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Filing # 121243794 E-Filed 02/11/2021 02:03:04 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
CASE NO.: 20-CA-001073
BERKLEY ROBERTS and DENISE
ROBERTS,
Plaintiffs,
Vv.
TOWER HILL PRIME INSURANCE
COMPANY,
Defendant.
/
PLAINTIFFS’ RESPONSE TO DEFENDANT’S REQUEST TO PRODUCE
COME NOW, BERKLEY ROBERTS and DENISE ROBERTS, (“Plaintiffs”), by
and through the undersigned counsel and hereby files its Objections and Responses to
Defendant, TOWER HILL PRIME INSURANCE COMPANY’s Request to Produce to
Plaintiffs, in accordance with the Florida Civil Rules of Procedure.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was
furnished by E-portal/E-mail to Counsel for Defendant: William J. Peterfriend, Esquire /
Brittany L. Ehrenman, Esquire of Luks, Santaniello, Petrillo & Cohen, 110 SE 6" Street,
20 Floor, Fort Lauderdale, FL 33301, LUKSFLL-Pleadings@LS-Law.com on this the
11th day of February, 2021.
4s/ Shaun J. Marker, Esquire
SHAUN J. MARKER, ESQUIRE
Florida Bar No. 0017378
ROBERT H. GREGORY, ESQUIRE
Florida Bar No. 0101736
MERLIN LAW GROUP, P.A.
222 Lakeview Avenue, Suite 1250
West Palm Beach, FL 33401
561-855-2120 / 561-249-1283 fax
marker@merliniawgroup.com
‘gregory@merlinlawgroup.com
dmyskowski merlinlawgroup.com
Attorneys for Plaintiffs
Preliminary Statement
Plaintiff reserves the right to supplement or amend her answers prior to trial upon
discovery of additional relevant information during the discovery phase, as provided by the law
and Florida Rules of Civil Procedure.
General Objection
Plaintiff responds to each and every request subject to and without waiving the following
objections:
1 Plaintiff objects to all requests to the extent that they are overly broad, require an
unduly burdensome search of Plaintiff's records, purport to cover persons and business entities
which are not parties to this action, purport to requires Plaintiff to supply information that is not
available to her, purports Plaintiff to submit documents which are not in her possession, custody
or control, or otherwise request information or attempt to impose requirements beyond the
scope of the applicable Florida Rules of Civil Procedure;
2. Plaintiff objects to each request calling for an answer regarding “each,” “all,”
“every,” or “any” document(s), record(s), information, person(s), or fact(s), or asking Plaintiff to
identify “all other persons with knowledge” or “each basis,” for a contention, no the grounds that
such requests are overly broad and unduly burdensome. Plaintiff has used reasonable
diligence to locate responsive information and documents based on inquiry of those persons
who may reasonable be expected to possess responsive information and examination of those
files that may reasonably be expected to contain responsive documents;
3 Plaintiff objects to each request to the extent they seek information without
proper limit to its subject matter; and
4, Plaintiff objects to each and every request as implicating documents covered by
the attorney-client and work product privileges. Privileged documents are not being produced
by Plaintiff, and Plaintiff does intend to preserve the attorney-client and work product privilege
protections, and any other judicially recognized protections or privileges with respect to all
information and to each and every document protected by such privileges. A privilege log will
be produced if applicable.
General Response:
Plaintiff incorporates each and every general objection stated above in each response
below.
In addition, Plaintiff also has in their possession copies of the below-listed documents
that support their claim for damages which, in the spirit of judicial economy, Plaintiff is not
reproducing to Defendant with this response, as Defendant is already in possession of same.
However, should Defendant wish to receive additional copies of the following documents,
Plaintiff will promptly produce same upon reasonable notice and reimbursement for any
duplication charges incurred with such request.
PLAINTIFFS’ RESPONSE TO DEFENDANT'S REQUEST TO PRODUCE
Correspondence
1 Any and all documents related to any Communication between you or
anyone on your behalf and Defendant, which documents should include but not be
limited to letters, electronic mail, telephone bills showing telephone calls, and online
forms and submissions.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached. Outside of these documents,
Plaintiffs object on the grounds of relevance, overbroad, and
unduly burdensome.
2 Any and all documents related to any Communication between you or
anyone on your behalf and/or any public adjuster, and/or contractor concerning the
Loss and/or Property, which documents should include but not be limited to letters,
electronic mail, telephone bills showing telephone calls, and online forms and
submissions.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
3 Any and all documents related to any Communication between you or
anyone on your behalf and any insurance agent, which documents should include but
not be limited to letters, electronic mail, telephone bills showing telephone calls, and
online forms and submissions.
RESPONSE: Plaintiffs object on the grounds of relevance, overbroad, and
unduly burdensome.
4 Any and all documents related to any Communication between you or
anyone on your behalf and any named insured, which documents should include but
not limited fo letters, electronic mail, telephone bills showing telephone calls, and online
forms and submissions.
RESPONSE: Plaintiffs object to this request as vague and ambiguous as
Plaintiffs are the named insureds.
5. Any and all sworn proof of loss forms executed by you or anyone else
related to the Loss.
RESPONSE: None in possession.
6 Any and all documents supporting the allegation(s) that you and/or
anyone else complied with your post-loss obligations under the insurance policy,
which documents should include but not be limited to documents showing compliance
with the obligations to promptly report the loss, make reasonable and necessary repairs
to protect the property from further damage, and show the damaged property.
RESPONSE: Plaintiffs object to this request as vague and ambiguous related to
“post-loss obligations under the insurance policy.” As it relates to
the delineated requests, those documents in Plaintiffs custody and
control are attached.
Claim Documents
7 Any and all documents that support your position regarding the cause and
extent of the damages to the Property and the necessary cost to repair the Property,
and specifically, any documents substantiating any costs of repair and any damages or
estimates for remedial measures relating to the Property.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
8 Any and all detailed invoices showing any services you and/or any person
or company at your direction have or will be performing at the Property.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
9 Any and all receipts, invoices and estimates related to any services
performed at the Property by you and/or any person or company at your direction.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
10. Any and all written standards, guidelines, or manuals supporting the scope
of the allegedly necessary work.
RESPONSE: None in possession.
11. Any and all contracts or agreements between you and any other person
or entity concerning repair of the Property.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
12. Any and all documents showing that all persons or entities that have
performed repairs or intends to perform repairs at the Subject Property are licensed to
conduct business in Florida.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
13. Any and all receipts or related documentation for purchased products
utilized in any repairs to the Property.
RESPONSE: None in possession.
14. Any and all documents evidencing damage from the Loss to the Property,
which documents may include but not be limited to estimates for repairs, proposals,
contracts, subcontracts, blueprints, invoices, reports, receipts, and correspondence.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
15. Any and all documents evidencing expenditures by you or on your behalf
for repair of the Property, which documents may include but not be limited to estimates
for repairs, proposals, contracts, subcontracts, blueprints, canceled checks for repairs,
receipts, invoices, other evidence of payments for such repairs, reconstruction,
modification or restoration of the Property.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
16. Any and all engineering reports, incident reports, statements, general
contractor’s reports, or other investigation-related documents showing an opinion
regarding the cause, origin and/or extent of the damage arising from the Loss.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
17. lf as part of this litigation you will seek reimbursement/indemnification
for replacement or rebuilding of any structure or appurtenance allegedly damaged in
the Loss, produce any and all documents evidencing the repair and/or replacement
of any such property, including but not limited to estimates, proposals, contracts,
subcontracts, cancelled checks, credit card slips, brochures, appraisals, invoices,
receipts, and purchase orders.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
18. If as part of this litigation you will seek reimbursement/indemnification for
replacement or repair of any Personal Property allegedly damaged in the Loss, produce
any and all documents evidencing the repair and/or replacement of any such property,
including but not limited to estimates, proposals, contracts, subcontracts, cancelled
checks, credit card slips, brochures, appraisals, invoices, receipts, and purchase orders.
RESPONSE: None at this time.
19. Any and all documents and/or records relating to any aspect of the
insurance claim submitted to any insurance company regarding the Loss.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
Photographs
20. Any and all photographs or other illustrative representations of the
Property or areas of the Property, which photographs or illustrative representations
show the Property or any portions of the Property before the alleged date that the Loss
occurred. Photographs are to be provided in their original, native format.
RESPONSE: None in possession.
21. Any and all photographs or other illustrative representations of the
Property or areas of the Property, which photographs or illustrative representations
show the Property or any portions of the Property after the alleged date that the Loss
occurred, Photographs are to be provided in their original, native format.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
Property Information
22. Any and all records pertaining to the rental or lease of the Property in the
past five (5) years, which documents should include but not be limited to any and all
lease agreements, cancelled checks, and contact information for any and all tenants.
RESPONSE: None in possession.
23. Any and all documents relating to any lawsuit involving, in any way, the
Property, including but not limited to any mortgage foreclosure actions and/or
bankruptcies.
RESPONSE: Other than the subject lawsuit, none in possession.
24. Any and all documents relating to any lawsuit involving you, in any way,
including but not limited to any lawsuits that arise from you filing a lawsuit against an
insurance company.
RESPONSE: None in possession.
25. Any and all correspondence related to the Property between you or
anyone and any mortgagee and/or note holder, which documents should include but not
be limited to any correspondence concerning foreclosure, a risk of foreclosure,
mortgage modifications, and/or any related documents.
RESPONSE: None in possession.
26. Any and all lease agreements for the Property.
RESPONSE: None in possession.
27. Any and all documents reflecting the amount of water usage at the
Property for the three year period prior to the date of the Loss, including water bills.
RESPONSE: None in possession.
28. Any and all documents reflecting the amount of water usage at the
Property for the three month period following the date of the Loss, including water bills.
RESPONSE: None in possession.
29. Any and all documents reflecting the amount of electrical usage at the
property for the three year period prior to the date of the Loss, including electric bills.
RESPONSE: None in possession.
30. Any and all documents reflecting the amount of electrical usage at the
Property for the three month period following the date of the Loss, including water bills.
RESPONSE: None in possession.
31. Any and all insurance policies that may provide insurance coverage for
the Loss (whether you submitted a claim to each insurer or not), and any and all
correspondence, applications, memoranda, policies, and any other documents relating to
said policies of insurance, including any and all notices of cancellation or requests for
premiums.
RESPONSE: None in possession.
32. Any and all contracts, subcontracts, blueprints, estimates, invoices,
proposals, statements, receipts, canceled checks, receipts, invoices and other evidence
of payments, and any and all other documents relating to repairs, remodeling,
restoration or maintenance performed at the Property in the last ten (10) years.
RESPONSE: Those documents related to the subject claim and in Plaintiffs’
custody and control are attached.
33. Any and all documents relating to any prior insurance claims regarding
property damage made by you or any resident of the Property.
RESPONSE: None in possession.
34 Any and ail inspection reports, photographs, disclosures, and/or related
documentation showing the Property had any damage of any kind at the time of
purchase.
RESPONSE: None in possession.
35. Any and all inspection reports, photographs, disclosures, and/or related
documentation showing the Property had any damage of any kind prior to the Loss.
RESPONSE: None in possession.
36. Any and all documents related to any purchase and/or sale of the
Property, which documents should include but not be limited to construction contracts,
any deeds evidencing your ownership of the Property, and seller's disclosures.
RESPONSE: Plaintiffs object to this request as irrelevant, overbroad, unduly
burdensome, and not reasonably calculated to lead to the
discovery of admissible evidence.
37. Any and all notes and mortgages related to the Property from the date of
purchase through the present time.
RESPONSE: None in possession.
38. Any and all documents showing you or anyone else have made any
attempt to distinguish for Defendant the claimed damage from any prior damage existing
at the Property before the Loss.
RESPONSE: Plaintiffs are unaware of “any prior damage existing at the Property
before the Loss.” Therefore, none.
39. Any and all documents related to any damage at the Property not being
alleged as a part of the claimed damages in your Complaint.
RESPONSE: None in possession.
40. Any and all documents evidencing damage from sources other than the
Loss to the Property, which documents may include but not be limited to estimates for
repairs, proposals, contracts, subcontracts, blueprints, invoices, reports, receipts, and
correspondence.
RESPONSE: Plaintiffs are unaware of any “damage from sources other than the
Loss to the Property.” Therefore, none.
41. A copy of each resume, curriculum vitae, and other document listing the
qualifications of each and every expert and/or consultant hired by you or on behalf of
you who may testify at trial.
RESPONSE: Plaintiffs have yet to determine experts for the purposes of trial.
42. Any and all lease agreements for the last 10 years for the Property.
RESPONSE: None in possession.
Preview
Filing # 121243794 E-Filed 02/11/2021 02:03:04 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION CASE NO.: 20-CA-001073 BERKLEY ROBERTS and DENISE ROBERTS, Plaintiffs, Vv. TOWER HILL PRIME INSURANCE COMPANY, Defendant. / PLAINTIFFS’ RESPONSE TO DEFENDANT’S REQUEST TO PRODUCE COME NOW, BERKLEY ROBERTS and DENISE ROBERTS, (“Plaintiffs”), by and through the undersigned counsel and hereby files its Objections and Responses to Defendant, TOWER HILL PRIME INSURANCE COMPANY’s Request to Produce to Plaintiffs, in accordance with the Florida Civil Rules of Procedure. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by E-portal/E-mail to Counsel for Defendant: William J. Peterfriend, Esquire / Brittany L. Ehrenman, Esquire of Luks, Santaniello, Petrillo & Cohen, 110 SE 6" Street, 20 Floor, Fort Lauderdale, FL 33301, LUKSFLL-Pleadings@LS-Law.com on this the 11th day of February, 2021. 4s/ Shaun J. Marker, Esquire SHAUN J. MARKER, ESQUIRE Florida Bar No. 0017378 ROBERT H. GREGORY, ESQUIRE Florida Bar No. 0101736 MERLIN LAW GROUP, P.A. 222 Lakeview Avenue, Suite 1250 West Palm Beach, FL 33401 561-855-2120 / 561-249-1283 fax marker@merliniawgroup.com ‘gregory@merlinlawgroup.com dmyskowski merlinlawgroup.com Attorneys for Plaintiffs Preliminary Statement Plaintiff reserves the right to supplement or amend her answers prior to trial upon discovery of additional relevant information during the discovery phase, as provided by the law and Florida Rules of Civil Procedure. General Objection Plaintiff responds to each and every request subject to and without waiving the following objections: 1 Plaintiff objects to all requests to the extent that they are overly broad, require an unduly burdensome search of Plaintiff's records, purport to cover persons and business entities which are not parties to this action, purport to requires Plaintiff to supply information that is not available to her, purports Plaintiff to submit documents which are not in her possession, custody or control, or otherwise request information or attempt to impose requirements beyond the scope of the applicable Florida Rules of Civil Procedure; 2. Plaintiff objects to each request calling for an answer regarding “each,” “all,” “every,” or “any” document(s), record(s), information, person(s), or fact(s), or asking Plaintiff to identify “all other persons with knowledge” or “each basis,” for a contention, no the grounds that such requests are overly broad and unduly burdensome. Plaintiff has used reasonable diligence to locate responsive information and documents based on inquiry of those persons who may reasonable be expected to possess responsive information and examination of those files that may reasonably be expected to contain responsive documents; 3 Plaintiff objects to each request to the extent they seek information without proper limit to its subject matter; and 4, Plaintiff objects to each and every request as implicating documents covered by the attorney-client and work product privileges. Privileged documents are not being produced by Plaintiff, and Plaintiff does intend to preserve the attorney-client and work product privilege protections, and any other judicially recognized protections or privileges with respect to all information and to each and every document protected by such privileges. A privilege log will be produced if applicable. General Response: Plaintiff incorporates each and every general objection stated above in each response below. In addition, Plaintiff also has in their possession copies of the below-listed documents that support their claim for damages which, in the spirit of judicial economy, Plaintiff is not reproducing to Defendant with this response, as Defendant is already in possession of same. However, should Defendant wish to receive additional copies of the following documents, Plaintiff will promptly produce same upon reasonable notice and reimbursement for any duplication charges incurred with such request. PLAINTIFFS’ RESPONSE TO DEFENDANT'S REQUEST TO PRODUCE Correspondence 1 Any and all documents related to any Communication between you or anyone on your behalf and Defendant, which documents should include but not be limited to letters, electronic mail, telephone bills showing telephone calls, and online forms and submissions. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. Outside of these documents, Plaintiffs object on the grounds of relevance, overbroad, and unduly burdensome. 2 Any and all documents related to any Communication between you or anyone on your behalf and/or any public adjuster, and/or contractor concerning the Loss and/or Property, which documents should include but not be limited to letters, electronic mail, telephone bills showing telephone calls, and online forms and submissions. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 3 Any and all documents related to any Communication between you or anyone on your behalf and any insurance agent, which documents should include but not be limited to letters, electronic mail, telephone bills showing telephone calls, and online forms and submissions. RESPONSE: Plaintiffs object on the grounds of relevance, overbroad, and unduly burdensome. 4 Any and all documents related to any Communication between you or anyone on your behalf and any named insured, which documents should include but not limited fo letters, electronic mail, telephone bills showing telephone calls, and online forms and submissions. RESPONSE: Plaintiffs object to this request as vague and ambiguous as Plaintiffs are the named insureds. 5. Any and all sworn proof of loss forms executed by you or anyone else related to the Loss. RESPONSE: None in possession. 6 Any and all documents supporting the allegation(s) that you and/or anyone else complied with your post-loss obligations under the insurance policy, which documents should include but not be limited to documents showing compliance with the obligations to promptly report the loss, make reasonable and necessary repairs to protect the property from further damage, and show the damaged property. RESPONSE: Plaintiffs object to this request as vague and ambiguous related to “post-loss obligations under the insurance policy.” As it relates to the delineated requests, those documents in Plaintiffs custody and control are attached. Claim Documents 7 Any and all documents that support your position regarding the cause and extent of the damages to the Property and the necessary cost to repair the Property, and specifically, any documents substantiating any costs of repair and any damages or estimates for remedial measures relating to the Property. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 8 Any and all detailed invoices showing any services you and/or any person or company at your direction have or will be performing at the Property. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 9 Any and all receipts, invoices and estimates related to any services performed at the Property by you and/or any person or company at your direction. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 10. Any and all written standards, guidelines, or manuals supporting the scope of the allegedly necessary work. RESPONSE: None in possession. 11. Any and all contracts or agreements between you and any other person or entity concerning repair of the Property. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 12. Any and all documents showing that all persons or entities that have performed repairs or intends to perform repairs at the Subject Property are licensed to conduct business in Florida. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 13. Any and all receipts or related documentation for purchased products utilized in any repairs to the Property. RESPONSE: None in possession. 14. Any and all documents evidencing damage from the Loss to the Property, which documents may include but not be limited to estimates for repairs, proposals, contracts, subcontracts, blueprints, invoices, reports, receipts, and correspondence. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 15. Any and all documents evidencing expenditures by you or on your behalf for repair of the Property, which documents may include but not be limited to estimates for repairs, proposals, contracts, subcontracts, blueprints, canceled checks for repairs, receipts, invoices, other evidence of payments for such repairs, reconstruction, modification or restoration of the Property. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 16. Any and all engineering reports, incident reports, statements, general contractor’s reports, or other investigation-related documents showing an opinion regarding the cause, origin and/or extent of the damage arising from the Loss. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 17. lf as part of this litigation you will seek reimbursement/indemnification for replacement or rebuilding of any structure or appurtenance allegedly damaged in the Loss, produce any and all documents evidencing the repair and/or replacement of any such property, including but not limited to estimates, proposals, contracts, subcontracts, cancelled checks, credit card slips, brochures, appraisals, invoices, receipts, and purchase orders. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 18. If as part of this litigation you will seek reimbursement/indemnification for replacement or repair of any Personal Property allegedly damaged in the Loss, produce any and all documents evidencing the repair and/or replacement of any such property, including but not limited to estimates, proposals, contracts, subcontracts, cancelled checks, credit card slips, brochures, appraisals, invoices, receipts, and purchase orders. RESPONSE: None at this time. 19. Any and all documents and/or records relating to any aspect of the insurance claim submitted to any insurance company regarding the Loss. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. Photographs 20. Any and all photographs or other illustrative representations of the Property or areas of the Property, which photographs or illustrative representations show the Property or any portions of the Property before the alleged date that the Loss occurred. Photographs are to be provided in their original, native format. RESPONSE: None in possession. 21. Any and all photographs or other illustrative representations of the Property or areas of the Property, which photographs or illustrative representations show the Property or any portions of the Property after the alleged date that the Loss occurred, Photographs are to be provided in their original, native format. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. Property Information 22. Any and all records pertaining to the rental or lease of the Property in the past five (5) years, which documents should include but not be limited to any and all lease agreements, cancelled checks, and contact information for any and all tenants. RESPONSE: None in possession. 23. Any and all documents relating to any lawsuit involving, in any way, the Property, including but not limited to any mortgage foreclosure actions and/or bankruptcies. RESPONSE: Other than the subject lawsuit, none in possession. 24. Any and all documents relating to any lawsuit involving you, in any way, including but not limited to any lawsuits that arise from you filing a lawsuit against an insurance company. RESPONSE: None in possession. 25. Any and all correspondence related to the Property between you or anyone and any mortgagee and/or note holder, which documents should include but not be limited to any correspondence concerning foreclosure, a risk of foreclosure, mortgage modifications, and/or any related documents. RESPONSE: None in possession. 26. Any and all lease agreements for the Property. RESPONSE: None in possession. 27. Any and all documents reflecting the amount of water usage at the Property for the three year period prior to the date of the Loss, including water bills. RESPONSE: None in possession. 28. Any and all documents reflecting the amount of water usage at the Property for the three month period following the date of the Loss, including water bills. RESPONSE: None in possession. 29. Any and all documents reflecting the amount of electrical usage at the property for the three year period prior to the date of the Loss, including electric bills. RESPONSE: None in possession. 30. Any and all documents reflecting the amount of electrical usage at the Property for the three month period following the date of the Loss, including water bills. RESPONSE: None in possession. 31. Any and all insurance policies that may provide insurance coverage for the Loss (whether you submitted a claim to each insurer or not), and any and all correspondence, applications, memoranda, policies, and any other documents relating to said policies of insurance, including any and all notices of cancellation or requests for premiums. RESPONSE: None in possession. 32. Any and all contracts, subcontracts, blueprints, estimates, invoices, proposals, statements, receipts, canceled checks, receipts, invoices and other evidence of payments, and any and all other documents relating to repairs, remodeling, restoration or maintenance performed at the Property in the last ten (10) years. RESPONSE: Those documents related to the subject claim and in Plaintiffs’ custody and control are attached. 33. Any and all documents relating to any prior insurance claims regarding property damage made by you or any resident of the Property. RESPONSE: None in possession. 34 Any and ail inspection reports, photographs, disclosures, and/or related documentation showing the Property had any damage of any kind at the time of purchase. RESPONSE: None in possession. 35. Any and all inspection reports, photographs, disclosures, and/or related documentation showing the Property had any damage of any kind prior to the Loss. RESPONSE: None in possession. 36. Any and all documents related to any purchase and/or sale of the Property, which documents should include but not be limited to construction contracts, any deeds evidencing your ownership of the Property, and seller's disclosures. RESPONSE: Plaintiffs object to this request as irrelevant, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. 37. Any and all notes and mortgages related to the Property from the date of purchase through the present time. RESPONSE: None in possession. 38. Any and all documents showing you or anyone else have made any attempt to distinguish for Defendant the claimed damage from any prior damage existing at the Property before the Loss. RESPONSE: Plaintiffs are unaware of “any prior damage existing at the Property before the Loss.” Therefore, none. 39. Any and all documents related to any damage at the Property not being alleged as a part of the claimed damages in your Complaint. RESPONSE: None in possession. 40. Any and all documents evidencing damage from sources other than the Loss to the Property, which documents may include but not be limited to estimates for repairs, proposals, contracts, subcontracts, blueprints, invoices, reports, receipts, and correspondence. RESPONSE: Plaintiffs are unaware of any “damage from sources other than the Loss to the Property.” Therefore, none. 41. A copy of each resume, curriculum vitae, and other document listing the qualifications of each and every expert and/or consultant hired by you or on behalf of you who may testify at trial. RESPONSE: Plaintiffs have yet to determine experts for the purposes of trial. 42. Any and all lease agreements for the last 10 years for the Property. RESPONSE: None in possession.