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Filing # 193408466 E-Filed 03/06/2024 10:15:50 AM
IN THE CIRCUIT COURT OF THE THIRD
JUDICIAL CIRCUIT IN AND FOR
COLUMBIA COUNTY, FLORIDA
ROBERT C. CREWS and
GINA A. CREWS,
Plaintiff,
Vv. Case No.:
NATIONWIDE MUTUAL
INSURANCE COMPANY,
Defendant,
NOTICE OF SERVICE OF INTERROGATORIES
Plaintiffs, Robert C. Crews and Gina A. Crews, by and through the undersigned
attorneys, pursuant to Rule 1.340(e) of the Florida Rules of Civil Procedure, hereby
requests Defendant, Nationwide Mutual Insurance Company, answer the Plaintiff's First
Set of Interrogatories, served through the initial process of service, separately and fully in
writing under oath, unless objected to, within forty-five (45) days from the date of service
thereof. The attorney making objections must state the grounds for objection and sign
the document.
[CONTINUED ON THE FOLLOWING PAGE]
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CERTIFICATE OF SERVICE
| HEREBY CERTIFY that in accordance with Florida Rule of Judicial Administration 2.516,
on March 6, 2024 a true and correct copy of the foregoing instrument was filed with the Clerk
of Court by using the Florida Courts e-filing Portal, which will be sent for service on the
Defendant along with the summons.
Respectfully submitted,
ARIAS & ABBASS YOUR ATTORNEYS
Trial Attorneys for Plaintiffs
4531 Ponce De Leon Blvd., Ste 200
Coral Gables, Florida 33146
Telephone: 786.530.HELP (4357)
Primary e-mail address: eservice@TalkToMyAttorneys.com
By: /s:/ Mohad Abbass
Juan C. Arias, Esq.
Florida Bar No.:1010330
Mohad Abbass, Esq.
Florida Bar No.: 1010543
Antonio Bayuelo, Esq.
Florida Bar No.: 1048994
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IN THE CIRCUIT COURT OF THE THIRD
JUDICIAL CIRCUIT IN AND FOR
COLUMBIA COUNTY, FLORIDA
ROBERT C. CREWS and
GINA A. CREWS,
Plaintiff,
Vv. Case No.:
NATIONWIDE MUTUAL
INSURANCE COMPANY,
Defendant,
/
PLAINTIFFS’ FIRST SET OF INTERROGATORIES
DEFINITIONS
A “You” or “Your” as used herein means: the Defendant named above and any
related entities who may be liable for the damages sought herein. The definition also
includes any individuals or entities handling, adjusting, or otherwise investigating claims
on your behalf; any lawyers retained by you on this or any other claim; and, any other
agents who have performed services on your behalf at any time material to this action.
B “Document” as used herein means: every writing or record of every type and
description that is or has been in your possession, control or custody or of which you have
knowledge, including without limitation on the generality of the foregoing,
correspondence, memoranda, tapes, stenographic or handwritten notes, studies,
publications, books, pamphlets, pictures, films, voice records, reports, surveys, maps,
statistical complications or minutes; every copy of such writing or record, where the
original is not in your possession, custody or control; and every copy of the any original
or where such copy contains any commentary or notation whatsoever that does appear
in the original.
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Cc “Correspondence” as used herein means: any correspondence and includes, but
not limited to handwritten, typed, emails, digital messages, recorded video, recorded
audio and facsimile correspondence.
D “Coverage Letter(s)” as used herein means: the correspondence running from you
to policyholder throughout the claim at issue regarding your position as to coverage for
the loss.
E “Date” as used herein means: the exact date, month, and year if ascertainable, or
if not, the best approximation) including relationship in time to other events).
F “Identify” and “identity” as used herein means:
| With respect to a natural person, to state the person’s name, title at the time
in question, employer and business address at the time in question and the
current or last known employer, business address, and home address;
IL With respect to an organization or entity, to state the full legal name of the
entity and full name by which the organization or entity is commonly known
or does business; and,
iii. With respect to data: In the case of a document, the title (if any), date,
author, sender recipient, type of document (i.e., letter, memorandum, book,
telegram, chart, etc.), or some other means of identifying it, a summary of
its contents and its present location or custodian; In the case of oral
communication, the date, the communicator, communicate, and a sufficient
summary of the contents of such oral communication to indicate its nature
and substance.
G “Loss” as used herein means: the event at issue in which the policyholder suffered
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property damage.
INSTRUCTIONS:
Should Defendant claim an Interrogatory is objected to or not answered pursuant
to a claim of privilege, Defendant is required to:
A. State the basis of the claim of privilege;
B. Identify the subject matter of the information to which a claim of privilege is
made;
C. Identify all persons and entities who have had access to, or claimed to be
privileged, or were present when the privileged information was discussed; and
D. Identify all persons and entities to whom the privileged information has been
disclosed.
INTERROGATORIES
1 What is the name and address of the person answering these interrogatories, and
if applicable, the person’s official position or relationship with the party to whom the
interrogatory is directed?
2 State the facts upon which you rely for each affirmative defense in your Answer to
the Complaint, or in support of a Motion to Dismiss, if such was filed.
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3 State each and every policy provision upon which you are relying in connection
with your decision to deny, or otherwise not make payment in full on Plaintiffs invoices
for the property damages incurred by Insured or claimed by Plaintiff in this matter.
4 State the name and address of every person known to you, your agents, or your
attorneys,who has knowledge about, or possession, custody, or control of, any model,
plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or
issue involved in this controversy; and describe as to each, what item such person has,
the name and address of the person who took or prepared it, and the date it was taken
or prepared.
5 State the name, address, and company name if not Defendant’s direct employee,
of every single person that inspected the subject property on your behalf including, but
not limited to, field adjusters, engineers, roofers, contractors, etc.
6 Have you heard, or do you know about any statement or remark made by or on
behalf of any party to this lawsuit, other than yourself, or by the Insured, concerning any
4.
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issue in this lawsuit? If so, state the name and address of each person who made the
statement or statements, the name and address of each person who heard it, and the
date, time, place, and substance of each statement.
7 Identify with specificity any policies of insurance that may provide insurance
coverageto the Insured, or any other person, firm, corporation or company, for the
property damage incident alleged in Plaintiff's Complaint or for the damages that Plaintiff
has alleged, including, but not limited to, the full legal name of the insurer, the full name
and address of each Insured, the policy number, any claim numbers applicable to this
action, the effective dates of the policy (including any lapses in coverage), the limits of
property damage and any deductibles applicable to the damages alleged in this action
8 As to each policy of insurance identified by you in Interrogatory 6 above, state in
specificity whether there any known coverage disputes or coverage issues currently
known to you or alleged by you, including but not limited to, denials of coverage, coverage
under reservation of rights, or other DEC actions to determine coverage or the extent
of coverage.
5.
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9 Identify by name, address, phone number, employer and title/position all persons
who areor have been responsible for making any decisions on your behalf to deny
insurance coverage to the Insured and/or Plaintiff, deny any of Plaintiff's bills or invoices
as stated in the Complaint, or to deny any portion of any bill or invoice submitted by
Plaintiff to you for the property damages described in Plaintiffs Complaint, and for each
such individual state what decisions were made by said individual.
10. Please provide the date Plaintiff first provided Defendant with notice of the claim.
11. Please provide the date Defendant provided Plaintiff with notification of its claim
decision.
12. Please provide the date you anticipated litigation.
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13. As to any and all decisions identified in answer to Interrogatory 8 above, identify
with specificity all documents that were reviewed by and relied upon by said individual(s)
in making said determination, identify (defined above) all persons with whom said
individual(s) communicated in making said determination and state the dates when each
such decision was made.
14. Identify (defined above) all persons involved on your behalf in the handling of the
claim sat issue in Plaintiffs Complaint and for each such person state the time period
during which they were involved in the handling of said claims on your behalf and what
role they played in the handling of this claim on your behalf.
15. If you allege that Plaintiff or the Insured has failed to perform any conditions
precedent to the bringing of this action, or has failed to fulfill any duties after the accident
and/or loss, please identify (defined above) each such person or company with specificity
and state what condition precedent or duty under your insurance policy was not timely
performed or met.
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16. List the names and addresses of all persons who are believed or known by you,
your agents, or your attorneys to have any knowledge concerning any of the issues in this
lawsuit; and specify the subject matter about which the witness has knowledge. The
issues in this lawsuit include, but are not limited to, the property damage event that is
alleged to have occurred on or about date of loss described in the Complaint, the
property damages sustained at the Insured’s Property in regard to said event, the work
performed by Plaintiff
and its representatives (defined above) described in the Complaint
and its attachments, the invoices and bills submitted by Plaintiff or its representatives
(defined above) to Defendant, the claims as set forth by Plaintiff in the Complaint, and the
defenses that you are or anticipate asserting to Plaintiffs claims.
17. With regard to any third parties who provided services, analyses, adjusting, or
otherwiserendered opinions to you in adjusting this claim, please identify:
a. The name of the individual who hired the third party on behalf of your
company;
b. The date and nature of the services provided by the third party;
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c. Each case in which the third party has been retained by you for any
purpose during the past three (3) years;
d. The amount of money that the third party has been paid by you during
the pastthree (3) years; and
e. Please state the taxpayer identification numbers for both you and the
third party.
18. As to any statements of any kind (written, recorded, transcribed, digital or
otherwise) obtained by you from the Insured or any other witness in connection with the
property damage occurrence that is the basis of this lawsuit, including the invoices and
damages alleged by Plaintiff, identify (defined above) each such person from whom a
statement was taken, state the date when each such statement was taken, state the
manner in which it was taken and identify (defined above) the person who took or
recorded each such statement.
9.
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19. As to any portion of the loss alleged and invoices Plaintiff attached to the Complaint
and or previously provided to Defendant that you contend are not covered by the
Insured’s Policy issued by Defendant, please set forththe specific amounts that you
contend are not covered, and for each such amount, all facts supporting your contention
that no coverage exists for said amount.
20. As to any portion of the invoices and bills of Plaintiff attached to the Complaint and
or previously provided to Defendant that you contend are not reasonable in the amount,
specifically identify that portion of the work performed, invoice or bill that you allege to
be unreasonable and state all factual and legal basis that you allege support that
contention.
(JURAT SECTION ON NEXT PAGE)
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JURAT PAGE
Dated
Signature of Agent for Defendant
Printed Name:
Title:
STATE OF
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared the Agent for
Defendant whose name is , and who is_ personally
known to me or who _ produced as identification, and who
deposed and stated that the information contained in the foregoing Answers to
Interrogatories is true and correct, to the best of his/her knowledge and belief.
SWORN AND SUBSCRIBED before me in the aforesaid County and State this
day of , 2024.
Notary Public
Commission No.
(Name of Notary typed, printed or stamped)
My commission expires:
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Preview
Filing # 193408466 E-Filed 03/06/2024 10:15:50 AM IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT IN AND FOR COLUMBIA COUNTY, FLORIDA ROBERT C. CREWS and GINA A. CREWS, Plaintiff, Vv. Case No.: NATIONWIDE MUTUAL INSURANCE COMPANY, Defendant, NOTICE OF SERVICE OF INTERROGATORIES Plaintiffs, Robert C. Crews and Gina A. Crews, by and through the undersigned attorneys, pursuant to Rule 1.340(e) of the Florida Rules of Civil Procedure, hereby requests Defendant, Nationwide Mutual Insurance Company, answer the Plaintiff's First Set of Interrogatories, served through the initial process of service, separately and fully in writing under oath, unless objected to, within forty-five (45) days from the date of service thereof. The attorney making objections must state the grounds for objection and sign the document. [CONTINUED ON THE FOLLOWING PAGE] -1- ARIAS & ABBASS YOUR ATTORNEYS, PLLC Electronically Filed CoftitfbLocas ee 2an Bhds Fe keeReuSe 94 e854 BANS: 5G 96N730-4357 www.TalkToMyAttorneys.com CERTIFICATE OF SERVICE | HEREBY CERTIFY that in accordance with Florida Rule of Judicial Administration 2.516, on March 6, 2024 a true and correct copy of the foregoing instrument was filed with the Clerk of Court by using the Florida Courts e-filing Portal, which will be sent for service on the Defendant along with the summons. Respectfully submitted, ARIAS & ABBASS YOUR ATTORNEYS Trial Attorneys for Plaintiffs 4531 Ponce De Leon Blvd., Ste 200 Coral Gables, Florida 33146 Telephone: 786.530.HELP (4357) Primary e-mail address: eservice@TalkToMyAttorneys.com By: /s:/ Mohad Abbass Juan C. Arias, Esq. Florida Bar No.:1010330 Mohad Abbass, Esq. Florida Bar No.: 1010543 Antonio Bayuelo, Esq. Florida Bar No.: 1048994 -2- ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT IN AND FOR COLUMBIA COUNTY, FLORIDA ROBERT C. CREWS and GINA A. CREWS, Plaintiff, Vv. Case No.: NATIONWIDE MUTUAL INSURANCE COMPANY, Defendant, / PLAINTIFFS’ FIRST SET OF INTERROGATORIES DEFINITIONS A “You” or “Your” as used herein means: the Defendant named above and any related entities who may be liable for the damages sought herein. The definition also includes any individuals or entities handling, adjusting, or otherwise investigating claims on your behalf; any lawyers retained by you on this or any other claim; and, any other agents who have performed services on your behalf at any time material to this action. B “Document” as used herein means: every writing or record of every type and description that is or has been in your possession, control or custody or of which you have knowledge, including without limitation on the generality of the foregoing, correspondence, memoranda, tapes, stenographic or handwritten notes, studies, publications, books, pamphlets, pictures, films, voice records, reports, surveys, maps, statistical complications or minutes; every copy of such writing or record, where the original is not in your possession, custody or control; and every copy of the any original or where such copy contains any commentary or notation whatsoever that does appear in the original. -1- ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com Cc “Correspondence” as used herein means: any correspondence and includes, but not limited to handwritten, typed, emails, digital messages, recorded video, recorded audio and facsimile correspondence. D “Coverage Letter(s)” as used herein means: the correspondence running from you to policyholder throughout the claim at issue regarding your position as to coverage for the loss. E “Date” as used herein means: the exact date, month, and year if ascertainable, or if not, the best approximation) including relationship in time to other events). F “Identify” and “identity” as used herein means: | With respect to a natural person, to state the person’s name, title at the time in question, employer and business address at the time in question and the current or last known employer, business address, and home address; IL With respect to an organization or entity, to state the full legal name of the entity and full name by which the organization or entity is commonly known or does business; and, iii. With respect to data: In the case of a document, the title (if any), date, author, sender recipient, type of document (i.e., letter, memorandum, book, telegram, chart, etc.), or some other means of identifying it, a summary of its contents and its present location or custodian; In the case of oral communication, the date, the communicator, communicate, and a sufficient summary of the contents of such oral communication to indicate its nature and substance. G “Loss” as used herein means: the event at issue in which the policyholder suffered -2- ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com property damage. INSTRUCTIONS: Should Defendant claim an Interrogatory is objected to or not answered pursuant to a claim of privilege, Defendant is required to: A. State the basis of the claim of privilege; B. Identify the subject matter of the information to which a claim of privilege is made; C. Identify all persons and entities who have had access to, or claimed to be privileged, or were present when the privileged information was discussed; and D. Identify all persons and entities to whom the privileged information has been disclosed. INTERROGATORIES 1 What is the name and address of the person answering these interrogatories, and if applicable, the person’s official position or relationship with the party to whom the interrogatory is directed? 2 State the facts upon which you rely for each affirmative defense in your Answer to the Complaint, or in support of a Motion to Dismiss, if such was filed. 3- ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com 3 State each and every policy provision upon which you are relying in connection with your decision to deny, or otherwise not make payment in full on Plaintiffs invoices for the property damages incurred by Insured or claimed by Plaintiff in this matter. 4 State the name and address of every person known to you, your agents, or your attorneys,who has knowledge about, or possession, custody, or control of, any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. 5 State the name, address, and company name if not Defendant’s direct employee, of every single person that inspected the subject property on your behalf including, but not limited to, field adjusters, engineers, roofers, contractors, etc. 6 Have you heard, or do you know about any statement or remark made by or on behalf of any party to this lawsuit, other than yourself, or by the Insured, concerning any 4. ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com issue in this lawsuit? If so, state the name and address of each person who made the statement or statements, the name and address of each person who heard it, and the date, time, place, and substance of each statement. 7 Identify with specificity any policies of insurance that may provide insurance coverageto the Insured, or any other person, firm, corporation or company, for the property damage incident alleged in Plaintiff's Complaint or for the damages that Plaintiff has alleged, including, but not limited to, the full legal name of the insurer, the full name and address of each Insured, the policy number, any claim numbers applicable to this action, the effective dates of the policy (including any lapses in coverage), the limits of property damage and any deductibles applicable to the damages alleged in this action 8 As to each policy of insurance identified by you in Interrogatory 6 above, state in specificity whether there any known coverage disputes or coverage issues currently known to you or alleged by you, including but not limited to, denials of coverage, coverage under reservation of rights, or other DEC actions to determine coverage or the extent of coverage. 5. ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com 9 Identify by name, address, phone number, employer and title/position all persons who areor have been responsible for making any decisions on your behalf to deny insurance coverage to the Insured and/or Plaintiff, deny any of Plaintiff's bills or invoices as stated in the Complaint, or to deny any portion of any bill or invoice submitted by Plaintiff to you for the property damages described in Plaintiffs Complaint, and for each such individual state what decisions were made by said individual. 10. Please provide the date Plaintiff first provided Defendant with notice of the claim. 11. Please provide the date Defendant provided Plaintiff with notification of its claim decision. 12. Please provide the date you anticipated litigation. 6- ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com 13. As to any and all decisions identified in answer to Interrogatory 8 above, identify with specificity all documents that were reviewed by and relied upon by said individual(s) in making said determination, identify (defined above) all persons with whom said individual(s) communicated in making said determination and state the dates when each such decision was made. 14. Identify (defined above) all persons involved on your behalf in the handling of the claim sat issue in Plaintiffs Complaint and for each such person state the time period during which they were involved in the handling of said claims on your behalf and what role they played in the handling of this claim on your behalf. 15. If you allege that Plaintiff or the Insured has failed to perform any conditions precedent to the bringing of this action, or has failed to fulfill any duties after the accident and/or loss, please identify (defined above) each such person or company with specificity and state what condition precedent or duty under your insurance policy was not timely performed or met. -7- ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com 16. List the names and addresses of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. The issues in this lawsuit include, but are not limited to, the property damage event that is alleged to have occurred on or about date of loss described in the Complaint, the property damages sustained at the Insured’s Property in regard to said event, the work performed by Plaintiff and its representatives (defined above) described in the Complaint and its attachments, the invoices and bills submitted by Plaintiff or its representatives (defined above) to Defendant, the claims as set forth by Plaintiff in the Complaint, and the defenses that you are or anticipate asserting to Plaintiffs claims. 17. With regard to any third parties who provided services, analyses, adjusting, or otherwiserendered opinions to you in adjusting this claim, please identify: a. The name of the individual who hired the third party on behalf of your company; b. The date and nature of the services provided by the third party; -8- ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com c. Each case in which the third party has been retained by you for any purpose during the past three (3) years; d. The amount of money that the third party has been paid by you during the pastthree (3) years; and e. Please state the taxpayer identification numbers for both you and the third party. 18. As to any statements of any kind (written, recorded, transcribed, digital or otherwise) obtained by you from the Insured or any other witness in connection with the property damage occurrence that is the basis of this lawsuit, including the invoices and damages alleged by Plaintiff, identify (defined above) each such person from whom a statement was taken, state the date when each such statement was taken, state the manner in which it was taken and identify (defined above) the person who took or recorded each such statement. 9. ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com 19. As to any portion of the loss alleged and invoices Plaintiff attached to the Complaint and or previously provided to Defendant that you contend are not covered by the Insured’s Policy issued by Defendant, please set forththe specific amounts that you contend are not covered, and for each such amount, all facts supporting your contention that no coverage exists for said amount. 20. As to any portion of the invoices and bills of Plaintiff attached to the Complaint and or previously provided to Defendant that you contend are not reasonable in the amount, specifically identify that portion of the work performed, invoice or bill that you allege to be unreasonable and state all factual and legal basis that you allege support that contention. (JURAT SECTION ON NEXT PAGE) -10- ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com JURAT PAGE Dated Signature of Agent for Defendant Printed Name: Title: STATE OF COUNTY OF BEFORE ME, the undersigned authority, personally appeared the Agent for Defendant whose name is , and who is_ personally known to me or who _ produced as identification, and who deposed and stated that the information contained in the foregoing Answers to Interrogatories is true and correct, to the best of his/her knowledge and belief. SWORN AND SUBSCRIBED before me in the aforesaid County and State this day of , 2024. Notary Public Commission No. (Name of Notary typed, printed or stamped) My commission expires: -ll- ARIAS & ABBASS YOUR ATTORNEYS, PLLC 4531 Ponce de Leon Blvd., Suite 200, Coral Gables, FL 33146 | 786.530.4357 www.TalkToMyAttorneys.com