,belts, tapes, magnetic tapes, paper tapes, plotter output recordings, discs, data cards, films, data processing files,computer files and other computer readable records or programs and all other written, printed or recorded matter of any kind, and all other data compilations from which Elors Etienne, et al.,v. UPCIC Case No.: CACE-21-010707 (13) Page 3 of 7 Defendant's First Request for Production to Plaintiffs information can be obtained, and translated,ifnecessary,and all originals,drafts and copies thereof. Any documents bearing any marks including,but not limited to, initials,stamped indicia, comments, or notations, of any kind that are not a part of the originaltext or photographic reproductionthereof are to be considered and identified as separate documents. 9. "Dwelling" means the physical dwelling located at the Insured Property (as defined herein). 10. "Insured Property" means the real property specifically listed on the declarations page of the Policy (as defined herein). 11. "Other Structures" means any structures located at the Insured Property that are from and/or not connected to the Dwelling including,but not limited to, those structures set apart connected only by a fence, utilityline,ancFor similar connection. 12. "Person" or "Persons" shall mean any natural person or any legal entity including,but not limited to, a corporation,partnershipand unincorporatedassociation,firm,joint venture, proprietorship,and/or any other entity or group ofnatural persons or such entities, singular or plural,male, female, or neuter gender, as the context may require,and any officer. 13. "Plaintiff" means any person and/or entitynamed as a plaintiff in this action. 14. "Policy" means the insurance policy that serves as a basis for any causes of action asserted against Defendant in this lawsuit. 15. "Related to", "relating to", and "relate to" shall include pertaining to, referring to, relevant to, supporting, contradicting, mentioning, evidencing, discussing or otherwise involving,whether directlyor indirectly, the subjectmatter of the specifiedrequest. 16. "Universal" means Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY 17. "Written Communication" or "correspondence" means the conveyance of information by a writing,whether by letters,e-mails, memoranda, handwritten notes and/or faxes. 18. "Witness Statement" or "Statement" means a statement of any person with knowledge of relevant facts,regardless of when the statement was made, and is either (i)a written statement signed or otherwise adopted and/or approved in writing by the person making it;or, (ii) a stenographic, mechanical, electrical,and/or other type of recording of a person's oral statement verbatim transcript and/or any substantially of such recording. 19. "You" or "Your" means the specificparty responding to these requests and/or any person and/or entitynamed as a Plaintiff in this action. 20. "Your Counsel" means the attorney or attorneys who are representing or have represented you either with regard to the claim or in this lawsuit. Elors Etienne, et al.,v. UPCIC Case No.: CACE-21-010707 (13) Page 4 of 7 Defendant's First Request for Production to Plaintiffs PRODUCTION REOUESTS 1. Copies of all reports, drafts,charts, drawings, diagrams, memoranda, and/or testingresults that show and/or intend to show the cause for the alleged damage to the Insured Property in connection with the Claim. 2. Copies of all documents evidencing the type ofwindows installed at the Insured Property. 3. Copies of all documents evidencing the type of roof installed at the Insured Property. 4. Copies of any rental agreements and/or lease agreements that You entered into concerning the Insured Property since the Date that You purchased the Insured Property. 5. Copies of all mold reports, lab results,and/or mold remediation reports concerning and/or relatingto the Insured Property from the Date that You purchased the Insured Property to the Date of the Claimed Cause of Loss. 6. Copies of all mold reports, lab results,and/or mold remediation reports concerning and/or relatingto the Insured Property from the Date of the Claimed Cause of Loss to the Date of responding to these production requests. 7. Copies of all documents evidencing damages that You are claiming for personal property as a result of the Claimed Cause of Loss. 8. Copies of all documents evidencing damages that You are claiming for additional living expenses as a result of the Claimed Cause of Loss. 9. Copies of any documents evidencing damages that You are claiming for loss of use of the Insured Property as a result of the Claimed Cause of Loss. 10. Copies of all repairestimates,contracts, and invoices related to the allegeddamages to the Insured Property as a result of the Claimed Cause of Loss. 11. Copies of all photographs and/or video taken of any alleged damages to the Insured Property as a result of the Claimed Cause of Loss. 12. Copies of all photographs and/or video taken of the Insured Property from the Date that You purchased the Insured Property to the Date of the Claimed Cause of Loss. 13. Copies of all documents pertainingto all insurance claims that You made and/or filed concerning and/or relatingto the Insured Property from the Date that You purchased the Insured Property to the Date of the Claimed Cause of Loss. 14.Copies of all documents pertainingto all insurance claims (otherthan this Claim) that You made ancFor filed concerning and/or relating to the Insured Property from the Date of the Claimed Cause of Loss to the Date ofresponding to these production requests. 15. Copies of all correspondences and/or documents that You sent to Universal with regard to the Claim prior to the initiation of this action. Elors Etienne, et al.,v. UPCIC Case No.: CACE-21-010707 (13) Page 5 of 7 Defendant's First Request for Production to Plaintiffs 16. Copies of any and all correspondences and/or documents exchanged between You and any third party regarding the damages to the Insured Property as a result of the Claimed Cause of but not limited to, correspondences and/or documents exchanged between You Loss, including, and any friends,family, co-workers, law enforcement, and/or, Local, State, and/or Federal agencies,programs, and/or departments. 17. A copy of the retainer agreement and/or other agreement for compensation between You and any attorney that You retained in connection with this action. 18. A copy of the retainer agreement and/or other agreement for compensation between You and any public adjusterthat You retained in connection with this action. 19. A copy of the retainer agreement and/or other agreement for compensation between You and any general contractor that You retained in connection with this action. 20. A copy of the retainer agreement and/or other agreement for compensation between You and any emergency mitigation services individual and/or company that You retained in connection with this action. 21. A copy of the retainer agreement and/or other agreement for compensation between You and any mold testing individual and/or company that You retained in connection with this action. 22. A copy of the retainer agreement and/or other agreement for compensation between You and any mold remediation individual and/or company that You retained in connection with this action. 23. A copy of the retainer agreement and/or other agreement for compensation between You and any expert witness that You retained in connection with this action. 24. Copies of all correspondences an(For documents exchanged between Plaintiff and any public adjuster;general contractor; mold testingindividual and/or company; mold remediation individual and/or company; emergency mitigation services individual and/or company; and/or, expert witness retained to inspect, examine, survey, and/or perform services at the Insured Property from the Date of the Claimed Cause of Loss to the Date of responding to these production requests. 25. Copies of all correspondence and/or documents exchanged between You and any person the cause of the damages in connection with the Claim. and/or entityidentifying 26. Copies of all inspections, due diligencereports, and/or investigation estimates,appraisals, records concerning and/or relatingto the Insured Property priorto the Date that You purchased the Insured Property. 27. Copies of all inspections,estimates,appraisals,due diligencereports, and/or investigation records concerning and/or relatingto the Insured Property from the Date that You purchased the Insured Property to the Date of the Claimed Cause of Loss. Elors Etienne, et al.,v. UPCIC Case No.: CACE-21-010707 (13) Page 6 of 7 Defendant's First Request for Production to Plaintiffs 28. Copies of all inspections,estimates, appraisals,due diligencereports, and/or investigation records concerning and/or relatingto the Insured Property from the Date of the Claimed Cause of Loss to the Date of responding to these production requests. 29. Copies of any pennits, pennit applications,architectural drawings and/or renderings, engineering reports, contracts, change orders, invoices, status updates, and evidence of payment for any repairs and/or renovations to the Insured Property from the Date that You purchased the Insured Property to the Date of the Claimed Cause of Loss. 30. Copies of any pennits, pennit applications, architectural drawings and/or renderings, engineering reports, contracts, change orders, invoices, status updates, and evidence of payment for any repairs and/or renovations to the Insured Property from the Date of the Claimed Cause of Loss to the Date ofresponding to these production requests. 31. Copies of any post by You on any social media platform (e.g.Facebook, Instagram, Twitter, WhatsApp, GroupMe, Snapchat, Pinterest, Reddit, Youtube, Nextdoor, Flickr, Tumblr, and/or Linke(lIn)concerning and/or relatingto the Claim, the Claimed Cause of Loss, damage to the Insured Property as a result of the Claimed Cause of Loss, and/or the Defendant. 32. Copies of documents supporting Your claim for damages to the Insured Property or pursuant to the Policy as a result of the Claimed Cause of Loss that have not already been produced in response to the aforementioned requests. 33. A PrivilegeLog for any documents withheld because of some asserted privilege. 34. Please produce copies of all documents, including correspondences, sent by You or Your to Universal at claimshelp@universalproperty.com. representatives [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Elors Etienne, et al.,v. UPCIC Case No.: CACE-21-010707 (13) Page 7 of 7 Defendant's First Request for Production to Plaintiffs CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- Service to: Carolina Lopez, Esq., Feldman & Lopez, P.A. (service@feldmanandlopez.com),) on March 17, 2022. AttorneyMDefendant Universal Property & CasualtyIns. Co. PO Box 9388 Fort Lauderdale, Florida 33310 Telephone: 954-958-3319 Toll Free: 1-833-658-8594 (JudgesOnly) Facsimile: 954-958-1262 By-. /s/ Joseph Henn Joseph Henn, Esq. Florida Bar No. 91143 For Service of Court Documents Onlv: Primary: upciceservice01@universalproperty.com Secondary: kb0615@universalproperty.com Tertiary:jh0518@universalproperty.com For Scheduling Matters: Is0601@universalproperty.com Please do not send any inquiriesor scheduling matters to upciceservice@universalpropertv. com or upciceservice01@universalpropertv.com.