Preview
Filing# 152104084 E-Filed 06/23/2022 06:56:50 PM
IN THE CIRCUIT COURT OF THE ,TH
17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
RAWATEE CECIL AND BALRAM CECIL, CASE NO: CACE-21-010688
Plaintiffs,
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S FIRST SET OF INTERROGATORIES TO PLAINTIFFS
Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
("Universal"),through counsel and pursuant to Rule 1.340 ofthe Florida Rules of Civil
upon Plaintiffs. Plaintiffs are to answer this set of
Procedure, propounds this set of Interrogatories
in writing,under oath, within the time specifiedunder the Florida Rules of Civil
Interrogatories
Procedure
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*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/23/2022 06:56:49 PM.****
Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 2 of 14
Defendant' s First of Interrogatories
to Plaintiffs
DEFENDANT CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E-
Service to: Jesus David Moises, Esq., MOISESIGROSS, P.L.L.C. (service@moisesgross.com
on June 23,2022.
and rnieto@moisesgross.com),
AttorneyMDefendant
Universal Property & CasualtyIns. Co.
PO Box 9388
Fort Lauderdale, Florida 33310
Telephone:954-958-3319
Toll Free: 1-833-658-8594 (JudgesOnly)
Facsimile: 954-958-1262
By-. /s/ Joseph Henn
Joseph Henn, Esq.
Florida Bar No. 91143
For Service of Court Documents Onlv:
Primary: upciceservice01@universalproperty.com
Secondary: kb0615@universalproperty.com
Tertiary:
jh0518@universalproperty.com
For Scheduling Matters:
Is0601@universalproperty.com
Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com
or upciceservice01@universalpropertv.com.
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Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 3 of 14
Defendant' s First of Interrogatories
to Plaintiffs
DEFINITIONS
1. "Calendar Year" means that period of time that beginsat 12:01 a.m. on January 1
of any given year and ends at 11.59 pm. on December 31 ofthat year.
2. "Claim" means the insurance claim (as defined herein)reportedto
that Plaintiff
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 (as defined
herein)are claimingthat the Insured Property (asdefined 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,
reflecting, and constituting.
analyzing,
5. "Control" means having possession of and/or the power and/or authorityto request
possession of 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).If the 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 & CasualtyInsurance Company.
8. "Document" or "documents" means anythingwhich may be considered to be a
document or tangiblethingwithin 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
telephoneconversations and conferences), studies,analyses,books, magazines, newspapers,
publications,booklets, pamphlets, circulars,bulletins,instructions,minutes, or other
communications (including,but not limited to, interoffice and intra-office communications),
questionnaires, surveys, contracts, memoranda ofagreements,assignments, books ofaccount,
journals,ledgers,summaries, opinions,reports, evaluations, financial statements and all
records of or reflectingbusiness operations, mortgages, evaluations,orders,working papers,
bills of lading,sh*ping lists, load sheets,warehouse rece*ts,letters of credit,insurance
policies,records of summaries of personal interviews or conversations, appointment
calendars,diaries, schedules,printouts,
drawings,specifications,
patents, patent applications,
certificates of registration, for registration,
applications graphs, charts,studies,planning
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Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 4 of 14
Defendant' s First of Interrogatories
to Plaintiffs
materials, statistical and compilations,forecasts,work papers, invoices,
statements
statements, bills,checks, bank books, bank statements, forms, vouchers, notebooks, data
sheets,microfilm,microfiche,photographicnegatives, audio tape, video tape, compact disks,
blueprints,specifications, architectural diagrams, schematics, logic diagrams, timing
diagrams, pictures, photographs,microscopicallyobtained 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 copies
thereof. Any documents bearing any marks including, but not limited to, initials,stamped
indicia,comments, or notations, of any kind that are not a part of the originaltext or
photographic reproduction thereof are to be considered and identified as separate
documents.
9. "Dwelling" means the physicaldwelling located at the Insured Property (as defined
herein).
10."Insured Property" means the real property specifically
listed on the declarations
page ofthe Policy (as defined herein).
11. "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.
12. "Person" or "Persons" shall mean any natural person or any legalentityincluding,
but not limited to, a corporation,partnersh* and unincorporatedassociation,firm, joint
venture, proprietorsh*,and/or any other entityor group of natural persons or such entities,
singularor plural, and any
male, female,or neuter gender,as the context may require, officer.
13. "Plaintiff" means any person and/or entitynamed as a in
plaintiff this action.
14."Policy" means the insurance policythat serves as a basis for any causes of action
asserted againstDefendant in this lawsuit.
15. "Related to", "relatingto", and "relate to" shall include pertainingto, referring
to,
mentioning, evidencing,discussingor otherwise
relevant to, supporting, contradicting,
involving,whether directly the subjectmatter ofthe specified
or indirectly, request.
16. "Universal" means Defendant UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY
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Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 5 of 14
Defendant' s First of Interrogatories
to Plaintiffs
17. "Written Communication" or "correspondence" means the conveyance of
whether by letters,
information by a writing, e-mails,memoranda, handwritten notes and/or
faxes.
18. "Witness Statement" or "Statement" means a statement of any person with
knowledge of relevant facts,regardlessofwhen the statement was made, and is either (i)a
written statement signed or otherwise adopted and/or approved in writing by the person
making it;or, (ii)a stenographic, and/or other type of recordingof
mechanical, electrical,
verbatim transcript
a person's oral statement and/or any substantially of such recording.
19. "You" or"Your" means the specificparty responding to these requests and/or any
person and/or entitynamed as a Plaintiff in this action.
20. "Your Counsel" means the attorney or attorneys who are representingor have
representedyou either with regard to the claim or in this lawsuit.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK1
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Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 6 of 14
Defendant' s First of Interrogatories
to Plaintiffs
INTERROGATORIES
In accordance with Rule 1.340(e)of the Fla. R. Civ. P., space has been provided aftereach
interrogatoryfor a response to be inserted. However, ifmore space is needed, "the answering
party may attach additional documents with answers and referto them in the space provided
in the interrogatories."
See, Fla. R. Civ. P. 1.340(e).
1. Please state the name, address, telephonenumber, and email of the person answeringthese
Interrogatories and the name, address,telephonenumber, and email of any person assisting
in preparingresponses to these Interrogatories.
RESPONSE:
2. Please providethe name, address, telephonenumber, email, place of employment, and job
title of any person who has, claims to have, or whom You, Your agents, and/or Your
Counsel believe to have knowledge and/or information relatingto any fact and/or
in the lawsuit that You filed againstUniversal or relating
allegation to any fact underlying
the subjectmatter ofthis action.
RESPONSE:
3. Please state name, address,telephonenumber, email, place of employment, and job title of
any person and/or entitythat has conducted an inspection, adjustment,and/or
investigation,
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Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 7 of 14
Defendant' s First of Interrogatories
to Plaintiffs
evaluation of the Insured Property since the Claimed Cause of Loss, includingany person
and/or entitythat created an estimate of Your damages.
RESPONSE:
4. Please state the Date that the allegeddamage to the Insured Property occurred.
RESPONSE:
5. Please state with specificitythe event and/or reason that You claim caused the alleged
damage to the Insured Property on the Date identified in Interrogatory
No. 4.
RESPONSE:
6. Please identifywith specificityeach area of the Insured Property that was purportedly
damaged by the Claimed Cause of Loss.
7
Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 8 of 14
Defendant' s First of Interrogatories
to Plaintiffs
RESPONSE:
7. Please describe any repairsand/or renovations to the Insured Property since the Claimed
Cause of Loss. In responding to this interrogatory,please be sure to identifythe person
and/or entitythat performed such repairsand/or renovations,the cost of such repairsand/or
renovations,and the Date of such repairsand/or renovations.
RESPONSE:
8. For each and every area ofthe Insured Property that You claim was purportedlydamaged
by the Claimed Cause of Loss, pleaseidentifythe scope of the damages, a description of
the damages, and the amount of money that You are claiming that You are owed by
please be sure to
Universal for such claimed damages. In responding to this interrogatory,
provide an explanationfor the computation of all damages that You identify.
RESPONSE:
9. Are You claiming any damage to personalproperty as a result of the Claimed Cause of
Loss? If "yes," pleaseidentifythe scope ofthe damages to personalproperty, a description
of the personal property damaged, and the amount of money that You are claiming that
You are owed by Universal for such claimed damages to personalproperty. In responding
to this
interrogatory,pleasebe sure to provide an explanationfor the computation of all
personalproperty damages that You identify.
RESPONSE:
8
Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 9 of 14
Defendant' s First of Interrogatories
to Plaintiffs
10. Are You claiming that You are owed any additional livingexpenses as a result of the
Claimed Cause of Loss? If "yes," please identifythe scope of the additional living
expenses, a descriptionof the additional livingexpenses, and the amount of money that
You are claiming that You are owed by Universal for such additional livingexpenses. In
responding to this interrogatory,please be sure to provide an explanation for the
computation of all additional livingexpenses that You identify.
RESPONSE:
11. Are You claimingthat You are owed any monies for loss ofuse of the Insured Property as
a result ofthe Claimed Cause of Loss? If "yes,"pleaseidentify the scope ofthe loss ofuse,
a description of the loss of use, and the amount of money that You are claiming that You
are owed by Universal
for such loss of use of the Insured Property. In responding to this
pleasebe sure to provide an explanationfor the computation of all monies
interrogatory,
that You identifyas loss of use damages.
RESPONSE:
12. Please state the Date that You first discovered the allegeddamage to the Insured Property
as a result ofthe Claimed Cause of Loss.
RESPONSE:
13. Please state all actions taken by You or anyone on Your behalf to protect the Insured
Property from further damage since the Claimed Cause of Loss.
RESPONSE:
9
Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 10 of 14
Defendant' s First of Interrogatories
to Plaintiffs
provide the address for each and every location that
14. Please You have resided for Calendar
Year 2012 through Calendar Year 2020.
RESPONSE:
15. Pleaseprovide the name, address, telephone number, and email of all persons that have
resided at the Insured Property from the Date that You purchased the Insured Property to
the date ofresponding to these interrogatories.
RESPONSE:
16. Please state all facts upon which You base the contention that Your purporteddamages to
the Insured Property are covered by the Policy.
RESPONSE:
17. Pleaseidentifyeach insurance claim that You have made from Calendar Year 2010 to
Calendar Year 2020. In responding to this interrogatory,
please be sure to provide a
descriptionof the claim, the insurer,and the date that You made the claim.
RESPONSE:
10
Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 11 of 14
Defendant' s First of Interrogatories
to Plaintiffs
18. Please identifyall insurance carriers that have insured the Insured Property from the Date
that You purchased the Insured Property to the date ofresponding to these interrogatories.
In responding to this interrogatory, please be sure to provide the policyperiod for each
policy of insurance that You carried with another insurance carrier.
RESPONSE:
19. Please identifythe Date that the roof at the Insured Property was installed. In responding
to this interrogatory,please be sure to identifythe person and/or entitythat installed the
roof at the Insured Property and the cost of such roof installation.
RESPONSE:
20. Please identifythe Date of any repairsto the roof at the Insured Property from the Date
that You purchased the Insured Property to the date ofresponding to these interrogatories.
In responding to this interrogatory,please be sure to identifythe person and/or entitythat
repairedthe roof at the Insured Property and the cost of such roof repair.
RESPONSE:
11
Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 12 of 14
Defendant' s First of Interrogatories
to Plaintiffs
21. Have You have ever been a party (whether as a plaintiff or a defendant)to a lawsuit
concerning and/or relatingto insurance benefits,insurance coverage, and/or a policy of
insurance. If "yes," pleaseprovide (i)the case style; the case number; and (iii)
(ii) the court
in which the suit was filed.
RESPONSE:
22. Please state each Date that You received a request from Universal to provide any type of
documents and/or records concerning Your Claim.
RESPONSE:
23. Please identifyall documents and/or records that You have provided to Universal
please be sure to identifythe
concerning your Claim. In responding to this interrogatory,
Date such documents and/or records were submitted to Universal.
RESPONSE:
24. Please state the Date that You purchased the Insured Property,the purchaseprice,and the
names of any seller,real estate agent, inspectioncompany, and closingagent involved with
Your purchase o f the Insured Property.
RESPONSE:
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Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 13 of 14
Defendant' s First of Interrogatories
to Plaintiffs
25. Please describe all damages that existed at the Insured Property at the time of Your
purchase o f the Insured Property.
RESPONSE:
26. Please describe any repairsand/or renovations to the Insured Property between the Date
that You purchased the Insured Property and the Date of the Claimed Cause of Loss. In
respondingto this interrogatory, pleasebe sure to identifythe person and/or entitythat
performed such repairsand/or renovations,the cost of such repairsand/or renovations, and
the Date of such repairsand/or renovations.
RESPONSE:
27. Pleasedescribe all documents, including correspondences,sent by You or Your
to Universal at claimshelp@universalproperty.com.
representatives
RESPONSE:
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Rawatee and Balram Cecil v. UPCIC
Case No.: CACE-21-010688
Page 14 of 14
Defendant' s First of Interrogatories
to Plaintiffs
VERIFICATION OF RESPONSES TO INTERROGATORIES
Ihave read and reviewed the foregoingresponses to the above-listed interrogatories in their
entirety.
I understand that I am or
swearing affirming under oath to the truthfulness ofthe foregoing
and that the punishment for knowingly making a false
responses to the above-listed interrogatories
statement includes fines and/or imprisonment.
By:
Name.
Title:
STATE OF
COUNTY OF
BEFORE ME, the undersigned authority,duly authorized to administer oaths and take
acknowledgment, personallyappeared
who is (check one) personallyknown to me or who produced identification in the
form of
and who did, under oath state that foregoingresponses to the above-listed interrogatoriesare true
and correct.
SignatureofNotary
Printed Name
NOTARY PUBLIC,
STATE OF
Commission Exp.:
Commission No..
14
Preview
Filing# 152104084 E-Filed 06/23/2022 06:56:50 PM IN THE CIRCUIT COURT OF THE ,TH 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RAWATEE CECIL AND BALRAM CECIL, CASE NO: CACE-21-010688 Plaintiffs, VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i DEFENDANT'S FIRST SET OF INTERROGATORIES TO PLAINTIFFS Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY ("Universal"),through counsel and pursuant to Rule 1.340 ofthe Florida Rules of Civil upon Plaintiffs. Plaintiffs are to answer this set of Procedure, propounds this set of Interrogatories in writing,under oath, within the time specifiedunder the Florida Rules of Civil Interrogatories Procedure [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/23/2022 06:56:49 PM.**** Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 2 of 14 Defendant' s First of Interrogatories to Plaintiffs DEFENDANT CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E- Service to: Jesus David Moises, Esq., MOISESIGROSS, P.L.L.C. (service@moisesgross.com on June 23,2022. and rnieto@moisesgross.com), AttorneyMDefendant Universal Property & CasualtyIns. Co. PO Box 9388 Fort Lauderdale, Florida 33310 Telephone:954-958-3319 Toll Free: 1-833-658-8594 (JudgesOnly) Facsimile: 954-958-1262 By-. /s/ Joseph Henn Joseph Henn, Esq. Florida Bar No. 91143 For Service of Court Documents Onlv: Primary: upciceservice01@universalproperty.com Secondary: kb0615@universalproperty.com Tertiary: jh0518@universalproperty.com For Scheduling Matters: Is0601@universalproperty.com Please do not send any inquiries or scheduling matters to upciceservice@universalpropertv.com or upciceservice01@universalpropertv.com. 2 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 3 of 14 Defendant' s First of Interrogatories to Plaintiffs DEFINITIONS 1. "Calendar Year" means that period of time that beginsat 12:01 a.m. on January 1 of any given year and ends at 11.59 pm. on December 31 ofthat year. 2. "Claim" means the insurance claim (as defined herein)reportedto that Plaintiff 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 (as defined herein)are claimingthat the Insured Property (asdefined 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, reflecting, and constituting. analyzing, 5. "Control" means having possession of and/or the power and/or authorityto request possession of 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).If the 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 & CasualtyInsurance Company. 8. "Document" or "documents" means anythingwhich may be considered to be a document or tangiblethingwithin 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 telephoneconversations and conferences), studies,analyses,books, magazines, newspapers, publications,booklets, pamphlets, circulars,bulletins,instructions,minutes, or other communications (including,but not limited to, interoffice and intra-office communications), questionnaires, surveys, contracts, memoranda ofagreements,assignments, books ofaccount, journals,ledgers,summaries, opinions,reports, evaluations, financial statements and all records of or reflectingbusiness operations, mortgages, evaluations,orders,working papers, bills of lading,sh*ping lists, load sheets,warehouse rece*ts,letters of credit,insurance policies,records of summaries of personal interviews or conversations, appointment calendars,diaries, schedules,printouts, drawings,specifications, patents, patent applications, certificates of registration, for registration, applications graphs, charts,studies,planning 3 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 4 of 14 Defendant' s First of Interrogatories to Plaintiffs materials, statistical and compilations,forecasts,work papers, invoices, statements statements, bills,checks, bank books, bank statements, forms, vouchers, notebooks, data sheets,microfilm,microfiche,photographicnegatives, audio tape, video tape, compact disks, blueprints,specifications, architectural diagrams, schematics, logic diagrams, timing diagrams, pictures, photographs,microscopicallyobtained 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 copies thereof. Any documents bearing any marks including, but not limited to, initials,stamped indicia,comments, or notations, of any kind that are not a part of the originaltext or photographic reproduction thereof are to be considered and identified as separate documents. 9. "Dwelling" means the physicaldwelling located at the Insured Property (as defined herein). 10."Insured Property" means the real property specifically listed on the declarations page ofthe Policy (as defined herein). 11. "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. 12. "Person" or "Persons" shall mean any natural person or any legalentityincluding, but not limited to, a corporation,partnersh* and unincorporatedassociation,firm, joint venture, proprietorsh*,and/or any other entityor group of natural persons or such entities, singularor plural, and any male, female,or neuter gender,as the context may require, officer. 13. "Plaintiff" means any person and/or entitynamed as a in plaintiff this action. 14."Policy" means the insurance policythat serves as a basis for any causes of action asserted againstDefendant in this lawsuit. 15. "Related to", "relatingto", and "relate to" shall include pertainingto, referring to, mentioning, evidencing,discussingor otherwise relevant to, supporting, contradicting, involving,whether directly the subjectmatter ofthe specified or indirectly, request. 16. "Universal" means Defendant UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY 4 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 5 of 14 Defendant' s First of Interrogatories to Plaintiffs 17. "Written Communication" or "correspondence" means the conveyance of whether by letters, information by a writing, e-mails,memoranda, handwritten notes and/or faxes. 18. "Witness Statement" or "Statement" means a statement of any person with knowledge of relevant facts,regardlessofwhen the statement was made, and is either (i)a written statement signed or otherwise adopted and/or approved in writing by the person making it;or, (ii)a stenographic, and/or other type of recordingof mechanical, electrical, verbatim transcript a person's oral statement and/or any substantially of such recording. 19. "You" or"Your" means the specificparty responding to these requests and/or any person and/or entitynamed as a Plaintiff in this action. 20. "Your Counsel" means the attorney or attorneys who are representingor have representedyou either with regard to the claim or in this lawsuit. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK1 5 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 6 of 14 Defendant' s First of Interrogatories to Plaintiffs INTERROGATORIES In accordance with Rule 1.340(e)of the Fla. R. Civ. P., space has been provided aftereach interrogatoryfor a response to be inserted. However, ifmore space is needed, "the answering party may attach additional documents with answers and referto them in the space provided in the interrogatories." See, Fla. R. Civ. P. 1.340(e). 1. Please state the name, address, telephonenumber, and email of the person answeringthese Interrogatories and the name, address,telephonenumber, and email of any person assisting in preparingresponses to these Interrogatories. RESPONSE: 2. Please providethe name, address, telephonenumber, email, place of employment, and job title of any person who has, claims to have, or whom You, Your agents, and/or Your Counsel believe to have knowledge and/or information relatingto any fact and/or in the lawsuit that You filed againstUniversal or relating allegation to any fact underlying the subjectmatter ofthis action. RESPONSE: 3. Please state name, address,telephonenumber, email, place of employment, and job title of any person and/or entitythat has conducted an inspection, adjustment,and/or investigation, 6 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 7 of 14 Defendant' s First of Interrogatories to Plaintiffs evaluation of the Insured Property since the Claimed Cause of Loss, includingany person and/or entitythat created an estimate of Your damages. RESPONSE: 4. Please state the Date that the allegeddamage to the Insured Property occurred. RESPONSE: 5. Please state with specificitythe event and/or reason that You claim caused the alleged damage to the Insured Property on the Date identified in Interrogatory No. 4. RESPONSE: 6. Please identifywith specificityeach area of the Insured Property that was purportedly damaged by the Claimed Cause of Loss. 7 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 8 of 14 Defendant' s First of Interrogatories to Plaintiffs RESPONSE: 7. Please describe any repairsand/or renovations to the Insured Property since the Claimed Cause of Loss. In responding to this interrogatory,please be sure to identifythe person and/or entitythat performed such repairsand/or renovations,the cost of such repairsand/or renovations,and the Date of such repairsand/or renovations. RESPONSE: 8. For each and every area ofthe Insured Property that You claim was purportedlydamaged by the Claimed Cause of Loss, pleaseidentifythe scope of the damages, a description of the damages, and the amount of money that You are claiming that You are owed by please be sure to Universal for such claimed damages. In responding to this interrogatory, provide an explanationfor the computation of all damages that You identify. RESPONSE: 9. Are You claiming any damage to personalproperty as a result of the Claimed Cause of Loss? If "yes," pleaseidentifythe scope ofthe damages to personalproperty, a description of the personal property damaged, and the amount of money that You are claiming that You are owed by Universal for such claimed damages to personalproperty. In responding to this interrogatory,pleasebe sure to provide an explanationfor the computation of all personalproperty damages that You identify. RESPONSE: 8 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 9 of 14 Defendant' s First of Interrogatories to Plaintiffs 10. Are You claiming that You are owed any additional livingexpenses as a result of the Claimed Cause of Loss? If "yes," please identifythe scope of the additional living expenses, a descriptionof the additional livingexpenses, and the amount of money that You are claiming that You are owed by Universal for such additional livingexpenses. In responding to this interrogatory,please be sure to provide an explanation for the computation of all additional livingexpenses that You identify. RESPONSE: 11. Are You claimingthat You are owed any monies for loss ofuse of the Insured Property as a result ofthe Claimed Cause of Loss? If "yes,"pleaseidentify the scope ofthe loss ofuse, a description of the loss of use, and the amount of money that You are claiming that You are owed by Universal for such loss of use of the Insured Property. In responding to this pleasebe sure to provide an explanationfor the computation of all monies interrogatory, that You identifyas loss of use damages. RESPONSE: 12. Please state the Date that You first discovered the allegeddamage to the Insured Property as a result ofthe Claimed Cause of Loss. RESPONSE: 13. Please state all actions taken by You or anyone on Your behalf to protect the Insured Property from further damage since the Claimed Cause of Loss. RESPONSE: 9 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 10 of 14 Defendant' s First of Interrogatories to Plaintiffs provide the address for each and every location that 14. Please You have resided for Calendar Year 2012 through Calendar Year 2020. RESPONSE: 15. Pleaseprovide the name, address, telephone number, and email of all persons that have resided at the Insured Property from the Date that You purchased the Insured Property to the date ofresponding to these interrogatories. RESPONSE: 16. Please state all facts upon which You base the contention that Your purporteddamages to the Insured Property are covered by the Policy. RESPONSE: 17. Pleaseidentifyeach insurance claim that You have made from Calendar Year 2010 to Calendar Year 2020. In responding to this interrogatory, please be sure to provide a descriptionof the claim, the insurer,and the date that You made the claim. RESPONSE: 10 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 11 of 14 Defendant' s First of Interrogatories to Plaintiffs 18. Please identifyall insurance carriers that have insured the Insured Property from the Date that You purchased the Insured Property to the date ofresponding to these interrogatories. In responding to this interrogatory, please be sure to provide the policyperiod for each policy of insurance that You carried with another insurance carrier. RESPONSE: 19. Please identifythe Date that the roof at the Insured Property was installed. In responding to this interrogatory,please be sure to identifythe person and/or entitythat installed the roof at the Insured Property and the cost of such roof installation. RESPONSE: 20. Please identifythe Date of any repairsto the roof at the Insured Property from the Date that You purchased the Insured Property to the date ofresponding to these interrogatories. In responding to this interrogatory,please be sure to identifythe person and/or entitythat repairedthe roof at the Insured Property and the cost of such roof repair. RESPONSE: 11 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 12 of 14 Defendant' s First of Interrogatories to Plaintiffs 21. Have You have ever been a party (whether as a plaintiff or a defendant)to a lawsuit concerning and/or relatingto insurance benefits,insurance coverage, and/or a policy of insurance. If "yes," pleaseprovide (i)the case style; the case number; and (iii) (ii) the court in which the suit was filed. RESPONSE: 22. Please state each Date that You received a request from Universal to provide any type of documents and/or records concerning Your Claim. RESPONSE: 23. Please identifyall documents and/or records that You have provided to Universal please be sure to identifythe concerning your Claim. In responding to this interrogatory, Date such documents and/or records were submitted to Universal. RESPONSE: 24. Please state the Date that You purchased the Insured Property,the purchaseprice,and the names of any seller,real estate agent, inspectioncompany, and closingagent involved with Your purchase o f the Insured Property. RESPONSE: 12 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 13 of 14 Defendant' s First of Interrogatories to Plaintiffs 25. Please describe all damages that existed at the Insured Property at the time of Your purchase o f the Insured Property. RESPONSE: 26. Please describe any repairsand/or renovations to the Insured Property between the Date that You purchased the Insured Property and the Date of the Claimed Cause of Loss. In respondingto this interrogatory, pleasebe sure to identifythe person and/or entitythat performed such repairsand/or renovations,the cost of such repairsand/or renovations, and the Date of such repairsand/or renovations. RESPONSE: 27. Pleasedescribe all documents, including correspondences,sent by You or Your to Universal at claimshelp@universalproperty.com. representatives RESPONSE: 13 Rawatee and Balram Cecil v. UPCIC Case No.: CACE-21-010688 Page 14 of 14 Defendant' s First of Interrogatories to Plaintiffs VERIFICATION OF RESPONSES TO INTERROGATORIES Ihave read and reviewed the foregoingresponses to the above-listed interrogatories in their entirety. I understand that I am or swearing affirming under oath to the truthfulness ofthe foregoing and that the punishment for knowingly making a false responses to the above-listed interrogatories statement includes fines and/or imprisonment. By: Name. Title: STATE OF COUNTY OF BEFORE ME, the undersigned authority,duly authorized to administer oaths and take acknowledgment, personallyappeared who is (check one) personallyknown to me or who produced identification in the form of and who did, under oath state that foregoingresponses to the above-listed interrogatoriesare true and correct. SignatureofNotary Printed Name NOTARY PUBLIC, STATE OF Commission Exp.: Commission No.. 14