Preview
Filing # 131690074 E-Filed 07/29/2021 04:09:58 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
HARDY Q. ZHANG CASE NO.: CACE-21-010701 (08)
AND JANET L. ZHANG,
Plaintiffs,
VS.
EDISON INSURANCE COMPANY,
Defendant.
i
DEFENDANT, EDISON INSURACNE COMPANY'S, RESPONSE TO
PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENT
Defendant, Edison Insurance Company, by and through undersigned counsel hereby files
this Response to Plaintiff's First Request for Production of Document on Defendant served with
the Summons and Complaint, and states as follows:
1. All insurance policies issued by you that would inure to the benefit of the Insured, together
with any declaration of coverage page(s) and the sworn statement of a corporate officer attesting
to the authenticity of the policy.
RESPONSE: See attached redacted insurance policy [EDI 001-071]. By producing the
attached documentation, Edison Insurance Company does not waive its privilege over claim
file materials. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See
also Defendant's Privilege Log.
2. Any correspondence or documentationthat establishes the date and manner that the subject
loss initially reported to you or your representative(s) by the Insured or the Insured's
was
representative(s).
RESPONSE: See attached correspondence [EDI 072-0751. The claim was reported on
August 16, 2020. By producing the attached documentation, Edison Insurance Company
does not waive its privilege over claim file materials. See State Farm Fla. Ins. Co. v. Aloni.
101 So. 3d 412 (Fla. 4th DCA 2012).
3. Any correspondence or documentationthat establishes what the Insured's or the Insured's
representative(s) initially reported to you or your representative(s) with regard to the date and
description ofthe subject loss.
1
SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304
TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/29/2021 04:09:58 PM.****
RESPONSE: Objection, the request seeks work product privileged claim file material. See
attached privilege log. Without waiving said objection, please see Response to Request for
Production No. 2.
4. All Proof of Loss forms pertaining to the subject loss that were sent or received by you or
your representatives to or from the Insured or the Insured's representatives.
RESPONSE: Objection, this request seeks work product privileged material. See Privilege
log. Without waiving said objection, please see attached [EDI 267]. By producing the
attached documentation, Edison Insurance Company does not waive its privilege over claim
file materials. See State Farm Fla. Ins. Co. v. Atmi, 101 So. 3d 412 (Fla. 4tth DCA 2012).
5. All correspondence sent by you or your representatives to the Insured or Insured's
representative(s) to advise of your determination(s)with regard to the availability of coverage.
RESPONSE: See attached coverage determination letter dated November 18, 2020 and letter
dated May 11, 2021 [EDI 254-257 and EDI 250-2521. By producing the attached
documentation, Edison Insurance Company does not waive its privilege over claim file
materials. See State Farm Fla. Ins. Co. v. Atmi, 101 So. 3d 412 (Fla. 4tth DCA 2012).
6. All correspondence sent by you or your representatives to the Insured or Insured's
representative(s) in response to a request for mediation or appraisal of the subject claim.
RESPONSE: None.
7. All correspondence sent by you or your representatives to the Insured or Insured's
representatives advising of the Insured's right to participate in mediation in accordance with
Florida Statute § 627.7015(2).
RESPONSE: Please see response to RFP #2.
8 To the extent not already provided in response to preceding requests, all correspondence
(includingattachments) pertainingto the subject loss that was sent by you or your representative(s)
to the Insured or Insured's representative(s).
RESPONSE: See attached correspondence [EDI 238-283]. By producing the attached
documentation, Edison Insurance Company does not waive its privilege over claim file
th
materials. See State Farm Fla. Ins. Co. v. Atmi, 101 So. 3d 412 (Fla. 4t DCA 2012).
9. All correspondence or documentation that establishes or evidences the date you began
anticipating there would be litigation arising out ofthe subject claim.
RESPONSE: Objection. Edison Insurance Company objects to this request on the ground
that it seeks work product privileged information and mental impressions. Further, the
request seeks a legal conclusion. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla.
2
SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304
TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005
4? DCA 2012). Lastly, Edison objects to this request on the grounds that it is irrelevant and
not reasonable calculated to lead to the discovery of admissible evidence.
10. All correspondence (includingattachments) pertaining to the subject loss that was received
by you or your representative(s) from the Insured or Insured's representative(s).
RESPONSE: See attached correspondence [EDI 240-257]. By producing the attached
documentation, Edison Insurance Company does not waive its privilege over claim file
materials. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See also
Defendant's Privilege Log.
11. All
correspondence (including attachments) pertaining to the subject loss that was sent or
received by you or your representative(s) to or from any third parties except your attorney.
RESPONSE: Objection, this request seeks work product privileged information. See
Privilege Log regarding documents received from Southern Safe Construction.
attached
Without waiving said objection, please see the response to produced in Response to Request
for Production No. 10.
12. Transcripts and any and all audio recordings of all recorded statements or Examinations
Under Oath taken by you or your representative(s) in connection with the subject loss.
RESPONSE: A recorded statement of Janet Zhang September 25,2020 and is
was taken on
being produced via e-mail. There was no examination under oath. By producing the
recorded statement, Edison Insurance Company does not waive its privilege over claim file
materials.See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4'Ith DCA 2012).
13. All documents or
graphic materials that were marked as exhibits, referenced or reviewed
on the record during Examinations Under Oath conducted by you or your representative(s) in
connection with the subject loss.
RESPONSE: None / not applicable.
14. All affidavitsor sworn statements in your possessionpertaining to the subject loss.
RESPONSE: See attached
[EDI 267]. By producing the attached documentation, Edison
Insurance Company does not waive its privilege over claim file materials. See State Farm
Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See also Defendant's Privilege Log
15. All documentation evidencing the date, time and subject matter of phone calls pertaining
to the subject loss that were made or received
you your representative(s) to or from the
by or
Insured or Insured's representative(s). If this informationis on records or phone logs containing
notations or comments for which you asserting a privilege,please redact the privilegedportions
are
and produce the remainderof the record or log.
3
SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304
TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005
RESPONSE: Objection. Overbroad, unduly burdensome, and not reasonably calculated to
lead to the discovery of admissible evidence. Edison Insurance Company further objects to
this request on the grounds that, as phrased, seeks documents/tangible items that were
prepared in anticipation of litigation and/or are work product privileged. See State Farm
Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See also Defendant's Privilege Log.
Without waiving said objection, Edison will determine if a recording was taken when the
claim was initially reported.
16. All documentation evidencing the date, time and subject matter of phone calls pertaining
to thesubject loss that were made or received
by you or your representativesto or from any third
parties other than your attorney(ies). If this information is on records or phone logs containing
notations or comments for which you asserting a privilege,please redact the privilegedportions
are
and produce the remainderof the record or log.
RESPONSE: See Response to Request for Production No. 15.
17. All
inspection reports or other documentsthat evidence the cause of the loss at issue in the
subject claim as determined by you or your representative(s).
RESPONSE: Objection, this request appears to seek
privileged claim file/ work product
privileged materials not
subject discovery. Notwithstanding same, please refer to
to
Defendant's Privilege Log. Without waiver, see photographs produced in Response to
,th
Request for Production No. 23. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4
DCA 2012).
18. All
inspection reports or other documentsthat evidence the cause of the loss at issue in the
subject claim as determined by the Insured or Insured's representative(s).
RESPONSE: See documents produced in Response to Request for Production No. 10.
19. To the extent not already provided in response to the preceding requests, all reports
resulting from inspections, appraisals, analyses or reviews performed in connection with the
subject loss by engineers, scientists, appraisers, contractors, accountants, or any other consultants
or experts retained by your or your representative(s).
RESPONSE: Objection, this request seeks work product privilege materials. See Privilege
Log.
20. All estimates of damages prepared by any individualwho inspected the property on behalf
of Defendant, with respect to the claim of loss at issue in this matter.
RESPONSE: Objection, this request seeks work product privilege materials. See Privilege
Log.
4
SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304
TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005
21. All inspection reports or other materials pertaining to the cause of the damages at issue in
the subject claim that were prepared by neutral, disinterested parties representing neither you nor
the Insured.
RESPONSE: Objection, the request seeks work product privilege materials. See Privilege
Log..
22. Allphotographs, video, diagrams, plans or other graphic representationsportraying the
subject Property or any portion thereof which were taken or prepared before the alleged date of
the subject loss.
RESPONSE: Objection. This request seeks information not reasonably calculated to lead
to the discovery of admissible evidence. Furthermore, the information sought is privileged,
confidential and proprietary information. See State Farm Fla. Ins. Co. v. Akmi, 101 So. 3d
412 (Fla. 4th DCA 2012). See Defendant's Privilege Log.
23. Allphotographs, video, diagrams, plans or other graphic representationsportraying the
subject Property or any portion thereof which were taken or prepared after the alleged date ofthe
subject loss.
RESPONSE: See attached redacted photographs taken by Victor Andrada on August 24,
2020 [EDI 80-237]. By producing the attached documentation, Edison Insurance Company
does not waive its privilege over claim file materials. See State Farm Fla. Ins. Co. v. Aloni,
101 So. 3d 412 (Fla. 4th DCA 2012). See also Defendant's Privilege Log.
24. Allcorrespondence, documents, photographs and video pertaining to any previous
insurance claim(s) made by the Insured or by previous owner(s) of the subject Property that were
reviewed by you or your representative(s) in the course of investigating the instant claim.
RESPONSE: This request seeks information which is irrelevant and not
Objection.
reasonably calculated to lead to the discovery of admissible evidence. Furthermore, Edison
objects to this request on the ground that it seeks privileged claim file material/mental
impressions not subject to discovery. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412
(Fla. 4th DCA 2012). See also Defendant's Privilege Log.
25. Allapplication(s) for insurance submitted by or on behalf of the Insured to you or your
representative(s) in connection with obtaining or renewing the subject Policy.
RESPONSE: None.
26. All inspection reports prepared by or for you or your representative(s) in connection with
the initial issuance or renewal of the subject Policy.
RESPONSE: Objection. This request seeks information not reasonably calculated to lead
to the discovery of admissible evidence. Furthermore the information sought is confidential
5
SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304
TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005
,th
andproprietary information. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4
DCA 2012). See Defendant's Privilege Log.
27. All photographs or video taken by or for you or your representative(s) in connection with
the initial issuance or renewal of the subject Policy.
RESPONSE: Objection. This request seeks information not reasonably calculated to lead
to thediscovery of admissible evidence. Furthermore, the information sought is privileged,
confidential and proprietary information. See State Farm Fla. Ins. Co. v. Akmi, 101 So. 3d
412 (Fla. 4th DCA 2012). See Defendant's Privilege Log.
28. To the extent not
already provided in response to preceding requests, all inspection reports,
appraisals, photographs, video or other documents or materials in your possession that evidence
or pertain to the condition of the subject Property or any portion thereof prior to the subject date
ofloss.
RESPONSE: Objection. This request seeks information not reasonably calculated to lead
to the discovery of admissible evidence. Furthermore, the information sought is privileged,
confidential and proprietary information. See State Farm Fla. Ins. Co. v. Akmi, 101 So. 3d
412 (Fla. 4th DCA 2012). See Defendant's Privilege Log.
29. A current curriculum vitae or resume for each person (other than independent adjusters)
retained on your behalf for the purpose of rendering an opinion as to the cause ofthe loss.
RESPONSE: None in Defendant's possession.
30. A copy ofthe "ISO" report pertainingto all property insurance claims filed by the Plaintiffs
at the subject property at issue in this litigation.
RESPONSE: This request seeks information which is irrelevant and not
Objection.
reasonably calculated to lead to the discovery of admissible evidence. Furthermore, Edison
objects to this request onground that it seeks privileged claim file/work product
the
materials not subject to discovery. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla.
ztt? DCA 2012). See also Defendant's Privilege Log.
31. Any correspondence sent by you or your representative(s) to the Insured or Insured's
representative(s) with respect to any insurance claims filed by Plaintiffs with Defendant prior to
the inception o f the instant lawsuit.
RESPONSE: None other than the correspondence produced herein.
32. Any correspondence sent by the Insured or their representative(s) to the Defendant or its
representatives with respect to any insurance claims filed by Plaintiffs with Defendant prior to the
inception o f the instant lawsuit.
6
SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304
TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005
RESPONSE: None other than the correspondence produced herein.
33. All estimates of damages prepared by Defendant in connection with any property damage
claim filed by Plaintiffs, which relate to damages claimed by Plaintiffs in the instant lawsuit.
RESPONSE: None other than the correspondence produced herein.
34. All photographs, video, diagrams, plans or other graphic representationsportraying the
subject Property or any portion thereofwith respect to any insurance claims filed by Plaintiffs with
Defendant prior to the inception of the instant lawsuit.
RESPONSE: None other than the correspondence produced herein.
35. A privilege log accounting for all responsivematerials being withheld from production on
the basis of privilege or protection, in accordance with Florida law.
RESPONSE: See Defendant's Privilege Log filed on this date.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a correct copy hereof has been furnished to: HL LAW
GROUP, P.A., NELSON A. PEREZ, ESQ., 2601 East Oakland Park Boulevard, Suite 503, Fort
Lauderdale, Florida 33306;
)th
by e-portal on this 29 day of July, 2021.
SEGAL McCAMBRIDGE
SINGER & MAHONEY, LTD.
1776 East Sunrise Blvd.
Fort Lauderdale, FL 33338-7990
Telephone: (954) 765-1001
Facsimile: (954) 765-1005
By-. Michael F. Barzyk
MICHAEL F. BARZYK
Florida Bar No: 0232040
mbarzyk@,
ismsm.com
CHRISTOPHER C. HORNE
Florida Bar No: 115981
chorne@smsm.com
(for emailservice only)
7
SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304
TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005
Preview
Filing # 131690074 E-Filed 07/29/2021 04:09:58 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA HARDY Q. ZHANG CASE NO.: CACE-21-010701 (08) AND JANET L. ZHANG, Plaintiffs, VS. EDISON INSURANCE COMPANY, Defendant. i DEFENDANT, EDISON INSURACNE COMPANY'S, RESPONSE TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENT Defendant, Edison Insurance Company, by and through undersigned counsel hereby files this Response to Plaintiff's First Request for Production of Document on Defendant served with the Summons and Complaint, and states as follows: 1. All insurance policies issued by you that would inure to the benefit of the Insured, together with any declaration of coverage page(s) and the sworn statement of a corporate officer attesting to the authenticity of the policy. RESPONSE: See attached redacted insurance policy [EDI 001-071]. By producing the attached documentation, Edison Insurance Company does not waive its privilege over claim file materials. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See also Defendant's Privilege Log. 2. Any correspondence or documentationthat establishes the date and manner that the subject loss initially reported to you or your representative(s) by the Insured or the Insured's was representative(s). RESPONSE: See attached correspondence [EDI 072-0751. The claim was reported on August 16, 2020. By producing the attached documentation, Edison Insurance Company does not waive its privilege over claim file materials. See State Farm Fla. Ins. Co. v. Aloni. 101 So. 3d 412 (Fla. 4th DCA 2012). 3. Any correspondence or documentationthat establishes what the Insured's or the Insured's representative(s) initially reported to you or your representative(s) with regard to the date and description ofthe subject loss. 1 SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304 TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/29/2021 04:09:58 PM.**** RESPONSE: Objection, the request seeks work product privileged claim file material. See attached privilege log. Without waiving said objection, please see Response to Request for Production No. 2. 4. All Proof of Loss forms pertaining to the subject loss that were sent or received by you or your representatives to or from the Insured or the Insured's representatives. RESPONSE: Objection, this request seeks work product privileged material. See Privilege log. Without waiving said objection, please see attached [EDI 267]. By producing the attached documentation, Edison Insurance Company does not waive its privilege over claim file materials. See State Farm Fla. Ins. Co. v. Atmi, 101 So. 3d 412 (Fla. 4tth DCA 2012). 5. All correspondence sent by you or your representatives to the Insured or Insured's representative(s) to advise of your determination(s)with regard to the availability of coverage. RESPONSE: See attached coverage determination letter dated November 18, 2020 and letter dated May 11, 2021 [EDI 254-257 and EDI 250-2521. By producing the attached documentation, Edison Insurance Company does not waive its privilege over claim file materials. See State Farm Fla. Ins. Co. v. Atmi, 101 So. 3d 412 (Fla. 4tth DCA 2012). 6. All correspondence sent by you or your representatives to the Insured or Insured's representative(s) in response to a request for mediation or appraisal of the subject claim. RESPONSE: None. 7. All correspondence sent by you or your representatives to the Insured or Insured's representatives advising of the Insured's right to participate in mediation in accordance with Florida Statute § 627.7015(2). RESPONSE: Please see response to RFP #2. 8 To the extent not already provided in response to preceding requests, all correspondence (includingattachments) pertainingto the subject loss that was sent by you or your representative(s) to the Insured or Insured's representative(s). RESPONSE: See attached correspondence [EDI 238-283]. By producing the attached documentation, Edison Insurance Company does not waive its privilege over claim file th materials. See State Farm Fla. Ins. Co. v. Atmi, 101 So. 3d 412 (Fla. 4t DCA 2012). 9. All correspondence or documentation that establishes or evidences the date you began anticipating there would be litigation arising out ofthe subject claim. RESPONSE: Objection. Edison Insurance Company objects to this request on the ground that it seeks work product privileged information and mental impressions. Further, the request seeks a legal conclusion. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 2 SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304 TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005 4? DCA 2012). Lastly, Edison objects to this request on the grounds that it is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. 10. All correspondence (includingattachments) pertaining to the subject loss that was received by you or your representative(s) from the Insured or Insured's representative(s). RESPONSE: See attached correspondence [EDI 240-257]. By producing the attached documentation, Edison Insurance Company does not waive its privilege over claim file materials. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See also Defendant's Privilege Log. 11. All correspondence (including attachments) pertaining to the subject loss that was sent or received by you or your representative(s) to or from any third parties except your attorney. RESPONSE: Objection, this request seeks work product privileged information. See Privilege Log regarding documents received from Southern Safe Construction. attached Without waiving said objection, please see the response to produced in Response to Request for Production No. 10. 12. Transcripts and any and all audio recordings of all recorded statements or Examinations Under Oath taken by you or your representative(s) in connection with the subject loss. RESPONSE: A recorded statement of Janet Zhang September 25,2020 and is was taken on being produced via e-mail. There was no examination under oath. By producing the recorded statement, Edison Insurance Company does not waive its privilege over claim file materials.See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4'Ith DCA 2012). 13. All documents or graphic materials that were marked as exhibits, referenced or reviewed on the record during Examinations Under Oath conducted by you or your representative(s) in connection with the subject loss. RESPONSE: None / not applicable. 14. All affidavitsor sworn statements in your possessionpertaining to the subject loss. RESPONSE: See attached [EDI 267]. By producing the attached documentation, Edison Insurance Company does not waive its privilege over claim file materials. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See also Defendant's Privilege Log 15. All documentation evidencing the date, time and subject matter of phone calls pertaining to the subject loss that were made or received you your representative(s) to or from the by or Insured or Insured's representative(s). If this informationis on records or phone logs containing notations or comments for which you asserting a privilege,please redact the privilegedportions are and produce the remainderof the record or log. 3 SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304 TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005 RESPONSE: Objection. Overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Edison Insurance Company further objects to this request on the grounds that, as phrased, seeks documents/tangible items that were prepared in anticipation of litigation and/or are work product privileged. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See also Defendant's Privilege Log. Without waiving said objection, Edison will determine if a recording was taken when the claim was initially reported. 16. All documentation evidencing the date, time and subject matter of phone calls pertaining to thesubject loss that were made or received by you or your representativesto or from any third parties other than your attorney(ies). If this information is on records or phone logs containing notations or comments for which you asserting a privilege,please redact the privilegedportions are and produce the remainderof the record or log. RESPONSE: See Response to Request for Production No. 15. 17. All inspection reports or other documentsthat evidence the cause of the loss at issue in the subject claim as determined by you or your representative(s). RESPONSE: Objection, this request appears to seek privileged claim file/ work product privileged materials not subject discovery. Notwithstanding same, please refer to to Defendant's Privilege Log. Without waiver, see photographs produced in Response to ,th Request for Production No. 23. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4 DCA 2012). 18. All inspection reports or other documentsthat evidence the cause of the loss at issue in the subject claim as determined by the Insured or Insured's representative(s). RESPONSE: See documents produced in Response to Request for Production No. 10. 19. To the extent not already provided in response to the preceding requests, all reports resulting from inspections, appraisals, analyses or reviews performed in connection with the subject loss by engineers, scientists, appraisers, contractors, accountants, or any other consultants or experts retained by your or your representative(s). RESPONSE: Objection, this request seeks work product privilege materials. See Privilege Log. 20. All estimates of damages prepared by any individualwho inspected the property on behalf of Defendant, with respect to the claim of loss at issue in this matter. RESPONSE: Objection, this request seeks work product privilege materials. See Privilege Log. 4 SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304 TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005 21. All inspection reports or other materials pertaining to the cause of the damages at issue in the subject claim that were prepared by neutral, disinterested parties representing neither you nor the Insured. RESPONSE: Objection, the request seeks work product privilege materials. See Privilege Log.. 22. Allphotographs, video, diagrams, plans or other graphic representationsportraying the subject Property or any portion thereof which were taken or prepared before the alleged date of the subject loss. RESPONSE: Objection. This request seeks information not reasonably calculated to lead to the discovery of admissible evidence. Furthermore, the information sought is privileged, confidential and proprietary information. See State Farm Fla. Ins. Co. v. Akmi, 101 So. 3d 412 (Fla. 4th DCA 2012). See Defendant's Privilege Log. 23. Allphotographs, video, diagrams, plans or other graphic representationsportraying the subject Property or any portion thereof which were taken or prepared after the alleged date ofthe subject loss. RESPONSE: See attached redacted photographs taken by Victor Andrada on August 24, 2020 [EDI 80-237]. By producing the attached documentation, Edison Insurance Company does not waive its privilege over claim file materials. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See also Defendant's Privilege Log. 24. Allcorrespondence, documents, photographs and video pertaining to any previous insurance claim(s) made by the Insured or by previous owner(s) of the subject Property that were reviewed by you or your representative(s) in the course of investigating the instant claim. RESPONSE: This request seeks information which is irrelevant and not Objection. reasonably calculated to lead to the discovery of admissible evidence. Furthermore, Edison objects to this request on the ground that it seeks privileged claim file material/mental impressions not subject to discovery. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012). See also Defendant's Privilege Log. 25. Allapplication(s) for insurance submitted by or on behalf of the Insured to you or your representative(s) in connection with obtaining or renewing the subject Policy. RESPONSE: None. 26. All inspection reports prepared by or for you or your representative(s) in connection with the initial issuance or renewal of the subject Policy. RESPONSE: Objection. This request seeks information not reasonably calculated to lead to the discovery of admissible evidence. Furthermore the information sought is confidential 5 SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304 TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005 ,th andproprietary information. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4 DCA 2012). See Defendant's Privilege Log. 27. All photographs or video taken by or for you or your representative(s) in connection with the initial issuance or renewal of the subject Policy. RESPONSE: Objection. This request seeks information not reasonably calculated to lead to thediscovery of admissible evidence. Furthermore, the information sought is privileged, confidential and proprietary information. See State Farm Fla. Ins. Co. v. Akmi, 101 So. 3d 412 (Fla. 4th DCA 2012). See Defendant's Privilege Log. 28. To the extent not already provided in response to preceding requests, all inspection reports, appraisals, photographs, video or other documents or materials in your possession that evidence or pertain to the condition of the subject Property or any portion thereof prior to the subject date ofloss. RESPONSE: Objection. This request seeks information not reasonably calculated to lead to the discovery of admissible evidence. Furthermore, the information sought is privileged, confidential and proprietary information. See State Farm Fla. Ins. Co. v. Akmi, 101 So. 3d 412 (Fla. 4th DCA 2012). See Defendant's Privilege Log. 29. A current curriculum vitae or resume for each person (other than independent adjusters) retained on your behalf for the purpose of rendering an opinion as to the cause ofthe loss. RESPONSE: None in Defendant's possession. 30. A copy ofthe "ISO" report pertainingto all property insurance claims filed by the Plaintiffs at the subject property at issue in this litigation. RESPONSE: This request seeks information which is irrelevant and not Objection. reasonably calculated to lead to the discovery of admissible evidence. Furthermore, Edison objects to this request onground that it seeks privileged claim file/work product the materials not subject to discovery. See State Farm Fla. Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. ztt? DCA 2012). See also Defendant's Privilege Log. 31. Any correspondence sent by you or your representative(s) to the Insured or Insured's representative(s) with respect to any insurance claims filed by Plaintiffs with Defendant prior to the inception o f the instant lawsuit. RESPONSE: None other than the correspondence produced herein. 32. Any correspondence sent by the Insured or their representative(s) to the Defendant or its representatives with respect to any insurance claims filed by Plaintiffs with Defendant prior to the inception o f the instant lawsuit. 6 SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304 TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005 RESPONSE: None other than the correspondence produced herein. 33. All estimates of damages prepared by Defendant in connection with any property damage claim filed by Plaintiffs, which relate to damages claimed by Plaintiffs in the instant lawsuit. RESPONSE: None other than the correspondence produced herein. 34. All photographs, video, diagrams, plans or other graphic representationsportraying the subject Property or any portion thereofwith respect to any insurance claims filed by Plaintiffs with Defendant prior to the inception of the instant lawsuit. RESPONSE: None other than the correspondence produced herein. 35. A privilege log accounting for all responsivematerials being withheld from production on the basis of privilege or protection, in accordance with Florida law. RESPONSE: See Defendant's Privilege Log filed on this date. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a correct copy hereof has been furnished to: HL LAW GROUP, P.A., NELSON A. PEREZ, ESQ., 2601 East Oakland Park Boulevard, Suite 503, Fort Lauderdale, Florida 33306; )th by e-portal on this 29 day of July, 2021. SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD. 1776 East Sunrise Blvd. Fort Lauderdale, FL 33338-7990 Telephone: (954) 765-1001 Facsimile: (954) 765-1005 By-. Michael F. Barzyk MICHAEL F. BARZYK Florida Bar No: 0232040 mbarzyk@, ismsm.com CHRISTOPHER C. HORNE Florida Bar No: 115981 chorne@smsm.com (for emailservice only) 7 SEGAL McCAMBRIDGE SINGER & MAHONEY, LTD . 1776 EAST SUNRISEBLVD . FORT LAUDERDALE,FL 33304 TELEPHONE (954) 765-1001 FACSIMILE (954) 765-1005