Letter,Correspondence: THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY

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                                April 4, 2024
                                                             2024SC001911
VIA SERVICE OF PROCESS
TYPTAP INSURANCE COMPANY




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       RE:         THE KIDWELL GROUP LLC d/b/a AIR QUALITY ASSESSORS OF




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       FLORIDA a/a/o Luis Galofre v. TYPTAP INSURANCE COMPANY

       COUNTY:       SEMINOLE




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       CASE NO.:




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To Whom It May Concern:




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       Please be advised that we would like to take the deposition of Defendant’s Corporate




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Representative with knowledge of the following:




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       1.     Knowledge of and explanation for all responses to interrogatories;




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       2.     Why Defendant has been prejudiced with respect to this claim;

       3.     What post loss conditions have not been complied with;

       4.     Knowledge of and basis for all affirmative defenses and exclusions;

       5.     Knowledge as to all allegations contained in the complaint, answer and

       6.     Affirmative defenses;

       7.     All documents requested prior to suit and reason for requesting same;

       8.     All estimates prepared by Defendant;

       9.     The insurance company’s inspection of the property;
       10.     Why the insurer could not determine coverage based on the information provided

               by the insured;

       11.     The subject claims file;

       12.     The subject policy of insurance;

       13.     Explanation of all policy language relied upon to deny coverage;

       14.     The pre-loss inspection and photographs of the insured property;

       15.     Explanation and understanding of all documents produced in response to request




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               for production;




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       16.     The inspection of the insured property after the loss.




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       17.     The payments made on the claim.

       18.

       19.


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               All reasons for coverage denial

               Any and all affidavits Defendant filed in this matter.

       20.




           O F Any and all Affirmative Defenses raised (or reserved) by Defendant in this

               matter, including all supporting bases and evidence.

       21.




        U N    The policy of insurance for the subject property, including but not limited to

               inception of the policy and subsequent modifications, amendments and notices.

       If Defendant has more than one corporate representative with knowledge regarding these

topics, please provide available dates for each individual with knowledge of those topics. Within

the next ten days, please respond to kareen@chadbarrlaw.com and will@chadbarrlaw.com and

provide my office with you and your client’s availability to appear for deposition. Should you

have any questions, please do not hesitate to contact my office. Thank you for your cooperation

and prompt attention regarding this matter.


                                              Sincerely,
      /s/ William S England
      William S England, Esquire




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