Preview
Filing# 154245959 E-Filed 07/28/2022 12:35:43 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
Case No.: CACE-21-007642
NECHAMA & AMIR BEN-ISHAY,
Plaintiffs,
V
TYPTAP INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S SUPPLEMENTAL REQUEST FOR PRODUCTION OF DOCUMENTS
Defendant, TYPTAP INSURANCE COMPANY, pursuant to Rule 1.350, Florida Rules of
Civil Procedure, hereby requests that Plaintiffs, NECHAMA & AMIR BEN-ISHAY, produce the
following for inspectionand/or copying at the offices of the undersigned counsel within 30 days
after service of this request.
DEFINITIONS
1. The term "documents" means and includes,without limitation,all writingsof any
kind, includingthe originalsand all non-identical copies or drafts,whether printed,recorded,
stored,or reproduced by any mechanical or electronic process or written or produced by hand,
includingcomputer tapes (and backup tapes),whether different from the originalby reason of any
notation made on such copy or draft or otherwise including,without limitation,correspondence,
memoranda, notes, diaries,statistics, e-mail,electronic computer files,
letters, telegrams,minutes,
contracts, reports, accident reports, incident reports, studies,calculations,
computations,surveys,
trade
returns, summaries, pamphlets,books, prospectuses, circulars,
checks, statements, receipts,
letters, advertisements, interoffice communications, offers, notations of any sort of
conversation(s),telephone calls,meetings or other communications, bulletins,printed matter,
computer print-outs, teletypes,facsimiles,invoices, work sheets and all drafts,alterations,
modifications,changes, and amendments of any of the foregoing,graphic or aural writs,records
or representations of any kind including,without limitation,photographs, charts, graphs,
microfiche, microfilm, videotape,recordings,motion pictures;and electronic,mechanical or
of any kind including,without limitation,tapes, cassettes and
electric records or representations
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/28/2022 12:35:43 PM.****
CASE NO.: CACE-21-007642
disc recordings,and writingsand printedmaterial of every kind, whether or not the document is
out of your possession,
custody or control.
2. The term "correspondence" means any tangibleobjectthat conveys information or
memorializes information that was conveyed in tangibleor oral form including,but not limited to,
memoranda, electronic mail (otherwiseknown as "e-mail"),facsimiles,reports,
writings,letters,
notes, telegramsand interoffice communication.
3 The term "relating
to" as used herein is defined to mean evidencing,referringto,
concerning,or in any
pertainingto, consistingof,reflecting, way logicallyor factuallyconnected
with the matters discussed.
4. The term "property"or "subjectproperty"refers to the property located at 4830
NW 65 -th
Avenue, Lauderhill,FL 33319.
5. The term "loss" or "this claim" refers to the loss described in the Complaint or the
loss reportedto for a date of loss occurringon or about November 8,2020.
6. The term "you" or "your" refers to Plaintiffs, NECHAMA & AMIR BEN-ISHAY.
DOCUMENTS REQUESTED
1. Any and all documents regardingincurred expenses as related to this loss.
2. Any and all photographs, videos, estimates, contracts, receipts,statements,
invoices, and work orders from Victory E&I
Roofing and Construction, LLC related to a roof
replacement,repair,or improvement on the subjectproperty.
3. Any and all photographs, videos, estimates, contracts, receipts,statements,
invoices, and work orders from Property One Int'1,Inc. and/or Optimum Contractors, Inc related
to additions,repairs, remodels, or improvements to the subjectproperty.
4. Any and all photographs, videos, estimates, contracts, receipts,statements,
invoices, and work orders from any company, individual,entity,or party relatingto additions,
remodels, or improvements to the subjectproperty related to the loss.
repairs,
5. Any and all permit applicationsfor the subjectproperty since January 2007.
6. Any and all permitsissued for the subjectproperty since January 2007.
7. Any and proof or documentation related to roofrepairs,
all roof improvements, or
roof replacements on the subjectproperty since January 2007 to the present.
CASE NO.: CACE-21-007642
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28? )th
day o f July,2022, this document was filed using the
Florida Courts E-FilingPortal. This document is being served on all counsel and pro se partiesof
record by the Florida Courts E-FilingPortal, pursuant to and in compliance with Fla. R. Jud.
Admin. 2.516. The mailing and electronic addresses are: Brett L. Schlacter, Esquire;
SCHLACTER LAW, bls@schlacterlaw.com, 1108 Kane Concourse, Suite 305, Bay Harbor
Islands,FL 33154, (305) 999-1111 / Nechama & Amir
(305) 440-1354 (F),Attorney for Plaintiffs,
Ben-Ishay.
KELLEY KRONENBERG
/WRDBNE.COUierIII
Robert E. Collier III, Esq.
Fla. Bar No.. 1031196
Kathryn M. Winkler, Esq.
Fla. Bar No.. 93147
10360 West State Road 84
Fort Lauderdale, FL 33324
Telephone: (954) 370-9970
Facsimile: (954) 382-1988
Attorneys for Defendant
Address for service of pleadingsonly
rcollier@kelleykronenberg.com
kwinkler@kelleykronenberg.com
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Filing# 154245959 E-Filed 07/28/2022 12:35:43 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE-21-007642 NECHAMA & AMIR BEN-ISHAY, Plaintiffs, V TYPTAP INSURANCE COMPANY, Defendant. i DEFENDANT'S SUPPLEMENTAL REQUEST FOR PRODUCTION OF DOCUMENTS Defendant, TYPTAP INSURANCE COMPANY, pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby requests that Plaintiffs, NECHAMA & AMIR BEN-ISHAY, produce the following for inspectionand/or copying at the offices of the undersigned counsel within 30 days after service of this request. DEFINITIONS 1. The term "documents" means and includes,without limitation,all writingsof any kind, includingthe originalsand all non-identical copies or drafts,whether printed,recorded, stored,or reproduced by any mechanical or electronic process or written or produced by hand, includingcomputer tapes (and backup tapes),whether different from the originalby reason of any notation made on such copy or draft or otherwise including,without limitation,correspondence, memoranda, notes, diaries,statistics, e-mail,electronic computer files, letters, telegrams,minutes, contracts, reports, accident reports, incident reports, studies,calculations, computations,surveys, trade returns, summaries, pamphlets,books, prospectuses, circulars, checks, statements, receipts, letters, advertisements, interoffice communications, offers, notations of any sort of conversation(s),telephone calls,meetings or other communications, bulletins,printed matter, computer print-outs, teletypes,facsimiles,invoices, work sheets and all drafts,alterations, modifications,changes, and amendments of any of the foregoing,graphic or aural writs,records or representations of any kind including,without limitation,photographs, charts, graphs, microfiche, microfilm, videotape,recordings,motion pictures;and electronic,mechanical or of any kind including,without limitation,tapes, cassettes and electric records or representations *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/28/2022 12:35:43 PM.**** CASE NO.: CACE-21-007642 disc recordings,and writingsand printedmaterial of every kind, whether or not the document is out of your possession, custody or control. 2. The term "correspondence" means any tangibleobjectthat conveys information or memorializes information that was conveyed in tangibleor oral form including,but not limited to, memoranda, electronic mail (otherwiseknown as "e-mail"),facsimiles,reports, writings,letters, notes, telegramsand interoffice communication. 3 The term "relating to" as used herein is defined to mean evidencing,referringto, concerning,or in any pertainingto, consistingof,reflecting, way logicallyor factuallyconnected with the matters discussed. 4. The term "property"or "subjectproperty"refers to the property located at 4830 NW 65 -th Avenue, Lauderhill,FL 33319. 5. The term "loss" or "this claim" refers to the loss described in the Complaint or the loss reportedto for a date of loss occurringon or about November 8,2020. 6. The term "you" or "your" refers to Plaintiffs, NECHAMA & AMIR BEN-ISHAY. DOCUMENTS REQUESTED 1. Any and all documents regardingincurred expenses as related to this loss. 2. Any and all photographs, videos, estimates, contracts, receipts,statements, invoices, and work orders from Victory E&I Roofing and Construction, LLC related to a roof replacement,repair,or improvement on the subjectproperty. 3. Any and all photographs, videos, estimates, contracts, receipts,statements, invoices, and work orders from Property One Int'1,Inc. and/or Optimum Contractors, Inc related to additions,repairs, remodels, or improvements to the subjectproperty. 4. Any and all photographs, videos, estimates, contracts, receipts,statements, invoices, and work orders from any company, individual,entity,or party relatingto additions, remodels, or improvements to the subjectproperty related to the loss. repairs, 5. Any and all permit applicationsfor the subjectproperty since January 2007. 6. Any and all permitsissued for the subjectproperty since January 2007. 7. Any and proof or documentation related to roofrepairs, all roof improvements, or roof replacements on the subjectproperty since January 2007 to the present. CASE NO.: CACE-21-007642 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 28? )th day o f July,2022, this document was filed using the Florida Courts E-FilingPortal. This document is being served on all counsel and pro se partiesof record by the Florida Courts E-FilingPortal, pursuant to and in compliance with Fla. R. Jud. Admin. 2.516. The mailing and electronic addresses are: Brett L. Schlacter, Esquire; SCHLACTER LAW, bls@schlacterlaw.com, 1108 Kane Concourse, Suite 305, Bay Harbor Islands,FL 33154, (305) 999-1111 / Nechama & Amir (305) 440-1354 (F),Attorney for Plaintiffs, Ben-Ishay. KELLEY KRONENBERG /WRDBNE.COUierIII Robert E. Collier III, Esq. Fla. Bar No.. 1031196 Kathryn M. Winkler, Esq. Fla. Bar No.. 93147 10360 West State Road 84 Fort Lauderdale, FL 33324 Telephone: (954) 370-9970 Facsimile: (954) 382-1988 Attorneys for Defendant Address for service of pleadingsonly rcollier@kelleykronenberg.com kwinkler@kelleykronenberg.com