Preview
Filing# 139479315 E-Filed 12/01/2021 02:52:03 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIALCIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
NEIL ESPENDEZ, CASE NO.: CACE-21-011840
Plaintiff
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
("Universal"),through counsel and pursuant to Rule 1.350 of the Florida Rules of Civil 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 requestedwithin thirty(30) days.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANKI
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/01/2021 02:52:02 PM.****
Neil Espendez v. UPCIC
Case No.: CACE-19-015763 (04)
Page 2
DEFINITIONS
1. "Calendar Year" means that period oftime that begins at 12:01 a.m. on January 1 of any
given year and ends at 11:59 pm. on December 31 ofthat year.
2. "Claim" means the insurance claim that Plaintiff (asdefined herein)reportedto Defendant
(as defined herein)and that serves as a basis for any causes of action asserted againstDefendant
in this action.
3. "Claimed Cause of Loss" means the event and/or reason that You (asdefined herein)are
claimingthat the Insured Property (asdefined herein)was damaged.
4. "Concerning", "concern," or any other derivative thereof as used herein, shall be
construed as referringto, responding to, relatingto, pertainingto, connected with, comprising,
memorializing, commenting on, substantiating,
regarding, discussing,showing, describing,
reflecting,
analyzing,and constituting.
5. "Control" means having possession of and/or the power and/or authorityto request
possession of the subjectmatter or a copy thereof,or direct the possession,movement, transfer or
other disposition of the subjectproperty or document.
6. "Date" means the exact date (including
day,month, and year).Ifthe exact day, month, and
year is then the best available approximationof the exact day,month, and year.
not ascertainable,
7. "Defendant" means Universal Property & Casualty Insurance Company.
8."Document" or"documents" means anythingwhich may be considered to be a document or
tangiblethingwithin 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 but not limited to,
(including,
interoffice and intra-office
communications), questionnaires, surveys, contracts, memoranda of
agreements, assignments, books of account, journals,ledgers,summaries, opinions,reports,
evaluations,financial statements and all records of or reflectingbusiness operations,mortgages,
evaluations,orders,working papers, bills of lading,sh*ping lists,load sheets,warehouse receipts,
letters of credit, records of summaries of personalinterviews or conversations,
insurance policies,
appointment calendars, diaries,schedules, printouts,drawings, specifications,
patents, patent
applications,certificates of registration, for registration,
applications 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,
photographicnegatives,audio tape, video tape, compact disks,blueprints, architectural
specifications,
diagrams, schematics, logic diagrams, timing diagrams, pictures,photographs,microscopically
obtained photographs,
test results,
belts,tapes, magnetictapes, paper tapes, plotter
output recordings,
Neil Espendez v. UPCIC
Case No.: CACE-19-015763 (04)
Page 3
discs,data cards,films,data processingfiles, computer files and other computer readable records or
programs and all other written,printedor recorded matter of any kind, and all other data compilations
from which information can be obtained, and translated,if necessary, and all originals, drafts and
copiesthereof. Any documents bearing any marks including,but not limited to, initials, stamped
indicia,comments, or o f
notations, any kind that are not a part o f the text
original 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 listed on the declarations page of
specifically
the Policy(as defined herein).
11. "Other Structures" means any structures located at the Insured Property that are set apart
from and/or not connected to the Dwelling including,but not limited to, those structures connected
line,and/or similar connection.
only by a fence,utility
12. "Person" or "Persons" shall mean any natural person
or any legalentity including,but not
limited to, a corporation,partnersh* and unincorporated association, firm, joint venture,
proprietorsh*,and/or any other entityor group ofnatural persons or such entities,
singularor plural,
male, female, or neuter gender,as the context and
may require, any officer.
13. "Plaintiff" means any person and/or entitynamed as a in
plaintiff this action.
14."Policy"means the insurance policythat serves as a basis for any causes of action asserted
againstDefendant in this lawsuit.
15. "Related to", "relatingto", and "relate to" shall include
pertaining to, relevant
to, referring
to, supporting, mentioning,evidencing,discussingor otherwise involving,
contradicting, whether
or the
directly indirectly, subjectmatter ofthe specified
request.
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,regardlessof when the statement was made, and is either (i)a written statement
signed or otherwise adopted and/or approved in writingby the person making it;or, (ii)a
stenographic, and/or other type of recording of a person's oral statement
mechanical, electrical,
and/or any substantially of such recording.
verbatim transcript
19. "You" or "Your" means the specific party responding to these requests and/or any person
and/or entitynamed as a Plaintiff in this action.
Neil Espendez v. UPCIC
Case No.: CACE-19-015763 (04)
Page 4
20. "Your Counsel" means the attorney or attorneys who are representingor have represented
you either with regardto the claim or in this lawsuit.
PRODUCTION REQUESTS
1. Copies of all reports, drafts,charts,drawings,diagrams,memoranda, and/or testingresults
thatshow and/or intend to show the cause for the allegeddamage to the Insured Property
in connection with the Claim.
2. Copies of all documents evidencingthe type of windows installed at the Insured Property.
3. Copies of all documents evidencingthe 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 concerningand/or
relatingto the Insured Property from the Date that You purchased the Insured Property to
the Date o f the Claimed Cause o f Loss.
6. Copies of all mold reports, lab results,and/or mold remediation reports concerningand/or
to the Insured Property from the Date o f the Claimed Cause o f Loss to the Date o f
relating
responding to these productionrequests.
7. Copies of all documents evidencing damages that You are claiming for personal property
as a result o f the Claimed Cause o f Loss.
8. Copies of all documents evidencingdamages that You are claimingfor additional living
expenses as a result ofthe Claimed Cause of Loss.
9. Copies of any documents evidencingdamages that You are claiming for loss of use of the
Insured Property as a result ofthe Claimed Cause of Loss.
10. Copies of all repairestimates,contracts, and invoices related to the allegeddamages to the
Insured Property as a result ofthe Claimed Cause of Loss.
11. Copies of all photographs and/or video taken of any alleged damages to the Insured
Property as a result ofthe 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 o f the Claimed Cause o f Loss.
Neil Espendez v. UPCIC
Case No.: CACE-19-015763 (04)
Page 5
14. Copies of all documents pertainingto all insurance claims (otherthan this Claim) that You
made and/or filed concerning and/or relating to the Insured Property from the Date of the
Claimed Cause of Loss to the Date of responding to these production requests.
15. Copies of all correspondencesand/or documents that You sent to Universal with regard to
the Claim priorto the initiation o f this action.
16. Copies of any and all correspondences and/or documents exchanged between You and any
third party regardingthe damages to the Insured Property as a result of the Claimed Cause
of Loss, including,but not limited to, correspondences and/or documents exchanged
between You 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 publicadjusterthat You retained in connection with this action.
19. A copy of the retainer agreement and/or other agreement for compensation between You
and any generalcontractor 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 mitigationservices 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 testingindividual 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 o f 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 and/or documents exchanged between Plaintiff and any
public adjuster;general contractor; mold testingindividual and/or company; mold
remediation individual and/or company; emergency mitigationservices individual and/or
company; and/or, expert witness retained to inspect,examine, survey, and/or perform
services at the Insured Property from the Date ofthe Claimed Cause of Loss to the Date of
responding to these productionrequests.
25. Copies of all correspondence and/or documents exchanged between You and any person
Neil Espendez v. UPCIC
Case No.: CACE-19-015763 (04)
Page 6
the cause ofthe 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 prior to the Date that You
purchased the Insured Property.
27. Copies of all inspections,
estimates,appraisals, due diligence
reports, and/or investigation
records concerning and/or relatingto the Insured Property from the Date that You
purchased the Insured Property to the Date ofthe Claimed Cause of Loss.
28. Copies of all inspections,
estimates,appraisals,due diligencereports, and/or investigation
records concerningand/or relating to the Insured Property from the Date of the Claimed
Cause of Loss to the Date of respondingto these productionrequests.
29. Copies of any permits, permit applications,architectural drawings and/or renderings,
engineeringreports, contracts, change orders,invoices, status updates, and evidence of
payment for any repairsand/or renovations to the Insured Property from the Date that You
purchasedthe Insured Property to the Date ofthe Claimed Cause of Loss.
30. Copies of any permits, permit applications,architectural drawings and/or renderings,
engineering reports, contracts, change orders, invoices, status updates, and evidence of
payment for any repairsand/or renovations to the Insured Property from the Date of the
Claimed Cause of Loss to the Date of responding to these productionrequests.
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 o f the Claimed Cause o f Loss that have not alreadybeen
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, includingcorrespondences,sent by You or Your
representatives com.
to Universal at claimshelp@universalproperty.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANKI
Neil Espendez v. UPCIC
Case No.: CACE-19-015763 (04)
Page 7
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
EService to: John A. Salcedo., Esq., The Mineo Salcedo Law Firm, P.A.,
(Service@mineolaw.com) on the 1st day of December, 2021.
AttorneyMDefendant
Universal Property & CasualtyIns. Co.
PO Box 9388
Fort Lauderdale, Florida 33310
Telephone: 954-958-3319
Toll-Free: 1-833-658-8594 (JudgesOnlyl
Facsimile: 954-958-1262
By: Omar J. Perez
/s/
Omar J. Perez, Esq.
Florida Bar No. 1010823
For Service of Court Documents onlv:
Primary upciceserviceO1@universalproperty.com
Secondary: kv0921@universalproperty.com
Tertiary:
op1215@universalproperty.com
For Scheduling Matters:
er0810@universalproperty.com
Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com
or upciceservice01@universalpropertv.com.
Preview
Filing# 139479315 E-Filed 12/01/2021 02:52:03 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIALCIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA NEIL ESPENDEZ, CASE NO.: CACE-21-011840 Plaintiff VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY ("Universal"),through counsel and pursuant to Rule 1.350 of the Florida Rules of Civil 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 requestedwithin thirty(30) days. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANKI *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/01/2021 02:52:02 PM.**** Neil Espendez v. UPCIC Case No.: CACE-19-015763 (04) Page 2 DEFINITIONS 1. "Calendar Year" means that period oftime that begins at 12:01 a.m. on January 1 of any given year and ends at 11:59 pm. on December 31 ofthat year. 2. "Claim" means the insurance claim that Plaintiff (asdefined herein)reportedto Defendant (as defined herein)and that serves as a basis for any causes of action asserted againstDefendant in this action. 3. "Claimed Cause of Loss" means the event and/or reason that You (asdefined herein)are claimingthat the Insured Property (asdefined herein)was damaged. 4. "Concerning", "concern," or any other derivative thereof as used herein, shall be construed as referringto, responding to, relatingto, pertainingto, connected with, comprising, memorializing, commenting on, substantiating, regarding, discussing,showing, describing, reflecting, analyzing,and constituting. 5. "Control" means having possession of and/or the power and/or authorityto request possession of the subjectmatter or a copy thereof,or direct the possession,movement, transfer or other disposition of the subjectproperty or document. 6. "Date" means the exact date (including day,month, and year).Ifthe exact day, month, and year is then the best available approximationof the exact day,month, and year. not ascertainable, 7. "Defendant" means Universal Property & Casualty Insurance Company. 8."Document" or"documents" means anythingwhich may be considered to be a document or tangiblethingwithin 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 but not limited to, (including, interoffice and intra-office communications), questionnaires, surveys, contracts, memoranda of agreements, assignments, books of account, journals,ledgers,summaries, opinions,reports, evaluations,financial statements and all records of or reflectingbusiness operations,mortgages, evaluations,orders,working papers, bills of lading,sh*ping lists,load sheets,warehouse receipts, letters of credit, records of summaries of personalinterviews or conversations, insurance policies, appointment calendars, diaries,schedules, printouts,drawings, specifications, patents, patent applications,certificates of registration, for registration, applications 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, photographicnegatives,audio tape, video tape, compact disks,blueprints, architectural specifications, diagrams, schematics, logic diagrams, timing diagrams, pictures,photographs,microscopically obtained photographs, test results, belts,tapes, magnetictapes, paper tapes, plotter output recordings, Neil Espendez v. UPCIC Case No.: CACE-19-015763 (04) Page 3 discs,data cards,films,data processingfiles, computer files and other computer readable records or programs and all other written,printedor recorded matter of any kind, and all other data compilations from which information can be obtained, and translated,if necessary, and all originals, drafts and copiesthereof. Any documents bearing any marks including,but not limited to, initials, stamped indicia,comments, or o f notations, any kind that are not a part o f the text original 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 listed on the declarations page of specifically the Policy(as defined herein). 11. "Other Structures" means any structures located at the Insured Property that are set apart from and/or not connected to the Dwelling including,but not limited to, those structures connected line,and/or similar connection. only by a fence,utility 12. "Person" or "Persons" shall mean any natural person or any legalentity including,but not limited to, a corporation,partnersh* and unincorporated association, firm, joint venture, proprietorsh*,and/or any other entityor group ofnatural persons or such entities, singularor plural, male, female, or neuter gender,as the context and may require, any officer. 13. "Plaintiff" means any person and/or entitynamed as a in plaintiff this action. 14."Policy"means the insurance policythat serves as a basis for any causes of action asserted againstDefendant in this lawsuit. 15. "Related to", "relatingto", and "relate to" shall include pertaining to, relevant to, referring to, supporting, mentioning,evidencing,discussingor otherwise involving, contradicting, whether or the directly indirectly, subjectmatter ofthe specified request. 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,regardlessof when the statement was made, and is either (i)a written statement signed or otherwise adopted and/or approved in writingby the person making it;or, (ii)a stenographic, and/or other type of recording of a person's oral statement mechanical, electrical, and/or any substantially of such recording. verbatim transcript 19. "You" or "Your" means the specific party responding to these requests and/or any person and/or entitynamed as a Plaintiff in this action. Neil Espendez v. UPCIC Case No.: CACE-19-015763 (04) Page 4 20. "Your Counsel" means the attorney or attorneys who are representingor have represented you either with regardto the claim or in this lawsuit. PRODUCTION REQUESTS 1. Copies of all reports, drafts,charts,drawings,diagrams,memoranda, and/or testingresults thatshow and/or intend to show the cause for the allegeddamage to the Insured Property in connection with the Claim. 2. Copies of all documents evidencingthe type of windows installed at the Insured Property. 3. Copies of all documents evidencingthe 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 concerningand/or relatingto the Insured Property from the Date that You purchased the Insured Property to the Date o f the Claimed Cause o f Loss. 6. Copies of all mold reports, lab results,and/or mold remediation reports concerningand/or to the Insured Property from the Date o f the Claimed Cause o f Loss to the Date o f relating responding to these productionrequests. 7. Copies of all documents evidencing damages that You are claiming for personal property as a result o f the Claimed Cause o f Loss. 8. Copies of all documents evidencingdamages that You are claimingfor additional living expenses as a result ofthe Claimed Cause of Loss. 9. Copies of any documents evidencingdamages that You are claiming for loss of use of the Insured Property as a result ofthe Claimed Cause of Loss. 10. Copies of all repairestimates,contracts, and invoices related to the allegeddamages to the Insured Property as a result ofthe Claimed Cause of Loss. 11. Copies of all photographs and/or video taken of any alleged damages to the Insured Property as a result ofthe 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 o f the Claimed Cause o f Loss. Neil Espendez v. UPCIC Case No.: CACE-19-015763 (04) Page 5 14. Copies of all documents pertainingto all insurance claims (otherthan this Claim) that You made and/or filed concerning and/or relating to the Insured Property from the Date of the Claimed Cause of Loss to the Date of responding to these production requests. 15. Copies of all correspondencesand/or documents that You sent to Universal with regard to the Claim priorto the initiation o f this action. 16. Copies of any and all correspondences and/or documents exchanged between You and any third party regardingthe damages to the Insured Property as a result of the Claimed Cause of Loss, including,but not limited to, correspondences and/or documents exchanged between You 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 publicadjusterthat You retained in connection with this action. 19. A copy of the retainer agreement and/or other agreement for compensation between You and any generalcontractor 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 mitigationservices 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 testingindividual 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 o f 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 and/or documents exchanged between Plaintiff and any public adjuster;general contractor; mold testingindividual and/or company; mold remediation individual and/or company; emergency mitigationservices individual and/or company; and/or, expert witness retained to inspect,examine, survey, and/or perform services at the Insured Property from the Date ofthe Claimed Cause of Loss to the Date of responding to these productionrequests. 25. Copies of all correspondence and/or documents exchanged between You and any person Neil Espendez v. UPCIC Case No.: CACE-19-015763 (04) Page 6 the cause ofthe 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 prior to the Date that You purchased the Insured Property. 27. Copies of all inspections, estimates,appraisals, due diligence reports, and/or investigation records concerning and/or relatingto the Insured Property from the Date that You purchased the Insured Property to the Date ofthe Claimed Cause of Loss. 28. Copies of all inspections, estimates,appraisals,due diligencereports, and/or investigation records concerningand/or relating to the Insured Property from the Date of the Claimed Cause of Loss to the Date of respondingto these productionrequests. 29. Copies of any permits, permit applications,architectural drawings and/or renderings, engineeringreports, contracts, change orders,invoices, status updates, and evidence of payment for any repairsand/or renovations to the Insured Property from the Date that You purchasedthe Insured Property to the Date ofthe Claimed Cause of Loss. 30. Copies of any permits, permit applications,architectural drawings and/or renderings, engineering reports, contracts, change orders, invoices, status updates, and evidence of payment for any repairsand/or renovations to the Insured Property from the Date of the Claimed Cause of Loss to the Date of responding to these productionrequests. 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 o f the Claimed Cause o f Loss that have not alreadybeen 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, includingcorrespondences,sent by You or Your representatives com. to Universal at claimshelp@universalproperty. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANKI Neil Espendez v. UPCIC Case No.: CACE-19-015763 (04) Page 7 I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via EService to: John A. Salcedo., Esq., The Mineo Salcedo Law Firm, P.A., (Service@mineolaw.com) on the 1st day of December, 2021. AttorneyMDefendant Universal Property & CasualtyIns. Co. PO Box 9388 Fort Lauderdale, Florida 33310 Telephone: 954-958-3319 Toll-Free: 1-833-658-8594 (JudgesOnlyl Facsimile: 954-958-1262 By: Omar J. Perez /s/ Omar J. Perez, Esq. Florida Bar No. 1010823 For Service of Court Documents onlv: Primary upciceserviceO1@universalproperty.com Secondary: kv0921@universalproperty.com Tertiary: op1215@universalproperty.com For Scheduling Matters: er0810@universalproperty.com Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com or upciceservice01@universalpropertv.com.