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35-2022-CA-000754-AXXX-XX
Filing # 148510658 E-Filed 04/27/2022 03:30:46 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT IN AND FOR LAKE
COUNTY, FLORIDA
CASE NO:
ERLENE FEDRICK,
Plaintiff,
Vv.
PATRICK DONALD HENES and ARCH
INSURANCE COMPANY, a Foreign Profit
Corporation,
Defendants.
/
PLAINTIFFS’ REQUEST TO PRODUCE TO DEFENDANT.
ARCH INSURANCE COMPANY
Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the undersigned
counsel requests that the Defendant, ARCH INSURANCE COMPANY, produce and permit the
inspection, copying, testing, sampling, measuring, surveying, photographing or otherwise
examining the following:
1 All insurance policies that would inure to the benefit of Plaintiffs, together with any
declaration of coverage page and sworn statement of a corporate officer of Defendant attesting to
the coverage and authenticity of the policy as required by Florida Statutes.
2. All internal procedural memos, regarding the handling of uninsured Motorist
claims, which were in effect during the last 12 months.
3. Defendant's latest claims manual on processing Uninsured Motorist claims.
4 Defendant's most recent claims manual on processing and handling auto insurance
claims in general.
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 04/27/2022 04:41:04 PM.
5 A copy of Defendant's standards for the proper investigation of claims, in effect at
any time during the last 12 months.
6 Copies of any and all leaflets, brochures, memoranda, correspondence, warnings,
or policies, disseminated by Defendant or any of Defendant's agents, employees, or
representatives, and in effect during the last 12 months, which set forth procedures, comments,
suggestions, guidelines or criteria for handling, adjusting, investigating, or settling Uninsured
Motorist claims.
7 Correspondence or Complaint forms which Defendant or anyone adjusting claims
on Defendant's behalf received during the last 12 months from any field operation office of The
Florida Department of Insurance concerning the handling of Uninsured Motorist claims.
8 Copies of Defendant's standards for the proper handling, investigation and
recording of all complaints received from insured or from The Florida Department of Insurance
which were in effect at any time during the last 12 months.
9 Copies of any and all leaflets, brochures, memoranda, correspondence, warnings or
policies, disseminated by Defendant or any of Defendant's agents, employees, or representatives,
and in effect during the last 12 months, which set forth procedures, comments, suggestions,
guidelines or criteria for handling, investigating, resolving or settling complaints from insured or
The Florida Department of Insurance regarding the handling of claims.
10. Any and all information bulletins Defendant received from The Florida Department
of Insurance between December 20, 1999 and the present concerning the handling of uninsured
Motorist claims.
11. Any and all surveillance reports, claims history reports or other investigative
reports claims Defendant or anyone acting on Defendant's behalf prepared with regard to Plaintiff.
12. Any and all surveillance films or photographs Defendant or anyone acting on
Defendant's behalf took of the Plaintiff.
13. The entire Personal Injury Protection file, including an up-to-date PIP and medical
payments payout sheet concerning the Plaintiff.
14. Any and all statements Defendant or anyone acting on Defendant's behalf took of
Plaintiff or any witnesses.
15. Any and all photographs Defendant or anyone acting on Defendant's behalf took
showing the extent of damage to any of the vehicles involved in the accident.
16. Any and all photographs Defendant or anyone acting on Defendant's behalf took of
the scene of the accident at any time prior to the filing of suit.
17. Any and all estimates of repair or statements concerning the nature and extent of
damage to any of the vehicles involved in the accident.
18. Any and all writings, memorandums, notes or other materials reflecting Defendant's
examination of any of the vehicles involved in the accident.
19. Any and all records reflecting the towing of any vehicles involved in the accident
from the scene of the accident.
It is requested that the above document be furnished or produced on or before forty-five
(45) days from the date of service hereof, to Devry Kelley, Esquire at the offices of Dan Newlin
Injury Attorneys, 7335 Sand Lake Road, Ste. 300, Orlando, FL 32819.
In support of this Request To Produce, it is shown that the documents and/or materials
being here requested are believed to be in the possession, custody or control of the party to whom
this request is directed. The information sought by this request is relevant to the subject matter of
this action and cannot otherwise be obtained without undue hardship. In the event that all or part
of the documents, and/or materials herein requested are not in the possession or control of the
above-named Defendant addressee, then the undersigned counsel further request the identity and
location all persons having such possession and control. This request is made in good faith and
for the purposes herein expressed.
I HEREBY CERTIFY that a copy hereof has been furnished the Defendant along with the
Summons and Complaint.
s/ Devry R. Kelley
Devry R. Kelley, Esquire
Florida Bar No.: 0567302
Dan Newlin Injury Attorneys
7335 W. Sand Lake Road, Suite 300
Orlando, FL 32819
Direct: (321) 234-3859
Fax: (863) 225-9853
Attorneys for Plaintiff
Devry.Kelley@newlinlaw.com
Patricia.Croc@newlinlaw.com
devry.pleadings@newlinlaw.com
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35-2022-CA-000754-AXXX-XX Filing # 148510658 E-Filed 04/27/2022 03:30:46 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA CASE NO: ERLENE FEDRICK, Plaintiff, Vv. PATRICK DONALD HENES and ARCH INSURANCE COMPANY, a Foreign Profit Corporation, Defendants. / PLAINTIFFS’ REQUEST TO PRODUCE TO DEFENDANT. ARCH INSURANCE COMPANY Pursuant to the provisions of Rule 1.350, Florida Rules of Civil Procedure, the undersigned counsel requests that the Defendant, ARCH INSURANCE COMPANY, produce and permit the inspection, copying, testing, sampling, measuring, surveying, photographing or otherwise examining the following: 1 All insurance policies that would inure to the benefit of Plaintiffs, together with any declaration of coverage page and sworn statement of a corporate officer of Defendant attesting to the coverage and authenticity of the policy as required by Florida Statutes. 2. All internal procedural memos, regarding the handling of uninsured Motorist claims, which were in effect during the last 12 months. 3. Defendant's latest claims manual on processing Uninsured Motorist claims. 4 Defendant's most recent claims manual on processing and handling auto insurance claims in general. FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 04/27/2022 04:41:04 PM. 5 A copy of Defendant's standards for the proper investigation of claims, in effect at any time during the last 12 months. 6 Copies of any and all leaflets, brochures, memoranda, correspondence, warnings, or policies, disseminated by Defendant or any of Defendant's agents, employees, or representatives, and in effect during the last 12 months, which set forth procedures, comments, suggestions, guidelines or criteria for handling, adjusting, investigating, or settling Uninsured Motorist claims. 7 Correspondence or Complaint forms which Defendant or anyone adjusting claims on Defendant's behalf received during the last 12 months from any field operation office of The Florida Department of Insurance concerning the handling of Uninsured Motorist claims. 8 Copies of Defendant's standards for the proper handling, investigation and recording of all complaints received from insured or from The Florida Department of Insurance which were in effect at any time during the last 12 months. 9 Copies of any and all leaflets, brochures, memoranda, correspondence, warnings or policies, disseminated by Defendant or any of Defendant's agents, employees, or representatives, and in effect during the last 12 months, which set forth procedures, comments, suggestions, guidelines or criteria for handling, investigating, resolving or settling complaints from insured or The Florida Department of Insurance regarding the handling of claims. 10. Any and all information bulletins Defendant received from The Florida Department of Insurance between December 20, 1999 and the present concerning the handling of uninsured Motorist claims. 11. Any and all surveillance reports, claims history reports or other investigative reports claims Defendant or anyone acting on Defendant's behalf prepared with regard to Plaintiff. 12. Any and all surveillance films or photographs Defendant or anyone acting on Defendant's behalf took of the Plaintiff. 13. The entire Personal Injury Protection file, including an up-to-date PIP and medical payments payout sheet concerning the Plaintiff. 14. Any and all statements Defendant or anyone acting on Defendant's behalf took of Plaintiff or any witnesses. 15. Any and all photographs Defendant or anyone acting on Defendant's behalf took showing the extent of damage to any of the vehicles involved in the accident. 16. Any and all photographs Defendant or anyone acting on Defendant's behalf took of the scene of the accident at any time prior to the filing of suit. 17. Any and all estimates of repair or statements concerning the nature and extent of damage to any of the vehicles involved in the accident. 18. Any and all writings, memorandums, notes or other materials reflecting Defendant's examination of any of the vehicles involved in the accident. 19. Any and all records reflecting the towing of any vehicles involved in the accident from the scene of the accident. It is requested that the above document be furnished or produced on or before forty-five (45) days from the date of service hereof, to Devry Kelley, Esquire at the offices of Dan Newlin Injury Attorneys, 7335 Sand Lake Road, Ste. 300, Orlando, FL 32819. In support of this Request To Produce, it is shown that the documents and/or materials being here requested are believed to be in the possession, custody or control of the party to whom this request is directed. The information sought by this request is relevant to the subject matter of this action and cannot otherwise be obtained without undue hardship. In the event that all or part of the documents, and/or materials herein requested are not in the possession or control of the above-named Defendant addressee, then the undersigned counsel further request the identity and location all persons having such possession and control. This request is made in good faith and for the purposes herein expressed. I HEREBY CERTIFY that a copy hereof has been furnished the Defendant along with the Summons and Complaint. s/ Devry R. Kelley Devry R. Kelley, Esquire Florida Bar No.: 0567302 Dan Newlin Injury Attorneys 7335 W. Sand Lake Road, Suite 300 Orlando, FL 32819 Direct: (321) 234-3859 Fax: (863) 225-9853 Attorneys for Plaintiff Devry.Kelley@newlinlaw.com Patricia.Croc@newlinlaw.com devry.pleadings@newlinlaw.com