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Filing# 168438597 E-Filed 03/09/2023 10:08:58 PM
IN THE CIRCUITCOURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
IRMA QURESHI, et. al., CASE NO- CACE 2021-007238
Plaintiffs,
VS.
UNIVERSAL PROPERTY AND CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S MOTION TO DISMISS FOR FRAUD UPON THE COURT
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
("Universal"),pursuant to Fla. R. Civ. P. 1.510 and Florida law, moves this Court to dismiss
Irma Qureshi's and George Guerrero's (hereinafter
Plaintiffs', lawsuit for Fraud
"Plaintiffs"),
Upon the the Statement of, and states:
Court. In support ofthis Motion, Universal incorporates
INTRODUCTION
property breach of contract lawsuit, Plaintiff,Irma Qureshi, has
In this first-party
perpetrateda fraud on the court by testifying
under oath at trial that (1) she discovered the loss as
a result of tiles fallingoff of the wall in her bathroom; (2) she reportedthe claim to Universal as
both a mold claim and a water loss claim; (3) she did not hire a mold inspectorpriorto notifying
Universal of the loss; and, most importantly,(4) that she was not having her guest bathroom
renovated at the time that she discovered the loss. The foregoing"facts" stand in direct opposition
to the recordingof Plaintiff Irma Qureshi's initial call to Universal duringwhich she reportedthe
claim. Further,the those present during trial in this action heard testimony and saw direct evidence
that certain of the foregoing"facts" were not true. Despite this,neither Plaintiffs nor Plaintiffs'
counsel made any effort to correct the record as to those "facts."
Page 1 of 18
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/09/2023 10:08:58 PM.****
Universal has defended this breach of insurance contract action by asserting
Primarily, that
no breach occurred because Plaintiffs' could not prove that the loss occurred during the Policy
period.However, Universal's defense of this action was upended by Plaintiff' s and Plaintiff's
handyman's intentional misstatements during trial as to the foregoing "facts." These
went to the very heart ofthis
misrepresentations action. and damages.
They affected both liability
Plaintiff's misrepresentationsgo beyond mere fraud to this insurer-which negates
coverage under the Policy.Because Plaintiffs presentedthe intentional misrepresentations
in open
Court and under oath,the actions constitute a fraud upon the Court and dismissal is appropriate.
MEMORANDUM OF LAW
Florida appellate have upheld "that a party
courts consistently who is guiltyof fraud or
misconduct in the prosecutionor defense of a civil proceeding should not be permittedto continue
to employ the very institution it has subverted to achieve ends. See Leo's Gulf Liquors
[their] v.
Lakhani, 802 So. 2d 337 (Fla.3d DCA 2001).
I. COURT'S INHERENT AUTHORITY TO DISMISS FOR FRAUD ON THE
COURT.
This Court has the inherent authorityand duty to dismiss a case with prejudicewhere a
party has perpetrateda fraud on the court. Herman v. Intracoastal Cariology Center, 121 So.3d
583, 588 (Fla.4?h DCA 2013);Long v. Swq#brd, 805 So. 2d 882 (Fla.3d DCA 2001) (reasoning
that a trial court has a to dismiss a case for fraud upon the court where plaintiff
duty and obligation
lied under oath concerningpre-existing The power to dismiss a case for fraud on the
conditions).
Court is and necessary
indispensable to the proper administration ofjusticeand prevents litigants
from trifling
with the courts. It is a power, that should be exercised cautiouslyand sparingly,and
only upon a clear showing of fraud,pretense, collusion,or similar wrongdoing. Tri Star Invs.,Inc.
v. Miele,407 So.2d 292, 293 (Fla.2d DCA 1981).
Page 2 of 18
II. STANDARD FOR DISMISSAL FOR FRAUD ON THE COURT.
Fraud on the Court occurs when the evidence clearlyand convincingly shows a party
schemed to interfere with the court's abilityto impartiallyadjudicateby intentionally
hampering
of the opposing party'sdefense.
the presentation O'Vahey v. Miller, 644 So. 2d 550 (Fla.3d DCA
1994) (affirmingdismissal for fraud upon the court where assiduous efforts by opposing counsel
repeatedly lied under oath concerning his education and background);
revealed that plaintiff
Hogan v. Dollar Rent A Car Sys.,
Inc., 783 So. 2d 1211 (Fla.4th DCA 2001) (affirmingdismissal
of suit for fraud upon the court where plaintifflied at deposition to thwart defendant from
conductingdiscoveryand where attorney knew plaintiff
was giving false testimonybut remained
Herman, 121 So.3d
silent); at 588. In Herman, false dismissal and the Fourth
testimonyjustified
District determined that the trial court did not abuse its discretion because the trial court found
"clear and convincing evidence that Mr. Herman sentiently
set in motion a scheme to defraud that
was calculated to interfere with the judicialsystem'sability
to adjudicatethe matter impartially.
Id at 588-89.
The Fourth District has recognized that the sanction of dismissal for fraud on the Court
"
requiresa clear showing of"fraud, pretense, collusion,or similar wrongdoing. Beseler v. Avatar
Prop. & Cas. Ins. Co., 291 So. 3d 137, 140 (Fla.4th DCA 2020). Dismissal is especially
appropriatewhen the "repeatedfabrications undermine the integrity
of a party'sentire case."
Herman, 121 So.3d at 590; Mendez v. Blanco, 665 So. ld 1149 (Fla.3d DCA court
1996) (trial
did not abuse its discretion in dismissingcomplaint filed who repeatedlylied under
by plaintiff
oath).
The Third District Court of Appeal has been clear that courts should not allow partiesto
subvert its resources to reach unjustends. Leo's Gulf Liquors v. Lakhani, 802 So. 2d 337 (Fla.3d
Page 3 of 18
DCA 2001) (citingMetropolitanDade Couno' v. Martinsen, 736 So.2d 794, 795 (Fla.3d DCA
Inc.,2013
1999));see also Bullard v. Lowry Group Properties, WL 12139893 1 li
th
Jud. Cir. Jun.
14, 2013). Notably, courts have been clear that when a witness lies under oath it will not accept
excuses such as those based on "inartfully and that
crafted questions", it "categorically this
rejects
type of gamesmanship during pretrial
or trial proceedings when such tactics ultimatelyserve to
subvert the truth." Leo's Guf Liquors, 802 So. 2d at 343. Ultimately,the Court in Leo's Gulf
Liquors stated,"Witnesses who give sworn testimony by way of interrogatories,
at depositions,
hearings and trial,swear or affirm to
pretrial tell the truth,the whole truth, and nothing but the
truth. We expect and will settle for nothing less. Lawyers who advise their clients and/or witnesses
to mince words, hold back on necessary clarifications,
or otherwise obstruct the truth-finding
process, do so at their own, and their clients' peril."
Id at 343 (emphasis in original).
III.PLAINTIFFINTENTIONALLY MADE NUMEROUS MISREPRESENTATIONS
THAT WENT TO THE VERY HEART OF THE BREACH OF CONTRACT
ACTION.
On October 15, 2020, Plaintiff,Irma Qureshi, contacted Universal to report a claim
,1
1. The crux ofthat
regardingher residential property. (Factsat 115) call was as follows:
Universal: Hello. You're callingUniversal Property & Casualty.This is Jorge.How
can I help you?
Plaintiff: Hi. My name is Irma Qureshi. I'm callingwith regardsto my policy,Policy
Number 150115032106. I was having a contractor do some remodeling work in our
guest bathroom because it was having a lot of issues,and it looks like there's mold in
- behind the walls, so I had Servepro come, and they're going to run an estimate
because it does - they believe it does look like mold, so they are going to do the testing
and stuff like that. Ans I justwanted to figureout with you guys, you know, if there
were any steps I can take through the insurance. I think mold is covered, but I don't
know to what extent. So, yeah, that's why I'm calling.
References to "Facts" refer to Universal's Statement of EvidentiaryFacts Adduced At Trial filed
1
contemporaneously herewith.
Page 4 of 18
Universal: Okay. So, yeah. We can set up the claim, and since you're in the process
of doing the mold test, once you get the results,you can present that to the claims
Okay?
adjuster.
Plaintiff: Okay.
Universal: And then they'llcome out and look at your damages due to the mold.
Plaintiff: Okay.
Trial Transcriptat 3:8-4:11. Several things are immediately clear from this conversation that
occurred on October 15,2020, the day after the claim was allegedly
discovered:
1. Plaintiff was having a contractor conduct remodeling work;
2. The remodeling work was being done to correct multiple preexistingissues in the
bathroom;
3. Plaintiff had alreadycontacted Servepro;
4. Servepro had alreadybeen to the Property;
5. Plaintiff only reporteda mold claim to Universal;
6. Plaintiff never mentioned a leak, water damage, moisture, or any other indication of
dampness at the Property.
Despite this,when Plaintiff took the stand at trial,she adamantly refuted (1) the facts that she
reportedto Universal; and (2)that she had ever reportedthe facts that Universal claimed she had.
In stark contrast to Plaintiff's direct testimony are picturesand unrefuted expert opinionshowing
that the facts of the claim demonstrably pointed toward renovations being done at the Property as
well as the nonexistence of a leak. Also pointingto intentional misrepresentations
having been
made is the evidence that was intentionally
not preserved.
Page 5 of 18
The totality
of the evidence demonstrates that Plaintiff set out to mislead
intentionally
Universal, this Court, and the jury as to the true facts of this case. Due to Plaintiff's intentional
scheme to defraud Universal and this Court, Plaintiff's action must be dismissed with prejudice.
At trial, Irma Qureshi testified that she initially
Plaintiff, called her handyman to investigate
and repairtiles that were popping off the walls of her guest bathroom (Factsat 73). She went on
that the next day, she notified Universal that Plaintiff was "doing repairwork because of
to testify
the tile popping out. handyman believes he found mold and a water leak and water
The [Plaintiff'sl
damage." (Facts at 76). Plaintiff was adamant that she was not having remodeling done in the
bathroom at the time of the claim. (Factsat 710).She also testified that she contacted SERVEPRO
qftercontactingUniversal and not before, and that SERVEPRO had not come to the Property
before she contacted Universal. (Factsat 711).
With respect to the remodeling, Plaintiff went so far as to blame Universal for
the guttingof the bathroom as a remodel. She stated,"You guys have phrased
mischaracterizing
it as remodeling bet I have consistentlysaid it was repairwork and I also mentioned that the tiles
were popping off to the person I spoke to at Universal." (IQ Test. at 81:13-17).Each of the
claims-about which Plaintiff emphaticallyand adamantly testified-are demonstrably false. She
told Universal that she was remodeling and never said a word about tiles popping offthe
explicitly
walls. (TrialTranscriptat 3:8-4:11).
It is plausiblethat between the time that Plaintiff reportedthe claim to Universal and the
date of trial,
Plaintiff merely forgotthe details of the call. That might explain(1) whether she
mentioned that the tiles were popping off the walls; (2) whether she recalled exactly when
SERVEPRO came to the Property or was initially
contacted; and perhaps even (3) whether she
mentioned a leak. However, with respect to whether she was conducting renovations in the
Page 6 of 18
bathroom, memory lapseis next to impossible.One simply does notfbrget that they were having
renovations done to their bathroom.
To be clear,the evidence supportingPlaintiff's initially
reportedclaim that she was having
renovations done is insurmountable. Consider the facts accordingto Plaintiffs' and their witnesses:
a. Plaintiff and Braulio Echevarria, the handyman, testified that he was merely at the home
to take care of the loose tiles. (Factsat ll3).
b. The loose tiles-and the allegedleak-were between the tub and the vanity.(Factsat 115).
c. Despite the location of the loose tiles and the leak, Braulio removed tiles on three walls of
the vanity,and the tub.
the bathroom, the toilet, He also removed the cement around the
tub drain pipe and the cement around the toilet drain pipe.Finally,
he removed tile floor
beneath the toilet. (Factsat lit P's Exhibit 3 at 12; P's Exhibit 2 at photo 3).
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Page 7 of 18
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Holes were created for no claim related reason. Tile was removed for no claim related reason.
Basically,Plaintiff had the bathroom entirelygutted for no reason related to the claim. Simply
applyinglogicto these facts,no sense can be made from what was done here.
But this Court does not have to rely on logic alone. Universal's expert witness provided
unrefuted testimonythat the only basis for demolishing the bathroom to this extent was to conduct
testified that the bathroom
renovations. In fact,the engineerexplicitly was being remodeled. (Facts
at She opined that there was no reason other than remodeling to remove a toilet,remove
1135(d)).
the tile beneath it,and dig a hole under it. She further opined that the toilet itself should not have
been removed because it was The tub, she
several feet from the allegedleak. (Factsat 735(d)(i)).
said,was removed despiteit not being in the place where the tiles were coming off the walls, and
mentioned that the big hole dug beneath it was certainlyunnecessary. (Factsat 735(d)(ii)).
This
coming from an engineerwell versed in these types of claims. (Factsat ll34).
Simply put, the guest bathroom was being renovated when Plaintiffs discovered the mold.
There is no other possibleconclusion based on (1) Plaintiff's admission to Universal that the
renovations were being completed; and (2) the direct evidence that the bathroom was being
renovated. Further,Plaintiffs did not forgetthat the bathroom was being renovated. Every time
Page 8 of 18
they saw a photograph of the gutted bathroom-which occurred regularlyat trial-they were
reminded that they had been renovatingthe bathroom. Renovations simply are not something that
one forgets-they are planned for and budgeted; the inconvenience of living through the
renovations is mentallyprepared for. That does not justslipthe mind because some years passed.
Plaintiff lied-she perjuredherself-with respect to the renovations. Once that has been
accepted,the remainder of the untruths take on a new light.
Plaintiff allegedthat she notified Universal that there was a leak. (Factsat 76).This Court
knows that such notification did not occur. (TrialTranscriptat 3:8-4: 11.)Perhaps, however, there
was a leak and Plaintiffmerely
forgotthat she did not inform Universal of it. Let's test that theory.
Plaintiff testified that she did not see a leak nor did she see any water on the floor. (Facts
at Braulio was clear,however, that he showed her the issues in the bathroom and told her to
117).
call the plumber. (Factsat 75).Before Braulio left the Property, the plumbing repairhad not been
completed,but when he returned, it had. Ud.) On October 16, 2020, MoldPros took photographs
of the bathroom, as depicted supra. (P's Exhibit 3). Those photographs demonstrate that on
October 16, 2020, the pipe had not been replaced.On October 17, 2020, Plaintiff had a pipe
replacedby a plumber. (Factsat ll14). testified that Universal
Universal's corporate representative
did,in fact,receive an invoice from Cala Prosolutions Corp. and that Plaintiffs purportedthat the
invoice was for the plumbing repair.2
In contrast to the foregoing are the items that were not preserved,introduced into evidence,
or testified to. Plaintiffs and their hired help did not take any photographs or videos of the allegedly
leakingp*e. Plaintiffs q#irmativelydecided to discard the allegedly
damaged pipe because "once
2
At
the time of this writing,Universal is not yet in possessionof the transcript of the corporate
representative's
testimony. Said testimony has been ordered and the record will be supplemented
priorto the hearing on this Motion.
Page 9 of 18
"
the backyard flooded, it didn't make any sense to keep them. (Facts at 914). Plaintiffs never
pointedto any photograph that depictedactual,current moisture in the area of the allegedleak.
Further,Universal's expert opined that it was impossible for the leak to have been current
at the time the photographs were taken, as the shared kitchen wall showed no discoloration,mold,
or moisture damage. (Factsat 735(c)(v)and 735(h)).In fact,the expert pointed out the area in the
photos that lacked damage that would be consistent with a current leak:
4
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There was absolutelyno damage to the adjoiningkitchen wall... yet somehow an active leak
mold and moisture damage to the bathroom wall, the
caused significant wood supports, and the
3
tile on the other side of Durock.Z In fact,the leak was so bad that portionsof the wood had
deteriorated to the point of needing to be replaced...
yet the kitchen wall was unscathed. (Factsat
1135(c)(iii).
3
Braulio Echevarria testified that the tile in the bathroom was attached to Durock, which unlike
drywall,"is more of a concrete, hard substance." (BE Test. at 23:10-23).
Page 10 of 18
The fact of the matter is that Plaintiff did not notifyUniversal of a leak or water damage
because there was no leak. In fact,the invoice that Plaintiff's submitted to Universal for the
purported plumbing repairis dated October 15,2020:
?
(ExhibitA). The pipe with the allegedleak was not repairedas of October 16,2020 and, according
to Irma Qureshi, it was not repaireduntil October 17, 2020. Why, then, did Plaintiffs submit this
invoice to Universal purportingto be for the plumbing repair?Where is the actual plumbing
invoice? There was certainly
no permitpulledto replaceany plumbing. (DA Test. at 28:18-24).
To be clear,the only evidence in the record that could possibly point to there being an
active leak at the Property in October of 2020 is testimony;and (2)
(1) Plaintiffs' self-serving
Braulio Echevarria's testimony.There is not a singlephoto or video that shows an active leak and
the allegedlybroken pipe was heedlesslydiscarded by Plaintiffs. Yet the photographic evidence
reveals beyond a shadow of a doubt that there was no active leak. Plaintiff lied not only about her
initial reportingof the claim, but more importantlyabout the allegedloss itself.
But Plaintiff did not stop there. In order to get around Universal's defense that Plaintiff
failed to provide the documents Universal requested,Plaintiff testified that she "didn't send
anything for the [thepriorclaim] because you guys already had everything."(Facts at 718). She
Page 11 of 18
went on to testifythat she knows Universal had the prior claim documents because Universal
"forwarded our emails from 2017 to us justlike a few days ago and that had the attachments from
it." Ud.).Amongst those documents was an invoice from 4 Star Services.
The 4 Star Services invoice demonstrates that during the priorclaim, there was a slab leak
in the master bedroom. The slab leak was stemming from a leak "on the cold water loop in the slab
going over to [SIC] kitchen and bathroom." Exhibit 2 at 3. To repairthe leak, 4 Star Services
"Eliminated both loopsunderground and ran new hot + cold lines through attic to kitchen and
bathroom. Repaired leaks on copper fittings
behind tub." (Id.)(emphasis added).
8 0626
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INVOICE #: i
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CUSTOMLR NAME ,!i ui,r,Ilv R?,t,poinble 1'.,ryi CALLER NAME JOB CONTACT NAME
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HEATERS.- ORAIN CLEANING .--: . ,i ?- .I (.
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NW iOB ADDRESS
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730 57 Place, Bay ] CITY 5 TATr 71r
Fort Lauderdale, Florida 33309
E-? Lu/.Lj? f-L
(954) //6-9888 BILLINi ADDRESS iiI [,ilfe i,i,ti PHI PH 2
www.4star5ervices.com j nJ
ic #'s: CFC 22535& CMC 03 g 559
F-MAII ADDRFK
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(}RIGINAI REASON FOR Tlll (A[L ,
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(ExhibitB at 3).
It is clear from the invoice that certain work was done in the kitchen. Less clear is which
bathroom is being referred to-the master bathroom or the guest bathroom. The lack of clarity
as
to the affected bathroom is of no consequence.
The plumbing lines in the kitchen happen to be the same plumbing lines supplying the
guest bathroom. In fact,that's what Plaintiffs' entire kitchen claim rests upon. Bearing that in
Page 12 of 18
relates to work that was done in the wall between the
mind, the 4 Star Services invoice directly
kitchen and the guest bathroom. The itemized portionof the invoice states:
'
. f
r- .,
(ExhibitB at 3). In case the scope of the services is not clear enough, Universal's engineering
expert shed some lightonto the priorrepairsthat were evident from the photographs she reviewed.
She testified:
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"Right here, there are two pipes coming from the ground. They're copper. . . So those pipes are
abandoned, and that shows that the plumbing in that wall has been altered." (DA Test. at 31:2-11).
That sounds eerily similar to what 4 Star Services did when they "eliminated both loops
underground."(ExhibitB at 3).
Universal's expert went on to testify
to the following:
Page 13 of 18
A So that's the one 1 was saying that i:
it had a lot of patlna and calciurr buildup
consistent with a p--nho--e ie-k for a long term.
And Lhen the red ilex.b.e pipe that. goes
korizonLal Jlung the wa-1 f
iI
P
Q. Yes.
A. -- that '5 the PPRX pipe that at some
0
f
point was replaced. So what 1 iinderstand fycm
the phc, L c, i s Lha t. t. wo p i pe s c c ming l r om the
ground, they were copper, they were abandoned, S
and replaced with copper and that red pipe lust
heca dse they h:d a leak ar snme p,oir-r.
Q. Sn y,22.'re saying the pipe going into
r-he q r (:und, th o se p. peg were abandoned and now
t]:ere ' s a h.o rizor.tal pipe, that red pipe?
A Yes. One for coldr which looks like
jt's the new copper --'.ne or the recent copper
line, and Lhen the ore in the back with the A'.
calcium tuilciuc 1 6 the he t wdter lir-e. 1>
(DA Test. at 32:3-21).Again, that's reads much like,"ran new hot + cold lines through attic to
kitchen and bathroom" and "re-pipehot and cold distribution lines." (ExhibitB at 3).
Again, the wall to the kitchen "has been repairedbefore." (DA Test. at By
14:17-15:3).
way of explanation,
Universal's expert testified:
Page 14 of 18
A. Yeah. at bathrco rn , ?r he cr i:est-
bathrocm anzi the kitchen, they shdred '-hd L
plambing wall, and that's done in a lot of
houses because they use cne, like, plumbing for
rwo a:eas that need plumbing sc they don'f have
'-o rurL pipes everywhere.
S!] lE thoge pi c Lures , I dor.
'
t- see
any damage. Like, L don't see staining, L don't
aee molri, I
don't see dererjcra?ion. On the
*2tchen wall heh=nd rhe ba rhri:orr., I mea n the
wall exactly f<]I '-he k.tcheri is clear:, and I
would expe c L L a see sone kin ci cf std-n-ng it Lhe }
leak was active at the time when they opened the
wall and took the pictures. And 1 dldc't see
any of That.
(DA Test. at 21:4-18).
In sum, in 2017, the Property had a slab leak that could only be repairedby reroutingthe
hot and cold supply lines between the guest bathroom and the kitchen. During the repiping,4
Star Solutions also conducted a "water line repair(copper)."(ExhibitB at 3).Universal's expert
testified that the photographs depictedthat these repairshad been conducted. The upshot of her
testimony is that 4 Star Services accessed the plumbing lines through the kitchen,which explains
why inside ofthe kitchen wall was spotless.
Despite this,Plaintiff testified that the priorclaim did not affect the kitchen and the she
was unaware of any priorissues with the plumbing in the guest bathroom. She testified:
Page 15 of 18
Q. I meant to ask you, the 2016 claim :S
g
that you had, do you remember there being an
issue with the plumbing in the same bathroom and t
f:
the kitchen area, the one that shares a wall?
A. It wasn't plumbing in the kitchen
area. It was plumbing in the master bedroom,
which is on the opposite side of the house. It
was in the wall between the master bedroom and
bathroom. SO in the closet, in the master 1.
bedroom closet, that wall that adjoins the
bathroom, that's where the leak started, and
that's what was the reason for the pipe leak.
Q And you weren't aware of any issues ti
?.:
with the plumbing in that guest bathroom that
was affected in 2020 and that kitchen; were you t
not aware of that?
A. Not until October 14th, 2020, when
the tiles were popping off.
Q. So not aware of it from the 2016
claim, correct?
A NO.
d.
Q And you hired Four Star Services for
the 2016 claim to deal with the leak; does that
c
ring any bells? t
A. Yes, yes. 8
(IQ Test. at 116:11-117:10).She made that testimonydespite(1)having retained copiesof the
documents from the 2016 claim but not providing them to Universal; and (2)having been given
copiesof the documents from Universal "justlike a few days ago." (Factsat 718).
Irma Qureshi's trial testimony was inundated with falsehoods, some of which Universal
has left Surely