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IN THE COUNTY COURT OF THE
EIGHTEENTH JUDICIAL CIRCUIT IN AND
FOR SEMINOLE COUNTY, FLORIDA
CASE NO: 2024SC001941
THE KIDWELL GROUP LLC d/b/a AIR
QUALITY ASSESSORS OF FLORIDA a/a/o
Kristin Horrighs,
Plaintiff,
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TYPTAP INSURANCE COMPANY,
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Defendant.
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NOTICE OF SERVING INTERROGATORIES TO DEFENDANT
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COMES NOW the Plaintiff, THE KIDWELL GROUP LLC d/b/a AIR QUALITY
ASSESSORS OF FLORIDA a/a/o Kristin Horrighs, pursuant to Rule 1.340(e) of the Florida
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Rules of Civil Procedure, hereby files Notice of Service of the original and one (1) copy of
Interrogatories number one (1) through nineteen (19) to be answered in oath and in writing,
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within forty-five (45) days from the date of service hereof.
U CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this April 4, 2024, I electronically filed the foregoing with
the Clerk of Courts by using the ECF system, which will send a notice to all counsel of record.
/s/ William S England________
William S England, Esquire
Fla. Bar No.: 0098941
Chad A. Barr, Esquire
Fla. Bar No.: 55365
Law Office of Chad A. Barr, P.A.
238 N. Westmonte Dr., Suite 200
Altamonte Springs, Florida 32714
Telephone: (407) 599-9036
wseservice@chadbarrlaw.com (Primary)
will@chadbarrlaw.com (Secondary)
IN THE COUNTY COURT OF THE
EIGHTEENTH JUDICIAL CIRCUIT IN AND
FOR SEMINOLE COUNTY, FLORIDA
CASE NO:
THE KIDWELL GROUP LLC d/b/a AIR
QUALITY ASSESSORS OF FLORIDA a/a/o
Kristin Horrighs,
L
Plaintiff,
IA
TYPTAP INSURANCE COMPANY,
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Defendant.
Definitions:
FF FIRST INTERROGATORIES TO DEFENDANT
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1. "You(r)" as used in these interrogatories 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;
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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.
2. The connectives "and" and "or" shall be constructed either disjunctively or
conjunctively as necessary to bring within the scope of these requests all responses that might
otherwise be constructed to be outside their scope.
3. The singular includes the plural, and vice versa. The masculine includes the feminine
and vice versa.
4. "All" shall be construed as "all and each" and the term "each" shall be construed as "all
and each."
5. "Coverage Letter(s)" means the correspondence running from You to policyholder
throughout the claim at issue regarding your position as to coverage for the loss.
6. "Document" means any kind of written, typewritten, or printed material whatsoever,
any kind of graphic material, and any computer readable media including, but without limitation,
papers, agreements, contracts, notes, memoranda, correspondence, electronic mail messages,
studies, working papers, letters, telegrams, invoices, personal diaries, reports, records, books,
forms, indexes, transcriptions and recordings, magnetic tapes, disks and printed cards, data
sheets, data processing cards, personal calendars, journals, diaries, inter office memoranda,
minutes and records of any sorts of meetings, financial statements, financial calculations,
estimates, reports of telephone or other oral conversations, appointment books, maps, drawings,
charts, graphs, photographs, sound recordings, videotape recordings, computer printouts,
microfilms, information sent or received via the internet, information stored electronically or on
computer chips, disks or databases, all other compilations of data from which information can be
obtained or translated if necessary, by plaintiff through detector devices into reasonable usable
form and all other writings and recoding of every kind, however produced or reproduced
whether signed or unsigned. The term "document" includes without limitation the original and all
file copies and other copies that are not identical to the original no matter how or by whom
prepared, and all drafts prepared in connection with any documents, whether or not used. If the
original of any document is not in your possession, custody, or control, a copy of that document
should be produced.
7. "Identify" and "identity" mean:
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a. with respect to a natural person, to state the persons name, title at the time in question,
employer and business address at the time in question and the current or last known employer,
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business address, and home address;
b. 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;
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c. with respect to a document, to state the names and titles of the author(s) and/ or signatory(ies),
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address(es), and recipient(s) of any copies; the subject matter or title; the date of the document;
the division, department, or unit of your organization with which the authors and/ or addressees
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are or were affiliated; and its present location and custodian; and
d. with respect to an oral communication, to state the names and title of all persons involved in
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the communication, and date and approximate time of the communication.
8. "Loss" means the event at issue in which the policy holder suffered property damage.
NO INSTRUCTIONS
1. These interrogatories are continuing in nature so as to require the filing of supplemental
answers to the extent required under Florida Law.
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2. If you cannot answer any interrogatory in full, answer to the extent possible, explain why you
cannot answer the remainder, state the nature of the information and knowledge that you can
furnish, and provide a supplemental response when you obtain more information.
3. If your answer to any interrogatory derives from a document, identify the document.
4. If you contend that any document or communication that is responsive to any interrogatory
propounded herein is privileged for any reason whatsoever, identify each such document or
communication in your answer to each interrogatory and include that document on a privilege
log.
INTERROGATORIES
1. Identify each person who prepared answers or supplied or provided information used
to prepare answers to these Interrogatories.
2. Describe in detail your efforts to gather information and documents responsive to each
of these interrogatories, as well as Plaintiff's first request for Production of documents, including
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the person(s) involved in such efforts.
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3. Identify all fact witnesses you expect to call to testify at the trial of this action and
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describe the substance of their expected testimony.
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4. Does the coverage letter(s) specifically cite to each and every policy provision and all
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facts upon which you are relying in connection with your decision to deny, or otherwise not
make full payment to Plaintiff? If your answer is anything other than an unqualified affirmative,
identify all other policy provisions and facts upon which you are relying for your denial or part
payment of the claim at issue.
5. Do you contend that all or any portion of the loss, as set forth in this matter is not
covered by any of the policies issued by you? Unless your answer is an unqualified negative,
please set forth the specific amounts that you contend are not covered, and for each such amount,
all facts, including exclusions or other provisions of the policies, supporting your contention that
no coverage exists.
6. State each and every policy provision and all facts related to each upon which you are
relying in connection with your decision to deny, or otherwise not make full payment in response
to the property damage invoice submitted by plaintiff in this matter.
7. Identify all persons who are or have been responsible for determining and/ or
analyzing on your behalf how the policy that is at issue in this case apply to the insured's claim.
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8. For each document listed on the privilege log that you have served in this action, or
otherwise being withheld by you on grounds of privilege or work product, identify each person,
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if any, to whom or with whom each such document was provided or shared.
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9. Identify all persons involved on your behalf in the handling of this claim. For each
person identified: identify the person(s) employer and explain the role of each person(s)
identified in the handling of this claim.
10. Do you contend that any of your policy contains any deductibles or other "self-
insurance" features? If your answer is anything other than an unqualified negative, identify such
policy, the policy provisions that you contend sets forth such a deductible or self-insurance
feature and all persons with knowledge of the operation of such feature that were involved in this
case and state whether you contend such deductible or self-insurance feature applies to defense
costs.
11. Have you established any reserves for the property damage claim at issue in this
action? If your answer is anything other than an unqualified negative then identify the amount of
such reserve, all persons involved in setting such reserves, and describe in detail the factors
considered in setting such reserve. What is the name and address of the person(s) answering
these interrogatories, and, if applicable, the person's official position or relationship with the
party to whom the interrogatories are directed?
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12. Please provide the name, Florida license number, and current address of any adjusters
or other individuals (whether employed by you or not) who were involved in any manner in
adjusting the claim, or who visited or inspected the subject premises.
F I C
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13. With regard to any third parties who provided services, analyses, adjusting, or
otherwise rendered opinions to you in this claim, please identify:
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a. The name of the individual who hired the third party on behalf of your company.
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b. The date and nature of the services provided by the third party.
c. Each case in which the third party has been retained by you for any purpose during the
past three years.
d. The amount of money that the third party has been paid by you during the past three
years.
e. Please state the taxpayer identification numbers for both you and the third party.
14. If you allege that Plaintiff or the insured has failed to perform any conditions
precedent, or failed to fulfill any duties after loss, please identify them with specificity, including
the date the individual failed to perform, citing the appropriate contractual language which
supports the individual's duty to perform.
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15. 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, concerning any issue in this lawsuit? If so, state
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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.
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16. 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 and time it was taken or prepared.
17. Set forth each and every fact supporting each of the Defendant’s Affirmative
Defenses.
18. Please set forth each and every date and time that the Defendant, a representative or
agent of the Defendant, or a third-party hired by the Defendant examined the subject property
following the subject loss.
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19. Please set forth the date of every conversation that the Defendant, a representative or
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agent of the Defendant, or a third-party hired by the Defendant spoke to the insured regarding the
subject loss at the subject property. Please set forth the content of each conversation.
F I C
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By: ____________________________
Signature
STATE OF
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COUNTY OF __________________)
The foregoing instrument was acknowledged before me this _____ day of
______________, 20___ by __________________________ who is personally known to me or
has produced ___________________________ as identification and who (did/did not) take an
oath.
Notary Public
Commission No.:
(SEAL)
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F I C
O F
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Preview
IN THE COUNTY COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR SEMINOLE COUNTY, FLORIDA CASE NO: 2024SC001941 THE KIDWELL GROUP LLC d/b/a AIR QUALITY ASSESSORS OF FLORIDA a/a/o Kristin Horrighs, Plaintiff, L TYPTAP INSURANCE COMPANY, IA Defendant. C NOTICE OF SERVING INTERROGATORIES TO DEFENDANT F I COMES NOW the Plaintiff, THE KIDWELL GROUP LLC d/b/a AIR QUALITY ASSESSORS OF FLORIDA a/a/o Kristin Horrighs, pursuant to Rule 1.340(e) of the Florida O F Rules of Civil Procedure, hereby files Notice of Service of the original and one (1) copy of Interrogatories number one (1) through nineteen (19) to be answered in oath and in writing, N within forty-five (45) days from the date of service hereof. U CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this April 4, 2024, I electronically filed the foregoing with the Clerk of Courts by using the ECF system, which will send a notice to all counsel of record. /s/ William S England________ William S England, Esquire Fla. Bar No.: 0098941 Chad A. Barr, Esquire Fla. Bar No.: 55365 Law Office of Chad A. Barr, P.A. 238 N. Westmonte Dr., Suite 200 Altamonte Springs, Florida 32714 Telephone: (407) 599-9036 wseservice@chadbarrlaw.com (Primary) will@chadbarrlaw.com (Secondary) IN THE COUNTY COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR SEMINOLE COUNTY, FLORIDA CASE NO: THE KIDWELL GROUP LLC d/b/a AIR QUALITY ASSESSORS OF FLORIDA a/a/o Kristin Horrighs, L Plaintiff, IA TYPTAP INSURANCE COMPANY, I C Defendant. Definitions: FF FIRST INTERROGATORIES TO DEFENDANT NO 1. "You(r)" as used in these interrogatories 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; U 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. 2. The connectives "and" and "or" shall be constructed either disjunctively or conjunctively as necessary to bring within the scope of these requests all responses that might otherwise be constructed to be outside their scope. 3. The singular includes the plural, and vice versa. The masculine includes the feminine and vice versa. 4. "All" shall be construed as "all and each" and the term "each" shall be construed as "all and each." 5. "Coverage Letter(s)" means the correspondence running from You to policyholder throughout the claim at issue regarding your position as to coverage for the loss. 6. "Document" means any kind of written, typewritten, or printed material whatsoever, any kind of graphic material, and any computer readable media including, but without limitation, papers, agreements, contracts, notes, memoranda, correspondence, electronic mail messages, studies, working papers, letters, telegrams, invoices, personal diaries, reports, records, books, forms, indexes, transcriptions and recordings, magnetic tapes, disks and printed cards, data sheets, data processing cards, personal calendars, journals, diaries, inter office memoranda, minutes and records of any sorts of meetings, financial statements, financial calculations, estimates, reports of telephone or other oral conversations, appointment books, maps, drawings, charts, graphs, photographs, sound recordings, videotape recordings, computer printouts, microfilms, information sent or received via the internet, information stored electronically or on computer chips, disks or databases, all other compilations of data from which information can be obtained or translated if necessary, by plaintiff through detector devices into reasonable usable form and all other writings and recoding of every kind, however produced or reproduced whether signed or unsigned. The term "document" includes without limitation the original and all file copies and other copies that are not identical to the original no matter how or by whom prepared, and all drafts prepared in connection with any documents, whether or not used. If the original of any document is not in your possession, custody, or control, a copy of that document should be produced. 7. "Identify" and "identity" mean: L a. with respect to a natural person, to state the persons name, title at the time in question, employer and business address at the time in question and the current or last known employer, IA business address, and home address; b. 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; C c. with respect to a document, to state the names and titles of the author(s) and/ or signatory(ies), I address(es), and recipient(s) of any copies; the subject matter or title; the date of the document; the division, department, or unit of your organization with which the authors and/ or addressees F are or were affiliated; and its present location and custodian; and d. with respect to an oral communication, to state the names and title of all persons involved in F the communication, and date and approximate time of the communication. 8. "Loss" means the event at issue in which the policy holder suffered property damage. NO INSTRUCTIONS 1. These interrogatories are continuing in nature so as to require the filing of supplemental answers to the extent required under Florida Law. U 2. If you cannot answer any interrogatory in full, answer to the extent possible, explain why you cannot answer the remainder, state the nature of the information and knowledge that you can furnish, and provide a supplemental response when you obtain more information. 3. If your answer to any interrogatory derives from a document, identify the document. 4. If you contend that any document or communication that is responsive to any interrogatory propounded herein is privileged for any reason whatsoever, identify each such document or communication in your answer to each interrogatory and include that document on a privilege log. INTERROGATORIES 1. Identify each person who prepared answers or supplied or provided information used to prepare answers to these Interrogatories. 2. Describe in detail your efforts to gather information and documents responsive to each of these interrogatories, as well as Plaintiff's first request for Production of documents, including L the person(s) involved in such efforts. I C IA 3. Identify all fact witnesses you expect to call to testify at the trial of this action and F describe the substance of their expected testimony. O F N 4. Does the coverage letter(s) specifically cite to each and every policy provision and all U facts upon which you are relying in connection with your decision to deny, or otherwise not make full payment to Plaintiff? If your answer is anything other than an unqualified affirmative, identify all other policy provisions and facts upon which you are relying for your denial or part payment of the claim at issue. 5. Do you contend that all or any portion of the loss, as set forth in this matter is not covered by any of the policies issued by you? Unless your answer is an unqualified negative, please set forth the specific amounts that you contend are not covered, and for each such amount, all facts, including exclusions or other provisions of the policies, supporting your contention that no coverage exists. 6. State each and every policy provision and all facts related to each upon which you are relying in connection with your decision to deny, or otherwise not make full payment in response to the property damage invoice submitted by plaintiff in this matter. 7. Identify all persons who are or have been responsible for determining and/ or analyzing on your behalf how the policy that is at issue in this case apply to the insured's claim. IAL I C 8. For each document listed on the privilege log that you have served in this action, or otherwise being withheld by you on grounds of privilege or work product, identify each person, F if any, to whom or with whom each such document was provided or shared. O F U N 9. Identify all persons involved on your behalf in the handling of this claim. For each person identified: identify the person(s) employer and explain the role of each person(s) identified in the handling of this claim. 10. Do you contend that any of your policy contains any deductibles or other "self- insurance" features? If your answer is anything other than an unqualified negative, identify such policy, the policy provisions that you contend sets forth such a deductible or self-insurance feature and all persons with knowledge of the operation of such feature that were involved in this case and state whether you contend such deductible or self-insurance feature applies to defense costs. 11. Have you established any reserves for the property damage claim at issue in this action? If your answer is anything other than an unqualified negative then identify the amount of such reserve, all persons involved in setting such reserves, and describe in detail the factors considered in setting such reserve. What is the name and address of the person(s) answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed? IAL 12. Please provide the name, Florida license number, and current address of any adjusters or other individuals (whether employed by you or not) who were involved in any manner in adjusting the claim, or who visited or inspected the subject premises. F I C O F 13. With regard to any third parties who provided services, analyses, adjusting, or otherwise rendered opinions to you in this claim, please identify: N a. The name of the individual who hired the third party on behalf of your company. U b. The date and nature of the services provided by the third party. c. Each case in which the third party has been retained by you for any purpose during the past three years. d. The amount of money that the third party has been paid by you during the past three years. e. Please state the taxpayer identification numbers for both you and the third party. 14. If you allege that Plaintiff or the insured has failed to perform any conditions precedent, or failed to fulfill any duties after loss, please identify them with specificity, including the date the individual failed to perform, citing the appropriate contractual language which supports the individual's duty to perform. IAL I C 15. 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, concerning any issue in this lawsuit? If so, state F 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. O F U N 16. 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 and time it was taken or prepared. 17. Set forth each and every fact supporting each of the Defendant’s Affirmative Defenses. 18. Please set forth each and every date and time that the Defendant, a representative or agent of the Defendant, or a third-party hired by the Defendant examined the subject property following the subject loss. L 19. Please set forth the date of every conversation that the Defendant, a representative or IA agent of the Defendant, or a third-party hired by the Defendant spoke to the insured regarding the subject loss at the subject property. Please set forth the content of each conversation. F I C O F By: ____________________________ Signature STATE OF U N COUNTY OF __________________) The foregoing instrument was acknowledged before me this _____ day of ______________, 20___ by __________________________ who is personally known to me or has produced ___________________________ as identification and who (did/did not) take an oath. Notary Public Commission No.: (SEAL) IAL F I C O F U N