Preview
Filing# 177368513 E-Filed 07/13/2023 03:29:01 PM
IN THE COUNTY COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
DRI-MAX RESTORATION, LLC. A/A/O CASE NO. CACE-21-010647
VERONICA TOMOR & FRED GAROFALO,
Plaintiff.
V
UNIVERSAL PROPERTY AND CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S AMENDED FIRST REQUEST FOR PRODUCTION
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by
and through undersigned counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure,
requests that Plaintiff DRI-MAX RESTORATION, LLC. A/A/O VERONICA TOMOR & FRED
GAROFALO provide a privilegelog for all matters to which an objectionis raised and to produce
copying or photographing,within thirty(30)days, the following documents:
for inspection,
DEFINITIONS
1. "Calendar Year" means that period of time that begins at 12:01 a.m. on January 1 of any
given year and ends at 11.59 pm. on December 31 of that year.
2. "Claim" means the insurance claim Insured(s)(as defined herein) reported to
that
Defendant (as defined herein)and that serves as a basis for any causes of action asserted
againstDefendant in this action.
3. "Claimed Cause of Loss" means the event and/or reason that You (asdefined herein)are
claimingthat the Insured Property (as defined herein)was damaged.
4. "Concerning", "concern," or any other derivative thereof as used herein, shall be
construed as referringto, responding to, relatingto, pertaining to, connected with,
comprising, memorializing, commenting on, substantiating,regarding, discussing,
showing, describing, analyzing,and constituting.
reflecting,
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/13/2023 03:29:00 PM.****
Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC
CASE NO: CACE-21-010647
Page 2 of 7
5. "Control" means having possessionof and/or the power and/or authorityto request
possessionof the subjectmatter or a copy thereof, or direct the possession,movement,
ofthe subjectproperty or document.
transfer or other disposition
6. "Date" means the exact date (includingday,month, and year).Ifthe exact day, month, and
year is not ascertainable,then the best available approximation of the exact day, month,
and year.
7. "Defendant" means Universal Property & Casualty Insurance Company.
8. "Document" or"documents" means anythingwhich may be considered to be a document
or tangiblething within the meaning of Fla. R. Civ. P. 1.350 and means any and all
correspondence,records,reports, memoranda, notes, letters,
telegrams,emails,voicemails,
telexes,texts, messages (including,but not limited to, memos, notes and/or reports of
telephone conversations andconferences), studies, analyses, books, magazines,
booklets,pamphlets, circulars,
newspapers, publications, bulletins,instructions,
minutes,
or other communications (including,but not limited to, interoffice and intra-office
communications), questionnaires,surveys, contracts, memoranda of agreements,
assignments, books of account, journals, ledgers, summaries, opinions, reports,
evaluations, financial statements and all records of or reflectingbusiness operations,
mortgages, evaluations,orders,working papers, bills of lading,shippinglists, load sheets,
warehouse receipts, records of summaries of personal
letters of credit,insurance policies,
interviews or conversations, appointment calendars, diaries, schedules, printouts,
drawings, specifications, patents, patent applications,certificates of registration,
applications for registration,graphs, charts, studies, planning materials, statistical
statements and compilations,forecasts,work papers, invoices, statements, bills,checks,
bank books, bank statements, forms, vouchers, notebooks, data sheets, microfilm,
microfiche, photographicnegatives,audio tape, video tape, compact disks, blueprints,
architectural diagrams, schematics, logic diagrams, timing diagrams,
specifications,
pictures,photographs, microscopically obtained photographs, test results,belts, tapes,
magnetic tapes, paper tapes, plotteroutput recordings, discs, data cards, films, data
processingfiles,computer files and other computer readable records or programs and all
other written,printedor recorded matter of any kind, and all other data compilationsfrom
which information can be obtained, and translated,if necessary, and all originals, drafts
and copiesthereof. Any documents bearingany marks including, but not limited to, initials,
stamped indicia,comments, or notations,of any kind that are not a part ofthe originaltext
or photographic reproduction thereof are to be considered and identified as separate
documents.
9. "Dwelling" means the physical dwelling located at the Insured Property (as defined
herein).
10. "Insured" means the Named listed on the declarations page of the
Insured specifically
Policy(asdefined herein).
Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC
CASE NO: CACE-21-010647
Page 3 of 7
11. "Insured Property" means the real property specifically
listed on the declarations page of
the Policy(asdefined herein).
12. "Other Structures" means any structures located at the Insured Property that are set apart
from and/or not connected to the Dwelling including,but not limited to, those structures
connected only by a fence, utility
line,and/or similar connection.
13. "Person" or"Persons" shall mean any natural person but not
or any legalentityincluding,
limited to, a corporation,partnershipand unincorporated association,firm, jointventure,
proprietorship, and/or any other entityor group ofnatural persons or such entities,
singular
male, female, or neuter gender,as the context
or plural, may require,and any officer.
14. "Plaintiff" means any person and/or entitynamed in this action.
as a plaintiff
15. "Policy" means the insurance policythat serves as a basis for any causes of action asserted
againstDefendant in this lawsuit.
16. "Related to", "relating to", and "relate to" shall include pertainingto, referringto,
mentioning, evidencing,discussingor otherwise
relevant to, supporting,contradicting,
involving,whether directlyor indirectly,
the subjectmatter ofthe specifiedrequest.
17. "Universal" means Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE
COMPANY
18. "Written Communication" or "correspondence" means the conveyance of information
by a writing,whether by letters,
e-mails,memoranda, handwritten notes and/or faxes.
19. "Witness Statement" or "Statement" means a statement of any person with knowledge
of relevant facts,regardlessof when the statement was made, and is either (i)a written
statement signed or otherwise adopted and/or approved in writingby the person making it;
a stenographic,mechanical, electrical,
or, (ii) and/or other type of recording of a person's
oral statement and/or any substantially of such recording.
verbatim transcript
20. "You" or"Your" means the specific party respondingto these requests and/or any person
and/or entitynamed as a Plaintiff in this action.
21. "Your Counsel" means the attorney or attorneys who are representingor have represented
you either with regard the claim or in this lawsuit.
to
PRODUCTION REQUESTS
1. All documents relating
to your answers to Defendant's First Set of Interrogatories
to Plaintiff
served contemporaneously herewith.
2. All documents relatingto your answers to Defendant's First Requests for Admission served
contemporaneously herewith.
Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC
CASE NO: CACE-21-010647
Page 4 of 7
3. All documents, photographs,videos, and communications relatingto the subjectclaim and all
allegationsin the Complaint. All photographs/videosimages must be produced in color in its
jpg, jpeg.,.png, etc.)with readable,unaltered metadata.
format (e.g.,
native digital
4. All documents and communications relatingto monies owed or paid to public adjusters,
engineers,consultants,construction experts, inspectors,experts of any kind, repairpersonnel
and/or contractors in connection with the insurance claim or the prosecutionof this action,
includingbut not limited between the Plaintiff and the previouslyreferenced
to, contracts
individuals or entities,invoices, copies of checks, proof of payments, and copies of any
estimates provided to Plaintiff.
5. All documents and communications in your possessionrelating to monies owed or paid for
costs in connection with the insurance claim or the prosecutiono f this action.
6. All documents and communications in your possession relatingto damage to the property
described in the complaint within five (5)years priorto the loss at issue,at the time ofthe loss
at issue,or anytime subsequentto the claim at issue.
7. All documents and communications in your possessionrelating to any repairsor maintenance
done, or proposed to be done, within five (5) years priorto the loss at issue,at the time of the
loss at issue,or anytime subsequentto the claim at issue.
8. All documents and communications relating of any expert you anticipate
to the qualifications
callingat trial.
9. All documents and communications generated by any expert you have retained or consulted
with in connection with the insurance claim, as well as any documents and communications
he/she/theymay have relied upon to form an opinionrelating
to the insurance claim.
10. All documents and communications relatingto the terms and conditions upon which the receipt
of financial income, including damages in this action, will be divided between you, your
representatives,or anyone actingon your behalf and any publicadjuster, appraiser,attorney,
contractor, expert, repairpersonneland/or anyone else related to this claim.
11. All documents and communications between you, your representatives,
or anyone actingon
your behalf and:
a. Universal relatingto the property which constitutes the basis of this lawsuit,the alleged
loss which constitutes the basis of this lawsuit,insurance coverage and/or the insurance
claim which constitutes the basis of this lawsuit;
b. Your agents relatingto the property which constitutes the basisofthis lawsuit,the alleged
loss which constitutes the basis of this lawsuit,insurance coverage and/or the insurance
claim which constitutes the basis of this lawsuit;
c. Public adjusters,engineers,consultants, construction experts, inspectors,experts of any
kind, repairpersonnel and/or contractors to
relating the property which constitutes the
Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC
CASE NO: CACE-21-010647
Page 5 of 7
basis of this lawsuit,the allegedloss which constitutes the basis of this lawsuit,insurance
coverage and/or the insurance claim which constitutes the basis of this lawsuit;
d. Government including,but not limited to, buildinginspectors,
or public officials, code
enforcement and code inspectors,relatingto the property which constitutes the basis of
thislawsuit,the allegedloss which constitutes the basis ofthis lawsuit,insurance coverage
and/or the insurance claim which constitutes the basis of this lawsuit;
12. All documents and communications relatingto Universal, in your actual or constructive
possession,other than those documents provided by Universal in this lawsuit.
13. and credentials of any engineers,consultants,construction experts,
Alllicenses,certifications,
inspectors,experts of any kind, repairpersonnel,or contractors who participated in the
evaluation or repairof the property described in the complaint from the date of loss to the
current date.
14. All permits and applications to the property and the allegedloss described
for permitsrelating
in the complaint.
15. All to the insurance policywhich
documents and communications relating is the subjectofthis
lawsuit.
16. All documents and communications relating to your ownersh* of, or insurable interest in,the
property which is the subjectofthis lawsuit.
17. Your complete paper and electronic files,includingthe covers, relatingto the insurance claim.
This request includes but is not limited to, dry logs,equipment calculation sheets,assessments,
reports, and certificates of completion.
18. All documents and communications relating to the subjectmatter of this lawsuit (this
request
privilegeor the work product
does not seek any items which are protectedby the attorney-client
doctrine).
19. All documents and communications relating materials and other documents used to
to training
teach agents or brokershow to advertise,promote and sell the services Plaintiff provided or
sought to provide regardingthe subjectclaim.
20. All documents, communications, proofs of delivery,or certified mail receipts evincing
Plaintiff's compliance with Fla. Stat. § 627.7152.
21. A copy of the written notice of intent to initiate served to the Insured(s)at
litigation least 10
days before filingthis lawsuit, along with any attachments or documents served therewith
pursuant to Fla. Stat. § 627.7152.
22. A copy of the written notice of intent to initiate served to the Universal
litigation at least 10
days before filingthis lawsuit, along with any attachments or documents served therewith
pursuant to Fla. Stat. § 627.7152.
Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC
CASE NO: CACE-21-010647
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23. A detailed written invoice or estimate of services
provided or to be provided by Plaintiff
concerningthe property which is the subjectofthis lawsuit,including(1)itemized information
on equ*ment, materials,and suppliesand (2)the number of labor hours.
24. If Xactimate or any other software was used to generate the estimate(s)/amount(s)
billed,then
providethe pricelist used as well as an electronic version ofthe estimate in its originalformat,
includingbut not limited to the original .ESX file.
25. All documents and communications relatingto the basis or standard(s)used in calculatingthe
amount o f Plaintiff" s invoice(s)or estimate(s).
26. Any proof that the work billed for has been performed in accordance with acceptedindustry
standards.
27. All documents relied upon in presentingthe insurance claim described in the complaint.
28. All documents and communications relatingto your damages claimed in connection with the
insurance claim which constitutes the subjectof this lawsuit.
29. All documents and communications relatingto any purported assignment of benefits for the
insurance claim which constitutes the subjectofthis lawsuit.
30. All documents and communications relating to payments received by the Plaintiff for repairs
to the property described in the complaint as a result of the allegedloss which constitutes the
basis for this lawsuit.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via
Electronic Service to: Annette Del Aguila, Esq. at Your Insurance Attorney, PLLC.
(YIA7@Yourinsuranceattomey.com), counsel on
for Plaintiff, Thursday, July 15, 2023.
AttorneyMDefendant
Universal Property & Casualty Company
P.O. Box 9388
Fort Lauderdale, Florida 33309
Legal Assistant Telephone: (954) 828-0680
ReceptionistTelephone: (954) 958-3319
Telephone: (954) 958-3319
Toll-Free: 1-833-658-8594 (JudgesOnly)
Facsimile: (954) 958-1262
By: /s/ Eneami Bestman-Range
Eneami Bestman-Range, Esq.
Florida Bar No. 118571
Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC
CASE NO: CACE-21-010647
Page 7 of 7
For Service of Court Documents onlv:
Primary:upciceservice04@universalproperty.com
Secondary: cw0419@universalproperty.com
Tertiary:
eb0517@universalproperty.com
For Scheduling Matters:
Scheduling04@universalproperty.com
:Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com
or upciceservice04@universalpropertv.com.
Preview
Filing# 177368513 E-Filed 07/13/2023 03:29:01 PM IN THE COUNTY COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA DRI-MAX RESTORATION, LLC. A/A/O CASE NO. CACE-21-010647 VERONICA TOMOR & FRED GAROFALO, Plaintiff. V UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. i DEFENDANT'S AMENDED FIRST REQUEST FOR PRODUCTION Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by and through undersigned counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, requests that Plaintiff DRI-MAX RESTORATION, LLC. A/A/O VERONICA TOMOR & FRED GAROFALO provide a privilegelog for all matters to which an objectionis raised and to produce copying or photographing,within thirty(30)days, the following documents: for inspection, DEFINITIONS 1. "Calendar Year" means that period of time that begins at 12:01 a.m. on January 1 of any given year and ends at 11.59 pm. on December 31 of that year. 2. "Claim" means the insurance claim Insured(s)(as defined herein) reported to that Defendant (as defined herein)and that serves as a basis for any causes of action asserted againstDefendant in this action. 3. "Claimed Cause of Loss" means the event and/or reason that You (asdefined herein)are claimingthat the Insured Property (as defined herein)was damaged. 4. "Concerning", "concern," or any other derivative thereof as used herein, shall be construed as referringto, responding to, relatingto, pertaining to, connected with, comprising, memorializing, commenting on, substantiating,regarding, discussing, showing, describing, analyzing,and constituting. reflecting, *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/13/2023 03:29:00 PM.**** Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC CASE NO: CACE-21-010647 Page 2 of 7 5. "Control" means having possessionof and/or the power and/or authorityto request possessionof the subjectmatter or a copy thereof, or direct the possession,movement, ofthe subjectproperty or document. transfer or other disposition 6. "Date" means the exact date (includingday,month, and year).Ifthe exact day, month, and year is not ascertainable,then the best available approximation of the exact day, month, and year. 7. "Defendant" means Universal Property & Casualty Insurance Company. 8. "Document" or"documents" means anythingwhich may be considered to be a document or tangiblething within the meaning of Fla. R. Civ. P. 1.350 and means any and all correspondence,records,reports, memoranda, notes, letters, telegrams,emails,voicemails, telexes,texts, messages (including,but not limited to, memos, notes and/or reports of telephone conversations andconferences), studies, analyses, books, magazines, booklets,pamphlets, circulars, newspapers, publications, bulletins,instructions, minutes, or other communications (including,but not limited to, interoffice and intra-office communications), questionnaires,surveys, contracts, memoranda of agreements, assignments, books of account, journals, ledgers, summaries, opinions, reports, evaluations, financial statements and all records of or reflectingbusiness operations, mortgages, evaluations,orders,working papers, bills of lading,shippinglists, load sheets, warehouse receipts, records of summaries of personal letters of credit,insurance policies, interviews or conversations, appointment calendars, diaries, schedules, printouts, drawings, specifications, patents, patent applications,certificates of registration, applications for registration,graphs, charts, studies, planning materials, statistical statements and compilations,forecasts,work papers, invoices, statements, bills,checks, bank books, bank statements, forms, vouchers, notebooks, data sheets, microfilm, microfiche, photographicnegatives,audio tape, video tape, compact disks, blueprints, architectural diagrams, schematics, logic diagrams, timing diagrams, specifications, pictures,photographs, microscopically obtained photographs, test results,belts, tapes, magnetic tapes, paper tapes, plotteroutput recordings, discs, data cards, films, data processingfiles,computer files and other computer readable records or programs and all other written,printedor recorded matter of any kind, and all other data compilationsfrom which information can be obtained, and translated,if necessary, and all originals, drafts and copiesthereof. Any documents bearingany marks including, but not limited to, initials, stamped indicia,comments, or notations,of any kind that are not a part ofthe originaltext or photographic reproduction thereof are to be considered and identified as separate documents. 9. "Dwelling" means the physical dwelling located at the Insured Property (as defined herein). 10. "Insured" means the Named listed on the declarations page of the Insured specifically Policy(asdefined herein). Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC CASE NO: CACE-21-010647 Page 3 of 7 11. "Insured Property" means the real property specifically listed on the declarations page of the Policy(asdefined herein). 12. "Other Structures" means any structures located at the Insured Property that are set apart from and/or not connected to the Dwelling including,but not limited to, those structures connected only by a fence, utility line,and/or similar connection. 13. "Person" or"Persons" shall mean any natural person but not or any legalentityincluding, limited to, a corporation,partnershipand unincorporated association,firm, jointventure, proprietorship, and/or any other entityor group ofnatural persons or such entities, singular male, female, or neuter gender,as the context or plural, may require,and any officer. 14. "Plaintiff" means any person and/or entitynamed in this action. as a plaintiff 15. "Policy" means the insurance policythat serves as a basis for any causes of action asserted againstDefendant in this lawsuit. 16. "Related to", "relating to", and "relate to" shall include pertainingto, referringto, mentioning, evidencing,discussingor otherwise relevant to, supporting,contradicting, involving,whether directlyor indirectly, the subjectmatter ofthe specifiedrequest. 17. "Universal" means Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY 18. "Written Communication" or "correspondence" means the conveyance of information by a writing,whether by letters, e-mails,memoranda, handwritten notes and/or faxes. 19. "Witness Statement" or "Statement" means a statement of any person with knowledge of relevant facts,regardlessof when the statement was made, and is either (i)a written statement signed or otherwise adopted and/or approved in writingby the person making it; a stenographic,mechanical, electrical, or, (ii) and/or other type of recording of a person's oral statement and/or any substantially of such recording. verbatim transcript 20. "You" or"Your" means the specific party respondingto these requests and/or any person and/or entitynamed as a Plaintiff in this action. 21. "Your Counsel" means the attorney or attorneys who are representingor have represented you either with regard the claim or in this lawsuit. to PRODUCTION REQUESTS 1. All documents relating to your answers to Defendant's First Set of Interrogatories to Plaintiff served contemporaneously herewith. 2. All documents relatingto your answers to Defendant's First Requests for Admission served contemporaneously herewith. Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC CASE NO: CACE-21-010647 Page 4 of 7 3. All documents, photographs,videos, and communications relatingto the subjectclaim and all allegationsin the Complaint. All photographs/videosimages must be produced in color in its jpg, jpeg.,.png, etc.)with readable,unaltered metadata. format (e.g., native digital 4. All documents and communications relatingto monies owed or paid to public adjusters, engineers,consultants,construction experts, inspectors,experts of any kind, repairpersonnel and/or contractors in connection with the insurance claim or the prosecutionof this action, includingbut not limited between the Plaintiff and the previouslyreferenced to, contracts individuals or entities,invoices, copies of checks, proof of payments, and copies of any estimates provided to Plaintiff. 5. All documents and communications in your possessionrelating to monies owed or paid for costs in connection with the insurance claim or the prosecutiono f this action. 6. All documents and communications in your possession relatingto damage to the property described in the complaint within five (5)years priorto the loss at issue,at the time ofthe loss at issue,or anytime subsequentto the claim at issue. 7. All documents and communications in your possessionrelating to any repairsor maintenance done, or proposed to be done, within five (5) years priorto the loss at issue,at the time of the loss at issue,or anytime subsequentto the claim at issue. 8. All documents and communications relating of any expert you anticipate to the qualifications callingat trial. 9. All documents and communications generated by any expert you have retained or consulted with in connection with the insurance claim, as well as any documents and communications he/she/theymay have relied upon to form an opinionrelating to the insurance claim. 10. All documents and communications relatingto the terms and conditions upon which the receipt of financial income, including damages in this action, will be divided between you, your representatives,or anyone actingon your behalf and any publicadjuster, appraiser,attorney, contractor, expert, repairpersonneland/or anyone else related to this claim. 11. All documents and communications between you, your representatives, or anyone actingon your behalf and: a. Universal relatingto the property which constitutes the basis of this lawsuit,the alleged loss which constitutes the basis of this lawsuit,insurance coverage and/or the insurance claim which constitutes the basis of this lawsuit; b. Your agents relatingto the property which constitutes the basisofthis lawsuit,the alleged loss which constitutes the basis of this lawsuit,insurance coverage and/or the insurance claim which constitutes the basis of this lawsuit; c. Public adjusters,engineers,consultants, construction experts, inspectors,experts of any kind, repairpersonnel and/or contractors to relating the property which constitutes the Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC CASE NO: CACE-21-010647 Page 5 of 7 basis of this lawsuit,the allegedloss which constitutes the basis of this lawsuit,insurance coverage and/or the insurance claim which constitutes the basis of this lawsuit; d. Government including,but not limited to, buildinginspectors, or public officials, code enforcement and code inspectors,relatingto the property which constitutes the basis of thislawsuit,the allegedloss which constitutes the basis ofthis lawsuit,insurance coverage and/or the insurance claim which constitutes the basis of this lawsuit; 12. All documents and communications relatingto Universal, in your actual or constructive possession,other than those documents provided by Universal in this lawsuit. 13. and credentials of any engineers,consultants,construction experts, Alllicenses,certifications, inspectors,experts of any kind, repairpersonnel,or contractors who participated in the evaluation or repairof the property described in the complaint from the date of loss to the current date. 14. All permits and applications to the property and the allegedloss described for permitsrelating in the complaint. 15. All to the insurance policywhich documents and communications relating is the subjectofthis lawsuit. 16. All documents and communications relating to your ownersh* of, or insurable interest in,the property which is the subjectofthis lawsuit. 17. Your complete paper and electronic files,includingthe covers, relatingto the insurance claim. This request includes but is not limited to, dry logs,equipment calculation sheets,assessments, reports, and certificates of completion. 18. All documents and communications relating to the subjectmatter of this lawsuit (this request privilegeor the work product does not seek any items which are protectedby the attorney-client doctrine). 19. All documents and communications relating materials and other documents used to to training teach agents or brokershow to advertise,promote and sell the services Plaintiff provided or sought to provide regardingthe subjectclaim. 20. All documents, communications, proofs of delivery,or certified mail receipts evincing Plaintiff's compliance with Fla. Stat. § 627.7152. 21. A copy of the written notice of intent to initiate served to the Insured(s)at litigation least 10 days before filingthis lawsuit, along with any attachments or documents served therewith pursuant to Fla. Stat. § 627.7152. 22. A copy of the written notice of intent to initiate served to the Universal litigation at least 10 days before filingthis lawsuit, along with any attachments or documents served therewith pursuant to Fla. Stat. § 627.7152. Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC CASE NO: CACE-21-010647 Page 6 of 7 23. A detailed written invoice or estimate of services provided or to be provided by Plaintiff concerningthe property which is the subjectofthis lawsuit,including(1)itemized information on equ*ment, materials,and suppliesand (2)the number of labor hours. 24. If Xactimate or any other software was used to generate the estimate(s)/amount(s) billed,then providethe pricelist used as well as an electronic version ofthe estimate in its originalformat, includingbut not limited to the original .ESX file. 25. All documents and communications relatingto the basis or standard(s)used in calculatingthe amount o f Plaintiff" s invoice(s)or estimate(s). 26. Any proof that the work billed for has been performed in accordance with acceptedindustry standards. 27. All documents relied upon in presentingthe insurance claim described in the complaint. 28. All documents and communications relatingto your damages claimed in connection with the insurance claim which constitutes the subjectof this lawsuit. 29. All documents and communications relatingto any purported assignment of benefits for the insurance claim which constitutes the subjectofthis lawsuit. 30. All documents and communications relating to payments received by the Plaintiff for repairs to the property described in the complaint as a result of the allegedloss which constitutes the basis for this lawsuit. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via Electronic Service to: Annette Del Aguila, Esq. at Your Insurance Attorney, PLLC. (YIA7@Yourinsuranceattomey.com), counsel on for Plaintiff, Thursday, July 15, 2023. AttorneyMDefendant Universal Property & Casualty Company P.O. Box 9388 Fort Lauderdale, Florida 33309 Legal Assistant Telephone: (954) 828-0680 ReceptionistTelephone: (954) 958-3319 Telephone: (954) 958-3319 Toll-Free: 1-833-658-8594 (JudgesOnly) Facsimile: (954) 958-1262 By: /s/ Eneami Bestman-Range Eneami Bestman-Range, Esq. Florida Bar No. 118571 Dri-Max Restoration LLC. a/a/o Veronica Tomor & Fred Garofalo v. UPCIC CASE NO: CACE-21-010647 Page 7 of 7 For Service of Court Documents onlv: Primary:upciceservice04@universalproperty.com Secondary: cw0419@universalproperty.com Tertiary: eb0517@universalproperty.com For Scheduling Matters: Scheduling04@universalproperty.com :Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com or upciceservice04@universalpropertv.com.