On April 17, 2020 a
Party Discovery
was filed
involving a dispute between
Davis Anthony Jr,
and
Security First Florida,
Security First Insurance Company,
for CONTRACT & INDEBTEDNESS
in the District Court of Brevard County.
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Filing # 106408909 E-Filed 04/17/2020 04:39:46 PM
IN THE CIRCUIT COURT OF THE
EIGHTEENTH JUDICIAL CIRCUIT IN
AND FOR BREVARD COUNTY, FL
CASE NO.
ANTHONY DAVIS JR.,
Plaintiff,
Vv
SECURITY FIRST INSURANCE COMPANY
DBA SECURITY FIRST FLORIDA,
Defendant.
/
REQUEST TO PRODUCE
Plaintiff, ANTHONY DAVIS JR., pursuant to Florida Rule of Civil Procedure 1.350,
requests the Defendant, SECURITY FIRST INSURANCE COMPANY DBA SECURITY
FIRST FLORIDA, a corporation authorized and doing business in the state of Florida, to
furnish copies of the following documents to the offices of the undersigned attorney within
45 days from the date of service hereof:
1 Certified copy of all insurance policies that insured Plaintiff's dwelling.
2 All correspondence, including electronic as well as paper format, exchanged
between Plaintiff and Defendant relative to the claim(s) at issue in this lawsuit.
3 All non-privileged portions of the claim file. For any items withheld, please set
forth the nature of the privilege or protection allowing you to withhold the document, the
date of the document, the drafter, recipient, and a general description of the document.
4 Copies of any and all forms, correspondence, or reports received by you or
any of your agents on your behalf concerning the Plaintiff's losses from anyone.
Filing 106408909 VS 05-2020-CA-024628-XXXX-XX
5 Any and all statements taken by the Defendant of any witnesses with regard
to any fact relevant to this case, including any statements taken prior to the filing of suit in
this matter.
6 Any and all photographs concerning Plaintiff's dwelling in the possession of
Defendant and any of Defendant's adjusters, agents, employees, experts, or consultants in
ative digital format.
7 All audiotapes, recordings, and transcripts of any statement given by Plaintiff.
8 Copies of all IRS Forms 1099 from Defendant to any consultants who
examined Plaintiffs dwelling (whether engineers, contractors, plumbers, or otherwise) for
past 5 years for the evaluation of claims submitted to Defendant by Defendant's insureds.
9 The complete underwriting file with regard to Defendant's issuance of
insurance on the subject risk and all renewals.
10. Defendant’s underwriting manual(s) in effect at the time of the issuance or
renewal of all policies issued to Plaintiff.
IT IS HEREBY requested that the aforesaid production be made within 45 days from
the date of service at the office of Corey B. Justus, Esquire, The Nation Law Firm, 570
Crown Oak Centre, Longwood, FL 32750. Inspection will be made by visual observation,
examination and/or copying.
Dated this 17 day of April, 2020.
Filing 106408909 VS 05-2020-CA-024628-XXXX-XX
THE NATION LAW FIRM, LLP
a
Core stus, Esquire
Florida Bar No. 113864
570 Crown Oak Centre Drive
Longwood, FL 32750
Telephone: (407) 339-1104
Facsimile: (407) 339-1118
Primary Email: lobrien@nationlaw.com
Secondary Email: cjustus@nationlaw.com
Attorneys for Plaintiff
Filing 106408909 VS 05-2020-CA-024628-XXXX-XX
Document Filed Date
April 17, 2020
Case Filing Date
April 17, 2020
Category
CONTRACT & INDEBTEDNESS
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Filing # 106408909 E-Filed 04/17/2020 04:39:46 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FL CASE NO. ANTHONY DAVIS JR., Plaintiff, Vv SECURITY FIRST INSURANCE COMPANY DBA SECURITY FIRST FLORIDA, Defendant. / REQUEST TO PRODUCE Plaintiff, ANTHONY DAVIS JR., pursuant to Florida Rule of Civil Procedure 1.350, requests the Defendant, SECURITY FIRST INSURANCE COMPANY DBA SECURITY FIRST FLORIDA, a corporation authorized and doing business in the state of Florida, to furnish copies of the following documents to the offices of the undersigned attorney within 45 days from the date of service hereof: 1 Certified copy of all insurance policies that insured Plaintiff's dwelling. 2 All correspondence, including electronic as well as paper format, exchanged between Plaintiff and Defendant relative to the claim(s) at issue in this lawsuit. 3 All non-privileged portions of the claim file. For any items withheld, please set forth the nature of the privilege or protection allowing you to withhold the document, the date of the document, the drafter, recipient, and a general description of the document. 4 Copies of any and all forms, correspondence, or reports received by you or any of your agents on your behalf concerning the Plaintiff's losses from anyone. Filing 106408909 VS 05-2020-CA-024628-XXXX-XX 5 Any and all statements taken by the Defendant of any witnesses with regard to any fact relevant to this case, including any statements taken prior to the filing of suit in this matter. 6 Any and all photographs concerning Plaintiff's dwelling in the possession of Defendant and any of Defendant's adjusters, agents, employees, experts, or consultants in ative digital format. 7 All audiotapes, recordings, and transcripts of any statement given by Plaintiff. 8 Copies of all IRS Forms 1099 from Defendant to any consultants who examined Plaintiffs dwelling (whether engineers, contractors, plumbers, or otherwise) for past 5 years for the evaluation of claims submitted to Defendant by Defendant's insureds. 9 The complete underwriting file with regard to Defendant's issuance of insurance on the subject risk and all renewals. 10. Defendant’s underwriting manual(s) in effect at the time of the issuance or renewal of all policies issued to Plaintiff. IT IS HEREBY requested that the aforesaid production be made within 45 days from the date of service at the office of Corey B. Justus, Esquire, The Nation Law Firm, 570 Crown Oak Centre, Longwood, FL 32750. Inspection will be made by visual observation, examination and/or copying. Dated this 17 day of April, 2020. Filing 106408909 VS 05-2020-CA-024628-XXXX-XX THE NATION LAW FIRM, LLP a Core stus, Esquire Florida Bar No. 113864 570 Crown Oak Centre Drive Longwood, FL 32750 Telephone: (407) 339-1104 Facsimile: (407) 339-1118 Primary Email: lobrien@nationlaw.com Secondary Email: cjustus@nationlaw.com Attorneys for Plaintiff Filing 106408909 VS 05-2020-CA-024628-XXXX-XX