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Filing # 160593754 E-Filed 11/03/2022 03:45:19 PM
IN THE CIRCUIT COURT OF THE
5 JUDICIAL CIRCUIT IN AND
FOR LAKE COUNTY, FLORIDA
CASE NO: 2021-CA-001217
KELLI AND NICHOLAS J. CROFT,
Plaintiff,
Vv.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S NOTICE OF TAKING DEPOSITION DUCES TECUM
VIA ZOOM
**Please advise if Interpreter is needed **
PLEASE TAKE NOTICE that the undersigned will take the deposition by oral
examination for the purpose of discovery or evidence, or both, pursuant to Florida Rules of Civil
Procedure 1.310, of the below named person(s) at the time, date and location indicated:
NAME TIME & DATE LOCATION
Corporate December 12, 2022 Via zoom
Representative of 11:00 a.m. Universal Court Reporting
Noland’s Roofing, Inc. (will be provided)
before a Court Reporter and Notary Public of Universal Court Reporting who is not of counsel to
either of the parties or interested in the events or outcome of said cause of action.
Said deposition to be taken pursuant to Florida Rules of Civil Procedure in such cases provided.
The said oral examination will continue from hour to hour and from day to day until completed.
The deponent(s) requested above should be prepared to provide testimony regarding those topics
and areas of inquiry designated with the attached Schedule ‘’A”.
[CERTIFICATE OF SERVICE ON FOLLOWING PAGE]
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 11/03/2022 03:48:52 PM.
NOTICE: In accordance with the Americans with Disabilities Act of 1990, persons
needing special accommodation to participate in this proceeding should contact the
undersigned at (239) 252-8800, no later than seven (7) days prior to the proceeding.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed
electronically and was sent by E-mail from the Florida Courts’ E-Filing Portal system, unless
otherwise noted below on this 3rd day of November 2022, on all counsel or parties of record listed
below:
SERVICE LIST
Attorney for Plaintiff
Jabari A. Bennett, Esq.
Cohen Law Group
350 North Lake Destiny Road
Maitland, FL 32751
jbennett@itsaboutjustice.law
tiina@itsaboutjustice.law
CHARTWELL LAW
Attorneys for Defendant
1191 East Newport Center Drive
Penthouse Suite H
Deerfield Beach, FL 33442
Telephone: (754) 227-7995
Facsimile: (754) 212-4170
By: /s/ J. Michael Magee, Jr.
Laurie Sharpe Dulcer
Florida Bar: 39323
Isharpe@chartwelllaw.com
mmarotto@chartwelllaw.com
J. Michael Magee, Jr., Esq.
Florida Bar: 108068
mmagee@chartwelllaw.com
dleal@chartwelllaw.com
PURSUANT TO FLORIDA ADMINISTRATIVE CODE 64B8-10.003, A FEE OF 1.00 PER
PAGE FOR THE FIRST TWENTY-FIVE (25) PAGES AND $0.25 PER PAGE FOR EACH
2
ADDITIONAL PAGE WILL BE PAID FOR THE PHOTOCOPYING OF SAID
RECORDS.
DEFINITIONS
1 “NOLAND’S ROOFING, INC.” collectively refers to the named Plaintiff,
NOLAND’S ROOFING, INC., INC., its owners, agents, employees, subcontractors,
independent contractors and DBA/Fictitious Entities.
2
“UNITED?” refers to the named Defendant, UNITED PROPERTY INSURANCE
AND CASUALTY INSURANCE COMPANY.
3 “CROFT” collectively refers to the named Insureds/Plaintiffs, KELLI AND
NICHOLAS J. CROFT.
4 “The Subject Claim” and/or “the subject loss” refers to all losses or damages that
make up claim no. 21FL00099436, date of loss 3/7/21, which forms the basis for the above-styled
lawsuit.
5 “The Insured Property” refers to the Insured Property located at 901 Elm Forest Dr,
Minneola, Florida 34715.
6 “Professional(s)” refers to any and all Public Adjusters, Loss Consultants, Engineers,
General Contractors, construction companies, contractors, architects, independent contractors,
subcontractors, builders, plumbers, roofers, painters, carpenters, installers, laborers, renovators,
electricians, flooring installers, handypersons, individuals, assessors, mold assessors or assessment
companies, mold remediators or remediation companies, water remediators or remediation
companies, insurance agents, insurance adjusters, claim consultants, fire remediators or
remediation companies, restoration companies, accountants, sales representatives, administrative
workers, assistants and/or bookkeepers.
7
“Documents”, “Records” or “Materials” are interchangeably used in the broad and
liberal sense and refers to, but is not limited to, any and all written, typed, printed, handwritten,
recorded or graphic matter, however produced or reproduced, of any kind and description, and
whether an original, master, native format, duplicate or copy, including, but not limited to,
accounts, advertisements, agreements, appointment books, bank checks, bills, books, books of
account, estimates, inventory sheets, cancelled checks, cashier's checks, charts, check stubs,
communications, computer printouts, contracts, corporate records, correspondence, diaries,
3
invoices, assignments, releases, disclosures, price lists, claim forms, acknowledgment forms,
authorizations, agreements for services, directions to pay, referral contracts, agreements, contracts,
reports, work orders, repair orders, charts, graphs, diagrams, evaluations, testing records and
results, sampling records and reports, notices, memos, receipts, photographs, videos, digital
images, sketches, drawings, mock-ups or other images, logs, notes, inventory sheets; lists,
calendars, appointment logs, employee time logs, equipment logs, schedules, handwritten or
typewritten notes, appraisals, valuations, payment records, bills, Notices of Commencement,
Permit Applications, Permits, Permit records, proofs of permits, proof of payment for permits and
any services related to same, Claims of Lien, Discharges of Lien, diary entries, e-mail, guarantees,
inter-office communications, manuals, models, pamphlets, sound recordings, specifications,
statements, statistics, studies, summaries, surveys, tape recordings, faxes, transcripts, warranties
and all amendments, changes, drafts, COLOR and Black and White photographs, videos,
videotapes, video recordings, audio, audiotapes, audio recordings, manually or digitally created
renderings, digital images, sketches, drawings, mock-ups or other images, CD’s, DVD’s, flash
drives, emails, electronic communications of any kind or type, databases, applications, programs,
and any other tangible or intangible item or data or documents of any kind pertaining to any and
all services rendered and/or any and all repairs or replacements made and modifications of any of
the foregoing, of which you have knowledge or which are now or were formerly in your actual or
constructive possession, custody or control, including any exhibits, attachments or documents
referenced therein.
8. When used in this Request, the terms “data” “electronic data" mean computerized
files and any non-identical copies (whether non-identical because of notes made on copies or
attached comments, annotations, marks, transmission notations, or highlighting of any kind) of
writings of every kind and description whether inscribed by mechanical, facsimile, electronic,
magnetic, digital, or other means in any format including but not limited to .ACCDB, .ADP,
-ARW., .BMP, .CSV, .DAT, .DIC, .DLINK, DOC, .DOCX, .DOC, .DOTX, .DOTM,.EML, .ESI,
-ESX, .EXC, .FDF,, GDOC, .GIF, .HTML, .INI, JPEG, .JPG, .LOG, .MAD, .MAF., .MP3, .MP4,
.MPEG, .MPV, .ODC, .ODP, .ODS, .ODT, .OLS, .ONE, .PDF, .PDX, .POT, .PPDF, .RTF, .TXT,
-WPD, .WP, etc. Electronic data includes, but is not limited to output resulting from the use of any
software program that is housed, stored, kept or maintained in any other file or document storage
program, including but not limited to word processing programs such as Microsoft Word,
WordPerfect, Notepad, Wordpad, PowerPoint, MS Excel, MS Access, Adobe Acrobat, Outlook,
Xactimate, Symbility, SimSol, JobNimbus, Google Docs, DropBox, spreadsheets, database files
(including descriptive information regarding tables, fields and values), charts, graphs and outlines,
electronic mail, photographs, pictures, and any and all miscellaneous files and/or file fragments,
regardless of the media on which they reside and regardless of whether said electronic data consists
in an active file, deleted file or file fragment. Electronic data includes any and all items stored on
computer memories, hard-disks, floppy disks, CD-ROMs, DVDs, removable media such as Zip
disks, thumb drives, digital memory cards and their equivalent, magnetic tapes of all types, on or
in any other vehicle for digital data storage and/or transmittal. The term electronic data also
includes the file, folder tabs and/or containers and labels appended to, or associated with, any
physical storage device associated with each original and/or copy.
SCHEDULE "A" — AREAS OF INQUIRY
Any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or
remediation made and/or any goods or services provided and/or repairs made to the
Insured Property in the Subject Claim including to the nature and scope of same, and.
the dates same were commenced and completed.
The cost of any and all evaluations, inspections, testing, repairs, reconstruction, rebuild
and/or remediation made and/or any goods or services provided and/or repairs made
to the Insured Property, including to knowledge of the source(s), price(s), condition
and identifying information (e.g., manufacturer, model, color, etc.) of materials used
at the Insured Property as well as the name(s), address(es), and licensure (if any) of
every individual who has performed work at the Insured Property on behalf of
NOLAND’S ROOFING, INC., the total number of the day(s) and time(s) work was
performed at the Insured Property by NOLAND’S ROOFING, INC. in the Subject
Claim, and any other factors that impact labor costs.
Each and every estimate prepared by NOLAND’S ROOFING, INC. in the Subject Claim
along with all supporting documentation for the pricing contained in same.
All correspondence between NOLAND’S ROOFING, INC. or NOLAND’S ROOFING, INC.’S
representative(s) and CROFT regarding the Subject Claim.
Whether NOLAND’S ROOFING, INC. reused or repurposed any materials at the Insured
Property for any repairs, reconstruction, rebuild and/or remediation in the Subject Claim.
Any and all dealings with the relevant building department governing the Insured Property
regarding the Subject Claim since the date of the subject loss, including knowledge of the
number and nature of permits applied for; status for each and every permit; valuations and fees
for each and every permit, and inspections, including whether the inspections were passed or
failed and the reason for failure, if applicable.
NOLAND’S ROOFING, INC.’S licenses and qualifications, including any qualifier(s) at all
times material to the Subject Claim.
Any payments made to NOLAND’S ROOFING, INC. by CROFT the Subject Claim for any
and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made
and/or any goods or services provided and/or repairs made to or for the benefit of CROFT or the
Insured Property and the amount of same.
Any payments made by NOLAND’S ROOFING, INC. to any entity(ies) or Professional(s) for
by CROFT any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or
remediation made and/or any goods or services provided and/or repairs made to or for the benefit
of CROFT or the Insured Property in the Subject Claim.
Any and all subcontractors retained or to be retained for any and all evaluations, inspections,
testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services
provided and/or repairs made to or for the benefit of CROFT or the Insured Property in the
Subject Claim.
The permit value for any permit pulled by NOLAND’S ROOFING, INC. and/or its qualifier for
any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation
made and/or any goods or services provided and/or repairs made to or for the benefit of CROFT
or the Insured Property in the Subject Claim.
The identity and version of all Software programs utilized by NOLAND’S ROOFING, INC. in
determining the cost of for any and all evaluations, inspections, testing, repairs, reconstruction,
rebuild and/or remediation made and/or any goods or services provided and/or repairs made to
or for the benefit of CROFT or the Insured Property in the Subject Claim.
All facts and information supporting the allegations in NOLAND’S ROOFING, INC.’S
Complaint as to the amount of actual damages to the Insured Property as claimed by
NOLAND’S ROOFING, INC. in the above-styled lawsuit.
All facts and information supporting the allegations in NOLAND’S ROOFING, INC.’S
Complaint as to the method(s) of calculation of the amount of actual damages to the Insured
Property as claimed by NOLAND’S ROOFING, INC. in the above-styled lawsuit.
All facts and information as to the cause of the subject loss and all damages claimed by
NOLAND’S ROOFING, INC. resulting from same in the Subject Claim.
All facts and information supporting the allegations in NOLAND’S ROOFING, INC.’S
Complaint that UNITED breached the subject policy of insurance, including the specific
portions of the subject policy NOLAND’S ROOFING, INC. alleges UNITED breached and how
UNITED allegedly breached each portion.
All facts and information alleged in NOLAND’S ROOFING, INC.’S responses to UNITED'S
Interrogatories and Request for Production in the above-styled lawsuit.
Any and all other facts and information NOLAND’S ROOFING, INC. contends supports the
allegations in the above-styled lawsuit.
SCHEDULE "B" —- DUCES TECUM
A complete copy of NOLAND’S ROOFING, INC.’S entire file, cover to cover, regarding
the Insured Property and the Subject Claim.
Any and all Document(s), Records or Material(s) evidencing proof of completion of the
exact evaluations, inspections, testing, repairs, reconstruction, rebuild and/or
remediation made and/or any goods or services provided and/or repairs made to the
Insured Property in the Subject Claim, as well as Document(s), Records or
Material(s) evidencing the identity of the person or Professional(s) who completed the
exact repairs, reconstruction and remediation made and/or any goods or services
provided repairs made to the Insured Property in the Subject Claim.
Any and all Document(s), Records or Material(s) evidencing proof of payment received
by or for the benefit of NOLAND’S ROOFING, INC. for evaluations, inspections,
testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or
services provided and/or repairs made to the Insured Property in the Subject Claim,
as well as Document(s), Records or Material(s) evidencing the identity of the person
or Professional(s) who completed the exact repairs, reconstruction and remediation
made and/or any goods or services provided repairs made to the Insured Property in
the Subject Claim.
Any and all Document(s), Records or Material(s) exchanged between NOLAND’S
ROOFING, INC. and UNITED pertaining to any of the evaluations, inspections,
testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or
services provided and/or repairs made to the Insured Property in the Subject Claim.
Any and all Document(s), Records or Material(s) exchanged between NOLAND’S,
ROOFING, INC. and anyone other than UNITED pertaining to any of the
evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation
made and/or any goods or services provided and/or repairs made to the Insured
Property in the Subject Claim.
Any and all Document(s), Records or Material(s) from or on behalf of NOLAND’S
ROOFING, INC. or its attorney(s), representative(s) or agent(s) to any agent,
attorney or employee of UNITED regarding the Subject Claim.
Any and all Document(s), Records or Material(s) regarding all pricing data utilized by
NOLAND’S ROOFING, INC. to prepare each and every estimate submitted to UNITED, and
whether any automatically populated pricing data was manually modified by or on behalf of
NOLAND’S ROOFING, INC. in the Subject Claim.
Any and all Document(s), Records or Material(s) exchanged between NOLAND’S
ROOFING, INC. and any and all contractors or subcontractors pertaining to any
and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or
remediation made and/or any goods or services provided and/or repairs made in the
Subject Claim.
Any and all Document(s), Records or Material(s) responsive to UNITED'S discovery
requests to NOLAND’S ROOFING, INC. in the above-styled lawsuit.
Any and all Document(s), Records or Material(s) NOLAND’S ROOFING, INC. contends
supports the allegations in the above-styled lawsuit
Any and all Document(s), Records or Material(s) referenced in or produced in response
to NOLAND’S ROOFING, INC.’S responses to UNITED'S Interrogatories and
Request for Production in the above-styled lawsuit.
A complete copy of NOLAND’S ROOFING, INC.’S entire file, cover to cover, regarding
the Insured Property for any prior or subsequent claims or losses at the Insured
Property in which NOLAND’S ROOFING, INC. was involved in any way.
Preview
Filing # 160593754 E-Filed 11/03/2022 03:45:19 PM IN THE CIRCUIT COURT OF THE 5 JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA CASE NO: 2021-CA-001217 KELLI AND NICHOLAS J. CROFT, Plaintiff, Vv. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / DEFENDANT’S NOTICE OF TAKING DEPOSITION DUCES TECUM VIA ZOOM **Please advise if Interpreter is needed ** PLEASE TAKE NOTICE that the undersigned will take the deposition by oral examination for the purpose of discovery or evidence, or both, pursuant to Florida Rules of Civil Procedure 1.310, of the below named person(s) at the time, date and location indicated: NAME TIME & DATE LOCATION Corporate December 12, 2022 Via zoom Representative of 11:00 a.m. Universal Court Reporting Noland’s Roofing, Inc. (will be provided) before a Court Reporter and Notary Public of Universal Court Reporting who is not of counsel to either of the parties or interested in the events or outcome of said cause of action. Said deposition to be taken pursuant to Florida Rules of Civil Procedure in such cases provided. The said oral examination will continue from hour to hour and from day to day until completed. The deponent(s) requested above should be prepared to provide testimony regarding those topics and areas of inquiry designated with the attached Schedule ‘’A”. [CERTIFICATE OF SERVICE ON FOLLOWING PAGE] FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 11/03/2022 03:48:52 PM. NOTICE: In accordance with the Americans with Disabilities Act of 1990, persons needing special accommodation to participate in this proceeding should contact the undersigned at (239) 252-8800, no later than seven (7) days prior to the proceeding. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed electronically and was sent by E-mail from the Florida Courts’ E-Filing Portal system, unless otherwise noted below on this 3rd day of November 2022, on all counsel or parties of record listed below: SERVICE LIST Attorney for Plaintiff Jabari A. Bennett, Esq. Cohen Law Group 350 North Lake Destiny Road Maitland, FL 32751 jbennett@itsaboutjustice.law tiina@itsaboutjustice.law CHARTWELL LAW Attorneys for Defendant 1191 East Newport Center Drive Penthouse Suite H Deerfield Beach, FL 33442 Telephone: (754) 227-7995 Facsimile: (754) 212-4170 By: /s/ J. Michael Magee, Jr. Laurie Sharpe Dulcer Florida Bar: 39323 Isharpe@chartwelllaw.com mmarotto@chartwelllaw.com J. Michael Magee, Jr., Esq. Florida Bar: 108068 mmagee@chartwelllaw.com dleal@chartwelllaw.com PURSUANT TO FLORIDA ADMINISTRATIVE CODE 64B8-10.003, A FEE OF 1.00 PER PAGE FOR THE FIRST TWENTY-FIVE (25) PAGES AND $0.25 PER PAGE FOR EACH 2 ADDITIONAL PAGE WILL BE PAID FOR THE PHOTOCOPYING OF SAID RECORDS. DEFINITIONS 1 “NOLAND’S ROOFING, INC.” collectively refers to the named Plaintiff, NOLAND’S ROOFING, INC., INC., its owners, agents, employees, subcontractors, independent contractors and DBA/Fictitious Entities. 2 “UNITED?” refers to the named Defendant, UNITED PROPERTY INSURANCE AND CASUALTY INSURANCE COMPANY. 3 “CROFT” collectively refers to the named Insureds/Plaintiffs, KELLI AND NICHOLAS J. CROFT. 4 “The Subject Claim” and/or “the subject loss” refers to all losses or damages that make up claim no. 21FL00099436, date of loss 3/7/21, which forms the basis for the above-styled lawsuit. 5 “The Insured Property” refers to the Insured Property located at 901 Elm Forest Dr, Minneola, Florida 34715. 6 “Professional(s)” refers to any and all Public Adjusters, Loss Consultants, Engineers, General Contractors, construction companies, contractors, architects, independent contractors, subcontractors, builders, plumbers, roofers, painters, carpenters, installers, laborers, renovators, electricians, flooring installers, handypersons, individuals, assessors, mold assessors or assessment companies, mold remediators or remediation companies, water remediators or remediation companies, insurance agents, insurance adjusters, claim consultants, fire remediators or remediation companies, restoration companies, accountants, sales representatives, administrative workers, assistants and/or bookkeepers. 7 “Documents”, “Records” or “Materials” are interchangeably used in the broad and liberal sense and refers to, but is not limited to, any and all written, typed, printed, handwritten, recorded or graphic matter, however produced or reproduced, of any kind and description, and whether an original, master, native format, duplicate or copy, including, but not limited to, accounts, advertisements, agreements, appointment books, bank checks, bills, books, books of account, estimates, inventory sheets, cancelled checks, cashier's checks, charts, check stubs, communications, computer printouts, contracts, corporate records, correspondence, diaries, 3 invoices, assignments, releases, disclosures, price lists, claim forms, acknowledgment forms, authorizations, agreements for services, directions to pay, referral contracts, agreements, contracts, reports, work orders, repair orders, charts, graphs, diagrams, evaluations, testing records and results, sampling records and reports, notices, memos, receipts, photographs, videos, digital images, sketches, drawings, mock-ups or other images, logs, notes, inventory sheets; lists, calendars, appointment logs, employee time logs, equipment logs, schedules, handwritten or typewritten notes, appraisals, valuations, payment records, bills, Notices of Commencement, Permit Applications, Permits, Permit records, proofs of permits, proof of payment for permits and any services related to same, Claims of Lien, Discharges of Lien, diary entries, e-mail, guarantees, inter-office communications, manuals, models, pamphlets, sound recordings, specifications, statements, statistics, studies, summaries, surveys, tape recordings, faxes, transcripts, warranties and all amendments, changes, drafts, COLOR and Black and White photographs, videos, videotapes, video recordings, audio, audiotapes, audio recordings, manually or digitally created renderings, digital images, sketches, drawings, mock-ups or other images, CD’s, DVD’s, flash drives, emails, electronic communications of any kind or type, databases, applications, programs, and any other tangible or intangible item or data or documents of any kind pertaining to any and all services rendered and/or any and all repairs or replacements made and modifications of any of the foregoing, of which you have knowledge or which are now or were formerly in your actual or constructive possession, custody or control, including any exhibits, attachments or documents referenced therein. 8. When used in this Request, the terms “data” “electronic data" mean computerized files and any non-identical copies (whether non-identical because of notes made on copies or attached comments, annotations, marks, transmission notations, or highlighting of any kind) of writings of every kind and description whether inscribed by mechanical, facsimile, electronic, magnetic, digital, or other means in any format including but not limited to .ACCDB, .ADP, -ARW., .BMP, .CSV, .DAT, .DIC, .DLINK, DOC, .DOCX, .DOC, .DOTX, .DOTM,.EML, .ESI, -ESX, .EXC, .FDF,, GDOC, .GIF, .HTML, .INI, JPEG, .JPG, .LOG, .MAD, .MAF., .MP3, .MP4, .MPEG, .MPV, .ODC, .ODP, .ODS, .ODT, .OLS, .ONE, .PDF, .PDX, .POT, .PPDF, .RTF, .TXT, -WPD, .WP, etc. Electronic data includes, but is not limited to output resulting from the use of any software program that is housed, stored, kept or maintained in any other file or document storage program, including but not limited to word processing programs such as Microsoft Word, WordPerfect, Notepad, Wordpad, PowerPoint, MS Excel, MS Access, Adobe Acrobat, Outlook, Xactimate, Symbility, SimSol, JobNimbus, Google Docs, DropBox, spreadsheets, database files (including descriptive information regarding tables, fields and values), charts, graphs and outlines, electronic mail, photographs, pictures, and any and all miscellaneous files and/or file fragments, regardless of the media on which they reside and regardless of whether said electronic data consists in an active file, deleted file or file fragment. Electronic data includes any and all items stored on computer memories, hard-disks, floppy disks, CD-ROMs, DVDs, removable media such as Zip disks, thumb drives, digital memory cards and their equivalent, magnetic tapes of all types, on or in any other vehicle for digital data storage and/or transmittal. The term electronic data also includes the file, folder tabs and/or containers and labels appended to, or associated with, any physical storage device associated with each original and/or copy. SCHEDULE "A" — AREAS OF INQUIRY Any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to the Insured Property in the Subject Claim including to the nature and scope of same, and. the dates same were commenced and completed. The cost of any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to the Insured Property, including to knowledge of the source(s), price(s), condition and identifying information (e.g., manufacturer, model, color, etc.) of materials used at the Insured Property as well as the name(s), address(es), and licensure (if any) of every individual who has performed work at the Insured Property on behalf of NOLAND’S ROOFING, INC., the total number of the day(s) and time(s) work was performed at the Insured Property by NOLAND’S ROOFING, INC. in the Subject Claim, and any other factors that impact labor costs. Each and every estimate prepared by NOLAND’S ROOFING, INC. in the Subject Claim along with all supporting documentation for the pricing contained in same. All correspondence between NOLAND’S ROOFING, INC. or NOLAND’S ROOFING, INC.’S representative(s) and CROFT regarding the Subject Claim. Whether NOLAND’S ROOFING, INC. reused or repurposed any materials at the Insured Property for any repairs, reconstruction, rebuild and/or remediation in the Subject Claim. Any and all dealings with the relevant building department governing the Insured Property regarding the Subject Claim since the date of the subject loss, including knowledge of the number and nature of permits applied for; status for each and every permit; valuations and fees for each and every permit, and inspections, including whether the inspections were passed or failed and the reason for failure, if applicable. NOLAND’S ROOFING, INC.’S licenses and qualifications, including any qualifier(s) at all times material to the Subject Claim. Any payments made to NOLAND’S ROOFING, INC. by CROFT the Subject Claim for any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to or for the benefit of CROFT or the Insured Property and the amount of same. Any payments made by NOLAND’S ROOFING, INC. to any entity(ies) or Professional(s) for by CROFT any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to or for the benefit of CROFT or the Insured Property in the Subject Claim. Any and all subcontractors retained or to be retained for any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to or for the benefit of CROFT or the Insured Property in the Subject Claim. The permit value for any permit pulled by NOLAND’S ROOFING, INC. and/or its qualifier for any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to or for the benefit of CROFT or the Insured Property in the Subject Claim. The identity and version of all Software programs utilized by NOLAND’S ROOFING, INC. in determining the cost of for any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to or for the benefit of CROFT or the Insured Property in the Subject Claim. All facts and information supporting the allegations in NOLAND’S ROOFING, INC.’S Complaint as to the amount of actual damages to the Insured Property as claimed by NOLAND’S ROOFING, INC. in the above-styled lawsuit. All facts and information supporting the allegations in NOLAND’S ROOFING, INC.’S Complaint as to the method(s) of calculation of the amount of actual damages to the Insured Property as claimed by NOLAND’S ROOFING, INC. in the above-styled lawsuit. All facts and information as to the cause of the subject loss and all damages claimed by NOLAND’S ROOFING, INC. resulting from same in the Subject Claim. All facts and information supporting the allegations in NOLAND’S ROOFING, INC.’S Complaint that UNITED breached the subject policy of insurance, including the specific portions of the subject policy NOLAND’S ROOFING, INC. alleges UNITED breached and how UNITED allegedly breached each portion. All facts and information alleged in NOLAND’S ROOFING, INC.’S responses to UNITED'S Interrogatories and Request for Production in the above-styled lawsuit. Any and all other facts and information NOLAND’S ROOFING, INC. contends supports the allegations in the above-styled lawsuit. SCHEDULE "B" —- DUCES TECUM A complete copy of NOLAND’S ROOFING, INC.’S entire file, cover to cover, regarding the Insured Property and the Subject Claim. Any and all Document(s), Records or Material(s) evidencing proof of completion of the exact evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to the Insured Property in the Subject Claim, as well as Document(s), Records or Material(s) evidencing the identity of the person or Professional(s) who completed the exact repairs, reconstruction and remediation made and/or any goods or services provided repairs made to the Insured Property in the Subject Claim. Any and all Document(s), Records or Material(s) evidencing proof of payment received by or for the benefit of NOLAND’S ROOFING, INC. for evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to the Insured Property in the Subject Claim, as well as Document(s), Records or Material(s) evidencing the identity of the person or Professional(s) who completed the exact repairs, reconstruction and remediation made and/or any goods or services provided repairs made to the Insured Property in the Subject Claim. Any and all Document(s), Records or Material(s) exchanged between NOLAND’S ROOFING, INC. and UNITED pertaining to any of the evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to the Insured Property in the Subject Claim. Any and all Document(s), Records or Material(s) exchanged between NOLAND’S, ROOFING, INC. and anyone other than UNITED pertaining to any of the evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made to the Insured Property in the Subject Claim. Any and all Document(s), Records or Material(s) from or on behalf of NOLAND’S ROOFING, INC. or its attorney(s), representative(s) or agent(s) to any agent, attorney or employee of UNITED regarding the Subject Claim. Any and all Document(s), Records or Material(s) regarding all pricing data utilized by NOLAND’S ROOFING, INC. to prepare each and every estimate submitted to UNITED, and whether any automatically populated pricing data was manually modified by or on behalf of NOLAND’S ROOFING, INC. in the Subject Claim. Any and all Document(s), Records or Material(s) exchanged between NOLAND’S ROOFING, INC. and any and all contractors or subcontractors pertaining to any and all evaluations, inspections, testing, repairs, reconstruction, rebuild and/or remediation made and/or any goods or services provided and/or repairs made in the Subject Claim. Any and all Document(s), Records or Material(s) responsive to UNITED'S discovery requests to NOLAND’S ROOFING, INC. in the above-styled lawsuit. Any and all Document(s), Records or Material(s) NOLAND’S ROOFING, INC. contends supports the allegations in the above-styled lawsuit Any and all Document(s), Records or Material(s) referenced in or produced in response to NOLAND’S ROOFING, INC.’S responses to UNITED'S Interrogatories and Request for Production in the above-styled lawsuit. A complete copy of NOLAND’S ROOFING, INC.’S entire file, cover to cover, regarding the Insured Property for any prior or subsequent claims or losses at the Insured Property in which NOLAND’S ROOFING, INC. was involved in any way.