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Filing # 195496212 E-Filed 04/04/2024 02:02:46 PM
IN THE CIRCUIT COURT OF THE 20TH
JUDICIAL CIRCUIT IN AND FOR LEE
COUNTY, FLORIDA
CASE NO.:
FOTIOS CARANICOLAS,
Plaintiff,
v.
AMERICAN STRATEGIC INSURANCE
CORP.,
Defendant.
________________________________________/
PLAINTIFF’S NOTICE OF PROPOUNDING FIRST SET OF
INTERROGATORIES TO DEFENDANT
The Plaintiff, FOTIOS CARANICOLAS, by and through its undersigned counsel, hereby
notifies the Court and all interested parties that, on this date, pursuant to Rule 1.340 of the Florida
Rules of Civil Procedure, the Plaintiff has served the Defendant, AMERICAN STRATEGIC
INSURANCE CORP., with Plaintiff’s First Set of Interrogatories, numbered 1-23, to be answered
under oath and in writing, in accordance with and within the time allowed under the Florida Rules
of Civil Procedure.
(CERTIFICATE OF SERVICE ON FOLLOWING PAGE)
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
-8-
eFiled Lee County Clerk of Courts Page 1
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was e-filed with the
Clerk of Court and served by electronic mail designation pursuant to Fla. R. Jud. Admin 2.516,
and/or the Florida Courts E-Filing Portal to , Counsel for Defendant, at ; on April 4, 2024.
Respectfully submitted,
/s/ Michael Wojnar, Esq.
Michael Wojnar, Esq.
Bar No.: 1031406
Property Litigation Group, PLLC
Attorneys for Plaintiff
2750 SW 145th AVE
Suite 509
Miramar, FL 33027
Primary Email: service@plglawyersfl.com
Secondary Email:
mwojnar@plglawyersfl.com
Alternate Email:
asardinas@plglawyersfl.com
PH: (786) 703-8810
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
-9-
eFiled Lee County Clerk of Courts Page 2
IN THE CIRCUIT COURT OF THE 20TH
JUDICIAL CIRCUIT IN AND FOR LEE
COUNTY, FLORIDA
CASE NO.:
FOTIOS CARANICOLAS,
Plaintiff,
v.
AMERICAN STRATEGIC INSURANCE
CORP.,
Defendant.
________________________________________/
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT
DEFINITIONS
A. The Term "documents" means all writings of any kind, including the originals and all non-
identical copies, whether different from the original by reason of any notation made on such copies
or otherwise, including (without limitations) correspondence, memoranda, notes, diaries, statistics,
letters, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns,
summaries, pamphlets, books, prospectuses, inter-office and intra-office communications, offers,
notations of any sort of conversation, telephone calls, meetings or other communications, bulletins,
printed matter, computer print-outs, teletypes, telefax, invoices, worksheets and all drafts,
alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural
writs, records or representations of any kind, including (without limitations) photographs, charts,
graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical
or electric records or representations of any kind, including (without limitation) tapes, cassettes,
computer magnetic or optical disc media and disc recordings.
B. The term "relating to" as used herein is defined to mean evidencing, referring to , pertaining
to, consisting of, reflecting, concerning, or in any way logically or factually connected with the
matter discussed.
C. As used in this Discovery request, the phrases "describe and explain", and "state" are
intended to and shall be interpreted to request a full and fair statement of the fact or matter being
described and explained, including a statement of all facts, statements, events and circumstances
necessary to understand and evaluate the fact or matter being described and explained.
D. Each of the following discovery requests seeking an identification of documents is intended
to be interpreted to request and require:
1. The date of the document;
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
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2. The originator of the document;
3. The type of document;
4. The addressee of the document, if any;
5. Identification of persons to whom copies of the documents were furnished;
6. Details as to the custody of the document on the date the Interrogatories are
answered;
7. Specific page numbers where the information requested may be found, if
appropriate; or, alternatively, documents may be identified by numbering each such
document and referring to the number in the answer and providing a true copy of
each such numbered document with the Answers to Interrogatories.
E. Each of the following Discovery Requests or Interrogatories requesting the identification
of persons is intended to be interpreted to request and require for each witness known to the
Defendant:
1. The name of the individual;
2. The last known address and phone number of the individual;
3. The place of employment of the individual and the person's last known address;
4. The substance of the witnesses' knowledge or information relating to the
information requested.
"Policy": means that certain insurance policy as described in the complaint
"Defendant" or “You”: means Defendant, its attorneys, agents, partners, employees,
officers, directors, stockholders, and all other persons acting on its
behalf.
"Person": means all individuals, corporations, partnerships, joint venture
groups, associations, governmental agencies and all other
organizations.
"Document": means all written, typed, photographic, computerized or printed
materials, including but not limited to the original and all non-
identical copies of all letters, books, records, charts, ledgers, drafts,
checks, check stubs, passbooks, certificates, graphs, facsimile
transmissions, telegrams, reports, contracts, invoices, receipts,
brochures, pamphlets, studies, lists, notes, memoranda, computer
printouts, data processing cards, pictures, drawings, diagrams,
sketches, video tapes, motion pictures, blue-prints, photographs,
microfilm, microfiche, computer discs and all other materials or
documentation which pertains or contains information directly or
indirectly, in whole or in part, and in any manner, to any of the
subjects inquired about.
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
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INSTRUCTIONS
Before answering the following Discovery requests and/or Interrogatories, will you please
make such inquiries of your agents, servants, employees and/or attorneys as will enable you to
make full and true answers to the following, in accordance with the applicable Florida Rules of
Civil Procedure. Additionally, if more space is required, please use a separate sheet of paper and
attach same behind the sheet where the respective question appears.
1. Please identify yourself fully by stating your full name, employment address and
position and job title that you hold with the Defendant.
2. Please identify the person whom defendant is designating as the person who shall
testify about all matters related to the claims in this case known or reasonably available to
the defendant pursuant to Fla. R. Civ. P. 1.310(b)(6).
3. Please explain with particularity each and every reason for the denial of each
Request for Admission which has been denied and for each such denial, state all facts which
support said denial, identifying all witnesses who have knowledge of such facts and the
extent of such knowledge.
4. Describe in as much detail as possible, each and every factual reason why the
Defendant denied or seeks to deny coverage for Plaintiff(s) claim described in the
Complaint, including the factual basis for each affirmative defense raised by you.
5. If Defendant has tendered payment to Plaintiff in any amount whatsoever, describe
in as much detail as possible, each and every factual reason why the Defendant failed to
tender payment in accordance with the estimate (attached hereto as “Exhibit A”).
6. Identify each representative of the defendant who visited Plaintiff's property that is
the subject of this claim in the last 20 months, and for each such visit, give the date of the
visit, identity of the defendant's representative at the visit, and identify with particularity
all documents generated by such visit so that the same can be identified in a request for
production. If a privilege is claimed as to any document identified, prepare a privilege log
as required by the rules.
7. State the location, including page(s), line(s) and paragraph number(s), and the exact
language contained in the Policy upon which the Defendant has based its coverage decision
for the claim described in the complaint, and the factual basis supporting the application of
the policy language referred to.
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
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8. Identify each document sent from Defendant to Plaintiff(s) in reference to the
subject loss involved herein, including the date sent, the name of the individual who sent
said communication.
9. Identify each person, who on behalf of Defendant, inspected the property described
in the complaint in reference to the claim described in the Complaint, including his or her
field of expertise and the date of each inspection.
10. Identify each written estimate of repair or replacement, including the amount set
forth in each said estimate by Defendant in reference to the claim described in the
Complaint, and for each such estimate state:
a. If it was provided to Plaintiff/Insured
b. If provided to Plaintiff/Insured, when it was so provided
c. Identify the person or persons who prepared the estimate or estimates and the nature
of that person’s participation in the preparation of said estimate.
d. The factual basis for the conclusions contained or implied in said estimate or
estimate.
11. Identify all persons (other than Plaintiff or his agents) believed or known by you,
your agents or attorneys to have any knowledge concerning any of the issues raised by the
pleadings, specifying the subject matter about which the witnesses have knowledge and
state whether you have obtained any statements (oral, written and/or recorded) from any of
said witnesses, list the dates any such witness statements were taken, by whom any such
witness statements were taken and who has present possession, custody and control of any
such statements.
12. Did the Defendant request Plaintiff(s) to perform any post loss duties for the subject
claim, including but not limited to, submitting to an examination under oath, submitting a
sworn proof of loss, permitting inspection, etc., and if so, identify each writing or request
made by defendant evidencing such request.
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
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13. If your answer to the preceding interrogatory was "YES", please state for each
request:
a. the exact request made and the identity of the person on behalf of
the defendant who made said request.
b. the date of the request
c. whether the request was written or oral
d. What did Plaintiff do in response to said request
14. Please describe all requests made by the Insurance Company upon the Insured (i.e.,
requests for examination under oath, information, documents, sworn proofs of loss, etc.,)
in reference to this claim and the dates made.
15. With reference to each of your affirmative defenses raised in this lawsuit, please
describe each and every fact upon which you rely to substantiate such affirmative defense,
including identification of all witnesses to each such fact, making sure that the description
you give correlates to the numbered or lettered affirmative defense raised by you.
16. Please identify and state the qualifications of the adjuster(s), engineer(s) and any
other individuals used by Defendant in investigating the stated claim involved in this
litigation.
17. Please identify each person you intend to call as a factual witness in this case and
provide a brief description of that person’s expected testimony (e.g. why is that person
being called as a witness).
18. Please identify each person you intend to call as an expert witness in this case and
provide a brief description of that person’s expected testimony (e.g. why is that person
being called as a witness).
19. Please identify each document you intend to use at trial and describe its purpose.
20. Identify all persons who participated in answering these interrogatories, and the
nature of their participation.
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
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21. Please explain with particularity, identifying each and every witness and
document, all facts which support your denial of each of Plaintiff's requests for admissions.
22. Did Defendant conduct an inspection of the property at issue prior to issuing an
insurance policy to either the Plaintiff or any other prior homeowner of the property at
issue? If so, was a report created?
23. Did Defendant ever provide an inspection report of the property to either the
Plaintiff or any other prior homeowner of the property at issue?
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
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IN WITNESS WHEREOF, the Insurance Company has executed the foregoing answers to
interrogatories and states that same are true and correct to the best of the undersigned’s knowledge
and belief.
__________________________________
Name of the Insurance Company
___________________________________
Name of Authorized Representative:
STATE OF FLORIDA )
COUNTY OF ____________ ) SS:
BEFORE ME, the undersigned authority, duly authorized to administer oaths and take
acknowledgments, personally appeared _________________, who, being first duly sworn,
deposes and says that he or she is the authorized representative of the defendant, and that he or she
is the affiant who answered the foregoing interrogatories and that the answers set forth in the
foregoing answers to interrogatories are true and correct.
SWORN TO and subscribed to before me on ________________________________.
_________________________________
Notary Public, State of Florida at Large
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
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EXHIBIT A
PROPERTY LITIGATION GROUP, PLLC
2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810
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1
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
Insured: Fotios Caranicolas Home: (813) 464-5989
Property: 19501 Estero Pointe Lane E-mail: fcaranic@gmail.com
Fort Myers, FL 33908
Estimator: Greg Swenson Business: (786) 457-0338
Position: Owner E-mail: greg@sfestimating.com
Company: SF Estimating, LLC
Claim Number: 1305873 Policy Number: FLA395972 Type of Loss: Wind Damage
Date of Loss: 9/28/2022 12:00 AM Date Received:
Date Inspected: Date Entered: 1/10/2024 11:26 PM
Price List: FLFM8X_JAN24
Restoration/Service/Remodel
Estimate: CARANICOLAS_FOTIOS_S
eFiled Lee County Clerk of Courts Page 11
2
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
CARANICOLAS_FOTIOS_S
General
DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL
1. Permits & Fees (Agreed Price) 1.00 EA 0.00 1,500.00 0.00 300.00 1,800.00
To cover the costs of permits, permit expeditors, labor to be on site for multiple inspections by the building department, etc.
2. Residential Supervision / Project 20.00 HR 0.00 78.09 0.00 312.36 1,874.16
Management - per hour
This accounts for time needed to review material with homeowner, verify/select material options, complete permit application, coordinate with
home owners association when applicable, coordinate with neighbors, obtain/post copy of approved permit, schedule dumpster delivery, coordinate
tear off crew, verify weather to avoid additional damages, update homeowner, update insurance carrier, schedule sheathing inspection, setup
ladder with inspection card, upload forward approved inspection cards, review on site required supplements, document production photos, schedule
final inspection with city, and more...
3. General clean - up 12.00 HR 0.00 54.72 0.01 131.32 787.97
Three guys for half day to roll property with magnets for nails, clean roof perimeter, and surrounding area to ensure customer satisfaction.
4. Dumpster load - Approx. 30 yards, 5- 1.00 EA 1,015.00 0.00 0.00 203.00 1,218.00
7 tons of debris
5. Material Only Sheathing - plywood - 192.00 SF 0.00 1.26 15.72 51.52 309.16
5/8" CDX
6 sheets of plywood measuring 24' long and 8 ' wide to accommodate a 7' wide 22' long 30 yd dumpster. This is crucial protection for the
driveway to prevent scarring the driveway from the roll off dumpsters steel drum wheels. Neighborhood ordinance/restrictions in force prevent
placement of the dumpster in the street during project duration.
6. Temporary toilet (per month) 1.00 MO 0.00 119.00 0.00 23.80 142.80
7. Delivery charge (Bid Item) 43.00 EA 0.00 60.00 0.00 516.00 3,096.00
Average $60/SQ
Totals: General 15.73 1,538.00 9,228.09
Roof
DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL
CARANICOLAS_FOTIOS_S 1/29/2024 Page: 2
eFiled Lee County Clerk of Courts Page 12
3
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
CONTINUED - Roof
DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL
Florida Building Code Section R908.3 Recovering Versus Replacement
New roof coverings shall not be installed without first removing all existing layers of roof coverings where any of the following conditions
occur:
1. Where the existing roof or roof covering is water soaked or has deteriorated to the point that the existing roof or roof covering is not
adequate as a base for additional roofing.
2. Where the existing roof covering is wood shingle or shake, slate, clay, cement or asbestos-cement tile.
3. Where the existing roof has two or more applications of any type of roof covering.
4. When blisters exist in any roofing, unless blisters are cut or scraped open and remaining materials secured down before applying additional
roofing.
5. Where the existing roof is to be used for attachment for a new roof system and compliance with the securement provisions of Section R905
cannot be met.
8. R&R Flashing - pipe jack - lead 3.00 EA 32.11 99.04 9.08 80.50 483.03
Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for
reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile.
Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be
installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the
Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance
with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code,
Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged
or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through
1525 of the Florida Building Code, Building).
9. Prime & paint roof jack 3.00 EA 0.00 41.71 1.54 25.32 151.99
10. R&R Exhaust cap - through roof - 5.00 EA 41.00 134.42 16.41 178.70 1,072.21
6" to 8"
Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for
reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile.
Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be
installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the
Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance
with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code,
Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged
or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through
1525 of the Florida Building Code, Building).
11. R&R Roof vent - off ridge type - 4' 6.00 EA 71.74 179.31 22.20 305.70 1,834.20
Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for
reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile.
Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be
installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the
Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance
with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code,
Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged
or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through
1525 of the Florida Building Code, Building).
12. Prime & paint roof vent 11.00 EA 0.00 41.71 5.63 92.88 557.32
CARANICOLAS_FOTIOS_S 1/29/2024 Page: 3
eFiled Lee County Clerk of Courts Page 13
4
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
CONTINUED - Roof
DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL
13. R&R Gutter / downspout - 347.00 LF 0.92 12.07 188.56 939.22 5,635.31
aluminum - 6"
14. R&R Gutter splash guard 5.00 EA 4.64 18.02 1.18 22.90 137.38
15. Prime & paint gutter / downspout 347.00 LF 0.00 1.98 6.54 138.72 832.32
16. R&R Drip edge/gutter apron 320.00 LF 1.49 4.02 29.12 358.46 2,150.78
Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for
reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile.
Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be
installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the
Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance
with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code,
Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged
or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through
1525 of the Florida Building Code, Building).
17. Remove Tile roofing - Clay - "S" 43.00 SQ 721.50 0.00 0.00 6,204.90 37,229.40
or flat tile
18. Tile roofing - Clay - "S" or flat tile 49.00 SQ 0.00 939.44 903.11 9,387.14 56,322.81
19. R&R Hip / Ridge / Rake cap - tile 258.00 LF 5.84 15.44 118.23 1,121.68 6,730.15
roofing
20. Hip & ridge nailer board for tile 258.00 LF 0.00 3.92 18.95 206.08 1,236.39
roofing - wood
21. Bird stop - Eave closure strip for 318.00 LF 0.00 6.53 54.36 426.18 2,557.08
tile roofing - clay
22. Re-nailing of roof sheathing - 4,279.00 SF 0.00 0.38 2.78 325.76 1,954.56
complete re-nail
Florida Building Code Section R905.2.1 Sheathing Requirements: Asphalt shingles shall be fastened to solidly sheathed decks.
23. R&R Valley metal - (W) profile - 35.00 LF 2.68 10.15 9.81 91.78 550.64
painted
The valley metal will unavoidably bend and compromise during the tear off. The tear off line item only accounts for removing shingles and felt.
24. Roofing felt - synthetic und. - 43.00 SQ 0.00 110.08 103.75 967.44 5,804.63
double coverage/low slope
Florida Building Code Section R905.1.1.1 Section 5 Underlayment: Two layers of a reinforced synthetic underlayment that has a product
approval as an alternative to underlayment complying with ASTM D226 Type II shall be permitted to be used. Synthetic underlayment shall
have a minimum tear strength of 15 lbf in accordance with ASTM D4533 and a minimum tensile strength of 20 lbf/inch in accordance with
ASTM D5035, and shall meet the liquid water transmission test of Section 8.6 of ASTM D4869. Synthetic underlayment shall be installed as
follows: Apply a strip of synthetic underlayment that is half the width of a full sheet parallel to and starting at the eaves, fastened sufficiently to
hold in place. Starting at the eave, apply full sheets of reinforced synthetic underlayment, overlapping successive sheets half the width of a full
sheet plus the width of the manufacturer's single-ply overlap. End laps shall be 6 inches and shall be offset by 6 feet. Synthetic underlayment
shall be attached to a nailable deck with corrosion-resistant fasteners with a maximum fastener spacing, measured horizontally and vertically, of
12 inches (305 mm) o.c. between side laps, and one row at the end and side laps fastened 6 inches (152 mm) o.c. Synthetic underlayment shall be
attached using annular ring or deformed shank nails with metal or plastic caps with a nominal cap diameter of not less than 1 inch. Metal caps
are required where the ultimate design wind speed, Vult, equals or exceeds 170 mph. Metal caps shall have a thickness of not less than 32-gage
sheet metal. Power-driven metal caps shall have a minimum thickness of 0.010 inch. Minimum thickness of the outside edge of plastic caps shall
be 0.035 inch. The cap nail shank shall be not less than 0.083 inch for ring shank cap nails. Cap nail shank shall have a length sufficient to
penetrate through the roof sheathing or not less than 3/4 inch into the roof sheathing.
25. Water barrier joint taping - Mod. 4,279.00 SF 0.00 0.42 19.47 363.34 2,179.99
bitumen - 4" seam tape
CARANICOLAS_FOTIOS_S 1/29/2024 Page: 4
eFiled Lee County Clerk of Courts Page 14
5
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
CONTINUED - Roof
DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL
26. R&R Flashing, 20" wide 5.00 LF 2.68 6.51 0.75 9.36 56.06
Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for
reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile.
Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be
installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the
Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance
with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code,
Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged
or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through
1525 of the Florida Building Code, Building).
27. Step flashing 40.00 LF 0.00 15.24 5.12 122.94 737.66
Florida Building Code Section R908.6 Flashings: Flashings shall be reconstructed in accordance with approved manufacturer's installation
instructions or in compliance with RAS 111. Metal flashing to which bituminous materials are to be adhered shall be primed prior to
installation.
28. R&R Fascia - metal - 6" 320.00 LF 0.62 5.57 52.21 406.60 2,439.61
29. Prime & paint exterior fascia - 320.00 LF 0.00 2.53 4.16 162.76 976.52
metal, 6"- 8" wide
30. Telehandler/forklift and operator 8.00 HR 0.00 171.56 0.00 274.50 1,646.98
Required to safely lift and place roofing materials onto the roof, ladder jacks and or platforms where workers gather materials and or tools. This
line item is for loading the roof. Equipment and licensed operator to be on-site during the construction of the roof portion of project.
Totals: Roof 1,572.96 22,212.86 133,277.02
Attic
DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL
31. Tear out and bag wet insulation in 4,279.00 SF 2.64 0.00 22.25 2,263.78 13,582.59
confined space - Cat 3
32. Apply plant-based anti-microbial 4,279.00 SF 0.00 0.36 16.69 311.42 1,868.55
agent to the surface area
33. Blown-in insulation - 12" depth - 4,279.00 SF 0.00 1.46 303.17 1,310.10 7,860.61
R30
Totals: Attic 342.11 3,885.30 23,311.75
Exterior
DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL
EXTERIOR
34. Mask the surface area per square 3,200.00 SF 0.00 0.30 14.56 194.92 1,169.48
foot - plastic and tape - 4 mil
Protect exterior ground/HVAC/pool equipment
CARANICOLAS_FOTIOS_S 1/29/2024 Page: 5
eFiled Lee County Clerk of Courts Page 15
6
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
CONTINUED - Exterior
DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL
35. Clean stucco 3,200.00 SF 0.00 0.82 2.08 525.22 3,151.30
Clean and prep stucco areas to be repaired to ensure proper bonding in order to warranty work.
36. Stucco patch / small repair - ready 5.00 EA 0.00 217.38 7.15 218.82 1,312.87
for color
37. Seal stucco - elastomeric sealer 300.00 SF 0.00 1.06 8.19 65.24 391.43
38. Exterior - paint two coats 3,200.00 SF 0.00 1.42 87.36 926.28 5,557.64
SCREENED ENCLOSURE
39. Patio/pool Enclosure - Rescreen - 460.00 SF 0.46 2.03 31.99 235.48 1,412.87
Heavy duty solar screen
40. R&R Screen door - metal - 30" - 1.00 EA 45.45 186.00 7.80 47.86 287.11
36" - full screen (no glass)
SOFFIT
41. R&R Soffit - metal 640.00 SF 0.57 6.78 154.75 971.76 5,830.51
42. Prime & paint exterior soffit - 640.00 SF 0.00 2.49 12.06 321.14 1,926.80
metal
Totals: Exterior 325.94 3,506.72 21,040.01
Labor Minimums Applied
DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL
43. Framing labor minimum 1.00 EA 0.00 240.13 0.00 48.02 288.15
44. Door labor minimum 1.00 EA 0.00 153.40 0.00 30.68 184.08
Totals: Labor Minimums Applied 0.00 78.70 472.23
Line Item Totals: CARANICOLAS_FOTIOS_S 2,256.74 31,221.58 187,329.10
CARANICOLAS_FOTIOS_S 1/29/2024 Page: 6
eFiled Lee County Clerk of Courts Page 16
7
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
Summary for Dwelling
Line Item Total 153,850.78
Material Sales Tax 2,256.74
Subtotal 156,107.52
Overhead 15,610.79
Profit 15,610.79
Replacement Cost Value $187,329.10
Net Claim $187,329.10
Greg Swenson
Owner
CARANICOLAS_FOTIOS_S 1/29/2024 Page: 7
eFiled Lee County Clerk of Courts Page 17
8
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
Recap of Taxes, Overhead and Profit
Overhead (10%) Profit (10%) Material Sales Tax Laundering Tax (2%) Manuf. Home Tax Storage Rental Tax
(6.5%) (6%) (6.5%)
Line Items
15,610.79 15,610.79 2,256.74 0.00 0.00 0.00
Total
15,610.79 15,610.79 2,256.74 0.00 0.00 0.00
CARANICOLAS_FOTIOS_S 1/29/2024 Page: 8
eFiled Lee County Clerk of Courts Page 18
9
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
Recap by Room
Estimate: CARANICOLAS_FOTIOS_S
General 7,674.36 4.99%
Roof 109,491.20 71.17%
Attic 19,084.34 12.40%
Exterior 17,207.35 11.18%
Labor Minimums Applied 393.53 0.26%
Subtotal of Areas 153,850.78 100.00%
Total 153,850.78 100.00%
CARANICOLAS_FOTIOS_S 1/29/2024 Page: 9
eFiled Lee County Clerk of Courts Page 19
10
SF Estimating, LLC
Direct: (786) 457-0338
Email: greg@sfestimating.com
Recap by Category
O&P Items Total %
AWNINGS & PATIO COVERS 933.80 0.50%
CLEANING 3,280.64 1.75%
GENERAL DEMOLITION 47,321.24 25.26%
DOORS 339.40 0.18%
HEAVY EQUIPMENT 1,372.48 0.73%
PERMITS AND FEES 4,080.00 2.18%
FRAMING & ROUGH CARPENTRY 482.05 0.26%
INSULATION 6,247.34 3.33%
LABOR ONLY 1,561.80 0.83%
PAINTING 9,496.20 5.07%
ROOFING 65,589.50
Preview
Filing # 195496212 E-Filed 04/04/2024 02:02:46 PM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR LEE COUNTY, FLORIDA CASE NO.: FOTIOS CARANICOLAS, Plaintiff, v. AMERICAN STRATEGIC INSURANCE CORP., Defendant. ________________________________________/ PLAINTIFF’S NOTICE OF PROPOUNDING FIRST SET OF INTERROGATORIES TO DEFENDANT The Plaintiff, FOTIOS CARANICOLAS, by and through its undersigned counsel, hereby notifies the Court and all interested parties that, on this date, pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, the Plaintiff has served the Defendant, AMERICAN STRATEGIC INSURANCE CORP., with Plaintiff’s First Set of Interrogatories, numbered 1-23, to be answered under oath and in writing, in accordance with and within the time allowed under the Florida Rules of Civil Procedure. (CERTIFICATE OF SERVICE ON FOLLOWING PAGE) PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 -8- eFiled Lee County Clerk of Courts Page 1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was e-filed with the Clerk of Court and served by electronic mail designation pursuant to Fla. R. Jud. Admin 2.516, and/or the Florida Courts E-Filing Portal to , Counsel for Defendant, at ; on April 4, 2024. Respectfully submitted, /s/ Michael Wojnar, Esq. Michael Wojnar, Esq. Bar No.: 1031406 Property Litigation Group, PLLC Attorneys for Plaintiff 2750 SW 145th AVE Suite 509 Miramar, FL 33027 Primary Email: service@plglawyersfl.com Secondary Email: mwojnar@plglawyersfl.com Alternate Email: asardinas@plglawyersfl.com PH: (786) 703-8810 PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 -9- eFiled Lee County Clerk of Courts Page 2 IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR LEE COUNTY, FLORIDA CASE NO.: FOTIOS CARANICOLAS, Plaintiff, v. AMERICAN STRATEGIC INSURANCE CORP., Defendant. ________________________________________/ PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT DEFINITIONS A. The Term "documents" means all writings of any kind, including the originals and all non- identical copies, whether different from the original by reason of any notation made on such copies or otherwise, including (without limitations) correspondence, memoranda, notes, diaries, statistics, letters, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, inter-office and intra-office communications, offers, notations of any sort of conversation, telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, telefax, invoices, worksheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind, including (without limitations) photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind, including (without limitation) tapes, cassettes, computer magnetic or optical disc media and disc recordings. B. The term "relating to" as used herein is defined to mean evidencing, referring to , pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected with the matter discussed. C. As used in this Discovery request, the phrases "describe and explain", and "state" are intended to and shall be interpreted to request a full and fair statement of the fact or matter being described and explained, including a statement of all facts, statements, events and circumstances necessary to understand and evaluate the fact or matter being described and explained. D. Each of the following discovery requests seeking an identification of documents is intended to be interpreted to request and require: 1. The date of the document; PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 1 eFiled Lee County Clerk of Courts Page 3 2. The originator of the document; 3. The type of document; 4. The addressee of the document, if any; 5. Identification of persons to whom copies of the documents were furnished; 6. Details as to the custody of the document on the date the Interrogatories are answered; 7. Specific page numbers where the information requested may be found, if appropriate; or, alternatively, documents may be identified by numbering each such document and referring to the number in the answer and providing a true copy of each such numbered document with the Answers to Interrogatories. E. Each of the following Discovery Requests or Interrogatories requesting the identification of persons is intended to be interpreted to request and require for each witness known to the Defendant: 1. The name of the individual; 2. The last known address and phone number of the individual; 3. The place of employment of the individual and the person's last known address; 4. The substance of the witnesses' knowledge or information relating to the information requested. "Policy": means that certain insurance policy as described in the complaint "Defendant" or “You”: means Defendant, its attorneys, agents, partners, employees, officers, directors, stockholders, and all other persons acting on its behalf. "Person": means all individuals, corporations, partnerships, joint venture groups, associations, governmental agencies and all other organizations. "Document": means all written, typed, photographic, computerized or printed materials, including but not limited to the original and all non- identical copies of all letters, books, records, charts, ledgers, drafts, checks, check stubs, passbooks, certificates, graphs, facsimile transmissions, telegrams, reports, contracts, invoices, receipts, brochures, pamphlets, studies, lists, notes, memoranda, computer printouts, data processing cards, pictures, drawings, diagrams, sketches, video tapes, motion pictures, blue-prints, photographs, microfilm, microfiche, computer discs and all other materials or documentation which pertains or contains information directly or indirectly, in whole or in part, and in any manner, to any of the subjects inquired about. PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 2 eFiled Lee County Clerk of Courts Page 4 INSTRUCTIONS Before answering the following Discovery requests and/or Interrogatories, will you please make such inquiries of your agents, servants, employees and/or attorneys as will enable you to make full and true answers to the following, in accordance with the applicable Florida Rules of Civil Procedure. Additionally, if more space is required, please use a separate sheet of paper and attach same behind the sheet where the respective question appears. 1. Please identify yourself fully by stating your full name, employment address and position and job title that you hold with the Defendant. 2. Please identify the person whom defendant is designating as the person who shall testify about all matters related to the claims in this case known or reasonably available to the defendant pursuant to Fla. R. Civ. P. 1.310(b)(6). 3. Please explain with particularity each and every reason for the denial of each Request for Admission which has been denied and for each such denial, state all facts which support said denial, identifying all witnesses who have knowledge of such facts and the extent of such knowledge. 4. Describe in as much detail as possible, each and every factual reason why the Defendant denied or seeks to deny coverage for Plaintiff(s) claim described in the Complaint, including the factual basis for each affirmative defense raised by you. 5. If Defendant has tendered payment to Plaintiff in any amount whatsoever, describe in as much detail as possible, each and every factual reason why the Defendant failed to tender payment in accordance with the estimate (attached hereto as “Exhibit A”). 6. Identify each representative of the defendant who visited Plaintiff's property that is the subject of this claim in the last 20 months, and for each such visit, give the date of the visit, identity of the defendant's representative at the visit, and identify with particularity all documents generated by such visit so that the same can be identified in a request for production. If a privilege is claimed as to any document identified, prepare a privilege log as required by the rules. 7. State the location, including page(s), line(s) and paragraph number(s), and the exact language contained in the Policy upon which the Defendant has based its coverage decision for the claim described in the complaint, and the factual basis supporting the application of the policy language referred to. PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 3 eFiled Lee County Clerk of Courts Page 5 8. Identify each document sent from Defendant to Plaintiff(s) in reference to the subject loss involved herein, including the date sent, the name of the individual who sent said communication. 9. Identify each person, who on behalf of Defendant, inspected the property described in the complaint in reference to the claim described in the Complaint, including his or her field of expertise and the date of each inspection. 10. Identify each written estimate of repair or replacement, including the amount set forth in each said estimate by Defendant in reference to the claim described in the Complaint, and for each such estimate state: a. If it was provided to Plaintiff/Insured b. If provided to Plaintiff/Insured, when it was so provided c. Identify the person or persons who prepared the estimate or estimates and the nature of that person’s participation in the preparation of said estimate. d. The factual basis for the conclusions contained or implied in said estimate or estimate. 11. Identify all persons (other than Plaintiff or his agents) believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues raised by the pleadings, specifying the subject matter about which the witnesses have knowledge and state whether you have obtained any statements (oral, written and/or recorded) from any of said witnesses, list the dates any such witness statements were taken, by whom any such witness statements were taken and who has present possession, custody and control of any such statements. 12. Did the Defendant request Plaintiff(s) to perform any post loss duties for the subject claim, including but not limited to, submitting to an examination under oath, submitting a sworn proof of loss, permitting inspection, etc., and if so, identify each writing or request made by defendant evidencing such request. PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 4 eFiled Lee County Clerk of Courts Page 6 13. If your answer to the preceding interrogatory was "YES", please state for each request: a. the exact request made and the identity of the person on behalf of the defendant who made said request. b. the date of the request c. whether the request was written or oral d. What did Plaintiff do in response to said request 14. Please describe all requests made by the Insurance Company upon the Insured (i.e., requests for examination under oath, information, documents, sworn proofs of loss, etc.,) in reference to this claim and the dates made. 15. With reference to each of your affirmative defenses raised in this lawsuit, please describe each and every fact upon which you rely to substantiate such affirmative defense, including identification of all witnesses to each such fact, making sure that the description you give correlates to the numbered or lettered affirmative defense raised by you. 16. Please identify and state the qualifications of the adjuster(s), engineer(s) and any other individuals used by Defendant in investigating the stated claim involved in this litigation. 17. Please identify each person you intend to call as a factual witness in this case and provide a brief description of that person’s expected testimony (e.g. why is that person being called as a witness). 18. Please identify each person you intend to call as an expert witness in this case and provide a brief description of that person’s expected testimony (e.g. why is that person being called as a witness). 19. Please identify each document you intend to use at trial and describe its purpose. 20. Identify all persons who participated in answering these interrogatories, and the nature of their participation. PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 5 eFiled Lee County Clerk of Courts Page 7 21. Please explain with particularity, identifying each and every witness and document, all facts which support your denial of each of Plaintiff's requests for admissions. 22. Did Defendant conduct an inspection of the property at issue prior to issuing an insurance policy to either the Plaintiff or any other prior homeowner of the property at issue? If so, was a report created? 23. Did Defendant ever provide an inspection report of the property to either the Plaintiff or any other prior homeowner of the property at issue? PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 6 eFiled Lee County Clerk of Courts Page 8 IN WITNESS WHEREOF, the Insurance Company has executed the foregoing answers to interrogatories and states that same are true and correct to the best of the undersigned’s knowledge and belief. __________________________________ Name of the Insurance Company ___________________________________ Name of Authorized Representative: STATE OF FLORIDA ) COUNTY OF ____________ ) SS: BEFORE ME, the undersigned authority, duly authorized to administer oaths and take acknowledgments, personally appeared _________________, who, being first duly sworn, deposes and says that he or she is the authorized representative of the defendant, and that he or she is the affiant who answered the foregoing interrogatories and that the answers set forth in the foregoing answers to interrogatories are true and correct. SWORN TO and subscribed to before me on ________________________________. _________________________________ Notary Public, State of Florida at Large PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 7 eFiled Lee County Clerk of Courts Page 9 EXHIBIT A PROPERTY LITIGATION GROUP, PLLC 2750 SW 145TH Ave., Ste. 509│ Miramar, Florida 33027 │ Phone: (786) 703-8810 8 eFiled Lee County Clerk of Courts Page 10 1 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com Insured: Fotios Caranicolas Home: (813) 464-5989 Property: 19501 Estero Pointe Lane E-mail: fcaranic@gmail.com Fort Myers, FL 33908 Estimator: Greg Swenson Business: (786) 457-0338 Position: Owner E-mail: greg@sfestimating.com Company: SF Estimating, LLC Claim Number: 1305873 Policy Number: FLA395972 Type of Loss: Wind Damage Date of Loss: 9/28/2022 12:00 AM Date Received: Date Inspected: Date Entered: 1/10/2024 11:26 PM Price List: FLFM8X_JAN24 Restoration/Service/Remodel Estimate: CARANICOLAS_FOTIOS_S eFiled Lee County Clerk of Courts Page 11 2 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com CARANICOLAS_FOTIOS_S General DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL 1. Permits & Fees (Agreed Price) 1.00 EA 0.00 1,500.00 0.00 300.00 1,800.00 To cover the costs of permits, permit expeditors, labor to be on site for multiple inspections by the building department, etc. 2. Residential Supervision / Project 20.00 HR 0.00 78.09 0.00 312.36 1,874.16 Management - per hour This accounts for time needed to review material with homeowner, verify/select material options, complete permit application, coordinate with home owners association when applicable, coordinate with neighbors, obtain/post copy of approved permit, schedule dumpster delivery, coordinate tear off crew, verify weather to avoid additional damages, update homeowner, update insurance carrier, schedule sheathing inspection, setup ladder with inspection card, upload forward approved inspection cards, review on site required supplements, document production photos, schedule final inspection with city, and more... 3. General clean - up 12.00 HR 0.00 54.72 0.01 131.32 787.97 Three guys for half day to roll property with magnets for nails, clean roof perimeter, and surrounding area to ensure customer satisfaction. 4. Dumpster load - Approx. 30 yards, 5- 1.00 EA 1,015.00 0.00 0.00 203.00 1,218.00 7 tons of debris 5. Material Only Sheathing - plywood - 192.00 SF 0.00 1.26 15.72 51.52 309.16 5/8" CDX 6 sheets of plywood measuring 24' long and 8 ' wide to accommodate a 7' wide 22' long 30 yd dumpster. This is crucial protection for the driveway to prevent scarring the driveway from the roll off dumpsters steel drum wheels. Neighborhood ordinance/restrictions in force prevent placement of the dumpster in the street during project duration. 6. Temporary toilet (per month) 1.00 MO 0.00 119.00 0.00 23.80 142.80 7. Delivery charge (Bid Item) 43.00 EA 0.00 60.00 0.00 516.00 3,096.00 Average $60/SQ Totals: General 15.73 1,538.00 9,228.09 Roof DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL CARANICOLAS_FOTIOS_S 1/29/2024 Page: 2 eFiled Lee County Clerk of Courts Page 12 3 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com CONTINUED - Roof DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL Florida Building Code Section R908.3 Recovering Versus Replacement New roof coverings shall not be installed without first removing all existing layers of roof coverings where any of the following conditions occur: 1. Where the existing roof or roof covering is water soaked or has deteriorated to the point that the existing roof or roof covering is not adequate as a base for additional roofing. 2. Where the existing roof covering is wood shingle or shake, slate, clay, cement or asbestos-cement tile. 3. Where the existing roof has two or more applications of any type of roof covering. 4. When blisters exist in any roofing, unless blisters are cut or scraped open and remaining materials secured down before applying additional roofing. 5. Where the existing roof is to be used for attachment for a new roof system and compliance with the securement provisions of Section R905 cannot be met. 8. R&R Flashing - pipe jack - lead 3.00 EA 32.11 99.04 9.08 80.50 483.03 Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile. Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code, Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through 1525 of the Florida Building Code, Building). 9. Prime & paint roof jack 3.00 EA 0.00 41.71 1.54 25.32 151.99 10. R&R Exhaust cap - through roof - 5.00 EA 41.00 134.42 16.41 178.70 1,072.21 6" to 8" Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile. Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code, Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through 1525 of the Florida Building Code, Building). 11. R&R Roof vent - off ridge type - 4' 6.00 EA 71.74 179.31 22.20 305.70 1,834.20 Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile. Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code, Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through 1525 of the Florida Building Code, Building). 12. Prime & paint roof vent 11.00 EA 0.00 41.71 5.63 92.88 557.32 CARANICOLAS_FOTIOS_S 1/29/2024 Page: 3 eFiled Lee County Clerk of Courts Page 13 4 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com CONTINUED - Roof DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL 13. R&R Gutter / downspout - 347.00 LF 0.92 12.07 188.56 939.22 5,635.31 aluminum - 6" 14. R&R Gutter splash guard 5.00 EA 4.64 18.02 1.18 22.90 137.38 15. Prime & paint gutter / downspout 347.00 LF 0.00 1.98 6.54 138.72 832.32 16. R&R Drip edge/gutter apron 320.00 LF 1.49 4.02 29.12 358.46 2,150.78 Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile. Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code, Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through 1525 of the Florida Building Code, Building). 17. Remove Tile roofing - Clay - "S" 43.00 SQ 721.50 0.00 0.00 6,204.90 37,229.40 or flat tile 18. Tile roofing - Clay - "S" or flat tile 49.00 SQ 0.00 939.44 903.11 9,387.14 56,322.81 19. R&R Hip / Ridge / Rake cap - tile 258.00 LF 5.84 15.44 118.23 1,121.68 6,730.15 roofing 20. Hip & ridge nailer board for tile 258.00 LF 0.00 3.92 18.95 206.08 1,236.39 roofing - wood 21. Bird stop - Eave closure strip for 318.00 LF 0.00 6.53 54.36 426.18 2,557.08 tile roofing - clay 22. Re-nailing of roof sheathing - 4,279.00 SF 0.00 0.38 2.78 325.76 1,954.56 complete re-nail Florida Building Code Section R905.2.1 Sheathing Requirements: Asphalt shingles shall be fastened to solidly sheathed decks. 23. R&R Valley metal - (W) profile - 35.00 LF 2.68 10.15 9.81 91.78 550.64 painted The valley metal will unavoidably bend and compromise during the tear off. The tear off line item only accounts for removing shingles and felt. 24. Roofing felt - synthetic und. - 43.00 SQ 0.00 110.08 103.75 967.44 5,804.63 double coverage/low slope Florida Building Code Section R905.1.1.1 Section 5 Underlayment: Two layers of a reinforced synthetic underlayment that has a product approval as an alternative to underlayment complying with ASTM D226 Type II shall be permitted to be used. Synthetic underlayment shall have a minimum tear strength of 15 lbf in accordance with ASTM D4533 and a minimum tensile strength of 20 lbf/inch in accordance with ASTM D5035, and shall meet the liquid water transmission test of Section 8.6 of ASTM D4869. Synthetic underlayment shall be installed as follows: Apply a strip of synthetic underlayment that is half the width of a full sheet parallel to and starting at the eaves, fastened sufficiently to hold in place. Starting at the eave, apply full sheets of reinforced synthetic underlayment, overlapping successive sheets half the width of a full sheet plus the width of the manufacturer's single-ply overlap. End laps shall be 6 inches and shall be offset by 6 feet. Synthetic underlayment shall be attached to a nailable deck with corrosion-resistant fasteners with a maximum fastener spacing, measured horizontally and vertically, of 12 inches (305 mm) o.c. between side laps, and one row at the end and side laps fastened 6 inches (152 mm) o.c. Synthetic underlayment shall be attached using annular ring or deformed shank nails with metal or plastic caps with a nominal cap diameter of not less than 1 inch. Metal caps are required where the ultimate design wind speed, Vult, equals or exceeds 170 mph. Metal caps shall have a thickness of not less than 32-gage sheet metal. Power-driven metal caps shall have a minimum thickness of 0.010 inch. Minimum thickness of the outside edge of plastic caps shall be 0.035 inch. The cap nail shank shall be not less than 0.083 inch for ring shank cap nails. Cap nail shank shall have a length sufficient to penetrate through the roof sheathing or not less than 3/4 inch into the roof sheathing. 25. Water barrier joint taping - Mod. 4,279.00 SF 0.00 0.42 19.47 363.34 2,179.99 bitumen - 4" seam tape CARANICOLAS_FOTIOS_S 1/29/2024 Page: 4 eFiled Lee County Clerk of Courts Page 14 5 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com CONTINUED - Roof DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL 26. R&R Flashing, 20" wide 5.00 LF 2.68 6.51 0.75 9.36 56.06 Florida Building Code Section R908.5 Reinstallation/Reuse of Materials: Existing or salvaged slate, clay or concrete tile shall be permitted for reinstallation or reuse, to repair an existing slate or tile roof, except that salvaged slate or tile shall be of like kind in both material and profile. Damaged, cracked or broken slate or tile shall not be reinstalled. The building official may permit salvaged slate, clay and concrete tile to be installed on additions and new construction, when the tile is tested in compliance with the provisions of Section R905 or Section 1523 of the Florida Building Code, Building (HVHZ shall comply with Section 1523 of the Florida Building Code, Building) and installed in accordance with Section R905 or Section 1518 of the Florida Building Code, Building (HVHZ shall comply with Section 1518 of the Florida Building Code, Building). Existing vent flashing, metal edgings, drain outlets, collars and metal counterflashings shall not be reinstalled where rusted, damaged or deteriorated. Aggregate surfacing materials shall not be reinstalled (High-Velocity Hurricane Zones shall comply with Sections 1512 through 1525 of the Florida Building Code, Building). 27. Step flashing 40.00 LF 0.00 15.24 5.12 122.94 737.66 Florida Building Code Section R908.6 Flashings: Flashings shall be reconstructed in accordance with approved manufacturer's installation instructions or in compliance with RAS 111. Metal flashing to which bituminous materials are to be adhered shall be primed prior to installation. 28. R&R Fascia - metal - 6" 320.00 LF 0.62 5.57 52.21 406.60 2,439.61 29. Prime & paint exterior fascia - 320.00 LF 0.00 2.53 4.16 162.76 976.52 metal, 6"- 8" wide 30. Telehandler/forklift and operator 8.00 HR 0.00 171.56 0.00 274.50 1,646.98 Required to safely lift and place roofing materials onto the roof, ladder jacks and or platforms where workers gather materials and or tools. This line item is for loading the roof. Equipment and licensed operator to be on-site during the construction of the roof portion of project. Totals: Roof 1,572.96 22,212.86 133,277.02 Attic DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL 31. Tear out and bag wet insulation in 4,279.00 SF 2.64 0.00 22.25 2,263.78 13,582.59 confined space - Cat 3 32. Apply plant-based anti-microbial 4,279.00 SF 0.00 0.36 16.69 311.42 1,868.55 agent to the surface area 33. Blown-in insulation - 12" depth - 4,279.00 SF 0.00 1.46 303.17 1,310.10 7,860.61 R30 Totals: Attic 342.11 3,885.30 23,311.75 Exterior DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL EXTERIOR 34. Mask the surface area per square 3,200.00 SF 0.00 0.30 14.56 194.92 1,169.48 foot - plastic and tape - 4 mil Protect exterior ground/HVAC/pool equipment CARANICOLAS_FOTIOS_S 1/29/2024 Page: 5 eFiled Lee County Clerk of Courts Page 15 6 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com CONTINUED - Exterior DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL 35. Clean stucco 3,200.00 SF 0.00 0.82 2.08 525.22 3,151.30 Clean and prep stucco areas to be repaired to ensure proper bonding in order to warranty work. 36. Stucco patch / small repair - ready 5.00 EA 0.00 217.38 7.15 218.82 1,312.87 for color 37. Seal stucco - elastomeric sealer 300.00 SF 0.00 1.06 8.19 65.24 391.43 38. Exterior - paint two coats 3,200.00 SF 0.00 1.42 87.36 926.28 5,557.64 SCREENED ENCLOSURE 39. Patio/pool Enclosure - Rescreen - 460.00 SF 0.46 2.03 31.99 235.48 1,412.87 Heavy duty solar screen 40. R&R Screen door - metal - 30" - 1.00 EA 45.45 186.00 7.80 47.86 287.11 36" - full screen (no glass) SOFFIT 41. R&R Soffit - metal 640.00 SF 0.57 6.78 154.75 971.76 5,830.51 42. Prime & paint exterior soffit - 640.00 SF 0.00 2.49 12.06 321.14 1,926.80 metal Totals: Exterior 325.94 3,506.72 21,040.01 Labor Minimums Applied DESCRIPTION QTY REMOVE REPLACE TAX O&P TOTAL 43. Framing labor minimum 1.00 EA 0.00 240.13 0.00 48.02 288.15 44. Door labor minimum 1.00 EA 0.00 153.40 0.00 30.68 184.08 Totals: Labor Minimums Applied 0.00 78.70 472.23 Line Item Totals: CARANICOLAS_FOTIOS_S 2,256.74 31,221.58 187,329.10 CARANICOLAS_FOTIOS_S 1/29/2024 Page: 6 eFiled Lee County Clerk of Courts Page 16 7 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com Summary for Dwelling Line Item Total 153,850.78 Material Sales Tax 2,256.74 Subtotal 156,107.52 Overhead 15,610.79 Profit 15,610.79 Replacement Cost Value $187,329.10 Net Claim $187,329.10 Greg Swenson Owner CARANICOLAS_FOTIOS_S 1/29/2024 Page: 7 eFiled Lee County Clerk of Courts Page 17 8 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com Recap of Taxes, Overhead and Profit Overhead (10%) Profit (10%) Material Sales Tax Laundering Tax (2%) Manuf. Home Tax Storage Rental Tax (6.5%) (6%) (6.5%) Line Items 15,610.79 15,610.79 2,256.74 0.00 0.00 0.00 Total 15,610.79 15,610.79 2,256.74 0.00 0.00 0.00 CARANICOLAS_FOTIOS_S 1/29/2024 Page: 8 eFiled Lee County Clerk of Courts Page 18 9 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com Recap by Room Estimate: CARANICOLAS_FOTIOS_S General 7,674.36 4.99% Roof 109,491.20 71.17% Attic 19,084.34 12.40% Exterior 17,207.35 11.18% Labor Minimums Applied 393.53 0.26% Subtotal of Areas 153,850.78 100.00% Total 153,850.78 100.00% CARANICOLAS_FOTIOS_S 1/29/2024 Page: 9 eFiled Lee County Clerk of Courts Page 19 10 SF Estimating, LLC Direct: (786) 457-0338 Email: greg@sfestimating.com Recap by Category O&P Items Total % AWNINGS & PATIO COVERS 933.80 0.50% CLEANING 3,280.64 1.75% GENERAL DEMOLITION 47,321.24 25.26% DOORS 339.40 0.18% HEAVY EQUIPMENT 1,372.48 0.73% PERMITS AND FEES 4,080.00 2.18% FRAMING & ROUGH CARPENTRY 482.05 0.26% INSULATION 6,247.34 3.33% LABOR ONLY 1,561.80 0.83% PAINTING 9,496.20 5.07% ROOFING 65,589.50