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Filing # 164455654 E-Filed 01/10/2023 02:37:36 PM
IN THE CIRCUIT COURT OF THE
4TH JUDICIAL CIRCUIT IN AND FOR
DUVAL COUNTY, FLORIDA
PATRICK WINGATE & CASE NO: 16-2022-CA-006138-
GINGER WINGATE, XXXX-MA
Plaintiffs,
vs.
UNIVERSAL PROPERTY &
CASUALTY INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFFS
Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, by
and through its undersigned counsel and pursuant to Rule 1.350(a), Florida Rules of Civil Procedure,
hereby requests Plaintiffs to produce and permit the undersigned, or someone acting on the
undersigned's behalf, to inspect and copy the following designated documents, items or matters:
1 Any and all photographs, video and/or any other form of visual recording in digital
format of the subject property including at the time of purchase, after purchase, before and during
the renovations described in your depositions in this matter, and both before and after the loss.
RESPONSE:
2 Any and all documents, including but not limited to estimates, invoices, and
receipts, which evidence the expense or cost to Plaintiff for the repair and/or replacement of the
damage and/or loss to the Subject Property.
RESPONSE:
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/10/2023 05:56:47 PM
Patrick & Ginger Wingate v. UPCIC
CASE NO.: 16-2022-CA-006138-XXXX-MA
Page 2 of 5
3 All documents and records relating to any aspect of any insurance claim submitted
to any insurance company other than the Defendant, relating to any loss at the property which is
subject of this Complaint.
RESPONSE:
4 Any and all documents evidencing the date each items to be repaired or replaced
was originally installed in the home, the manufacturer of the item, the amount paid for the item.
RESPONSE:
5 Any and all documents evidencing permits obtained relating to all modifications,
repairs and/or construction that has been performed on the subject property from the date of
purchase to present date.
RESPONSE:
6 Any and all documents relating to the Plaintiff's purchase of the property at issue
in this lawsuit, including but not limited to all information detailing who the home was purchased
from, the date of purchase, all mortgage companies and mortgage information, remaining balance
of any and all mortgage(s), closing agent, all closing documents, home inspection, appraisal, and
any and all refinance documents.
RESPONSE:
Patrick & Ginger Wingate v. UPCIC
CASE NO.: 16-2022-CA-006138-XXXX-MA
Page 3 of 5
7
Any and all estimates, reports, opinions, correspondence, documentation, records
or other written memorandum from anyone relating to the property damage allegedly sustained as
outlined in Plaintiffs Complaint.
RESPONSE:
8 Any and all reports, opinions, correspondence, documentation, records or other
written memorandum from anyone relating to the causation of Plaintiffs damages alleged in the
Complaint.
RESPONSE:
10. All documentation evidencing all communications between you or anyone on your
behalf with any representative of Defendant, including but not limited to, any correspondence,
telephone messages, written memoranda, and notes concerning the loss.
RESPONSE:
11. Any and all documents relating to any repairs, modifications or construction that
have been performed on the subject property from the date of purchase to present date.
RESPONSE:
Patrick & Ginger Wingate v. UPCIC
CASE NO.: 16-2022-CA-006138-XXXX-MA
Page 4 of 5
12. Complete copies of any and all contracts, subcontracts, rental agreements, and any
other agreements between Plaintiff and any other entities or persons relating to the property that is
the subject of this litigation.
RESPONSE:
CERTIFICATE OF SERVICE
THEREBY CERTIFY that on the 10th day of January, 2023, a true and correct copy of the
foregoing was furnished via E-Service to: Francisco E. Serrano II, Esquire; at Serrano Cagan &
Cagan (sferrano@serranocagan.com; service@serranocagan.com).
Attorneys for Defendant
Universal Property & Casualty Insurance Company
491 Montgomery Place, Suite 2001
Altamonte Springs, FL 32714
Telephone: 833-658-8594
Facsimile: 954-958-1262
By:_/s/P. Alejandro Perez, Esq.
P. Alejandro Perez, Esq.
Florida Bar No.: 1016189
For Service of Court Documents only:
Primary: upciceservice05@universalproperty.com
Secondary: hp0208@universalproperty.com
Tertiary: bv1203@universalproperty.com
*Please do not any
send inquiries or scheduling matters to
upciceservice@universalproperty.com or upciceservice05@universalproperty.com. Please send
all inquiries and scheduling matters to hp0208@universalproperty.com.
Patrick & Ginger Wingate v. UPCIC
CASE NO.: 16-2022-CA-006138-XXXX-MA
Page 5 of 5
Preview
Filing # 164455654 E-Filed 01/10/2023 02:37:36 PM IN THE CIRCUIT COURT OF THE 4TH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA PATRICK WINGATE & CASE NO: 16-2022-CA-006138- GINGER WINGATE, XXXX-MA Plaintiffs, vs. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFFS Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, by and through its undersigned counsel and pursuant to Rule 1.350(a), Florida Rules of Civil Procedure, hereby requests Plaintiffs to produce and permit the undersigned, or someone acting on the undersigned's behalf, to inspect and copy the following designated documents, items or matters: 1 Any and all photographs, video and/or any other form of visual recording in digital format of the subject property including at the time of purchase, after purchase, before and during the renovations described in your depositions in this matter, and both before and after the loss. RESPONSE: 2 Any and all documents, including but not limited to estimates, invoices, and receipts, which evidence the expense or cost to Plaintiff for the repair and/or replacement of the damage and/or loss to the Subject Property. RESPONSE: ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/10/2023 05:56:47 PM Patrick & Ginger Wingate v. UPCIC CASE NO.: 16-2022-CA-006138-XXXX-MA Page 2 of 5 3 All documents and records relating to any aspect of any insurance claim submitted to any insurance company other than the Defendant, relating to any loss at the property which is subject of this Complaint. RESPONSE: 4 Any and all documents evidencing the date each items to be repaired or replaced was originally installed in the home, the manufacturer of the item, the amount paid for the item. RESPONSE: 5 Any and all documents evidencing permits obtained relating to all modifications, repairs and/or construction that has been performed on the subject property from the date of purchase to present date. RESPONSE: 6 Any and all documents relating to the Plaintiff's purchase of the property at issue in this lawsuit, including but not limited to all information detailing who the home was purchased from, the date of purchase, all mortgage companies and mortgage information, remaining balance of any and all mortgage(s), closing agent, all closing documents, home inspection, appraisal, and any and all refinance documents. RESPONSE: Patrick & Ginger Wingate v. UPCIC CASE NO.: 16-2022-CA-006138-XXXX-MA Page 3 of 5 7 Any and all estimates, reports, opinions, correspondence, documentation, records or other written memorandum from anyone relating to the property damage allegedly sustained as outlined in Plaintiffs Complaint. RESPONSE: 8 Any and all reports, opinions, correspondence, documentation, records or other written memorandum from anyone relating to the causation of Plaintiffs damages alleged in the Complaint. RESPONSE: 10. All documentation evidencing all communications between you or anyone on your behalf with any representative of Defendant, including but not limited to, any correspondence, telephone messages, written memoranda, and notes concerning the loss. RESPONSE: 11. Any and all documents relating to any repairs, modifications or construction that have been performed on the subject property from the date of purchase to present date. RESPONSE: Patrick & Ginger Wingate v. UPCIC CASE NO.: 16-2022-CA-006138-XXXX-MA Page 4 of 5 12. Complete copies of any and all contracts, subcontracts, rental agreements, and any other agreements between Plaintiff and any other entities or persons relating to the property that is the subject of this litigation. RESPONSE: CERTIFICATE OF SERVICE THEREBY CERTIFY that on the 10th day of January, 2023, a true and correct copy of the foregoing was furnished via E-Service to: Francisco E. Serrano II, Esquire; at Serrano Cagan & Cagan (sferrano@serranocagan.com; service@serranocagan.com). Attorneys for Defendant Universal Property & Casualty Insurance Company 491 Montgomery Place, Suite 2001 Altamonte Springs, FL 32714 Telephone: 833-658-8594 Facsimile: 954-958-1262 By:_/s/P. Alejandro Perez, Esq. P. Alejandro Perez, Esq. Florida Bar No.: 1016189 For Service of Court Documents only: Primary: upciceservice05@universalproperty.com Secondary: hp0208@universalproperty.com Tertiary: bv1203@universalproperty.com *Please do not any send inquiries or scheduling matters to upciceservice@universalproperty.com or upciceservice05@universalproperty.com. Please send all inquiries and scheduling matters to hp0208@universalproperty.com. Patrick & Ginger Wingate v. UPCIC CASE NO.: 16-2022-CA-006138-XXXX-MA Page 5 of 5