Preview
Filing # 189530395 E-Filed 01/11/2024 12:34:22 AM
IN THE CIRCUIT COURT OF THE
JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
AURIANA LAUTURE
GENERAL JURISDICTI DIVISION
Plaintiff,
CASE NO.: 23CA0017
vs.
EDIS INSURANCE COMPANY,
ndant.
___________________________________/
EDISON INSURANCE COMPANY’S RESPONSES TO
PLAINTIFF S FIRST REQUEST FOR PRODUCTION
Pursuant to Fla. R. Civ. P. 1.350(b), Defendant, EDISON INSURANCE COMPANY
(hereafter “Edison”), responds to the Plaintiff First Request for Production as follows:
PREAMBLE
Edison reserves its right to supplement its responses.
Edison objects to each request to produce to the extent that its response is
protected by the attorney-client privilege, the work-product doctrine, or any other available
privilege or protection.
INSTRUCTIONS
The Florida Rules of Civil Procedure set forth the manner in which written discovery is
to be responded to. To the extent that Plaintiff’s definitions and instructions either vary from or
exceed the Rules of Civil Procedure, they are objectionable. Edison is entitled to rely on the
usual and ordinary meaning of words and the Florida Rules of Civil Procedure in responding to
Plaintiffs First Request for Production. Edison objects to any instruction that seeks to impose
obligations beyond those required by the Florida Rules of Civil Procedure.
PRELIMINARY STATEMENT
UINTAIROS RIETO OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670-11 Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
These responses are made solely for the purpose of this litigation. These answers
represent this responding party’s diligent and best efforts to respond to written discovery based
on the investigations which this responding party has thus far been able to carry out in
connection with the facts relevant to this litigation. There may exist further information
responsive to the discovery that is not within this responding party’s present knowledge or
reasonably available to this party. There may exist documents relating to the subject matter of
written discovery which this responding party has not yet located, identified or reviewed, despite
its best efforts to do so. There may exist persons with knowledge relating to the subject matter of
written discovery of whom this responding party is not presently aware of or of whom this
responding party has not yet conducted interviews. Accordingly, these responses are based upon
the facts and information now known to this responding party as well as its present analysis of
this litigation, and does not constitute an admission or representation that additional facts,
documents or witnesses having knowledge relevant to the subject matter of discovery does not
exist.
As this litigation proceeds, this responding party anticipates other facts, documents, or
witnesses may be discovered or identified by it. This responding party reserves the right to alter,
supplement, amend or otherwise modify these answers, as appropriate, in any way at any time.
Except for the explicit facts stated herein, no incidental admissions are intended hereby.
The fact that Defendant responded to any of the requests is not an admission that it accepts or
admits the existence of facts set forth or assumed by any request or that such response is
constituted admissible evidence. The fact that Defendant answered all or part of any request is
not intended and should not be construed to be a waiver of all or any part of any objections to the
request.
-2-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
The term "Property" shall refer to the property located at 1541 ROMMEL ST, PORT
CHARLOTTE, FL 33952.
The term "Policy" shall refer to Defendant’s policy numbe EDH5378714- .
RESPONSES AND OBJECTIONS
1. RESPONSE: See attached a copy of Policy Number EDH5378714-
2. RESPONSE Defendant objects to this request as it is equally available to Plaintiff and
not limited in time, scope or subject matter. Moreover, Defendant objects to this request as
it seeks the production of documents not reasonably calculated to lead to the discovery of
admissible evidence and that calls for claim handling procedures and not discoverable, as
they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v.
Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d
389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v.
Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo
Homeowners Ass’n, 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432
So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes
beyond the scope of permissible discovery in that it fails to exclude and calls for
information and documentation protected by the attorney-client privilege and/or work
product doctrine.
3. RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n,
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
permissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
4. RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
-3-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n,
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
permissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
5 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
Notwithstanding said objections and without waiver of same, see attached correspondence
sent to Plaintiff.
6 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
Notwithstanding said objections and without waiver of same, see attached correspondence
sent to Plaintiff s agents/representatives.
7. RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
-4-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
Notwithstanding said objections and without waiver of same, see attached redacted
photographs.
8. RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
9 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
Notwithstanding said objections and without waiver of same, see attached documents.
10. RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
-5-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
11. RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
Notwithstanding said objections and without waiver of same, none.
12. RESPONSE Defendant objects to this request as it is lear what documents
Plaintiffs seeks since Edison Insurance Company and Defendant are the same entity.
Defendant further objects to this request to the extent the same is not limited in time, scope
or subject matter. Moreover, Defendant objects to this request to the extent the same seeks
the production of documents not reasonably calculated to lead to the discovery of
admissible evidence and that calls for claim handling procedures and not discoverable, as
they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v.
Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d
389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v.
Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997 Am. Reliance Ins. Co. v. Rosemont Condo.
Homeowners Ass’n, 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432
So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request to the extent the
ques goes beyond the scope of permissible discovery in that it fails to exclude and calls
for information and documentation protected by the attorney-client privilege and/or work
product doctrine.
13. RESPONSE Defendant objects to this request as it is lear what documents
Plaintiffs seeks since Edison Insurance Company and Defendant are the same entity.
Defendant further objects to this request to the extent the same is not limited in time, scope
or subject matter. Moreover, Defendant objects to this request to the extent the same seeks
-6-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
the production of documents not reasonably calculated to lead to the discovery of
admissible evidence and that calls for claim handling procedures and not discoverable, as
they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v.
Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d
389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v.
Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997 Am. Reliance Ins. Co. v. Rosemont Condo.
Homeowners Ass’n, 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432
So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request to the extent the
ques goes beyond the scope of permissible discovery in that it fails to exclude and calls
for information and documentation protected by the attorney-client privilege and/or work
product doctrine.
1 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
Notwithstanding said objections and without waiver of same, see attached estimate.
15. RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
16 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
-7-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
17 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
18 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
19 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
-8-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
20 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
Notwithstanding said objections and without waiver of same, see attached estimate from
Top Flight 1 PA Services LLC.
21 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
22 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
-9-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
23 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
24 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
Notwithstanding said objections and without waiver of same, see attached estimate.
25 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
-10-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
26 RESPONSE See attached Sworn Statement in Proof of Loss dated December 21, 2022.
27 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
28 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
29 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
-11-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
31 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
3 RESPONSE Defendant objects to this request as it is not limited in time, scope or
subject matter. Moreover, Defendant objects to this request as it seeks the production of
documents not reasonably calculated to lead to the discovery of admissible evidence and
that calls for claim handling procedures and not discoverable, as they are irrelevant to a
first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012
(Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA
2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So.
2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n
671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st
DCA 1983). Defendant further objects to this request as it goes beyond the scope of
rmissible discovery in that it fails to exclude and calls for information and
documentation protected by the attorney-client privilege and/or work product doctrine.
Notwithstanding said objections and without waiver of same, see attached estimate in
connection with the subjec claim.
-12-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Lauture v. Edison
Circuit Court Case No 1CA
CERTIFICATE OF SERVI
WE HEREBY CERTIFY that pursuant to Florida Rule of Judicial Admi stration 2.516,
a true and correct copy of the foregoing was served via the Florida E-Filing Portal: Otto Berges,
Esq., Joseph Bendel, Esq., Alliance Law Firm, 1665 Palm Beach Lakes Blvd., Suite 1001, West
Palm Be h, FL 33401, oberges@allliancelawfirm.org jbendel@alliancelawfirm.org
eservice@alliancelawfirm.com on thi 10th y of January, 2024.
UINTAIROS RIETO OOD OYER P.A.
Attorneys for Defendant
9300 South Dadeland Boulevard, 4 Floor
Miami, Florida
Telephone: (305) -1101
Facsimile: (305) 670-1161
By: /s/Sandra Rodriguez, Esq.
JOSE E. BOSCH, ESQUIRE
Florida Bar No.: 542431
jbosch@qpwblaw.com
DANIEL TAMAROFF, ESQUIRE
Florida Bar No.: 92083
daniel.tamaroff@qpwblaw.com
SANDRA RODRIGUEZ, ESQ.
sandra.rodriguez@qpwblaw.com
Florida Bar No.: 121661
For service of court documents only:
dtamaroff.pleadings@qpwblaw.com
odriguez.pleadings@qpwblaw.com
jbosch.pleadings@qpwblaw.com
-13-
UINTAIROS OYER P.A., TTORNEYS
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161
Preview
Filing # 189530395 E-Filed 01/11/2024 12:34:22 AM IN THE CIRCUIT COURT OF THE JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA AURIANA LAUTURE GENERAL JURISDICTI DIVISION Plaintiff, CASE NO.: 23CA0017 vs. EDIS INSURANCE COMPANY, ndant. ___________________________________/ EDISON INSURANCE COMPANY’S RESPONSES TO PLAINTIFF S FIRST REQUEST FOR PRODUCTION Pursuant to Fla. R. Civ. P. 1.350(b), Defendant, EDISON INSURANCE COMPANY (hereafter “Edison”), responds to the Plaintiff First Request for Production as follows: PREAMBLE Edison reserves its right to supplement its responses. Edison objects to each request to produce to the extent that its response is protected by the attorney-client privilege, the work-product doctrine, or any other available privilege or protection. INSTRUCTIONS The Florida Rules of Civil Procedure set forth the manner in which written discovery is to be responded to. To the extent that Plaintiff’s definitions and instructions either vary from or exceed the Rules of Civil Procedure, they are objectionable. Edison is entitled to rely on the usual and ordinary meaning of words and the Florida Rules of Civil Procedure in responding to Plaintiffs First Request for Production. Edison objects to any instruction that seeks to impose obligations beyond those required by the Florida Rules of Civil Procedure. PRELIMINARY STATEMENT UINTAIROS RIETO OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670-11 Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA These responses are made solely for the purpose of this litigation. These answers represent this responding party’s diligent and best efforts to respond to written discovery based on the investigations which this responding party has thus far been able to carry out in connection with the facts relevant to this litigation. There may exist further information responsive to the discovery that is not within this responding party’s present knowledge or reasonably available to this party. There may exist documents relating to the subject matter of written discovery which this responding party has not yet located, identified or reviewed, despite its best efforts to do so. There may exist persons with knowledge relating to the subject matter of written discovery of whom this responding party is not presently aware of or of whom this responding party has not yet conducted interviews. Accordingly, these responses are based upon the facts and information now known to this responding party as well as its present analysis of this litigation, and does not constitute an admission or representation that additional facts, documents or witnesses having knowledge relevant to the subject matter of discovery does not exist. As this litigation proceeds, this responding party anticipates other facts, documents, or witnesses may be discovered or identified by it. This responding party reserves the right to alter, supplement, amend or otherwise modify these answers, as appropriate, in any way at any time. Except for the explicit facts stated herein, no incidental admissions are intended hereby. The fact that Defendant responded to any of the requests is not an admission that it accepts or admits the existence of facts set forth or assumed by any request or that such response is constituted admissible evidence. The fact that Defendant answered all or part of any request is not intended and should not be construed to be a waiver of all or any part of any objections to the request. -2- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA The term "Property" shall refer to the property located at 1541 ROMMEL ST, PORT CHARLOTTE, FL 33952. The term "Policy" shall refer to Defendant’s policy numbe EDH5378714- . RESPONSES AND OBJECTIONS 1. RESPONSE: See attached a copy of Policy Number EDH5378714- 2. RESPONSE Defendant objects to this request as it is equally available to Plaintiff and not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo Homeowners Ass’n, 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of permissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 3. RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n, 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of permissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 4. RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 -3- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n, 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of permissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 5 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. Notwithstanding said objections and without waiver of same, see attached correspondence sent to Plaintiff. 6 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. Notwithstanding said objections and without waiver of same, see attached correspondence sent to Plaintiff s agents/representatives. 7. RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a -4- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. Notwithstanding said objections and without waiver of same, see attached redacted photographs. 8. RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 9 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. Notwithstanding said objections and without waiver of same, see attached documents. 10. RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a -5- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 11. RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. Notwithstanding said objections and without waiver of same, none. 12. RESPONSE Defendant objects to this request as it is lear what documents Plaintiffs seeks since Edison Insurance Company and Defendant are the same entity. Defendant further objects to this request to the extent the same is not limited in time, scope or subject matter. Moreover, Defendant objects to this request to the extent the same seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997 Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n, 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request to the extent the ques goes beyond the scope of permissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 13. RESPONSE Defendant objects to this request as it is lear what documents Plaintiffs seeks since Edison Insurance Company and Defendant are the same entity. Defendant further objects to this request to the extent the same is not limited in time, scope or subject matter. Moreover, Defendant objects to this request to the extent the same seeks -6- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997 Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n, 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request to the extent the ques goes beyond the scope of permissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 1 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. Notwithstanding said objections and without waiver of same, see attached estimate. 15. RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 16 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a -7- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 17 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 18 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 19 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st -8- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 20 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. Notwithstanding said objections and without waiver of same, see attached estimate from Top Flight 1 PA Services LLC. 21 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 22 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of -9- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 23 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 24 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. Notwithstanding said objections and without waiver of same, see attached estimate. 25 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. -10- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA 26 RESPONSE See attached Sworn Statement in Proof of Loss dated December 21, 2022. 27 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 28 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 29 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. -11- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 31 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. 3 RESPONSE Defendant objects to this request as it is not limited in time, scope or subject matter. Moreover, Defendant objects to this request as it seeks the production of documents not reasonably calculated to lead to the discovery of admissible evidence and that calls for claim handling procedures and not discoverable, as they are irrelevant to a first party breach of contract action. State Farm Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Fla. Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003); Florida Residential Property and Cas. Join Underwriters Ass’n v. Sanchez, 693 So. 2d 68 (Fla. 3d DCA 1997); Am. Reliance Ins. Co. v. Rosemont Condo. Homeowners Ass’n 671 So. 2d 250 (Fla. 3d DCA 1996); Utica Mut. Ins. Co. vs. Croft, 432 So. 2d 196 (Fla. 1st DCA 1983). Defendant further objects to this request as it goes beyond the scope of rmissible discovery in that it fails to exclude and calls for information and documentation protected by the attorney-client privilege and/or work product doctrine. Notwithstanding said objections and without waiver of same, see attached estimate in connection with the subjec claim. -12- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161 Lauture v. Edison Circuit Court Case No 1CA CERTIFICATE OF SERVI WE HEREBY CERTIFY that pursuant to Florida Rule of Judicial Admi stration 2.516, a true and correct copy of the foregoing was served via the Florida E-Filing Portal: Otto Berges, Esq., Joseph Bendel, Esq., Alliance Law Firm, 1665 Palm Beach Lakes Blvd., Suite 1001, West Palm Be h, FL 33401, oberges@allliancelawfirm.org jbendel@alliancelawfirm.org eservice@alliancelawfirm.com on thi 10th y of January, 2024. UINTAIROS RIETO OOD OYER P.A. Attorneys for Defendant 9300 South Dadeland Boulevard, 4 Floor Miami, Florida Telephone: (305) -1101 Facsimile: (305) 670-1161 By: /s/Sandra Rodriguez, Esq. JOSE E. BOSCH, ESQUIRE Florida Bar No.: 542431 jbosch@qpwblaw.com DANIEL TAMAROFF, ESQUIRE Florida Bar No.: 92083 daniel.tamaroff@qpwblaw.com SANDRA RODRIGUEZ, ESQ. sandra.rodriguez@qpwblaw.com Florida Bar No.: 121661 For service of court documents only: dtamaroff.pleadings@qpwblaw.com odriguez.pleadings@qpwblaw.com jbosch.pleadings@qpwblaw.com -13- UINTAIROS OYER P.A., TTORNEYS 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ∙ Tel: (305) 670 1101 ∙ Fax: (305) 670-1161