On September 05, 2021 a
Party Discovery
was filed
involving a dispute between
Cancio, Jiuver,
Cornerstone Mobile Glass Inc,
Florida Mobile Glass,
and
Usaa General Indemnity Company,
for Civil
in the District Court of Hillsborough County.
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Filing # 134064546 E-Filed 09/05/2021 12:04:41 AM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CORNERSTONE MOBILE GLASS INC
(D/B/A FLORIDA MOBILE GLASS)
a/a/o
JIUVER CANCIO,
CASE NUMBER: 2021-______________
Plaintiff,
vs.
USAA GENERAL INDEMNITY COMPANY,
Defendant.
______________________________________/
REQUEST FOR PRODUCTION TO DEFENDANT
COMES NOW, Plaintiff, CORNERSTONE MOBILE GLASS INC (D/B/A FLORIDA
MOBILE GLASS) a/a/o JIUVER CANCIO, and requests that Defendant, USAA GENERAL
INDEMNITY COMPANY, respond to the following Requests for Production pursuant to, and
within the time frame provided by, Florida Rule of Civil Procedure 1.350.
1. All insurance policies that would inure to the benefit of Plaintiff or to the Plaintiff’s
assignor, 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 communications and documentation associated with JIUVER CANCIO’s
windshield replacement that are in the possession, custody, or control of Defendant (in its
original/native format). Including but not limited to:
a. All correspondence to or from Plaintiff regarding this claim;
b. All correspondence to or from the Insured regarding this claim;
c. All communications to any company regarding the amount to pay in this claim;
d. All telephone messages to/from Plaintiff or the Insured regarding this claim;
e. All vendor agreements with any third party that provided an estimate or data
utilized in the reduction of this claim;
f. All statements transcripts and/or recordings of any communication made by
Plaintiff regarding this claim;
g. All statements, transcripts and/or recordings of any communication made by the
Insured regarding this claim;
h. All assignment of benefit forms/direction to pay forms received by Defendant in
relation to this claim;
i. All photographs of the Insured’s vehicle after the windshield repair/replacement
or while the windshield was damaged;
j. All bills, invoices work orders, estimates, and quotes regarding the subject
windshield repair/replacement;
k. All drafts, checks or check stubs, electronic funds transfers, and cancelled checks
issued for the Insured’s loss;
l. All documents reflecting any payment made to any person or entity as a result of
Plaintiff’s claim;
m. All Explanations of Benefits, Explanations of Review, correspondence, or
documents generated by Defendant explaining the basis of Defendant’s payment
or failure to make payment;
n. All emails to the Insured, Plaintiff, or any glass shop regarding the cost of the
Insured’s windshield repair/replacement;
o. All records documenting the time and date of any communication from Plaintiff
regarding this claim;
p. All records documenting the first notice of loss report regarding the Insured’
claim;
q. All communications regarding the valuing of the Insured’s loss, including
computer records, adjuster log notes, claim reports, , communications with any
third party administrators, communications with any third party glass shops, and
communications with any person retained to assist in valuing the Insured’s loss.
I HEREBY CERTIFY that a true and correct copy of the foregoing was served with
Plaintiff’s Complaint.
/s/ Jack W. Vasilaros
Jack W. Vasilaros, Esquire
Florida Bar Number: 0125152
Chris Thibodeaux, Esquire
Florida Bar Number: 119418
United Law Group of Florida
1920 West Bay Drive, Suite 1
Largo, Florida 33770
Phone: (727) 306-3324
Email: Chris@unitedlawfla.com
Email: Amy@unitedlawfla.com
Attorney for Plaintiff
Document Filed Date
September 05, 2021
Case Filing Date
September 05, 2021
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Filing # 134064546 E-Filed 09/05/2021 12:04:41 AM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CORNERSTONE MOBILE GLASS INC (D/B/A FLORIDA MOBILE GLASS) a/a/o JIUVER CANCIO, CASE NUMBER: 2021-______________ Plaintiff, vs. USAA GENERAL INDEMNITY COMPANY, Defendant. ______________________________________/ REQUEST FOR PRODUCTION TO DEFENDANT COMES NOW, Plaintiff, CORNERSTONE MOBILE GLASS INC (D/B/A FLORIDA MOBILE GLASS) a/a/o JIUVER CANCIO, and requests that Defendant, USAA GENERAL INDEMNITY COMPANY, respond to the following Requests for Production pursuant to, and within the time frame provided by, Florida Rule of Civil Procedure 1.350. 1. All insurance policies that would inure to the benefit of Plaintiff or to the Plaintiff’s assignor, 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 communications and documentation associated with JIUVER CANCIO’s windshield replacement that are in the possession, custody, or control of Defendant (in its original/native format). Including but not limited to: a. All correspondence to or from Plaintiff regarding this claim; b. All correspondence to or from the Insured regarding this claim; c. All communications to any company regarding the amount to pay in this claim; d. All telephone messages to/from Plaintiff or the Insured regarding this claim; e. All vendor agreements with any third party that provided an estimate or data utilized in the reduction of this claim; f. All statements transcripts and/or recordings of any communication made by Plaintiff regarding this claim; g. All statements, transcripts and/or recordings of any communication made by the Insured regarding this claim; h. All assignment of benefit forms/direction to pay forms received by Defendant in relation to this claim; i. All photographs of the Insured’s vehicle after the windshield repair/replacement or while the windshield was damaged; j. All bills, invoices work orders, estimates, and quotes regarding the subject windshield repair/replacement; k. All drafts, checks or check stubs, electronic funds transfers, and cancelled checks issued for the Insured’s loss; l. All documents reflecting any payment made to any person or entity as a result of Plaintiff’s claim; m. All Explanations of Benefits, Explanations of Review, correspondence, or documents generated by Defendant explaining the basis of Defendant’s payment or failure to make payment; n. All emails to the Insured, Plaintiff, or any glass shop regarding the cost of the Insured’s windshield repair/replacement; o. All records documenting the time and date of any communication from Plaintiff regarding this claim; p. All records documenting the first notice of loss report regarding the Insured’ claim; q. All communications regarding the valuing of the Insured’s loss, including computer records, adjuster log notes, claim reports, , communications with any third party administrators, communications with any third party glass shops, and communications with any person retained to assist in valuing the Insured’s loss. I HEREBY CERTIFY that a true and correct copy of the foregoing was served with Plaintiff’s Complaint. /s/ Jack W. Vasilaros Jack W. Vasilaros, Esquire Florida Bar Number: 0125152 Chris Thibodeaux, Esquire Florida Bar Number: 119418 United Law Group of Florida 1920 West Bay Drive, Suite 1 Largo, Florida 33770 Phone: (727) 306-3324 Email: Chris@unitedlawfla.com Email: Amy@unitedlawfla.com Attorney for Plaintiff