On March 18, 2019 a
Party Discovery
was filed
involving a dispute between
Watson, Wanda,
and
American Integrity Insurance C,
for Circuit Civil 3-D
in the District Court of Madison County.
Preview
Filing # 86569573 E-Filed 03/18/2019 04:22:28 PM
IN THE CIRCUIT COURT OF THE
THIRD JUDICIAL CIRCUIT, IN AND
FOR MADISON COUNTY, FLORIDA
CASE :
DIV. NO.:
WANDA WATSON,
Plaintiff,
vs.
AMERICAN INTEGRITY INSURANCE
COMPANY OF FLORIDA,
Defendant.
/
REQUEST TO PRODUCE
Plaintiff, WANDA WATSON, through undersigned counsel, pursuant to Florida Rule of
Civil Procedure 1.350, hereby requests Defendant, AMERICAN INTEGRITY INSURANCE
COMPANY OF FLORIDA, to produce for inspection or copying the documents set forth
below. Defendant shall produce these documents at 313 N Monroe St, Suite 401 Tallahassee, FL
32301. Pursuant to Florida Rule of Civil Procedure 1.350, Defendant shall serve a written
response or production within forty-five (45) days after service of this Request to Produce.
DEFENDANT SHALL PRODUCE THE FOLLOWING ITEMS AND MATTERS:
1. All insurance policies which would provide coverage to the Plaintiff herein, together with
any declaration of coverage page, and a sworn statement of a corporate officer of
Defendant attesting to the coverage and authenticity of the policy.
2. All documents reflecting any payment made to any person or entity for any reason as a
result of Plaintiff’s claim for property damage.
3. All transcripts of Examinations Under Oath taken regarding Plaintiff's claim for benefits.
4. Tapes and/or transcripts of all statements taken of any person regarding Plaintiffs claim
for benefits.
5. All correspondence between Plaintiff, or any representatives of Plaintiff, and any
representative of Defendant regarding Plaintiff's claim for benefits.
Electronically Filed Madison Case # 19000023CAAXMX 03/18/2019 04:22:28 PM10.
11.
12.
13.
14.
15.
16.
17.
18.
All documents which Defendant contends support any affirmative defense raised in
Defendant’s Answer in this case.
All reports from any expert retained for any reason in this claim.
A current curriculum vitae form any individual who prepared and/or signed a written
report produced in response to paragraph 7, above.
All photographs, video depiction of Plaintiff's property in the possession of the
Defendant or any agent of the Defendant.
All Proofs of Loss received by Defendant from Plaintiff or any representative of
Plaintiffs.
All estimates received by Defendant from any source for repairs to Plaintiff's structure.
All non-privileged portions of the claim files with regard to claims of Plaintiff's Complaint.
For any items withheld, please set forth the nature of the privilege or protection allowing
you to withhold the document, the date of the document, the drafter, recipient, and a
general description of the document.
Copies of any and all forms, correspondence, or reports received by you or any of your
agents on your behalf concerning the Plaintiff's losses from anyone.
Any and all statements taken by the Defendant of any witnesses with regard to any fact
relevant to any fact in this case, such as were taken prior to the filing of suit in this
matter.
Any and all photographs in the Defendant’s possession related to Plaintiff's claim in their
native digital format.
Copies of all IRS Forms 1099 from Defendant to any roof consultants who examined
Plaintiff's roof (whether engineers, contractors or roofers) for past 5 years for the
evaluation of claims submitted to Defendant by Defendant’s insureds.
All reports in your possession that support Defendant’s contention that any of Plaintiffs
charges are not covered or proper.
The complete underwriting file with regard to Defendant’s issuance of insurance on the
subject risk, and all renewals.I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
to the Defendant along with the Summons and Complaint.
MORGAN & MORGAN
/s/ Robert L. Ehrhardt
ROBERT L EHRHARDT, ESQUIRE
FBN: 0010381
313 N Monroe St, Suite 401
Tallahassee, FL 32301
Primary email: rehrhardt@forthepeople.com
Secondary: blockwood@forthepeople.com
Telephone: (850) 201-2447
Fax: (850) 201-2775
Attorney for Plaintiff
Document Filed Date
March 18, 2019
Case Filing Date
March 18, 2019
Category
Circuit Civil 3-D
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Filing # 86569573 E-Filed 03/18/2019 04:22:28 PM IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT, IN AND FOR MADISON COUNTY, FLORIDA CASE : DIV. NO.: WANDA WATSON, Plaintiff, vs. AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA, Defendant. / REQUEST TO PRODUCE Plaintiff, WANDA WATSON, through undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Defendant, AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA, to produce for inspection or copying the documents set forth below. Defendant shall produce these documents at 313 N Monroe St, Suite 401 Tallahassee, FL 32301. Pursuant to Florida Rule of Civil Procedure 1.350, Defendant shall serve a written response or production within forty-five (45) days after service of this Request to Produce. DEFENDANT SHALL PRODUCE THE FOLLOWING ITEMS AND MATTERS: 1. All insurance policies which would provide coverage to the Plaintiff herein, together with any declaration of coverage page, and a sworn statement of a corporate officer of Defendant attesting to the coverage and authenticity of the policy. 2. All documents reflecting any payment made to any person or entity for any reason as a result of Plaintiff’s claim for property damage. 3. All transcripts of Examinations Under Oath taken regarding Plaintiff's claim for benefits. 4. Tapes and/or transcripts of all statements taken of any person regarding Plaintiffs claim for benefits. 5. All correspondence between Plaintiff, or any representatives of Plaintiff, and any representative of Defendant regarding Plaintiff's claim for benefits. Electronically Filed Madison Case # 19000023CAAXMX 03/18/2019 04:22:28 PM10. 11. 12. 13. 14. 15. 16. 17. 18. All documents which Defendant contends support any affirmative defense raised in Defendant’s Answer in this case. All reports from any expert retained for any reason in this claim. A current curriculum vitae form any individual who prepared and/or signed a written report produced in response to paragraph 7, above. All photographs, video depiction of Plaintiff's property in the possession of the Defendant or any agent of the Defendant. All Proofs of Loss received by Defendant from Plaintiff or any representative of Plaintiffs. All estimates received by Defendant from any source for repairs to Plaintiff's structure. All non-privileged portions of the claim files with regard to claims of Plaintiff's Complaint. For any items withheld, please set forth the nature of the privilege or protection allowing you to withhold the document, the date of the document, the drafter, recipient, and a general description of the document. Copies of any and all forms, correspondence, or reports received by you or any of your agents on your behalf concerning the Plaintiff's losses from anyone. Any and all statements taken by the Defendant of any witnesses with regard to any fact relevant to any fact in this case, such as were taken prior to the filing of suit in this matter. Any and all photographs in the Defendant’s possession related to Plaintiff's claim in their native digital format. Copies of all IRS Forms 1099 from Defendant to any roof consultants who examined Plaintiff's roof (whether engineers, contractors or roofers) for past 5 years for the evaluation of claims submitted to Defendant by Defendant’s insureds. All reports in your possession that support Defendant’s contention that any of Plaintiffs charges are not covered or proper. The complete underwriting file with regard to Defendant’s issuance of insurance on the subject risk, and all renewals.I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the Defendant along with the Summons and Complaint. MORGAN & MORGAN /s/ Robert L. Ehrhardt ROBERT L EHRHARDT, ESQUIRE FBN: 0010381 313 N Monroe St, Suite 401 Tallahassee, FL 32301 Primary email: rehrhardt@forthepeople.com Secondary: blockwood@forthepeople.com Telephone: (850) 201-2447 Fax: (850) 201-2775 Attorney for Plaintiff