On September 07, 2021 a
Trial Materials
was filed
involving a dispute between
Marie Pierre,
and
Universal Property & Casualty Insurance Company,
for Insurance Claim
in the District Court of Miami-Dade County.
Preview
Filing # 148625300 E-Filed 04/28/2022 10:45:44 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,
v.
UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
DEFENDANT.
__________________________________/
PLAINTIFF’S EXHIBIT LIST
Plaintiff, MARIE PIERRE, by and through undersigned counsel, list the following exhibits for
use at arbitration and trial:
1. A complete copy of UNIVERSAL PROPERTY & CASUALTY INSURANCE
COMPANY, INC’s Policy number 1501-1506-4343.
2. All photographs of the subject property taken by Plaintiff (and any of its agents).
3. All photographs of the subject property taken by NATIONAL WATER RESTORATION,
INC. (and any of its agents).
4. All photographs of the subject property taken by CENTURY PUBLIC ADJUSTERS (and
any of its agents).
5. All photographs of the subject property taken by IGE CONSTRUCTION, INC (and any of
its agents)
6. All videos of the subject property taken by IGE CONSTRUCTION, INC. (and any of its
agents)
7. All photographs of the subject property taken by UNIVERSAL PROPERTY &
CASUALTY INSURANCE COMPANY, INC. (and any of its agents).
8. Estimate(s) and diagrams(s) prepared by Plaintiff (any and of its agents).
9. Estimate(s) and diagram(s) prepared by National Water Restoration, Inc. (and any of its
agents).
10. Estimate(s) and diagrams prepared by Defendant (and any of its agents).
11. Estimate(s) and diagrams prepared by IGE Construction, Inc. (and of its agents).
12. Deposition Transcript of MARIE PIERRE.
13. Deposition Transcript of Defendant’s Field Adjuster.
14. Deposition Transcript of Defendant’s Corporate Representative.
15. Deposition Transcript of Defendant’s Expert.
16. Defendant’s answers to interrogatories.
17. Correspondence to and from Defendant (or its agents) and Plaintiff or Plaintiff’s
representative.
18. Any and all documents exchanged through the discovery process without waiving
objections.
19. All non-privileged documents in Defendant’s claim file.
20. All pleadings, discovery, discovery response, motions, affidavits, etc., filed with the Court
in this matter.
21. Transcripts of all depositions taken in this matter.
22. Any and all exhibits necessary for impeachment or rebuttal purposes.
23. All exhibits listed by Defendant.
24. All documents used as an exhibit in depositions already taken, and to be taken, in this case.
25. Any and all deposition transcripts of all witnesses deposed in this action, which may be
introduced.
26. Any and all documents filed with the court in this litigation.
27. Demonstrative aids to be used at trail for the benefit of the jury.
28. The subject and operating Complaint for damages.
29. Any and all documents not presently known at this time, but which may become known up
to the time of arbitration and/or trial.
30. Plaintiff reserves the right to add exhibits as they become known.
31. Plaintiff reserves any and all objections to any and all exhibits listed by the Defendant.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy hereof has been furnished to all parties
of record in compliance with Fla. R. Jud. Admin 2.516 by filing the same with the Florida Courts
eFiling ePortal to all parties of records this 28th day of April 2022.
By:/s/ Nirav A. Desai .
William J. Roe, Esq.
Florida Bar No.: 85337
Nirav A. Desai, Esq.
Florida Bar No.: 93202
LAW OFFICE OF WILLIAM J. ROE, P.A.
17971 Biscayne Blvd. Ste. 214
Aventura, FL 33160
Office: (786) 332-6323
Fax: (786) 233-9562
Primary Eservice: wjroe@wjroelaw.com
Secondary Eservice: ndesai@wjroelaw.com
info@wjroelaw.com
Document Filed Date
April 28, 2022
Case Filing Date
September 07, 2021
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Filing # 148625300 E-Filed 04/28/2022 10:45:44 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, v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY DEFENDANT. __________________________________/ PLAINTIFF’S EXHIBIT LIST Plaintiff, MARIE PIERRE, by and through undersigned counsel, list the following exhibits for use at arbitration and trial: 1. A complete copy of UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, INC’s Policy number 1501-1506-4343. 2. All photographs of the subject property taken by Plaintiff (and any of its agents). 3. All photographs of the subject property taken by NATIONAL WATER RESTORATION, INC. (and any of its agents). 4. All photographs of the subject property taken by CENTURY PUBLIC ADJUSTERS (and any of its agents). 5. All photographs of the subject property taken by IGE CONSTRUCTION, INC (and any of its agents) 6. All videos of the subject property taken by IGE CONSTRUCTION, INC. (and any of its agents) 7. All photographs of the subject property taken by UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, INC. (and any of its agents). 8. Estimate(s) and diagrams(s) prepared by Plaintiff (any and of its agents). 9. Estimate(s) and diagram(s) prepared by National Water Restoration, Inc. (and any of its agents). 10. Estimate(s) and diagrams prepared by Defendant (and any of its agents). 11. Estimate(s) and diagrams prepared by IGE Construction, Inc. (and of its agents). 12. Deposition Transcript of MARIE PIERRE. 13. Deposition Transcript of Defendant’s Field Adjuster. 14. Deposition Transcript of Defendant’s Corporate Representative. 15. Deposition Transcript of Defendant’s Expert. 16. Defendant’s answers to interrogatories. 17. Correspondence to and from Defendant (or its agents) and Plaintiff or Plaintiff’s representative. 18. Any and all documents exchanged through the discovery process without waiving objections. 19. All non-privileged documents in Defendant’s claim file. 20. All pleadings, discovery, discovery response, motions, affidavits, etc., filed with the Court in this matter. 21. Transcripts of all depositions taken in this matter. 22. Any and all exhibits necessary for impeachment or rebuttal purposes. 23. All exhibits listed by Defendant. 24. All documents used as an exhibit in depositions already taken, and to be taken, in this case. 25. Any and all deposition transcripts of all witnesses deposed in this action, which may be introduced. 26. Any and all documents filed with the court in this litigation. 27. Demonstrative aids to be used at trail for the benefit of the jury. 28. The subject and operating Complaint for damages. 29. Any and all documents not presently known at this time, but which may become known up to the time of arbitration and/or trial. 30. Plaintiff reserves the right to add exhibits as they become known. 31. Plaintiff reserves any and all objections to any and all exhibits listed by the Defendant. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy hereof has been furnished to all parties of record in compliance with Fla. R. Jud. Admin 2.516 by filing the same with the Florida Courts eFiling ePortal to all parties of records this 28th day of April 2022. By:/s/ Nirav A. Desai . William J. Roe, Esq. Florida Bar No.: 85337 Nirav A. Desai, Esq. Florida Bar No.: 93202 LAW OFFICE OF WILLIAM J. ROE, P.A. 17971 Biscayne Blvd. Ste. 214 Aventura, FL 33160 Office: (786) 332-6323 Fax: (786) 233-9562 Primary Eservice: wjroe@wjroelaw.com Secondary Eservice: ndesai@wjroelaw.com info@wjroelaw.com