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Filing # 176001659 E-Filed 06/23/2023 12:27:04 PM
H98041
IN THE CIRCUIT COURT OF THE TW NTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CASE NO: 23001753CA
JOHN MILLER AND TAMARA MILLER
Plaintiff(s),
vs.
HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY
Defendant.
_______________________________________/
DEFENDANT’S FIRST REQUEST FOR PRODUCTION
Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, by and
through its undersigned counsel and pursuant to Rule 1.350(a) of the Florida Rules of Civil
Procedure, hereby request(s) the Plaintiff(s) to produce and permit the inspection/copying of the
following designated documents that are in the possession, custody, or control of the Plaintiff(s
within thirty (30) days after service of this Request, at the offices of the undersigned attorneys for
the Defendant:
All documents exchanged between you or any agent or representative of yours and
Heritage Property and Casualty Insurance Company, and/or its agents from the reporting of the
alleged loss through the present date.
All documents evidencing agreements for representation between you and any
individual or business entity representing you in this claim, including but not limited to contracts,
letters of representation, correspondence, and fee schedules for representation by loss consultants,
public adjusters, or public adjuster firms. This request does not seek agreements for legal
representation.
All documents and correspondence between you and any third party vendor or
contractor relating to the loss.
All documents and correspondence between you and any handyman, person or
company that has performed any work on the property relating to the loss.
All documents evidencing the damages that you are claiming in this lawsuit,
including, but not limited to estimates, contracts, receipts, statements, invoices, and work orders.
All documents evidencing payment to any third-party for services relating to the
loss.
Any proof of loss statements from you relating to the claim.
All documents evidencing the repair and/or replacement of damaged property as a
result of the loss, including but not limited to contracts, receipts, canceled checks, bills of sale,
statements, ATM receipts, credit card statements, evidence of bank withdrawals, and invoices.
All documents evidencing any mitigation or repairs to any area of the property that
are being claimed as damaged in your loss.
The original .jpeg files for any photographs taken which show the alleged damage
at the property on or after the date of loss.
All videos, recordings, film, diagrams, photographs, drawings, charts, sketches or
any other depictions illustrating the damages sustained in the loss.
Any and all photographs or videos which show the damaged area, prior to the date
of the loss.
All engineer, or expert reports in support of the claim that the property has sustained
damage as a result of the alleged loss.
Any and all documents prepared by third parties who inspected or evaluated the
property and/or the damages as a result of the alleged loss.
All documents evidencing your efforts to protect the property from further damage.
All maintenance and/or repair records for the property from the date of loss thr
the present.
All documents relating to any prior insurance claims at the property, including, but
not limited to: proofs of loss; any repair receipts; estimates; photographs; invoices; evidences of
payments; and/or evidences of settlement.
All documents relating to any other losses at the property occurring prior to or
subsequent to the date of loss, including, but not limited to: proofs of loss; any repair receipts;
estimates; photographs; invoices; evidences of payments; and/or evidences of settlement.
Copies of all telephone records (land line and/or cellular) evidencing incoming and
outgoing calls for all adults residing at the Property encompassing the 30 days prior to the alleged
date of loss through 30 days after the alleged date of loss.
All documents in your possession relating to the loss alleged in the Complaint that
were not previously produced in response to the above requests.
Copies of any liens, sales contracts, disclosure reports, inspection reports, appraisal
reports and/or other documents relative to your purchase or acquisition of the Property.
A copy of any and all lease agreements, rental agreements, contracts or other
documents with any tenant or tenant(s) residing at the Property from the two years prior to the
alleged loss through the current date.
Copies of any and all documents created as part of the home inspection report from
your purchase of the subject property, including, but not limited to all inspection reports, 4-point
inspection reports, appraisal reports, photographs and videos in their native format.
Copies of any documentation evidencing repairs and/or renovations at the Property
that occurred during the five (5) years prior to the alleged loss.
Copies of any checks (front and back) for any repairs made to the property as a
result of this claim.
Copies of any policies of homeowners’ insurance which cover damage caused by
flood.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic
mail to Brooke Boltz, Esq., BOLTZ LEGAL, 1221 E. Broadway St., Suite 1011, Oviedo, FL
32765; brookeboltz@boltzlegal.com eservice@boltzlegal.com June 23, 2023, pursuant to
Rule 2.516.
ttorney for Heritage Property & Casualty
Insurance Company
1401 N. Westshore Boulevard
Tampa, FL 33607
Telephone: (727) 465-4711
abruce@heritagepci.com
smoya@heritagepci.com
rrexroad@heritagepci.com
By: \s\ Andrew Bruce________
ANDREW BRUCE, ESQUIRE
Florida Bar No. 99713
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Filing # 176001659 E-Filed 06/23/2023 12:27:04 PM H98041 IN THE CIRCUIT COURT OF THE TW NTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CASE NO: 23001753CA JOHN MILLER AND TAMARA MILLER Plaintiff(s), vs. HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY Defendant. _______________________________________/ DEFENDANT’S FIRST REQUEST FOR PRODUCTION Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, by and through its undersigned counsel and pursuant to Rule 1.350(a) of the Florida Rules of Civil Procedure, hereby request(s) the Plaintiff(s) to produce and permit the inspection/copying of the following designated documents that are in the possession, custody, or control of the Plaintiff(s within thirty (30) days after service of this Request, at the offices of the undersigned attorneys for the Defendant: All documents exchanged between you or any agent or representative of yours and Heritage Property and Casualty Insurance Company, and/or its agents from the reporting of the alleged loss through the present date. All documents evidencing agreements for representation between you and any individual or business entity representing you in this claim, including but not limited to contracts, letters of representation, correspondence, and fee schedules for representation by loss consultants, public adjusters, or public adjuster firms. This request does not seek agreements for legal representation. All documents and correspondence between you and any third party vendor or contractor relating to the loss. All documents and correspondence between you and any handyman, person or company that has performed any work on the property relating to the loss. All documents evidencing the damages that you are claiming in this lawsuit, including, but not limited to estimates, contracts, receipts, statements, invoices, and work orders. All documents evidencing payment to any third-party for services relating to the loss. Any proof of loss statements from you relating to the claim. All documents evidencing the repair and/or replacement of damaged property as a result of the loss, including but not limited to contracts, receipts, canceled checks, bills of sale, statements, ATM receipts, credit card statements, evidence of bank withdrawals, and invoices. All documents evidencing any mitigation or repairs to any area of the property that are being claimed as damaged in your loss. The original .jpeg files for any photographs taken which show the alleged damage at the property on or after the date of loss. All videos, recordings, film, diagrams, photographs, drawings, charts, sketches or any other depictions illustrating the damages sustained in the loss. Any and all photographs or videos which show the damaged area, prior to the date of the loss. All engineer, or expert reports in support of the claim that the property has sustained damage as a result of the alleged loss. Any and all documents prepared by third parties who inspected or evaluated the property and/or the damages as a result of the alleged loss. All documents evidencing your efforts to protect the property from further damage. All maintenance and/or repair records for the property from the date of loss thr the present. All documents relating to any prior insurance claims at the property, including, but not limited to: proofs of loss; any repair receipts; estimates; photographs; invoices; evidences of payments; and/or evidences of settlement. All documents relating to any other losses at the property occurring prior to or subsequent to the date of loss, including, but not limited to: proofs of loss; any repair receipts; estimates; photographs; invoices; evidences of payments; and/or evidences of settlement. Copies of all telephone records (land line and/or cellular) evidencing incoming and outgoing calls for all adults residing at the Property encompassing the 30 days prior to the alleged date of loss through 30 days after the alleged date of loss. All documents in your possession relating to the loss alleged in the Complaint that were not previously produced in response to the above requests. Copies of any liens, sales contracts, disclosure reports, inspection reports, appraisal reports and/or other documents relative to your purchase or acquisition of the Property. A copy of any and all lease agreements, rental agreements, contracts or other documents with any tenant or tenant(s) residing at the Property from the two years prior to the alleged loss through the current date. Copies of any and all documents created as part of the home inspection report from your purchase of the subject property, including, but not limited to all inspection reports, 4-point inspection reports, appraisal reports, photographs and videos in their native format. Copies of any documentation evidencing repairs and/or renovations at the Property that occurred during the five (5) years prior to the alleged loss. Copies of any checks (front and back) for any repairs made to the property as a result of this claim. Copies of any policies of homeowners’ insurance which cover damage caused by flood. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail to Brooke Boltz, Esq., BOLTZ LEGAL, 1221 E. Broadway St., Suite 1011, Oviedo, FL 32765; brookeboltz@boltzlegal.com eservice@boltzlegal.com June 23, 2023, pursuant to Rule 2.516. ttorney for Heritage Property & Casualty Insurance Company 1401 N. Westshore Boulevard Tampa, FL 33607 Telephone: (727) 465-4711 abruce@heritagepci.com smoya@heritagepci.com rrexroad@heritagepci.com By: \s\ Andrew Bruce________ ANDREW BRUCE, ESQUIRE Florida Bar No. 99713