Party Discovery: TUTTLE, LINDA vs FIRST PROTECTIVE INSURANCE CO

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                                Filing # 187132411 E-Filed 11/30/2023 07:30:01 PM



                        IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT,
                                  IN AND FOR NASSAU COUNTY, FLORIDA

        LINDA TUTTLE,

                 Plaintiff,
        Vv.                                                    CASE NO.:

        FIRST PROTECTIVE
        INSURANCE COMPANY,

                 Defendant.
                                                        /

                              PLAINTIFF’S REQUEST FOR PRODUCTION TO DEFENDANT
              The Plaintiff, Linda Tuttle, pursuant to Rule 1.350, Florida Rules of Civil Procedure, propound

        this Request    for Production to Defendant,   FIRST   PROTECTIVE       INSURANCE      COMPANY,      to

        produce the items and materials hereinafter set forth on or before the applicable time prescribed by

        said rule for inspection and/or copying at the office of the undersigned attorney, the following items

        and/or documents:

                 1        A true and correct certified copy of the insurance policy issued described in the

        complaint, including all declaration sheet(s), addendums and attachments.

                 2.       All photographs taken by Defendant’s adjuster during the initial inspection of the

        claimed loss.

                 3        Copies of all photographs taken during Defendant’s investigation conducted during the

        normal business of evaluating the claim.

                 4        All estimates of damage    prepared by or on behalf of Defendant after its initial

        inspection of the claimed loss.

                 5        Copies of all damage estimates prepared during Defendant’s investigation conducted

        during the normal business of evaluating the claim.

                 6.       All letters, faxes, email communications, and log notes from Defendant’s adjusters or

        agents which in any manner references any and all damages or causes of loss observed that were


        Electronically Filed Nassau Case # 23CA000545AXYX 11/30/2023 07:30:01 PM
prepared or generated during Defendant’s investigation conducted during the normal business of

evaluating the claim.

           7     Defendant’s entire claim file from the date of the initial notice of the loss until the day

before Defendant knew that Defendant was going to deny any further payment or litigate the claim.

           8     Defendant’s entire claim file for the entire time that the claim was being handled by

Defendant not in anticipation of litigation of the loss.

           9     Any and all correspondence or written communications from Defendant, or its agents

to Plaintiff, or their agents, which in any manner pertain to Plaintiffs alleged loss as described in the

Compliant.

           10.   Any and all correspondence or written communications from Plaintiff, or his agents to

Defendant, or its agents, which in any manner pertain to Plaintiffs alleged loss as described in the

Complaint.

           11.   Any and all photographs taken by the Defendant or Defendant’s agents showing the

extent of damage to the insured premises involved herein as were taken prior to the filing of this

lawsuit.

           12.   Any and all tape recordings of any statements made by Plaintiff or Plaintiff's agents or

employees.

           13.   Any and all transcripts or written statements from the Plaintiff(s) including, without

limitation, transcripts of EUO.

           14.   Copies of each and every bill or estimate for repair to the subject property submitted

to Defendant by Plaintiff or Plaintiff's agents or employees.

           15.   Any    and all written estimates or reports reflecting examination or inspection by

Defendant or Defendant’s agents of any of the alleged damage to the insured premises.

           16.   All documents    relating to or supporting Defendant’s denial of any allegation of

Plaintiff's Complaint.
17.   All documents relating to or supporting each of Defendant’s affirmative or general

defenses asserted by Defendant.

          18.   All   underwriting   files pertaining   to the   policy   of insurance   described   in the

Complaint/Petition.

          19.   Any   and all documents      related to any and all other insurance      claims made     by

Plaintiff(s) which are not the subject of this action, including estimates, reports, pictures, cancelled

checks, releases, proofs of loss, recorded statements, transcripts of EUO, and correspondence by and

between the parties related to any and all said other claims.

          20.   Any   and all brochures, summary        statements, pamphlets and advertising materials

prepared by or on behalf of Defendant and disseminated to insurance agencies or policyholders which

in any manner describe the coverages and/or exclusions under the same type of policy involved in this

action.

                                     CERTIFICATE OF SERVICE

        WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the
Defendant in this action along with the Complaint.


                                       By:      /s/ Kevin Weisser
                                                   KEVIN WEISSER
                                                   Florida Bar No: 98828
                                                   WEISSER ELAZAR & KANTOR, PLLC
                                                 Attorneys for Plaintiff
                                                 800 East Broward Boulevard, Suite 510
                                                 Fort Lauderdale, FL 33301
                                                 T: (954) 486-2623
                                                 F: (954) 572-8695
                                                 Email: KW@WEKLaw.com
                                                         JK WEKLaw.com
                                                         Service@WEKLaw.com