Party Discovery: ANTHONY DAVIS J VS SECURITY

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                                Filing # 143382528 E-Filed 02/07/2022 09:53:33 AM



                                                                                 IN THE CIRCUIT COURT OF THE
                                                                                 EIGHTEENTH JUDICIAL CIRCUIT IN
                                                                                 AND FOR BREVARD COUNTY, FL

                                                                                 CASE NO. 052020CA024628XXXXXX
            ANTHONY DAVIS JR.,

                    Plaintiff,

            V.

            SECURITY FIRST INSURANCE COMPANY
            DBA SECURITY FIRST FLORIDA,

                    Defendant.
                                                                        /

                    PLAINTIFF'S SUPPLEMENTAL REQUEST TO PRODUCE TO DEFENDANT

                    COMES          NOW      the      Plaintiff,     ANTHONY             DAVIS      JR.,     by     and        through      the

            undersigned attorney, and pursuant to Florida Rule of Civil Procedure 1.350, requests the

            Defendant,      SECURITY              FIRST       INSURANCE               COMPANY        DBA         SECURITY            FIRST

            FLORIDA,      to furnish copies of the following documents to the offices of the undersigned

            attorney within thirty (30) days from the date of service hereof:
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                             All non-privileged portions of the underwriting file with regard to Defendant's

                             issuance of insurance on the subject property and all renewals.

                             Any      and    all     photographs         of     the     subject    property        contained         in    the

                             underwriting file with            regard to Defendant's              issuance of insurance              on the

                             subject property, and all renewals.

                             Any     and    all     reports       contained      in    the   underwriting        file    with     regard    to

                             Defendant's issuance of insurance on the subject risk, and all renewals, that

                             depict the condition of the subject property.

                             Defendant's underwriting manual(s) in effect at the time of the issuance or

                                 enewal_of_all         olicies_issued_to_Plaintiff_that_identi                          the     Defendant's




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 Filing 143382528                           ANTHONY DAVIS J VS SECURITY                                                 05-2020-CA-024628-XXXX-XX
guidelines with respect to the plumbing conditions and issuance of insurance

                            policies.

                            Any and all examination under oath transcripts with regard to the insurance

                            claim that is the subject of this lawsuit.


                                              CERTIFICATE OF SERVICE

           I HEREBY CERTIFY that a true and correct copy of the foregoing Notice has been filed with the

           Clerk of the Court via E-Portal system which will send electronic notice to Iniv Gabay,     Esquire;

           Jennifer     L       Velazco,      Esquire;      and      Ashley     Ward-Singleton,        Esquire,

           [iniv.gabay@qpwblaw.com; jvelazco@qpwblaw.com;

           ashley.wardsingleton@qpwblaw.com; cynthia.mejias@qpwblaw.com] Quintairos, Prieto,

           Wood & Boyer, P.A., 1410 North Westshore Boulevard Suite 200, Tampa,                   FL    33607,

           this 7" day of February, 2022.



                                                           ls! Gina Kimmel
                                                           GINA KIMMEL, ESQ., Esquire
                                                           Florida Bar No. 0121929
                                                           Morgan & Morgan, P.A.
                                                           20 N. Orange Avenue, 4” Floor
                                                           Post Office Box 4979
                                                           Orlando, Florida 32802-4979
                                                           Telephone: (407) 420-1414
                                                           Facsimile: (407) 245-3414
                                                           Primary email: GKimmel@forthepeople.com
                                                           Secondary email:SFloresrivera@forthepeople.com
                                                           LRolon@forthepeople.com
                                                           Attorneys for Plaintiff
           GK/sfr




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Filing 143382528                        ANTHONY DAVIS J VS SECURITY                        05-2020-CA-024628-XXXX-XX