Preview
Filing # 148345117 E-Filed 04/25/2022 04:53:35 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
MARIE PIERRE, CASE NO.: 2021-020636-CA-01
Plaintiff,
vs.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
_______________________________________/
NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by
and through undersigned counsel, propounds the attached Interrogatories to Plaintiff, MARIE
PIERRE to be answered under oath within thirty (30) days from receipt hereof in accordance with
the applicable Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
Service to: William J. Roe, Esq., Nirav A. Desai, Esq., LAW OFFICE OF WILLIAM J. ROE,
P.A. (wjroe@wjroelaw.com; ndesai@wjroelaw.com; info@wjroelaw.com) on this 25th day of
April 2022.
Attorneys for Defendant
Universal Property & Casualty Ins. Co.
Post Office Box 9388
Fort Lauderdale, Florida 33310
Telephone: 954-958-3319
Toll-Free: 1-833-658-8594 (Judges Only)
Facsimile: 954-958-1262
By: /s/ Ricardo Clerge-Apollon
Ricardo Clerge-Apollon, Esq.
Florida Bar No. 119731
For Service of Court Documents only:
Primary: upciceservice03@universalproperty.com
Secondary: jz0807@universalproperty.com
Tertiary: rc0921@universalproperty.com
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 2 of 7
DEFENDANT’S INTERROGATORIES TO PLAINTIFF
In accordance with Rule 1.340(e) of the Fla. R. Civ. P., sufficient space has been provided
after each interrogatory for the answer to be inserted. However, if more space is needed,
you should append the answer to the interrogatory, making reference to such attachment in
the space provided for the answer. The Rule does not provide for placing all the answers on
a single, separate page.
1. Please state the name and address of the person answering these Interrogatories and the
name and address of any person assisting in preparing responses to these Interrogatories.
ANSWER:
2. Please state all facts upon which you base the contention that the damage(s) sustained to
the Plaintiff’s property is covered under the subject insurance policy.
ANSWER:
3. Please state the name and address of all persons who are believed or known by you, your
agents or your attorneys to have any knowledge concerning any issues in this lawsuit;
please specify the subject matter about which each witness has knowledge.
ANSWER:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 3 of 7
4. Please state the name and address of every person known to you, your agents or your
attorneys, who have knowledge about or possession, custody or control of any model, plat,
map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue
involved in this controversy; please describe as each what items such individual(s) have,
the name and address of the party who took or prepared itand the date itwas taken or
prepared.
ANSWER:
5. Please state the name and address of every individual who has conducted an investigation,
adjustment or evaluation of the Plaintiff’s residence to determine the cause of the alleged
damage to which Plaintiff is seeking insurance coverage.
ANSWER:
6. Please state each item of damage to the dwelling, contents or for additional living expenses
that you are claiming and/or other damages that you are claiming and provide an
explanation for the computation of each item of damage.
ANSWER:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 4 of 7
7. Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other
than the present matter and, if so, please state whether you were plaintiff or defendant, the
nature of the action and the date and court in which suit was filed.
ANSWER:
8. Please indicate whether you have filed any insurance claims in the last ten years prior to
the claim allegedly occurring on May 10, 2020, or any claims subsequent to the
aforementioned date. If so, please identify the nature of the claim, the insurer and the date
of the claim.
ANSWER:
9. Please indicate if the dwelling, contents, additional living expenses, etc. with respect to
18130 NW 9th Ave., Miami, FL 33169 were insured by you pursuant to any other insurance
policies prior to the issuance of the Universal policy at issue. If so, please name the
insurance carrier and the applicable policy periods.
ANSWER:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 5 of 7
10. Please identify the initial date and time that the alleged damage claimed in the lawsuit
occurred to the property located at 18130 NW 9th Ave., Miami, FL 33169 and the nature
of the damage.
ANSWER:
11. Please list all damages discovered on the date referenced in Interrogatory 10 and identify
the individual that discovered the damage.
ANSWER:
12. Please identify any and all repairs made to the areas of the home located at 18130 NW 9th
Ave., Miami, FL 33169 you are claiming were damaged, within five (5) years prior to the
loss at issue or anytime subsequent to the claim at issue, as well as the nature of the repair(s)
and the party making the repair.
ANSWER:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 6 of 7
13. Please state any and all actions taken by you or anyone on your behalf to protect the
alleged damaged property from further damage.
ANSWER:
14. Please identify all persons/companies that inspected and/or appraised the property located
at 18130 NW 9th Ave., Miami, FL 33169 at the time of or prior to your purchase of the
property.
ANSWER:
15. Please state the date the property located at 18130 NW 9th Ave., Miami, FL 33169 was
purchased as well as the purchase price and the name of the seller of the property.
ANSWER:
16. Within the year prior to the loss, had you considered renovating the property that was
damaged? If so, describe the intended renovations and list the names and addresses of any
persons, contractors, or entities that were contacted, interviewed, or otherwise asked to
prepare a proposal or bid for the renovation.
ANSWER:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 7 of 7
___________________________________
MARIE PIERRE
STATE OF FLORIDA )
S.S.)
COUNTY OF ___________ )
BEFORE ME, the foregoing instrument was acknowledged by MARIE PIERRE who is
personally known to me or has produced identification in the form of ________________ and who
executed the foregoing instrument for the purposes therein expressed.
IN WITNESS WHEREOF, I have hereto set my hand and official seal this _____ day of
__________________, 2022.
____________________________________
Signature of Notary Public
Name of Notary Typed, Printed or Stamped
Commission Number
Preview
Filing # 148345117 E-Filed 04/25/2022 04:53:35 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA MARIE PIERRE, CASE NO.: 2021-020636-CA-01 Plaintiff, vs. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. _______________________________________/ NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by and through undersigned counsel, propounds the attached Interrogatories to Plaintiff, MARIE PIERRE to be answered under oath within thirty (30) days from receipt hereof in accordance with the applicable Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- Service to: William J. Roe, Esq., Nirav A. Desai, Esq., LAW OFFICE OF WILLIAM J. ROE, P.A. (wjroe@wjroelaw.com; ndesai@wjroelaw.com; info@wjroelaw.com) on this 25th day of April 2022. Attorneys for Defendant Universal Property & Casualty Ins. Co. Post Office Box 9388 Fort Lauderdale, Florida 33310 Telephone: 954-958-3319 Toll-Free: 1-833-658-8594 (Judges Only) Facsimile: 954-958-1262 By: /s/ Ricardo Clerge-Apollon Ricardo Clerge-Apollon, Esq. Florida Bar No. 119731 For Service of Court Documents only: Primary: upciceservice03@universalproperty.com Secondary: jz0807@universalproperty.com Tertiary: rc0921@universalproperty.com Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 2 of 7 DEFENDANT’S INTERROGATORIES TO PLAINTIFF In accordance with Rule 1.340(e) of the Fla. R. Civ. P., sufficient space has been provided after each interrogatory for the answer to be inserted. However, if more space is needed, you should append the answer to the interrogatory, making reference to such attachment in the space provided for the answer. The Rule does not provide for placing all the answers on a single, separate page. 1. Please state the name and address of the person answering these Interrogatories and the name and address of any person assisting in preparing responses to these Interrogatories. ANSWER: 2. Please state all facts upon which you base the contention that the damage(s) sustained to the Plaintiff’s property is covered under the subject insurance policy. ANSWER: 3. Please state the name and address of all persons who are believed or known by you, your agents or your attorneys to have any knowledge concerning any issues in this lawsuit; please specify the subject matter about which each witness has knowledge. ANSWER: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 3 of 7 4. Please state the name and address of every person known to you, your agents or your attorneys, who have knowledge about or possession, custody or control of any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this controversy; please describe as each what items such individual(s) have, the name and address of the party who took or prepared itand the date itwas taken or prepared. ANSWER: 5. Please state the name and address of every individual who has conducted an investigation, adjustment or evaluation of the Plaintiff’s residence to determine the cause of the alleged damage to which Plaintiff is seeking insurance coverage. ANSWER: 6. Please state each item of damage to the dwelling, contents or for additional living expenses that you are claiming and/or other damages that you are claiming and provide an explanation for the computation of each item of damage. ANSWER: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 4 of 7 7. Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other than the present matter and, if so, please state whether you were plaintiff or defendant, the nature of the action and the date and court in which suit was filed. ANSWER: 8. Please indicate whether you have filed any insurance claims in the last ten years prior to the claim allegedly occurring on May 10, 2020, or any claims subsequent to the aforementioned date. If so, please identify the nature of the claim, the insurer and the date of the claim. ANSWER: 9. Please indicate if the dwelling, contents, additional living expenses, etc. with respect to 18130 NW 9th Ave., Miami, FL 33169 were insured by you pursuant to any other insurance policies prior to the issuance of the Universal policy at issue. If so, please name the insurance carrier and the applicable policy periods. ANSWER: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 5 of 7 10. Please identify the initial date and time that the alleged damage claimed in the lawsuit occurred to the property located at 18130 NW 9th Ave., Miami, FL 33169 and the nature of the damage. ANSWER: 11. Please list all damages discovered on the date referenced in Interrogatory 10 and identify the individual that discovered the damage. ANSWER: 12. Please identify any and all repairs made to the areas of the home located at 18130 NW 9th Ave., Miami, FL 33169 you are claiming were damaged, within five (5) years prior to the loss at issue or anytime subsequent to the claim at issue, as well as the nature of the repair(s) and the party making the repair. ANSWER: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 6 of 7 13. Please state any and all actions taken by you or anyone on your behalf to protect the alleged damaged property from further damage. ANSWER: 14. Please identify all persons/companies that inspected and/or appraised the property located at 18130 NW 9th Ave., Miami, FL 33169 at the time of or prior to your purchase of the property. ANSWER: 15. Please state the date the property located at 18130 NW 9th Ave., Miami, FL 33169 was purchased as well as the purchase price and the name of the seller of the property. ANSWER: 16. Within the year prior to the loss, had you considered renovating the property that was damaged? If so, describe the intended renovations and list the names and addresses of any persons, contractors, or entities that were contacted, interviewed, or otherwise asked to prepare a proposal or bid for the renovation. ANSWER: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 7 of 7 ___________________________________ MARIE PIERRE STATE OF FLORIDA ) S.S.) COUNTY OF ___________ ) BEFORE ME, the foregoing instrument was acknowledged by MARIE PIERRE who is personally known to me or has produced identification in the form of ________________ and who executed the foregoing instrument for the purposes therein expressed. IN WITNESS WHEREOF, I have hereto set my hand and official seal this _____ day of __________________, 2022. ____________________________________ Signature of Notary Public Name of Notary Typed, Printed or Stamped Commission Number