Party Discovery: Olympic Integrity Auto Glass, Llc vs Geico General Insurance Company

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                                Filing # 190910601 E-Filed 01/31/2024 10:10:42 AM


                     IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
                             IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

             OLYMPIC INTEGRITY AUTO GLASS,
             LLC a/a/o
             MELISSA BARBAROSSA,
                                                                CASE NUMBER: 2023-______________
                    Plaintiff,
             vs.

             GEICO GENERAL INSURANCE COMPANY,

                   Defendant.
             ______________________________________/

                                    REQUEST FOR PRODUCTION TO DEFENDANT

                    COMES NOW, Plaintiff, OLYMPIC INTEGRITY AUTO GLASS, LLC a/a/o MELISSA

             BARBAROSSA, and requests that Defendant, GEICO GENERAL INSURANCE COMPANY,

             respond to the following Requests for Production pursuant to, and within the time frame provided

             by, Florida Rule of Civil Procedure 1.350.


                    1.        All insurance policies that would inure to the benefit of Plaintiff or to the Plaintiff’s

             assignor, together with any declaration of coverage page and sworn statement of a corporate officer

             of Defendant attesting to the coverage and authenticity of the policy as required by Florida Statutes.


                    2.        All   communications        and    documentation      associated     with    MELISSA

             BARBAROSSA’s windshield replacement that are in the possession, custody, or control of

             Defendant (in its original/native format). Including but not limited to:

                         a.   All correspondence to or from Plaintiff regarding this claim;
                         b.   All correspondence to or from the Insured regarding this claim;
                         c.   All communications to any company regarding the amount to pay in this claim;
                         d.   All telephone messages to/from Plaintiff or the Insured regarding this claim;
                         e.   All vendor agreements with any third party that provided an estimate or data
                              utilized in the reduction of this claim;




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                        f. All statements transcripts and/or recordings of any communication made by
                           Plaintiff regarding this claim;
                        g. All statements, transcripts and/or recordings of any communication made by the
                           Insured regarding this claim;
                        h. All assignment of benefit forms/direction to pay forms received by Defendant in
                           relation to this claim;
                        i. All photographs of the Insured’s vehicle after the windshield repair/replacement
                           or while the windshield was damaged;
                        j. All bills, invoices work orders, estimates, and quotes regarding the subject
                           windshield repair/replacement;
                        k. All drafts, checks or check stubs, electronic funds transfers, and cancelled checks
                           issued for the Insured’s loss;
                        l. All documents reflecting any payment made to any person or entity as a result of
                           Plaintiff’s claim;
                        m. All Explanations of Benefits, Explanations of Review, correspondence, or
                           documents generated by Defendant explaining the basis of Defendant’s payment
                           or failure to make payment;
                        n. All emails to the Insured, Plaintiff, or any glass shop regarding the cost of the
                           Insured’s windshield repair/replacement;
                        o. All records documenting the time and date of any communication from Plaintiff
                           regarding this claim;
                        p. All records documenting the first notice of loss report regarding the Insured’
                           claim;
                        q. All communications regarding the valuing of the Insured’s loss, including
                           computer records, adjuster log notes, claim reports, , communications with any
                           third party administrators, communications with any third party glass shops, and
                           communications with any person retained to assist in valuing the Insured’s loss.

                    I HEREBY CERTIFY that a true and correct copy of the foregoing was served with

             Plaintiff’s Complaint.

                                                                         /s/ Jack W. Vasilaros
                                                                         Jack W. Vasilaros, Esquire
                                                                         Florida Bar Number: 0125152
                                                                         Vasilaros Law, PA
                                                                         1920 West Bay Drive, Suite 1
                                                                         Largo, Florida 33770
                                                                         Phone: (727) 455-9400
                                                                         Email: Jack@vlawpa.com
                                                                         Email: Madi@vlawpa.com
                                                                         Attorney for Plaintiff




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