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 NOTICE OF SERVICE OF SUPPLEMENTAL SET OF
INTERROGATORIES TO PLAINTIFFS
COMES NOW Defendant, TYPTAP INSURANCE COMPANY, by and through
undersigned counsel, pursuant to Rule 1.340, Florida Rules of Civil Procedure, hereby files its
Notice of Serving its Supplemental Set of Interrogatories
to Plaintiffs to be answered within thirty
(30)days after service hereof.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/28/2022 12:35:43 PM.****
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
CASE NO.: CACE-21-007642
DEFINITIONS
1. The term "documents" means and includes,without limitation,all writingsof any
kind, including the 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 original by reason of any
notation made on such copy or draft or otherwise including,without limitation,correspondence,
memoranda, notes, diaries,statistics, letters,e-mail, electronic computer files,
telegrams,minutes,
contracts, reports, accident reports, incident reports, studies,calculations,computations,surveys,
checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, circulars, trade
letters, advertisements, interoffice communications, offers, notations of any sort of
conversation(s), telephone calls,meetings or other communications, bulletins,printedmatter,
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 representationsof any kind including, without limitation,photographs, charts, graphs,
microfiche, microfilm, videotape, recordings,motion pictures;and electronic,mechanical or
electric records or representationsof any kind including,without limitation,
tapes, cassettes and
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 "relatingto" 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 "and" be read and appliedas though
as well as "or" as used herein shall
interchangeableand shall be construed either disjunctively or conjunctivelyso as to requirethe
fullest and most complete disclosure of all requiredinformation and documents.
5. The phrase "describe and explain"and the term "state" as used herein are intended
to and shall be interpreted
to request a full and fair statement of the fact or matter being described
and explained,includinga statement of all facts,statements, events and circumstances necessary
to understand and evaluate the fact or matter being described and explained.
6. The term "identify"
as used requestingan
in each of the followingInterrogatories
identification of documents is intended to be interpretedto request and require:
A. The date of the document;
B. The originator
ofthe document;
C. The type of document;
CASE NO.: CACE-21-007642
D. The addressee ofthe document, if any;
E. Identification of persons to whom copies of the documents were furnished;
F. Details as to the custody ofthe document on the date the Interrogatories
are
answered;
G. Specificpage numbers where the information requestedmay be found, if
appropriate;or, alternatively,documents may be identified by numbering
each such document and referringto the number in the answer and
providing a true copy of each such numbered document with the Answers
to Interrogatories.
7. The term "identify"as used in each of the followingInterrogatories
requestingthe
identification of persons is intended to be interpretedto request and require for each witness
known.
A. The full name of the individual;
B. The last known address and phone number of the individual;
C. The last known place,address and phone number of employment of the
individual;
D. The substance of the witness' knowledge or information relatingto the
information requested.
8 The term "property" or "subjectproperty" refers to the property located at 4830
NW 65 -th
Avenue, Lauderhill,FL 33319.
9- The term "you" or "your" refers to Plaintiffs, NECHAMA & AMIR BEN-ISHAY.
10. The term "loss" or "this claim" refers to the loss described in the Complaint or the
loss reportedto Defendant for a date o f loss occurringon or about November 8,2020.
INSTRUCTIONS
Before answering the following Interrogatories, will you please make such inquiriesof
your agents, servants, employees and/or attorneys as will enable you to make full and true answers
to the following,in accordance with the applicableFlorida Rules of Civil Procedure. Additionally,
if more space is required,please use a separate sheet of paper and attach same behind the sheet
where the respectivequestionappears.
CASE NO.: CACE-21-007642
INTERROGATORIES
1. State the name and and any
address of the person answering these Interrogatories
individual assisting
the person answering these Interrogatories.
2. Please provide the date when construction,repairs,and/or improvements began
regardingthe second floor addition to the subjectproperty.
3 Please provide the date when roof repairs,improvements, and/or replacements
began regardingthe roof on the subjectproperty.
4. Please state the names of all individuals,companies, entities, and/or any parties
involved in the repairand/or construction regardingthe addition ofthe second floor on the subject
property.
5. Please state the names of all
individuals,companies, entities,and/or any parties
involved in the repairand/or replacement of the roof on the subjectproperty.
6. Please state the date of any agreements, contracts, etc. that you executed with
Victory E&I Roofing and Construction LLC.
CASE NO.: CACE-21-007642
7. Please state the date of any agreements, contracts, etc. that you executed with
Property One Int'l or Optimum Contractors,Inc.
8 Please state what repairs,improvements, and/or additions have been completed
regardingthe addition ofthe second floor on the subjectproperty.
9- Please state what repairs,
improvements, and/or replacements have been completed
regardingthe roof on the subjectproperty
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 NOTICE OF SERVICE OF SUPPLEMENTAL SET OF INTERROGATORIES TO PLAINTIFFS COMES NOW Defendant, TYPTAP INSURANCE COMPANY, by and through undersigned counsel, pursuant to Rule 1.340, Florida Rules of Civil Procedure, hereby files its Notice of Serving its Supplemental Set of Interrogatories to Plaintiffs to be answered within thirty (30)days after service hereof. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/28/2022 12:35:43 PM.**** 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 CASE NO.: CACE-21-007642 DEFINITIONS 1. The term "documents" means and includes,without limitation,all writingsof any kind, including the 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 original by reason of any notation made on such copy or draft or otherwise including,without limitation,correspondence, memoranda, notes, diaries,statistics, letters,e-mail, electronic computer files, telegrams,minutes, contracts, reports, accident reports, incident reports, studies,calculations,computations,surveys, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, circulars, trade letters, advertisements, interoffice communications, offers, notations of any sort of conversation(s), telephone calls,meetings or other communications, bulletins,printedmatter, 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 representationsof any kind including, without limitation,photographs, charts, graphs, microfiche, microfilm, videotape, recordings,motion pictures;and electronic,mechanical or electric records or representationsof any kind including,without limitation, tapes, cassettes and 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 "relatingto" 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 "and" be read and appliedas though as well as "or" as used herein shall interchangeableand shall be construed either disjunctively or conjunctivelyso as to requirethe fullest and most complete disclosure of all requiredinformation and documents. 5. The phrase "describe and explain"and the term "state" as used herein are intended to and shall be interpreted to request a full and fair statement of the fact or matter being described and explained,includinga statement of all facts,statements, events and circumstances necessary to understand and evaluate the fact or matter being described and explained. 6. The term "identify" as used requestingan in each of the followingInterrogatories identification of documents is intended to be interpretedto request and require: A. The date of the document; B. The originator ofthe document; C. The type of document; CASE NO.: CACE-21-007642 D. The addressee ofthe document, if any; E. Identification of persons to whom copies of the documents were furnished; F. Details as to the custody ofthe document on the date the Interrogatories are answered; G. Specificpage numbers where the information requestedmay be found, if appropriate;or, alternatively,documents may be identified by numbering each such document and referringto the number in the answer and providing a true copy of each such numbered document with the Answers to Interrogatories. 7. The term "identify"as used in each of the followingInterrogatories requestingthe identification of persons is intended to be interpretedto request and require for each witness known. A. The full name of the individual; B. The last known address and phone number of the individual; C. The last known place,address and phone number of employment of the individual; D. The substance of the witness' knowledge or information relatingto the information requested. 8 The term "property" or "subjectproperty" refers to the property located at 4830 NW 65 -th Avenue, Lauderhill,FL 33319. 9- The term "you" or "your" refers to Plaintiffs, NECHAMA & AMIR BEN-ISHAY. 10. The term "loss" or "this claim" refers to the loss described in the Complaint or the loss reportedto Defendant for a date o f loss occurringon or about November 8,2020. INSTRUCTIONS Before answering the following Interrogatories, will you please make such inquiriesof your agents, servants, employees and/or attorneys as will enable you to make full and true answers to the following,in accordance with the applicableFlorida Rules of Civil Procedure. Additionally, if more space is required,please use a separate sheet of paper and attach same behind the sheet where the respectivequestionappears. CASE NO.: CACE-21-007642 INTERROGATORIES 1. State the name and and any address of the person answering these Interrogatories individual assisting the person answering these Interrogatories. 2. Please provide the date when construction,repairs,and/or improvements began regardingthe second floor addition to the subjectproperty. 3 Please provide the date when roof repairs,improvements, and/or replacements began regardingthe roof on the subjectproperty. 4. Please state the names of all individuals,companies, entities, and/or any parties involved in the repairand/or construction regardingthe addition ofthe second floor on the subject property. 5. Please state the names of all individuals,companies, entities,and/or any parties involved in the repairand/or replacement of the roof on the subjectproperty. 6. Please state the date of any agreements, contracts, etc. that you executed with Victory E&I Roofing and Construction LLC. CASE NO.: CACE-21-007642 7. Please state the date of any agreements, contracts, etc. that you executed with Property One Int'l or Optimum Contractors,Inc. 8 Please state what repairs,improvements, and/or additions have been completed regardingthe addition ofthe second floor on the subjectproperty. 9- Please state what repairs, improvements, and/or replacements have been completed regardingthe roof on the subjectproperty