On June 30, 2021 a
Party Discovery
was filed
involving a dispute between
Schumacher, Jereme,
and
Heritage Property & Casualty Insurance Company,
for Civil
in the District Court of Hillsborough County.
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Filing # 161372451 E-Filed 11/16/2022 03:28:11 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CASE NO.: 21-CA-005495
JEREME SCHUMACHER,
Plaintiff,
vs.
HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
_______________________________________/
DEFENDANT’S SUPPLEMENTAL RESPONSE
TO EXPERT REQUEST FOR PRODUCTION
COMES NOW, the Defendant, HERITAGE PROPERTY AND CASUALTY
INSURANCE COMPANY (“Heritage”), pursuant to Florida Rule of Civil Procedure 1.350, files
its Response to Plaintiff’s Expert Request for Production to Defendant:
2. All written reports generated by Defendant’s Expert(s).
RESPONSE: Attached is the Roof Evaluation report dated November 16, 2022.
5. All documents Defendant’s Expert(s) reviewed with respect to this matter.
RESPONSE: The following records were reviewed by the engineer:
- FA Loss Report (redacted)
- FA Photographs dated June 14, 2021
- FA Photographs dated October 29, 2018
- Apex Roofing & Restoration (Hold Harmless Agreement, Direct Payment
Authorization, & Assignment of Benefits dated June 9, 2021, and Initial
Roofing & Estimating Checklist, and
- AQA Engineering Report and Repair Plan
CERTIFICATE OF SERVICE FOLLOWING
11/16/2022 3:28 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
CASE NO.: 21-CA-005495
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
electronic mail via the Florida e-filing portal to: Robert Gonzalez, Esq., Florida Insurance Law
Group, LLC, 8724 Sunset Drive, #260, Miami, Florida 33173; pleadings@flinslaw.com; on this
16th day of November 2022, pursuant to Rule 2.516.
Attorney for Heritage Property and Casualty
Insurance Company
1401 North Westshore Boulevard
Tampa, Florida 33607
Telephone: (727) 667-8486
pferreira@heritagepci.com
mlejman@heritagepci.com
aestevez@heritagepci.com
By: \s\ Priscila Ferreira
Priscila Ferreira, Esq.
Florida Bar No. 1015840
2
11/16/2022 3:28 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Document Filed Date
November 16, 2022
Case Filing Date
June 30, 2021
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Filing # 161372451 E-Filed 11/16/2022 03:28:11 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CASE NO.: 21-CA-005495 JEREME SCHUMACHER, Plaintiff, vs. HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. _______________________________________/ DEFENDANT’S SUPPLEMENTAL RESPONSE TO EXPERT REQUEST FOR PRODUCTION COMES NOW, the Defendant, HERITAGE PROPERTY AND CASUALTY INSURANCE COMPANY (“Heritage”), pursuant to Florida Rule of Civil Procedure 1.350, files its Response to Plaintiff’s Expert Request for Production to Defendant: 2. All written reports generated by Defendant’s Expert(s). RESPONSE: Attached is the Roof Evaluation report dated November 16, 2022. 5. All documents Defendant’s Expert(s) reviewed with respect to this matter. RESPONSE: The following records were reviewed by the engineer: - FA Loss Report (redacted) - FA Photographs dated June 14, 2021 - FA Photographs dated October 29, 2018 - Apex Roofing & Restoration (Hold Harmless Agreement, Direct Payment Authorization, & Assignment of Benefits dated June 9, 2021, and Initial Roofing & Estimating Checklist, and - AQA Engineering Report and Repair Plan CERTIFICATE OF SERVICE FOLLOWING 11/16/2022 3:28 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 CASE NO.: 21-CA-005495 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail via the Florida e-filing portal to: Robert Gonzalez, Esq., Florida Insurance Law Group, LLC, 8724 Sunset Drive, #260, Miami, Florida 33173; pleadings@flinslaw.com; on this 16th day of November 2022, pursuant to Rule 2.516. Attorney for Heritage Property and Casualty Insurance Company 1401 North Westshore Boulevard Tampa, Florida 33607 Telephone: (727) 667-8486 pferreira@heritagepci.com mlejman@heritagepci.com aestevez@heritagepci.com By: \s\ Priscila Ferreira Priscila Ferreira, Esq. Florida Bar No. 1015840 2 11/16/2022 3:28 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2