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Filing # 154365093 E-Filed 07/29/2022 04:57:29 PM
IN THE CIRCUIT COURT OF THE
FIFTH JUDICIAL CIRCUIT, IN AND
FOR LAKE COUNTY, FLORIDA
CASE NUMBER: 352021CA001217AXXXXX
Kelli and Nicholas J. Croft,
Plaintiffs,
Vv.
United Property & Casualty Insurance
Company
Defendant.
/
NOTICE OF SERVING PLAINTIFF’S RESPONSES TO
DEFENDANT’S REQUEST FOR PRODUCTION
NOTICE IS HEREBY GIVEN that Plaintiffs Kelli and Nicholas J. Croft, by and
through the undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.350 has served
their Responses to Defendant’s Request for Production.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 29, 2022, I electronically filed the foregoing with the
Clerk of the Court by using the Florida Courts E-Filing Portal which will send notice of this
electronic filing to counsel of record.
/s/ Jabari A. Bennett
COHEN LAW GROUP
Jabari A. Bennett, Esq.
FOR THE FIRM
Florida Bar Number: 0110725
350 North Lake Destiny Road, Suite 200
Maitland, Florida 32751
Primary: jbennett@itsaboutjustice.law
Secondary: tiina@itsaboutjustice.law
Phone: (407) 478-4878
Fax: (407) 478-0204
Attorneys for Plaintiff
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 08/01/2022 10:21:43 AM
PRELIMINARY STATEMENT
These responses are made solely for the purpose, and in relation to this action. Each
response is given subject to appropriate objection (including, but not limited to, objections
concerning competency, relevancy, materiality and admissibility) which would require the
exclusion of any statement or document contained herein if the information contained
within the Request were asked of or any statement contained herein were made by, a
witness present and testifying in court. All such objections and grounds therefore are
reserved and may be interposed at the time of trial.
This responding party has not completed its investigation of the facts relating to this
action, has not yet completed discovery in this action, and has not yet completed
preparation for trial. The following Responses are therefore given without prejudice to this
party’s right to allege and/or produce evidence of any subsequently discovered documents,
facts or circumstances.
Except for documents explicitly produced or discussed herein, no admission of any
nature is to be implied or inferred. The fact that any Request herein has been answered
should not be taken as an admission, or confession of the existence of any fact set forth or
assumed by such Request or that such response constitutes evidence of any fact thus set
forth or assumed. All preliminary instructions and definitions to said responses are objected
to as being burdensome and oppressive.
These comments shall apply to each and every response given herein and shall be incorporated
by reference as though fully set forth in all the responses appearing in the following pages.
RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION
Any and all documents relating to repairs performed in relation to the claims that are the
subject of this litigation, including but not limited to receipts, invoices, permits,
estimates, photographs, checks, bank statements, etc.
RESPONSE: See Attached Exhibits. Discovery in this matter is ongoing and thus,
Plaintiffs reserve the right to amend and/or supplement this Response.
Any and all documents relating to, reflecting, or evidencing any action taken by you, or
anyone or your behalf, to protect the insured property from further damage following the
respective losses.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
Any and all documents relating to, reflecting, or evidencing expenses incurred by you as
aresult of the subject loss occurring on or about September 10, 2017.
RESPONSE: Plaintiffs do not have documents responsive to this Request currently in
their possession, custody or control. Discovery in this matter is ongoing and thus,
Plaintiffs reserve the right to amend and/or supplement this Response.
Any and all documents relating to, reflecting, or evidencing the reporting to Defendant
of the subject loss and damage(s) you allege were caused as a result of the subject loss.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
All photographs and/or videos depicting the claimed damages to the Insured Property
that you maintain were caused by the subject loss or in any way relate to the claim that is
the subject of this litigation.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
Any and all documents and correspondence in your possession that were exchanged
between you, your representatives, and attorneys and Defendant regarding the claim that
is the subject of this litigation.
RESPONSE: Objection: This Request calls for documents protected under the attorney-
client privilege doctrine and/or the work product privilege doctrine. Discovery in this
matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this
Response.
Any and all documents evidencing payment(s) by the Defendant in relation to the claim
that is the subject of this litigation, including any copies of checks, deposit slips, receipts,
or correspondences enclosing any such payment(s).
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
Any and all surveys, inspection reports, estimates and/or similar documents regarding
damages to the Insured Property as a result of the claim that is the subject of this
litigation.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
Any and all bills, invoices, estimates, contracts, and similar documents pertaining to the
claim that is the subject of this litigation.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
10. Any and all documents evidencing your efforts to repair the reported damages to the
Insured Property relating to the claim that is the subject of this litigation.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
11 Any and all receipts, vouchers, or other documents that reflect any and all benefits paid
or payable to you as a result of the damages alleged in the Complaint.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
12 Any and all written statements in your or your attorney's possession from any employee,
representative, adjuster, attorney, or agent of Defendant pertaining to the subject claims
and/or the instant litigation.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
13 Any and all documents relating to any oral, written, or electronic communications
between Defendant and/or its representatives and you or anyone representing you
regarding the subject claim.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
14 Any and all correspondence, contracts, agreements, assignments, assignment of benefits,
direct payment authorization, hold harmless agreement, or any other documents between
you and any third parties in relation to the claim forming the basis of this lawsuit.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
15 Any and all photographs (color if available) taken by or on behalf of you, your attorney,
or your other representatives between 2017 and the present that depict the subject areas
of the Insured Property that sustained the damages claimed in this lawsuit.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
16 All documents relating to and memorializing any repairs and/or maintenance performed
to the Insured Property for the last five (5) years to the present date.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
17 Any and all documents relating to prior claims made by you or your representatives
against Defendant, other insurance carriers, or any collateral sources of insurance i.e.,
flood insurance or any other property insurance coverage, within the past ten (10) years
for the Insured Property.
RESPONSE: Objection: Overly broad and unduly burdensome and not reasonably
calculated to lead to the discovery of admissible evidence. Without waiving said
objection and upon information and belief, see Response to Request Number 3.
Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or
supplement this Response.
18 Any and all correspondences, documents, photographs, reports, analysis, study, or other
similar documents prepared by any expert or engineer retained by you regarding the
claims subject to this litigation.
RESPONSE: Plaintiffs’ expert witness list and any corresponding reports will be
produced by the date established during the pre-trial Case Management Conference as
set forth by Florida Rule of Civil Procedure 1.200(a)(8). Such conference has not yet
been held in this matter. Discovery is ongoing and thus, Plaintiffs reserves the right to
amend and/or supplement this Response.
19 Any and all correspondences, documents, photographs, reports, analysis, study, or other
similar documents prepared by any public adjuster retained by you in relation to the
claims that are the subject of this litigation.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
20 Any and all documents and exhibits that you intend to use at trial in this matter.
RESPONSE: Plaintiffs’ exhibit list and any corresponding exhibits will be produced by
the date established during the pre-trial Case Management Conference as set forth by
Florida Rule of Civil Procedure 1.200(a)(8). Such conference has not yet been held in
this matter. Discovery is ongoing and thus, Plaintiffs reserves the right to amend and/or
supplement this Response.
21 A current mortgage statement reflecting your mortgagee/lien holder and principle
balance of your mortgage, if applicable.
RESPONSE: Objection: Overly broad and unduly burdensome and not reasonably
calculated to lead to the discovery of admissible evidence. Discovery in this matter is
ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
22 Any assignment of mortgage, transfer of mortgage, or satisfactions of mortgage received
on the Insured Property.
RESPONSE: See Response to Request Number 21. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
23 Any and all copies of checks or any form of payment received by you from the
Defendant in relation to the subject claims, including any such documents in your
possession indicating the date such payment was made, the amount of the payment and
what it was intended for, and any other such documents evidencing the status of the
checks (deposit slips, cash receipts, bank statements).
RESPONSE: Objection: Cumulative. Without waiving said objection, see Response to
Request Number 7. Discovery in this matter is ongoing and thus, Plaintiffs reserve the
right to amend and/or supplement this Response.
24 Any and all documents relating to expenses paid by you or your representatives with the
funds issued by Defendant for the subject claim.
RESPONSE: Objection: Cumulative. Without waiving said objection, see Response to
Request Number 7. Discovery in this matter is ongoing and thus, Plaintiffs reserve the
right to amend and/or supplement this Response.
25 Any all contracts or agreements signed by you with any third party related to the Insured
Property and subject claim.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
26 Any and all past receipts and invoices for any repairs made to the roof of the Insured
Property within the past 7 years.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
27 Any and all photographs of the Insured property within the past 7 years.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
28 Any and all bids or estimates for roof replacement of the Insured Property from any
roofing contractor.
RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
29 Any and all documents relating to, reflecting, or evidencing the sale of the subject
property, including all closing documents.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
30 Any and all documents relating to, reflecting, or evidencing any claim the subject
property was sold at less than fair market value (/.e. Diminution of Value).
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
31 Any and all documents relating to, reflecting, or evidencing pre-purchase inspections of
the subject property.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
32 Any and all documents relating to, reflecting, or evidencing COMPS, aka comparable
sales, relied upon in the sale of the subject property.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
33 Any and all documents relating to, reflecting, or evidencing Appraisal of the subject
property.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
34 Any and all documents relating to, reflecting, or evidencing your application, including
inspection reports, to Frontline Insurance.
RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing
and thus, Plaintiffs reserve the right to amend and/or supplement this Response.
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Preview
Filing # 154365093 E-Filed 07/29/2022 04:57:29 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR LAKE COUNTY, FLORIDA CASE NUMBER: 352021CA001217AXXXXX Kelli and Nicholas J. Croft, Plaintiffs, Vv. United Property & Casualty Insurance Company Defendant. / NOTICE OF SERVING PLAINTIFF’S RESPONSES TO DEFENDANT’S REQUEST FOR PRODUCTION NOTICE IS HEREBY GIVEN that Plaintiffs Kelli and Nicholas J. Croft, by and through the undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.350 has served their Responses to Defendant’s Request for Production. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 29, 2022, I electronically filed the foregoing with the Clerk of the Court by using the Florida Courts E-Filing Portal which will send notice of this electronic filing to counsel of record. /s/ Jabari A. Bennett COHEN LAW GROUP Jabari A. Bennett, Esq. FOR THE FIRM Florida Bar Number: 0110725 350 North Lake Destiny Road, Suite 200 Maitland, Florida 32751 Primary: jbennett@itsaboutjustice.law Secondary: tiina@itsaboutjustice.law Phone: (407) 478-4878 Fax: (407) 478-0204 Attorneys for Plaintiff FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 08/01/2022 10:21:43 AM PRELIMINARY STATEMENT These responses are made solely for the purpose, and in relation to this action. Each response is given subject to appropriate objection (including, but not limited to, objections concerning competency, relevancy, materiality and admissibility) which would require the exclusion of any statement or document contained herein if the information contained within the Request were asked of or any statement contained herein were made by, a witness present and testifying in court. All such objections and grounds therefore are reserved and may be interposed at the time of trial. This responding party has not completed its investigation of the facts relating to this action, has not yet completed discovery in this action, and has not yet completed preparation for trial. The following Responses are therefore given without prejudice to this party’s right to allege and/or produce evidence of any subsequently discovered documents, facts or circumstances. Except for documents explicitly produced or discussed herein, no admission of any nature is to be implied or inferred. The fact that any Request herein has been answered should not be taken as an admission, or confession of the existence of any fact set forth or assumed by such Request or that such response constitutes evidence of any fact thus set forth or assumed. All preliminary instructions and definitions to said responses are objected to as being burdensome and oppressive. These comments shall apply to each and every response given herein and shall be incorporated by reference as though fully set forth in all the responses appearing in the following pages. RESPONSE TO DEFENDANT’S REQUEST FOR PRODUCTION Any and all documents relating to repairs performed in relation to the claims that are the subject of this litigation, including but not limited to receipts, invoices, permits, estimates, photographs, checks, bank statements, etc. RESPONSE: See Attached Exhibits. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. Any and all documents relating to, reflecting, or evidencing any action taken by you, or anyone or your behalf, to protect the insured property from further damage following the respective losses. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. Any and all documents relating to, reflecting, or evidencing expenses incurred by you as aresult of the subject loss occurring on or about September 10, 2017. RESPONSE: Plaintiffs do not have documents responsive to this Request currently in their possession, custody or control. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. Any and all documents relating to, reflecting, or evidencing the reporting to Defendant of the subject loss and damage(s) you allege were caused as a result of the subject loss. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. All photographs and/or videos depicting the claimed damages to the Insured Property that you maintain were caused by the subject loss or in any way relate to the claim that is the subject of this litigation. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. Any and all documents and correspondence in your possession that were exchanged between you, your representatives, and attorneys and Defendant regarding the claim that is the subject of this litigation. RESPONSE: Objection: This Request calls for documents protected under the attorney- client privilege doctrine and/or the work product privilege doctrine. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. Any and all documents evidencing payment(s) by the Defendant in relation to the claim that is the subject of this litigation, including any copies of checks, deposit slips, receipts, or correspondences enclosing any such payment(s). RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. Any and all surveys, inspection reports, estimates and/or similar documents regarding damages to the Insured Property as a result of the claim that is the subject of this litigation. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. Any and all bills, invoices, estimates, contracts, and similar documents pertaining to the claim that is the subject of this litigation. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 10. Any and all documents evidencing your efforts to repair the reported damages to the Insured Property relating to the claim that is the subject of this litigation. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 11 Any and all receipts, vouchers, or other documents that reflect any and all benefits paid or payable to you as a result of the damages alleged in the Complaint. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 12 Any and all written statements in your or your attorney's possession from any employee, representative, adjuster, attorney, or agent of Defendant pertaining to the subject claims and/or the instant litigation. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 13 Any and all documents relating to any oral, written, or electronic communications between Defendant and/or its representatives and you or anyone representing you regarding the subject claim. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 14 Any and all correspondence, contracts, agreements, assignments, assignment of benefits, direct payment authorization, hold harmless agreement, or any other documents between you and any third parties in relation to the claim forming the basis of this lawsuit. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 15 Any and all photographs (color if available) taken by or on behalf of you, your attorney, or your other representatives between 2017 and the present that depict the subject areas of the Insured Property that sustained the damages claimed in this lawsuit. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 16 All documents relating to and memorializing any repairs and/or maintenance performed to the Insured Property for the last five (5) years to the present date. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 17 Any and all documents relating to prior claims made by you or your representatives against Defendant, other insurance carriers, or any collateral sources of insurance i.e., flood insurance or any other property insurance coverage, within the past ten (10) years for the Insured Property. RESPONSE: Objection: Overly broad and unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving said objection and upon information and belief, see Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 18 Any and all correspondences, documents, photographs, reports, analysis, study, or other similar documents prepared by any expert or engineer retained by you regarding the claims subject to this litigation. RESPONSE: Plaintiffs’ expert witness list and any corresponding reports will be produced by the date established during the pre-trial Case Management Conference as set forth by Florida Rule of Civil Procedure 1.200(a)(8). Such conference has not yet been held in this matter. Discovery is ongoing and thus, Plaintiffs reserves the right to amend and/or supplement this Response. 19 Any and all correspondences, documents, photographs, reports, analysis, study, or other similar documents prepared by any public adjuster retained by you in relation to the claims that are the subject of this litigation. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 20 Any and all documents and exhibits that you intend to use at trial in this matter. RESPONSE: Plaintiffs’ exhibit list and any corresponding exhibits will be produced by the date established during the pre-trial Case Management Conference as set forth by Florida Rule of Civil Procedure 1.200(a)(8). Such conference has not yet been held in this matter. Discovery is ongoing and thus, Plaintiffs reserves the right to amend and/or supplement this Response. 21 A current mortgage statement reflecting your mortgagee/lien holder and principle balance of your mortgage, if applicable. RESPONSE: Objection: Overly broad and unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 22 Any assignment of mortgage, transfer of mortgage, or satisfactions of mortgage received on the Insured Property. RESPONSE: See Response to Request Number 21. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 23 Any and all copies of checks or any form of payment received by you from the Defendant in relation to the subject claims, including any such documents in your possession indicating the date such payment was made, the amount of the payment and what it was intended for, and any other such documents evidencing the status of the checks (deposit slips, cash receipts, bank statements). RESPONSE: Objection: Cumulative. Without waiving said objection, see Response to Request Number 7. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 24 Any and all documents relating to expenses paid by you or your representatives with the funds issued by Defendant for the subject claim. RESPONSE: Objection: Cumulative. Without waiving said objection, see Response to Request Number 7. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 25 Any all contracts or agreements signed by you with any third party related to the Insured Property and subject claim. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 26 Any and all past receipts and invoices for any repairs made to the roof of the Insured Property within the past 7 years. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 27 Any and all photographs of the Insured property within the past 7 years. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 28 Any and all bids or estimates for roof replacement of the Insured Property from any roofing contractor. RESPONSE: See Response to Request Number 1. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 29 Any and all documents relating to, reflecting, or evidencing the sale of the subject property, including all closing documents. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 30 Any and all documents relating to, reflecting, or evidencing any claim the subject property was sold at less than fair market value (/.e. Diminution of Value). RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 31 Any and all documents relating to, reflecting, or evidencing pre-purchase inspections of the subject property. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 32 Any and all documents relating to, reflecting, or evidencing COMPS, aka comparable sales, relied upon in the sale of the subject property. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 33 Any and all documents relating to, reflecting, or evidencing Appraisal of the subject property. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 34 Any and all documents relating to, reflecting, or evidencing your application, including inspection reports, to Frontline Insurance. RESPONSE: See Response to Request Number 3. Discovery in this matter is ongoing and thus, Plaintiffs reserve the right to amend and/or supplement this Response. 8