On May 28, 2021 a
Party Discovery
was filed
involving a dispute between
Etienne , Adjanie,
Etienne , Elors,
and
Universal Property & Casualty Insurance Company,
for 3
in the District Court of Broward County.
Preview
Filing# 152858015 E-Filed 07/07/2022 12:08:26 PM
THE CIRCUIT COURT OF THE 17TH
IN
JUDICIAL CIRCUIT IN AND FOR
ELORS ETIENNE AND ADJANIE BROWARD COUNTY, FLORIDA
ETIENNE,
CASE NO. CACE-21-010707
Plaintiffs,
V
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
PLAINTIFF'S SUPPLEMENTAL REQUEST FOR PRODUCTION
Pursuant to Rule 1.350, Florida Rules of Civil Procedure, Plaintiff,ELORS ETIENNE
AND ADJANIE ETIENNE, (the"Insured")request upon Defendant, UNIVERSAL PROPERTY
& CASUALTY INSURANCE COMPANY, (the"InsuranceCompany"), to produce the following
identified documents and thingsfor inspectionand duplicationto the offices of Feldman & Lopez,
P.A. at service@feldmanandlopez.com within the time permitted by the Florida Rules of Civil
Procedure.
1. A true and correct copy of the Plaintiff' s insurance application.
2. A true and correct copy ofthe Plaintiff's entire Underwriting file.
3. A true and correct copy of any and all of Plaintiff's claims history,ISO search
reports, including but not limited to, all correspondence to/from the insured,
of the
estimates,photographs,includingany estimates prepared by representatives
insured,copies of any payments with their explanation,as well as any reports from
any adjusters, experts you
representatives, may have retained in the investigation
and evaluation of any other claims of Plaintiff previouslyreported.
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/07/2022 12:08:26 PM.****
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing was furnished via electronic mail
to: Lindsay C. Tropnas, Esq., Universal Property & CasualtyInsurance Co., P.O. Box 9388, Fort
Lauderdale, FL 33310,
lt0223@universalproperty.com;is0601@universalproperty.comjh0518@universalproperty.com
on July 7,2022.
Respectfullysubmitted,
FELDMAN & LOPEZ, P.A.
9990 SW 77th Avenue
Miami, FL 33156
Phone: (305) 779-5904
By: /s/ Carolina Lopez
Carolina Lopez, Esq.
Florida Bar No. 1000488
com
service@feldmanandlopez.
2
Document Filed Date
July 07, 2022
Case Filing Date
May 28, 2021
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