Party Discovery: Gloria H Oliveras , et al Plaintiff vs. United Property & Casualty Insurance Company Defendant

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                                Filing# 138353516 E-Filed 11/11/2021 12:41:39                        PM


        INTHE CIRCUIT COURT OF THE
        17TH JUDICIAL CIRCUIT IN AND
        FOR BROWARD COUNTY, FLORIDA
        Case No.: CACE-21-010649

        GLORIA H. OLIVERAS               &,
        JOSE OLIVERAS,

                           Plaintiffs,


        V.


        UNITED PROPERTY & CASUALTY
        INSURANCE COMPANY,

                           Defendant.
                                                                i




                                               DEFENDANT'S PRIVILEGE LOG

                   The Defendant,      UNITED PROPERTY & CASUALTY INSURANCE COMPANY, by

        and through undersigned counsel, pursuant to                  all   applicableFlorida Rules of Civil Procedure,

        hereby serves      its   PrivilegeLog in Support o f its Response to           Plaintiff' s   Request for Production

        and   Plaintiff' s First Set                    and
                                       of Interrogatories,          states as follows:


                   The Defendant possesses        a claims   file   which includes log notes,    interoffice   memorandum,

        communications between the Defendant and undersigned counsel, and various other documents


        concerningthe claim         at issue   (Claim Number: 19FL00005988). The information providedin                   this


        claims     file   was taken specificallyin anticipation of anticipated/andpending litigation.

                                     the Defendant
        Notwithstandingsaid objection,                               is   in the possessionof:



              1.   A 6-page,Loss Report & Estimate by IndependentAdjusterAli Aladin of Hancock Claims

                   Consultants which details the damages of the subjectproperty.                  The same     constitutes the




             *** FILED:   BROWARD COUNTY,         FL   BRENDA D. FORMAN, CLERK             11/11/2021 12:41:39 PM.****
     Defendant claims handling practicesas well as mental impressions as to what the


     photographsproduced and/or actuallydepict.

2.   A 2-page Claims Search Report providing details on any and all priorclaims that have been
     made    in previousyears.   The same     constitutes the   Defendant claims handling practicesas

     well as mental impressionsas to what the photographs produced and/or actuallydepict.


3.   Eleven pages of notes regarding the condition, facts of loss,claim history,correspondence


     timeline, policy information, risks, among other essential information relatingto the


     property and the    named     insured.   The same   constitutes the   Defendant claims handling


     practicesas well as mental impressions as to what the photographs produced and/or

     actuallydepict.

4.   A 3-page First Notice of Loss Report providing all information relatingto the parties.The
     same   constitutes the   Defendant claims handlingpracticesas well as mental impressionsas

     to   what the photographs produced and/or actuallydepict.

5.   A 3-page invoice for inspectionof the property by Rimkus Consulting Group, Inc. which

     provides details regarding the physical condition of the property upon inspectionand

     affected areas.   The same    constitutes the Defendant claims      handling practicesas well as

     mental impressionsas to what the photographs produced and/or actuallydepict.




                    [CERTIFICATE OF SERVICE           ON FOLLOWING PAGE]
                                  CERTIFICATE OF SERVICE
         I   HEREBY CERTIFY      that   on
                                                   th
                                             the 11I    day of November, 2021,            this   document was    filed



using the Florida Courts E-FilingPortal. This document             is   being served on       all   counsel and pro se


partiesof record by the Florida Courts E-FilingPortal,pursuant                  to   and in compliance with    Fla. R.


Jud.   Admin. 2.516. The mailing and         electronic addresses are: Jamie Alvarez, Esq., Shield               Law

                                                                15751 Sheridan Street
Group, P.A., jamie@shieldlawgp.com; legalservice@shieldlawgp.com,

#300, Davie,   FL                                 Gloria H. Oliveras and Jose Oliveras.
                    33331, Attorney for Plaintiffs,


                                                          KELLEY KRONENBERG


                                                          Isl   Jesse   J.   Feder
                                                          Jesse J. Feder, Esq.
                                                          Fla. Bar No.: 1023567

                                                         jfeder@kelleykronenberg.com
                                                         Stephanie T. Merchant, Esq.
                                                         Fla. Bar No.. 1007142

                                                          smerchant@kelleykronenberg.com
                                                          10360 West State Road 84
                                                          Fort Lauderdale, FL 33324
                                                          Telephone: (954) 370-9970
                                                          Facsimile: (954) 382-1988

                                                          Attorneys           for    United   Property    &   Casualty
                                                          Insurance          Company
                                                          Address for service of pleadingsonly:
                                                         jfeder@kelleykronenberg.com
                                                         smerchant@kelleykronenberg.com
                                                         cvalerio@kelleykronenberg.com