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Filing # 158980261 E-Filed 10/11/2022 12:28:59 PM
IN THE CIRCUIT COURT OF THE
St JUDICIAL CIRCUIT IN AND FOR
LAKE COUNTY, FLORIDA
THE DIOCESE OF CENTRAL FLORIDA,
Case No. 35-2021-CA-001639
PLAINTIFF,
V.
CERTAIN UNDERWRITERS AT LLOYD’S, LONDON
SUBSCRIBING TO POLicy No. MSRC-2830-00-00,
DEFENDANTS. /
SECOND RE-NOTICE OF TAKING DEPOSITION DUCES TECUM
(Date and time were coordinated with Opposing Counsel)
PLEASE TAKE NOTICE that the undersigned will take the deposition of the
following deponent(s), at the date and time indicated, below, upon oral examination
before Phipps Reporting Court reporters, or any other Notary Public or officer
authorized by law to take depositions in the State of Florida:
DEPONENT DATE & TIME LOCATION
Canon Scott Holcombe
Rule 1.310 (b)(6) Corporate
Representative for The December 13, 2022 at VIA ZOOM
Diocese of Central Florida 12:30 p.m.
designated to provide (zoom info will be provided
testimony regarding the prior to the deposition)
areas of inquiry set forth in
the attached Schedule “A.”
Deponent to appear with the items responsive to the attached Schedule “B” and
provide them to the undersigned counsel no later
than ten (10) days prior to the deposition.
The oral examination(s) of the deponent(s) will continue from day to day until complete,
and are being taken for the purpose of discovery, or for such other purposes as are
permitted under the rules of Court, including the applicable local Rules of Civil
Procedure.
BERK, MERCHANT |&|Srms
2 Alhambra Plaza, Suite 700 ¢ CORAL GABLES, FLORIDA 33134 # PHONE: 786.338.2900 @ FAX: 786.338.2888
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 10/11/2022 12:41:25 PM
Case No. 2021-CA-001639-AXXX-XX
THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT
Ltoyp’s, LONDON
Page 2 of 7
In accordance with the Americans with Disabilities Act of 1990, persons requiring
special accommodations to participate in this proceeding should contact the
undersigned no later than seven (7) days before the proceeding to arrange for such
accommodations; if hearing impaired, please telephone the Court TDD Coordinator at
1-800-955-8771.
Respectfully submitted,
BERK, MERCHANT & Sims, PLC
/s/ Laura C. Tapia
Patrick E. Betar / FBN: 11073
Laura C. Tapia / FBN: 968676
2 Alhambra Plaza, Suite 700
Coral Gables, Florida 33134
Tel: (786) 338-2900 / Fax: (786) 338-2888
Email: pbetar@berklawfirm.com
kmendez@berklawfirm.com
ltapia@berklawfirm.com
anorwitch@berklawfirm.com
Counsel for Defendants
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was served via
email on this 11" day of October, 2022 to:
Jeremy T. Schilling / FBN: 0098111
Aaron D. Silvers / FBN: 104811
SCHILLING & SILVERS, PLLC
1700 NW 64" Street, Suite 460
Fort Lauderdale, FL 33301
Tel: (954) 712-8877
E-Mail: jschilling@schillingsilvers.com
dadams@schillingsilvers.com
Counsel for Plaintiff
/s/ Laura C. Tapia
BERK, MERCHANT je| Sums
2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888
Case No. 2021-CA-001639-AXXX-XX
THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT
Ltoyp’s, LONDON
Page 3 of 7
ATTACHMENT “A”
Areas of Inquiry
The facts and circumstances that gave rise to the loss claimed;
The factual basis for each and every component of the Insured’s claim;
The cause(s), nature, and extent of the damage sustained by the Insured and
Additional Insureds, if any, due to the subject incident;
The cost of repairing and/or replacing the building components damaged by the
subject incident;
The details of the claim set forth in the Sworn Proof of loss submitted and any
subsequent Sworn Statements In Proof of Loss submitted by the Insured in
connection with this claim;
All individuals with knowledge of the loss claimed;
All individuals/entities the Insured communicated with in connection with the loss
claimed, as well as all communications exchanged between the Insured and any
individuals/entities in connection with the loss claimed, and all records of those
communications;
All written and verbal communications with contractors, engineers, architects,
and other persons/entities the Insured consulted with in connection with the loss
and/or this insurance claim;
All statements, opinions, conclusions, or recommendations made by any
contractors, engineers, architects, and other persons/entities the Insured
consulted with in connection with the loss and/or this insurance claim;
10 The installation, maintenance, condition, and repair histories of all buildings and
building components included in this insurance claim (e.g. windows, sliding glass
doors, roofs, stucco, siding, floors, air conditioning units, etc.);
11 The nature and amount of the Insured’s claim for the subject loss, as well as the
factual basis for the amount claimed, the individual(s) involved with calculating
the amount claimed, and the method(s) utilized to calculate the amount claimed;
12. The Insured’s compliance with policy conditions, including all requests for
inspections of the subject property, all requests for information regarding the
Insured’s claim, all records maintained in connection with the subject loss, and all
BERK, MERCHANT je| Sums
2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888
Case No. 2021-CA-001639-AXXX-XX
THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT
Lioyp’s, LONDON
Page 4 of 7
efforts made to provide information in response to the requests conveyed in
connection with this claim;
13. All documents, invoices, bills, receipts, cancelled checks, paystubs, credit card
statements, expenses, log books, reservation list(s), accounting records,
documents, and other materials believed to support the Insured’s claim;
14 All other insurance claims made by, or on behalf of, the Insured, whether before
or after the subject loss;
15. All damage sustained by the subject property before or after the subject loss, all
insurance claims or lawsuits concerning such damage, and all repairs,
renovations, and construction work performed, or believed required, to address
such damage;
16. The Insured’s record retention policy, as well as the nature, substance, and
location of all records relevant to the Insured’s claim and those concerning all
building components claimed as damaged by the loss;
17 The history of the Insured’s officers and directors, as well as all individuals
employed by the Insured, between January 1, 2015 and the present;
18 All insurance applicable to the Property since 2015;
19 The Property’s condition before and after the above-referenced loss, as well as
all repairs, renovations, or other construction work performed on the Property
since January 1, 2015;
20. All lawsuits brought in connection with damage sustained by the Property before
the subject incident and all discovery exchanged in any such lawsuits;
21 All estimates, proposals, bids, and/or quotations for work reportedly needed to
address damage sustained due to the subject loss, as well as all testing and
evaluations performed upon the Property in connection with the subject loss;
22. The individuals present, or believed to be present, at the subject property at the
time of the subject loss;
23. All items produced in response to the requests made in this letter, below, or in
response to prior requests made in connection with this claim; and
24, All information and materials the Insured would like considered in support of its
claim.
BERK, MERCHANT je| Sums
2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888
Case No. 2021-CA-001639-AXXX-XX
THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT
Lioyp’s, LONDON
Page 5 of 7
25. All information regarding the members of the vestry, and any other governing
body, of Holy Trinity Episcopal Church in Fruitland Park, Florida from the date of
loss alleged in the Complaint to the present, including each person’s title with the
vestry (or other governing body) such as “Senior Warden, Junior Warden,
Treasurer, Director, President, etc.”. This request is limited to any vestry or
governing body directly involved in the “day to day” running of the parish church.
SCHEDULE “B”
DEFINITIONS
AND INSTRUCTIONS
The following terms, whether plural or singular, shall have the meaning set forth
below:
“Document” means any written, typed, recorded, or graphic matter, however
produced or reproduced, of any kind or description, including originals, non-
identical copies, drafts, computer generated materials, magnetically or electronically
stored materials capable of being reduced to hard copies by a computer and all
other materials within the scope of Florida Rule of Civil Procedure 1.350.
“You,” "your," “Insured” and/or “Plaintiff shall refer to The Diocese of Central
Florida, as well as any person(s) or entit(y)(ies) acting on its behalf.
“Defendants” shall refer to Certain Underwriters at Lloyd’s, London Subscribing to
Policy No. MSRC-2830-00-00 and its agents, employees, representatives or any
other person(s) acting for or on behalf of Certain Underwriters at Lloyd’s, London
Subscribing to Policy No. MSRC-2830-00-00.
“Loss” means the alleged event(s) that purportedly resulted in the damage claimed
by Plaintiff in this action, more particularly described in the Complaint and any
subsequent pleadings or filings submitted in the instant litigation.
The term “Property” shall mean the property identified in the Complaint.
“Policy” refers to the subject insurance policy, number MSRC-2830-00.
BERK, MERCHANT je| Sums
2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888
Case No. 2021-CA-001639-AXXX-XX
THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT
Ltoyp’s, LONDON
Page 6 of 7
SCHEDULE
“B”
DUCES TECUM CLAUSE
All materials in Plaintiff's possession regarding the Property pertaining to the
allegations as set forth in the Complaint. The materials you are requested to produce
include, but are not necessarily limited to, the following:
1. All documents regarding maintenance and repairs performed at the Property for
five (5) years prior to the date of loss set forth in the Complaint.
2. All documents and materials which you believe support your claim for damages
in this lawsuit.
3. Color copies of photographs taken by you, or at your direction, of the damages
claimed in this lawsuit.
4. All inspection reports, appraisals, valuations or other reports which reference the
condition of the Property at the time of your purchase of the Property.
5. All correspondence, reports, estimates, proposals, bids, quotes, invoices,
receipts, and other such documents pertaining to the Property provided to you by any
roofer, architect, engineer, HVAC contractor, plumber, electrician, general contractor,
handyman, or other repair professional for the seven(7) years prior to the date of loss as
set forth in your Complaint.
6. All correspondence, reports, estimates, proposals, bids, quotes, invoices,
receipts, and other such documents pertaining to the Property provided to you by any
roofer, architect, engineer, HVAC contractor, plumber, electrician, general contractor,
handyman, or other repair professional after the date of loss as set forth in your
Complaint to the present.
7. All executed written contracts/agreements between you and all general
contractors, roofers, electricians, plumbers, HVAC contractors, handymen, or any other
repair professionals that were entered into within seven (7) years prior to the date of
loss as set forth in your Complaint.
8. All executed written contracts/agreements between you and all general
contractors, roofers, electricians, plumbers, HVAC contractors, handymen, or any other
repair professionals that were entered into after the date of loss as set forth in your
Complaint to the present.
9. All documentation showing payments made by you to all general contractors,
BERK, MERCHANT je| Sums
2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888
Case No. 2021-CA-001639-AXXX-XX
THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT
Ltoyp’s, LONDON
Page 7 of 7
roofers, electricians, plumbers, HVAC contractors, handymen, or any other repair
professionals for repairs at the Property following the date of loss as set forth in your
Complaint to the present.
10.All correspondence, emails, faxes or other written communications between you
and your public adjuster.
11.All contracts entered into with any public adjusters for the loss set forth in your
Complaint.
12.All reports from any experts you retained in this lawsuit which pertain to the
damages claimed for the date of loss as set forth in your Complaint.
13.All documents submitted by you or on your behalf to Lake County to obtain
permits for work to be prepared at the Property for the three (3) years preceding the
date of loss set forth in your Complaint.
14.All documents submitted by you or on your behalf to Lake County to obtain
permits for work to be prepared at the Property following the date of loss set forth in
your Complaint.
15.All documents received by you from the Lake County regarding repairs to the
Property for the seven (7) years preceding the date of loss set forth in your Complaint.
16.All documents received by you from Lake County regarding repairs to the
property following the date of loss set forth in your Complaint to the present.
17.All maintenance or repair records regarding any repairs, replacements, and acts
of maintenance to the roofs at the property identified in the Complaint for the last seven
(7) years.
18.All contracts, estimates, proposals, invoices, and reports for related to repairs,
replacements, and acts of maintenance to the roofs at the property identified in the
Complaint for the last seven (7) years.
19.All records relating to clean-up, debris removal or emergency services in
conjunction with this loss.
BERK, MERCHANT je| Sums
2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888
Preview
Filing # 158980261 E-Filed 10/11/2022 12:28:59 PM IN THE CIRCUIT COURT OF THE St JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA THE DIOCESE OF CENTRAL FLORIDA, Case No. 35-2021-CA-001639 PLAINTIFF, V. CERTAIN UNDERWRITERS AT LLOYD’S, LONDON SUBSCRIBING TO POLicy No. MSRC-2830-00-00, DEFENDANTS. / SECOND RE-NOTICE OF TAKING DEPOSITION DUCES TECUM (Date and time were coordinated with Opposing Counsel) PLEASE TAKE NOTICE that the undersigned will take the deposition of the following deponent(s), at the date and time indicated, below, upon oral examination before Phipps Reporting Court reporters, or any other Notary Public or officer authorized by law to take depositions in the State of Florida: DEPONENT DATE & TIME LOCATION Canon Scott Holcombe Rule 1.310 (b)(6) Corporate Representative for The December 13, 2022 at VIA ZOOM Diocese of Central Florida 12:30 p.m. designated to provide (zoom info will be provided testimony regarding the prior to the deposition) areas of inquiry set forth in the attached Schedule “A.” Deponent to appear with the items responsive to the attached Schedule “B” and provide them to the undersigned counsel no later than ten (10) days prior to the deposition. The oral examination(s) of the deponent(s) will continue from day to day until complete, and are being taken for the purpose of discovery, or for such other purposes as are permitted under the rules of Court, including the applicable local Rules of Civil Procedure. BERK, MERCHANT |&|Srms 2 Alhambra Plaza, Suite 700 ¢ CORAL GABLES, FLORIDA 33134 # PHONE: 786.338.2900 @ FAX: 786.338.2888 FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 10/11/2022 12:41:25 PM Case No. 2021-CA-001639-AXXX-XX THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT Ltoyp’s, LONDON Page 2 of 7 In accordance with the Americans with Disabilities Act of 1990, persons requiring special accommodations to participate in this proceeding should contact the undersigned no later than seven (7) days before the proceeding to arrange for such accommodations; if hearing impaired, please telephone the Court TDD Coordinator at 1-800-955-8771. Respectfully submitted, BERK, MERCHANT & Sims, PLC /s/ Laura C. Tapia Patrick E. Betar / FBN: 11073 Laura C. Tapia / FBN: 968676 2 Alhambra Plaza, Suite 700 Coral Gables, Florida 33134 Tel: (786) 338-2900 / Fax: (786) 338-2888 Email: pbetar@berklawfirm.com kmendez@berklawfirm.com ltapia@berklawfirm.com anorwitch@berklawfirm.com Counsel for Defendants CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was served via email on this 11" day of October, 2022 to: Jeremy T. Schilling / FBN: 0098111 Aaron D. Silvers / FBN: 104811 SCHILLING & SILVERS, PLLC 1700 NW 64" Street, Suite 460 Fort Lauderdale, FL 33301 Tel: (954) 712-8877 E-Mail: jschilling@schillingsilvers.com dadams@schillingsilvers.com Counsel for Plaintiff /s/ Laura C. Tapia BERK, MERCHANT je| Sums 2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888 Case No. 2021-CA-001639-AXXX-XX THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT Ltoyp’s, LONDON Page 3 of 7 ATTACHMENT “A” Areas of Inquiry The facts and circumstances that gave rise to the loss claimed; The factual basis for each and every component of the Insured’s claim; The cause(s), nature, and extent of the damage sustained by the Insured and Additional Insureds, if any, due to the subject incident; The cost of repairing and/or replacing the building components damaged by the subject incident; The details of the claim set forth in the Sworn Proof of loss submitted and any subsequent Sworn Statements In Proof of Loss submitted by the Insured in connection with this claim; All individuals with knowledge of the loss claimed; All individuals/entities the Insured communicated with in connection with the loss claimed, as well as all communications exchanged between the Insured and any individuals/entities in connection with the loss claimed, and all records of those communications; All written and verbal communications with contractors, engineers, architects, and other persons/entities the Insured consulted with in connection with the loss and/or this insurance claim; All statements, opinions, conclusions, or recommendations made by any contractors, engineers, architects, and other persons/entities the Insured consulted with in connection with the loss and/or this insurance claim; 10 The installation, maintenance, condition, and repair histories of all buildings and building components included in this insurance claim (e.g. windows, sliding glass doors, roofs, stucco, siding, floors, air conditioning units, etc.); 11 The nature and amount of the Insured’s claim for the subject loss, as well as the factual basis for the amount claimed, the individual(s) involved with calculating the amount claimed, and the method(s) utilized to calculate the amount claimed; 12. The Insured’s compliance with policy conditions, including all requests for inspections of the subject property, all requests for information regarding the Insured’s claim, all records maintained in connection with the subject loss, and all BERK, MERCHANT je| Sums 2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888 Case No. 2021-CA-001639-AXXX-XX THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT Lioyp’s, LONDON Page 4 of 7 efforts made to provide information in response to the requests conveyed in connection with this claim; 13. All documents, invoices, bills, receipts, cancelled checks, paystubs, credit card statements, expenses, log books, reservation list(s), accounting records, documents, and other materials believed to support the Insured’s claim; 14 All other insurance claims made by, or on behalf of, the Insured, whether before or after the subject loss; 15. All damage sustained by the subject property before or after the subject loss, all insurance claims or lawsuits concerning such damage, and all repairs, renovations, and construction work performed, or believed required, to address such damage; 16. The Insured’s record retention policy, as well as the nature, substance, and location of all records relevant to the Insured’s claim and those concerning all building components claimed as damaged by the loss; 17 The history of the Insured’s officers and directors, as well as all individuals employed by the Insured, between January 1, 2015 and the present; 18 All insurance applicable to the Property since 2015; 19 The Property’s condition before and after the above-referenced loss, as well as all repairs, renovations, or other construction work performed on the Property since January 1, 2015; 20. All lawsuits brought in connection with damage sustained by the Property before the subject incident and all discovery exchanged in any such lawsuits; 21 All estimates, proposals, bids, and/or quotations for work reportedly needed to address damage sustained due to the subject loss, as well as all testing and evaluations performed upon the Property in connection with the subject loss; 22. The individuals present, or believed to be present, at the subject property at the time of the subject loss; 23. All items produced in response to the requests made in this letter, below, or in response to prior requests made in connection with this claim; and 24, All information and materials the Insured would like considered in support of its claim. BERK, MERCHANT je| Sums 2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888 Case No. 2021-CA-001639-AXXX-XX THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT Lioyp’s, LONDON Page 5 of 7 25. All information regarding the members of the vestry, and any other governing body, of Holy Trinity Episcopal Church in Fruitland Park, Florida from the date of loss alleged in the Complaint to the present, including each person’s title with the vestry (or other governing body) such as “Senior Warden, Junior Warden, Treasurer, Director, President, etc.”. This request is limited to any vestry or governing body directly involved in the “day to day” running of the parish church. SCHEDULE “B” DEFINITIONS AND INSTRUCTIONS The following terms, whether plural or singular, shall have the meaning set forth below: “Document” means any written, typed, recorded, or graphic matter, however produced or reproduced, of any kind or description, including originals, non- identical copies, drafts, computer generated materials, magnetically or electronically stored materials capable of being reduced to hard copies by a computer and all other materials within the scope of Florida Rule of Civil Procedure 1.350. “You,” "your," “Insured” and/or “Plaintiff shall refer to The Diocese of Central Florida, as well as any person(s) or entit(y)(ies) acting on its behalf. “Defendants” shall refer to Certain Underwriters at Lloyd’s, London Subscribing to Policy No. MSRC-2830-00-00 and its agents, employees, representatives or any other person(s) acting for or on behalf of Certain Underwriters at Lloyd’s, London Subscribing to Policy No. MSRC-2830-00-00. “Loss” means the alleged event(s) that purportedly resulted in the damage claimed by Plaintiff in this action, more particularly described in the Complaint and any subsequent pleadings or filings submitted in the instant litigation. The term “Property” shall mean the property identified in the Complaint. “Policy” refers to the subject insurance policy, number MSRC-2830-00. BERK, MERCHANT je| Sums 2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888 Case No. 2021-CA-001639-AXXX-XX THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT Ltoyp’s, LONDON Page 6 of 7 SCHEDULE “B” DUCES TECUM CLAUSE All materials in Plaintiff's possession regarding the Property pertaining to the allegations as set forth in the Complaint. The materials you are requested to produce include, but are not necessarily limited to, the following: 1. All documents regarding maintenance and repairs performed at the Property for five (5) years prior to the date of loss set forth in the Complaint. 2. All documents and materials which you believe support your claim for damages in this lawsuit. 3. Color copies of photographs taken by you, or at your direction, of the damages claimed in this lawsuit. 4. All inspection reports, appraisals, valuations or other reports which reference the condition of the Property at the time of your purchase of the Property. 5. All correspondence, reports, estimates, proposals, bids, quotes, invoices, receipts, and other such documents pertaining to the Property provided to you by any roofer, architect, engineer, HVAC contractor, plumber, electrician, general contractor, handyman, or other repair professional for the seven(7) years prior to the date of loss as set forth in your Complaint. 6. All correspondence, reports, estimates, proposals, bids, quotes, invoices, receipts, and other such documents pertaining to the Property provided to you by any roofer, architect, engineer, HVAC contractor, plumber, electrician, general contractor, handyman, or other repair professional after the date of loss as set forth in your Complaint to the present. 7. All executed written contracts/agreements between you and all general contractors, roofers, electricians, plumbers, HVAC contractors, handymen, or any other repair professionals that were entered into within seven (7) years prior to the date of loss as set forth in your Complaint. 8. All executed written contracts/agreements between you and all general contractors, roofers, electricians, plumbers, HVAC contractors, handymen, or any other repair professionals that were entered into after the date of loss as set forth in your Complaint to the present. 9. All documentation showing payments made by you to all general contractors, BERK, MERCHANT je| Sums 2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888 Case No. 2021-CA-001639-AXXX-XX THE DIOCESE OF CENTRAL FLA. V CERT. UWRS AT Ltoyp’s, LONDON Page 7 of 7 roofers, electricians, plumbers, HVAC contractors, handymen, or any other repair professionals for repairs at the Property following the date of loss as set forth in your Complaint to the present. 10.All correspondence, emails, faxes or other written communications between you and your public adjuster. 11.All contracts entered into with any public adjusters for the loss set forth in your Complaint. 12.All reports from any experts you retained in this lawsuit which pertain to the damages claimed for the date of loss as set forth in your Complaint. 13.All documents submitted by you or on your behalf to Lake County to obtain permits for work to be prepared at the Property for the three (3) years preceding the date of loss set forth in your Complaint. 14.All documents submitted by you or on your behalf to Lake County to obtain permits for work to be prepared at the Property following the date of loss set forth in your Complaint. 15.All documents received by you from the Lake County regarding repairs to the Property for the seven (7) years preceding the date of loss set forth in your Complaint. 16.All documents received by you from Lake County regarding repairs to the property following the date of loss set forth in your Complaint to the present. 17.All maintenance or repair records regarding any repairs, replacements, and acts of maintenance to the roofs at the property identified in the Complaint for the last seven (7) years. 18.All contracts, estimates, proposals, invoices, and reports for related to repairs, replacements, and acts of maintenance to the roofs at the property identified in the Complaint for the last seven (7) years. 19.All records relating to clean-up, debris removal or emergency services in conjunction with this loss. BERK, MERCHANT je| Sums 2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 @PHONE: 786.338.2900 @ FAX: 786.338.2888