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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,
Plaintiff, CASE NO.: 2021-020636-CA-01
vs.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
_______________________________________/
DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFF
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by
and through undersigned counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, request
Plaintiff, MARIE PIERRE to produce for inspection, copying or photographing, within thirty (30)
days, the following documents:
1. Copies of any and all reports, drafts, charts, drawings, diagrams, and memoranda and/or
results of any testing showing or intending to show the cause of damage to Plaintiff’s
property.
RESPONSE:
2. Copies of any and all repair estimates, contracts, invoices, etc. with respect to the damages
to Plaintiff’s home as claimed in the Complaint.
RESPONSE:
3. Copies of any and all photographs or videotape taken of Plaintiff’s home with regard to
any inspection or testing performed by an expert or representative of the Plaintiff after the
date of loss as referenced in the Complaint.
RESPONSE:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 2 of 6
4. Copies of any and all correspondence between Plaintiff and Defendant with regard to this
claim.
RESPONSE:
5. Copies of any documents which support any claim for damages to the home located at
property address or pursuant to the Policy set forth in this matter.
RESPONSE:
6. Copies of any and all correspondence between Plaintiff or his attorneys and any experts
retained to inspect, examine or survey the property to render an opinion as to the cause of
the damage.
RESPONSE:
7. Copies of any and all photographs or videotape showing the damage which is being
claimed in the Complaint and pursuant to the Policy.
RESPONSE:
8. Copies of any and all correspondence between the Plaintiff and any public adjuster
regarding this claim.
RESPONSE:
9. Copies of any and all documents, correspondence, etc., between Plaintiff and any other
party regarding the damages claimed, including any and all State and Federal agencies,
programs or departments.
RESPONSE:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 3 of 6
10. Copies of any and all photographs and videotape taken of Plaintiff’s home for the five years
prior to the date of loss.
RESPONSE:
11. Copies of any and all photographs or videotape taken of the property on or subsequent to
the alleged date of loss in the Complaint. Please provide all photos or videos in
electronic/digital format.
RESPONSE:
12. Copies of any and all photographs or videotape taken of the area(s) of the interior of the
home to which you are claiming damages in this Complaint. Please provide all photos or
videos in electronic/digital format.
RESPONSE:
13. Copies of any and all invoices, cancelled checks or other evidence of payment for repairs,
remodels or renovations made to the property relative to the Loss alleged in the Complaint.
RESPONSE:
14. Copies of any and all invoices, receipts, documents or other proofs of payment for repairs
or renovations made to the home for the five years prior to the date of loss as referenced in
the Complaint.
RESPONSE:
15. Copies of any and all water bills from May 10, 2019, through November 10, 2020.
RESPONSE:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 4 of 6
16. Copies of any and all documents pertaining to any and all insurance claims filed with
respect to the home for ten years prior to the date of loss.
RESPONSE:
17. Copies of any and all inspections, appraisals or other investigations for the property prior
to the date of purchase.
RESPONSE:
18. Copies of any and all rules or regulation violations, notices or correspondence issued by
any homeowners or condominium association regarding the property for the three (3) year
period prior to the date of loss.
RESPONSE:
19. Copies of any and all rules or regulation violations, notices or correspondence issued by
any homeowners or condominium association regarding the property subsequent to the
date of loss.
RESPONSE:
20. Copies of any and all ordinance or code violations, notices or correspondence issued by
any city/county municipality regarding the property for the three (3) year period prior to
the date of loss.
RESPONSE:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 5 of 6
21. Copies of any and all ordinance or code violations, notices or correspondence issued by
any city/county municipality regarding the property subsequent to the date of loss.
RESPONSE:
22. Any and all documents including, but not limited to, receipts, invoices, credit card
statements, cancelled checks, bank statements and/or photographs evidencing original cost
of the items Plaintiff alleges was damaged as a result of the loss described in the Complaint.
RESPONSE:
23. Any and all documents including, but not limited to, receipts, invoices, credit card
statements, cancelled checks, bank statements and/or photographs of the items Plaintiff
purchased to replace any items Plaintiff alleges was damaged as a result of the loss
described in the Complaint.
RESPONSE:
24. Any and all documents regarding the sale of the subject property including, but not limited
to, all contracts between you and any realtor for the sale of the subject property, all
photographs of the property in your possession used for the sale or listing of the subject
property for sale, all comparables for your subject property, all disclosure forms pertaining
to the subject property including the Seller’s Disclosure Statement, the residential realtor
report for the subject property, and any contracts for the sale of the subject property.
RESPONSE:
Marie Pierre vs. UPCIC
Case No.: 2021-020636-CA-01
Page 6 of 6
25. Any and all documents which Plaintiff(s), and/or their agents, provided to Universal
Property & Casualty Insurance Company, via claimshelp@universalproperty.com, during
the claims process up to the time Plaintiff(s) filed their lawsuit.
RESPONSE:
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
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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, Plaintiff, CASE NO.: 2021-020636-CA-01 vs. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. _______________________________________/ DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFF Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by and through undersigned counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, request Plaintiff, MARIE PIERRE to produce for inspection, copying or photographing, within thirty (30) days, the following documents: 1. Copies of any and all reports, drafts, charts, drawings, diagrams, and memoranda and/or results of any testing showing or intending to show the cause of damage to Plaintiff’s property. RESPONSE: 2. Copies of any and all repair estimates, contracts, invoices, etc. with respect to the damages to Plaintiff’s home as claimed in the Complaint. RESPONSE: 3. Copies of any and all photographs or videotape taken of Plaintiff’s home with regard to any inspection or testing performed by an expert or representative of the Plaintiff after the date of loss as referenced in the Complaint. RESPONSE: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 2 of 6 4. Copies of any and all correspondence between Plaintiff and Defendant with regard to this claim. RESPONSE: 5. Copies of any documents which support any claim for damages to the home located at property address or pursuant to the Policy set forth in this matter. RESPONSE: 6. Copies of any and all correspondence between Plaintiff or his attorneys and any experts retained to inspect, examine or survey the property to render an opinion as to the cause of the damage. RESPONSE: 7. Copies of any and all photographs or videotape showing the damage which is being claimed in the Complaint and pursuant to the Policy. RESPONSE: 8. Copies of any and all correspondence between the Plaintiff and any public adjuster regarding this claim. RESPONSE: 9. Copies of any and all documents, correspondence, etc., between Plaintiff and any other party regarding the damages claimed, including any and all State and Federal agencies, programs or departments. RESPONSE: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 3 of 6 10. Copies of any and all photographs and videotape taken of Plaintiff’s home for the five years prior to the date of loss. RESPONSE: 11. Copies of any and all photographs or videotape taken of the property on or subsequent to the alleged date of loss in the Complaint. Please provide all photos or videos in electronic/digital format. RESPONSE: 12. Copies of any and all photographs or videotape taken of the area(s) of the interior of the home to which you are claiming damages in this Complaint. Please provide all photos or videos in electronic/digital format. RESPONSE: 13. Copies of any and all invoices, cancelled checks or other evidence of payment for repairs, remodels or renovations made to the property relative to the Loss alleged in the Complaint. RESPONSE: 14. Copies of any and all invoices, receipts, documents or other proofs of payment for repairs or renovations made to the home for the five years prior to the date of loss as referenced in the Complaint. RESPONSE: 15. Copies of any and all water bills from May 10, 2019, through November 10, 2020. RESPONSE: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 4 of 6 16. Copies of any and all documents pertaining to any and all insurance claims filed with respect to the home for ten years prior to the date of loss. RESPONSE: 17. Copies of any and all inspections, appraisals or other investigations for the property prior to the date of purchase. RESPONSE: 18. Copies of any and all rules or regulation violations, notices or correspondence issued by any homeowners or condominium association regarding the property for the three (3) year period prior to the date of loss. RESPONSE: 19. Copies of any and all rules or regulation violations, notices or correspondence issued by any homeowners or condominium association regarding the property subsequent to the date of loss. RESPONSE: 20. Copies of any and all ordinance or code violations, notices or correspondence issued by any city/county municipality regarding the property for the three (3) year period prior to the date of loss. RESPONSE: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 5 of 6 21. Copies of any and all ordinance or code violations, notices or correspondence issued by any city/county municipality regarding the property subsequent to the date of loss. RESPONSE: 22. Any and all documents including, but not limited to, receipts, invoices, credit card statements, cancelled checks, bank statements and/or photographs evidencing original cost of the items Plaintiff alleges was damaged as a result of the loss described in the Complaint. RESPONSE: 23. Any and all documents including, but not limited to, receipts, invoices, credit card statements, cancelled checks, bank statements and/or photographs of the items Plaintiff purchased to replace any items Plaintiff alleges was damaged as a result of the loss described in the Complaint. RESPONSE: 24. Any and all documents regarding the sale of the subject property including, but not limited to, all contracts between you and any realtor for the sale of the subject property, all photographs of the property in your possession used for the sale or listing of the subject property for sale, all comparables for your subject property, all disclosure forms pertaining to the subject property including the Seller’s Disclosure Statement, the residential realtor report for the subject property, and any contracts for the sale of the subject property. RESPONSE: Marie Pierre vs. UPCIC Case No.: 2021-020636-CA-01 Page 6 of 6 25. Any and all documents which Plaintiff(s), and/or their agents, provided to Universal Property & Casualty Insurance Company, via claimshelp@universalproperty.com, during the claims process up to the time Plaintiff(s) filed their lawsuit. RESPONSE: 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