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Filing # 137435945 E-Filed 10/28/2021 09:50:37 AM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
SAMER SAMHOURY and
CHRYSSA SAMHOURY,
Plaintiff(s),
vs. Case No.: 21-CA-002884
DIV. C
CENTAURI SPECIALTY INSURANCE
COMPANY,
Defendant(s).
______________________________________/
DEFENDANT, CENTAURI SPECIALTY INSURANCE COMPANY’S,
FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO THE PLAINTIFFS
Defendant, CENTAURI SPECIALTY INSURANCE COMPANY (“CENTAURI”), by
and through its undersigned attorney, and pursuant to Rule 1.350, Florida Rules of Civil
Procedure, requests that the Plaintiffs, SAMER SAMHOURY and CHRYSSA SAMHOURY,
produce the documents or things designated on the attached Exhibit “A” for inspection and
copying at the offices of ZINOBER DIANA & MONTEVERDE, P.A., 607 West Horatio Street,
Tampa, Florida 33610. Alternatively, the Plaintiff may produce the documents identified herein
by providing legible copies of said documents to counsel for the Defendant in conjunction with
service of his written response to this Request for Production within thirty (30) days from the date
of service hereof.
This Request relates to all documents in the possession, custody or control of the Plaintiffs
or any agent or other person acting or allegedly acting on their behalf.
Pursuant to Rule 1.350(b), Florida Rules of Civil Procedure, the documents produced for
inspection pursuant to this Request shall be produced either as they are kept in the usual course by
10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
the Plaintiffs, or the Plaintiffs shall organize and label the documents to correspond with the
individually numbered categories of this Request.
DEFINITIONS AND INSTRUCTIONS
1. “Person” means any natural person, corporation, partnership, proprietorship, joint
venture, association, governmental entity or other legal entity.
2. “Agent” means agent, attorney, officer, director, employee or other authorized
representative.
3. “Document” means:
a. All written, printed, typed, recorded or graphic matter of every type and
description, however and by whomever prepared, produced, reproduced, disseminated or made, in
the Plaintiffs’ actual or constructive possession, custody or control, including but not limited to,
all writings, letters, minutes, bulletins, correspondence, telegrams, memoranda, notes, instructions,
literature, work assignments, notebooks, records, agreements, contracts, notations of telephone or
personal conservations or conferences, address books, interoffice communications, receipts,
microfilm, circulars, pamphlets, advertisements, catalogs, studies, notices, summaries, reports,
books, invoices, checks, bills, graphs, photographs, drafts, data sheets, data compilations,
computer data sheets, computer data compilations, work sheets, calendars, statistics, speeches or
other writings, tape recordings, transcripts of tape recordings, phonograph records or data
compilations from which information can be obtained or translated into reasonably usable form;
b. The original and all other copies not absolutely identical; and
c. All drafts and notes (whether typed, handwritten or otherwise) made or
10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
prepared in connection with such documents, whether used or not.
4. “Communication” means any contact, oral or written, formal or informal, at any
time or place, under any circumstance, in any manner, whereby a statement of any nature is
transmitted or transferred, including any meeting or other conversation, and shall include, without
limitation, any document relating to any such contact.
5. The “Residence” shall mean the real property and related improvements owned by
Plaintiffs that is the subject of the underlying lawsuit alleged to be insured by CENTAURI
SPECIALTY INSURANCE COMPANY, located at 5404 Reflections Boulevard, Lutz, Florida
33558.
6. The words “and” and “or” shall be construed conjunctively or disjunctively as
necessary to make the specific request inclusive rather than exclusive.
7. “Relating to” means referring to, reflecting, responding to, commenting upon,
recording, discussing, showing, describing, analyzing, constituting or in any way concerning.
8. The terms “you” or “your” refer to Plaintiff in this action.
9. The singular form of a noun or pronoun shall be considered to include within its
meaning the plural form of the noun or pronoun so used, and vice versa; the use of a masculine
form of a pronoun shall be considered to include also within its meaning the feminine form of the
pronoun so used, and vice versa; and the use of any tense of any verb shall be considered to include
also within its meaning all other tenses of the verb so used.
10. If any document requested herein was at one time in existence and under Plaintiffs’
possession, custody or control but has been lost, discarded or destroyed or has been removed from
10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
its possession, custody or control, that it shall provide, with respect to each such document, a
description of the document and the date it was lost, discarded, destroyed or removed.
11. If any document or portion thereof is or will be withheld because of a claim of
privilege or work product, state the following:
a. The basis on which the privilege is or will be claimed;
b. The author or the document;
c. The identity of each person to whom the document indicates the original or
a copy was sent, and any other person who at any time possessed the document or a copy thereof.
d. The date of the document;
e. The general subject matter of the document or portion thereof for which
privilege is claimed; and
f. The type of document (e.g., memorandum, report, draft, letter, etc.).
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true copy of the foregoing pleading was sent by
electronic mail on this 28th day of October, 2021, to Counsel for Plaintiff(s) listed below:
Kevin E. Vorhis, Esquire (FBN: 118482)
COHEN LAW GROUP
350 North Lake Destiny Road
Maitland, FL 32751
Phone: 407-478-4878
Fax: 407-478-0204
Email: kvorhis@itsaboutjustice.law
Email: rachael@itsaboutjustice.law
Attorneys for Plaintiffs
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ZINOBER DIANA & MONTEVERDE, P.A.
___________________________________
Fredric S. Zinober, Esq. (FBN: 0341657)
E-Service: Fred@zinoberdiana.com
E-Service: Shannon@zinoberdiana.com
Michelle E. Sabin, Esquire (FBN: 0059471)
E-Service: Michelle@zinoberdiana.com
E-Service: Pam@zinoberdiana.com
607 West Horatio Street
Tampa, FL 33606
Phone: 813-642-4229
Fax: 727-498-8902
Attorneys for Defendant
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EXHIBIT A: DOCUMENTS TO BE PRODUCED
1. Any and all documents, records, engineering reports, roofer reports, contractor
reports, photographs, and estimates establishing that a “loss” or damage occurred during the policy
period, at your insured property located at 5404 Reflections Boulevard, Lutz, Florida 33558.
2. Any and all documents, records, reports, photographs, and estimates concerning
any repairs or improvements to your property located at 5404 Reflections Boulevard, Lutz, Florida
33558, following the “loss” or damage that allegedly occurred during the policy period. If
applicable, please include receipts or other verification that payment for these repairs were made
by you.
3. Any and all documents, records, reports, photographs, and estimates concerning the
purchase of your property located at 5404 Reflections Boulevard, Lutz, Florida 33558. Please also
include any such records evidencing any attempts to sell your property listed above at any time
during your ownership.
4. Any and all documents, records, reports, photographs, and estimates concerning
any repairs, renovations or improvements to your property located at insured property located at
5404 Reflections Boulevard, Lutz, Florida 33558, at any time since your purchase of the property.
If applicable, please include receipts or other verification that payment for these repairs were made
by you.
5. Any and all documents, records, reports, photographs, and estimates concerning the
damages you are alleging to be caused by a covered peril under your insurance policy that occurred
during the policy period, at your insured property located at 5404 Reflections Boulevard, Lutz,
Florida 33558.
6. Any and all documents regarding property insurance coverage for your property
located at 5404 Reflections Boulevard, Lutz, Florida 33558, which was in effect at any time during
10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6
your ownership of the property. As part of your response, please include the insurance carriers,
policy numbers that provided coverage, and any claims reported by you or any other owner of the
property.
7. All correspondence between Plaintiff and Defendant, including their agents and
attorneys, regarding the subject matter of the instant claims and litigation.
8. All communications between Plaintiff and any third party regarding the subject
matter of the instant claims and litigation, other than Plaintiff’s counsel.
9. All documents, reports, photographs, and estimates concerning any inspections or
investigations of the subject property following the loss, and all written communications between
Plaintiff and any third party concerning said report(s).
10. Documentation regarding payments to experts retained regarding the subject matter
of the instant claim and litigation.
11. A copy of any signed contracts for the remediation or repair of the Plaintiff’s
property in relation to the damages alleged in this lawsuit.
12. Any photographs or video footage of alleged damage to the property, other than the
materials produced in responses to the requests above.
13. Any and all documents referenced in Plaintiff’s response to Defendant’s First Set
of Interrogatories.
10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7
Preview
Filing # 137435945 E-Filed 10/28/2021 09:50:37 AM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SAMER SAMHOURY and CHRYSSA SAMHOURY, Plaintiff(s), vs. Case No.: 21-CA-002884 DIV. C CENTAURI SPECIALTY INSURANCE COMPANY, Defendant(s). ______________________________________/ DEFENDANT, CENTAURI SPECIALTY INSURANCE COMPANY’S, FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO THE PLAINTIFFS Defendant, CENTAURI SPECIALTY INSURANCE COMPANY (“CENTAURI”), by and through its undersigned attorney, and pursuant to Rule 1.350, Florida Rules of Civil Procedure, requests that the Plaintiffs, SAMER SAMHOURY and CHRYSSA SAMHOURY, produce the documents or things designated on the attached Exhibit “A” for inspection and copying at the offices of ZINOBER DIANA & MONTEVERDE, P.A., 607 West Horatio Street, Tampa, Florida 33610. Alternatively, the Plaintiff may produce the documents identified herein by providing legible copies of said documents to counsel for the Defendant in conjunction with service of his written response to this Request for Production within thirty (30) days from the date of service hereof. This Request relates to all documents in the possession, custody or control of the Plaintiffs or any agent or other person acting or allegedly acting on their behalf. Pursuant to Rule 1.350(b), Florida Rules of Civil Procedure, the documents produced for inspection pursuant to this Request shall be produced either as they are kept in the usual course by 10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 the Plaintiffs, or the Plaintiffs shall organize and label the documents to correspond with the individually numbered categories of this Request. DEFINITIONS AND INSTRUCTIONS 1. “Person” means any natural person, corporation, partnership, proprietorship, joint venture, association, governmental entity or other legal entity. 2. “Agent” means agent, attorney, officer, director, employee or other authorized representative. 3. “Document” means: a. All written, printed, typed, recorded or graphic matter of every type and description, however and by whomever prepared, produced, reproduced, disseminated or made, in the Plaintiffs’ actual or constructive possession, custody or control, including but not limited to, all writings, letters, minutes, bulletins, correspondence, telegrams, memoranda, notes, instructions, literature, work assignments, notebooks, records, agreements, contracts, notations of telephone or personal conservations or conferences, address books, interoffice communications, receipts, microfilm, circulars, pamphlets, advertisements, catalogs, studies, notices, summaries, reports, books, invoices, checks, bills, graphs, photographs, drafts, data sheets, data compilations, computer data sheets, computer data compilations, work sheets, calendars, statistics, speeches or other writings, tape recordings, transcripts of tape recordings, phonograph records or data compilations from which information can be obtained or translated into reasonably usable form; b. The original and all other copies not absolutely identical; and c. All drafts and notes (whether typed, handwritten or otherwise) made or 10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 prepared in connection with such documents, whether used or not. 4. “Communication” means any contact, oral or written, formal or informal, at any time or place, under any circumstance, in any manner, whereby a statement of any nature is transmitted or transferred, including any meeting or other conversation, and shall include, without limitation, any document relating to any such contact. 5. The “Residence” shall mean the real property and related improvements owned by Plaintiffs that is the subject of the underlying lawsuit alleged to be insured by CENTAURI SPECIALTY INSURANCE COMPANY, located at 5404 Reflections Boulevard, Lutz, Florida 33558. 6. The words “and” and “or” shall be construed conjunctively or disjunctively as necessary to make the specific request inclusive rather than exclusive. 7. “Relating to” means referring to, reflecting, responding to, commenting upon, recording, discussing, showing, describing, analyzing, constituting or in any way concerning. 8. The terms “you” or “your” refer to Plaintiff in this action. 9. The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun so used, and vice versa; the use of a masculine form of a pronoun shall be considered to include also within its meaning the feminine form of the pronoun so used, and vice versa; and the use of any tense of any verb shall be considered to include also within its meaning all other tenses of the verb so used. 10. If any document requested herein was at one time in existence and under Plaintiffs’ possession, custody or control but has been lost, discarded or destroyed or has been removed from 10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 its possession, custody or control, that it shall provide, with respect to each such document, a description of the document and the date it was lost, discarded, destroyed or removed. 11. If any document or portion thereof is or will be withheld because of a claim of privilege or work product, state the following: a. The basis on which the privilege is or will be claimed; b. The author or the document; c. The identity of each person to whom the document indicates the original or a copy was sent, and any other person who at any time possessed the document or a copy thereof. d. The date of the document; e. The general subject matter of the document or portion thereof for which privilege is claimed; and f. The type of document (e.g., memorandum, report, draft, letter, etc.). CERTIFICATE OF SERVICE The undersigned hereby certifies that a true copy of the foregoing pleading was sent by electronic mail on this 28th day of October, 2021, to Counsel for Plaintiff(s) listed below: Kevin E. Vorhis, Esquire (FBN: 118482) COHEN LAW GROUP 350 North Lake Destiny Road Maitland, FL 32751 Phone: 407-478-4878 Fax: 407-478-0204 Email: kvorhis@itsaboutjustice.law Email: rachael@itsaboutjustice.law Attorneys for Plaintiffs 10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4 ZINOBER DIANA & MONTEVERDE, P.A. ___________________________________ Fredric S. Zinober, Esq. (FBN: 0341657) E-Service: Fred@zinoberdiana.com E-Service: Shannon@zinoberdiana.com Michelle E. Sabin, Esquire (FBN: 0059471) E-Service: Michelle@zinoberdiana.com E-Service: Pam@zinoberdiana.com 607 West Horatio Street Tampa, FL 33606 Phone: 813-642-4229 Fax: 727-498-8902 Attorneys for Defendant 10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5 EXHIBIT A: DOCUMENTS TO BE PRODUCED 1. Any and all documents, records, engineering reports, roofer reports, contractor reports, photographs, and estimates establishing that a “loss” or damage occurred during the policy period, at your insured property located at 5404 Reflections Boulevard, Lutz, Florida 33558. 2. Any and all documents, records, reports, photographs, and estimates concerning any repairs or improvements to your property located at 5404 Reflections Boulevard, Lutz, Florida 33558, following the “loss” or damage that allegedly occurred during the policy period. If applicable, please include receipts or other verification that payment for these repairs were made by you. 3. Any and all documents, records, reports, photographs, and estimates concerning the purchase of your property located at 5404 Reflections Boulevard, Lutz, Florida 33558. Please also include any such records evidencing any attempts to sell your property listed above at any time during your ownership. 4. Any and all documents, records, reports, photographs, and estimates concerning any repairs, renovations or improvements to your property located at insured property located at 5404 Reflections Boulevard, Lutz, Florida 33558, at any time since your purchase of the property. If applicable, please include receipts or other verification that payment for these repairs were made by you. 5. Any and all documents, records, reports, photographs, and estimates concerning the damages you are alleging to be caused by a covered peril under your insurance policy that occurred during the policy period, at your insured property located at 5404 Reflections Boulevard, Lutz, Florida 33558. 6. Any and all documents regarding property insurance coverage for your property located at 5404 Reflections Boulevard, Lutz, Florida 33558, which was in effect at any time during 10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6 your ownership of the property. As part of your response, please include the insurance carriers, policy numbers that provided coverage, and any claims reported by you or any other owner of the property. 7. All correspondence between Plaintiff and Defendant, including their agents and attorneys, regarding the subject matter of the instant claims and litigation. 8. All communications between Plaintiff and any third party regarding the subject matter of the instant claims and litigation, other than Plaintiff’s counsel. 9. All documents, reports, photographs, and estimates concerning any inspections or investigations of the subject property following the loss, and all written communications between Plaintiff and any third party concerning said report(s). 10. Documentation regarding payments to experts retained regarding the subject matter of the instant claim and litigation. 11. A copy of any signed contracts for the remediation or repair of the Plaintiff’s property in relation to the damages alleged in this lawsuit. 12. Any photographs or video footage of alleged damage to the property, other than the materials produced in responses to the requests above. 13. Any and all documents referenced in Plaintiff’s response to Defendant’s First Set of Interrogatories. 10/28/2021 9:50 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7