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Filing # 192029512 E-Filed 02/15/2024 11:51:46 AM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
JD RESTORATION, INC.
(A/A/O SANTOS BAZAN),
CASE NO: 24-CC-005304
Plaintiff,
v.
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
_____________________________________/
PLAINTIFF’S AMENDED REQUEST FOR PRODUCTION TO
DEFENDANT
The Plaintiff, JD RESTORATION, INC. (A/A/O SANTOS BAZAN), pursuant to Rule 1.350,
Florida Rules of Civil Procedure, propound this Request for Production to Defendant, CITIZENS
PROPERTY INSURANCE CORPORATION, to produce the items and materials hereinafter set
forth on or before the applicable time prescribed by said rule for inspection and/or copying at the
office of the undersigned attorney, the following items and/or documents:
1. A true and correct certified copy of the insurance policy issued described in the
complaint, including all declaration sheet(s), addendums and attachments.
2. All photographs taken by Defendant’s adjuster during the initial inspection of the
claimed loss.
3. Copies of all photographs taken during Defendant’s investigation conducted during
the normal business of evaluating the claim.
4. All estimates of damage prepared by or on behalf of Defendant after its initial
inspection of the claimed loss.
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5. Copies of all damage estimates prepared during Defendant’s investigation
conducted during the normal business of evaluating the claim.
6. All letters, faxes, email communications, and log notes from Defendant’s adjusters
or agents which in any manner references any and all damages or causes of loss observed that were
prepared or generated during Defendant’s investigation conducted during the normal business of
evaluating the claim.
7. Defendant’s entire claim file from the date of the initial notice of the loss until the
day before Defendant knew that Defendant was going to deny any further payment or litigate the
claim.
8. Defendant’s entire claim file for the entire time that the claim was being handled
by Defendant not in anticipation of litigation of the loss.
9. Any and all correspondence or written communications from Defendant, or its
agents to Plaintiff, or his agents, which in any manner pertain to Plaintiff’s alleged loss as described
in the Compliant.
10. Any and all correspondence or written communications from Defendant, or its
agents to insured, or his agents, which in any manner pertain to Plaintiff’s alleged loss as described
in the Compliant.
11. Any and all correspondence or written communications from Plaintiff, or his agents
to Defendant, or its agents, which in any manner pertain to Plaintiff’s alleged loss as described in
the Complaint.
12. Any and all correspondence or written communications from insured, or his agents
to Defendant, or its agents, which in any manner pertain to Plaintiff’s alleged loss as described in
the Complaint.
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13. Any and all photographs taken by the Defendant or Defendant’s agents showing
the extent of damage to the insured premises involved herein as were taken prior to the filing of
this lawsuit.
14. Any and all tape recordings of any statements made by Plaintiff or Plaintiff’s agents
or employees.
15. Any and all tape recordings of any statements made by insured or insured’s agents
or employees.
16. Any and all transcripts or written statements from the Plaintiff(s) including, without
limitation, transcripts of EUO.
17. Any and all transcripts or written statements from the Insured(s) including, without
limitation, transcripts of EUO.
18. Copies of each and every bill or estimate for repair to the subject property submitted
to Defendant by Plaintiff or Plaintiff’s agents or employees.
19. Copies of each and every bill or estimate for repair to the subject property submitted
to Defendant by Insured or Insured’s agents or employees.
20. Any and all written estimates or reports reflecting examination or inspection by
Defendant or Defendant’s agents of any of the alleged damage to the insured premises.
21. All documents relating to or supporting Defendant’s denial of any allegation of
Plaintiff’s Complaint.
22. All documents relating to or supporting each of Defendant’s affirmative or general
defenses asserted by Defendant.
23. All underwriting files pertaining to the policy of insurance described in the
Complaint/Petition.
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24. Any and all documents related to any and all other insurance claims made by
Plaintiff(s) which are not the subject of this action, including estimates, reports, pictures, cancelled
checks, releases, proofs of loss, recorded statements, transcripts of EUO, and correspondence by
and between the parties related to any and all said other claims.
25. Any and all documents related to any and all other insurance claims made by
Insured(s) which are not the subject of this action, including estimates, reports, pictures, cancelled
checks, releases, proofs of loss, recorded statements, transcripts of EUO, and correspondence by
and between the parties related to any and all said other claims.
26. Any and all brochures, summary statements, pamphlets and advertising materials
prepared by or on behalf of Defendant and disseminated to insurance agencies or policyholders
which in any manner describe the coverages and/or exclusions under the same type of policy
involved in this action.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon
the Defendant in this action along with the Complaint.
By: /s/ Kevin Weisser
KEVIN WEISSER
Florida Bar No: 98828
WEISSER ELAZAR & KANTOR, PLLC
Attorneys for Plaintiff
800 East Broward Boulevard, Suite 510
Fort Lauderdale, FL 33301
T: (954) 486-2623
F: (954) 572-8695
Email: KW@WEKLaw.com
JK@WEKLaw.com
Service@WEKLaw.com
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Filing # 192029512 E-Filed 02/15/2024 11:51:46 AM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA JD RESTORATION, INC. (A/A/O SANTOS BAZAN), CASE NO: 24-CC-005304 Plaintiff, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. _____________________________________/ PLAINTIFF’S AMENDED REQUEST FOR PRODUCTION TO DEFENDANT The Plaintiff, JD RESTORATION, INC. (A/A/O SANTOS BAZAN), pursuant to Rule 1.350, Florida Rules of Civil Procedure, propound this Request for Production to Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, to produce the items and materials hereinafter set forth on or before the applicable time prescribed by said rule for inspection and/or copying at the office of the undersigned attorney, the following items and/or documents: 1. A true and correct certified copy of the insurance policy issued described in the complaint, including all declaration sheet(s), addendums and attachments. 2. All photographs taken by Defendant’s adjuster during the initial inspection of the claimed loss. 3. Copies of all photographs taken during Defendant’s investigation conducted during the normal business of evaluating the claim. 4. All estimates of damage prepared by or on behalf of Defendant after its initial inspection of the claimed loss. Page 33 of 36 2/15/2024 11:51 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 5. Copies of all damage estimates prepared during Defendant’s investigation conducted during the normal business of evaluating the claim. 6. All letters, faxes, email communications, and log notes from Defendant’s adjusters or agents which in any manner references any and all damages or causes of loss observed that were prepared or generated during Defendant’s investigation conducted during the normal business of evaluating the claim. 7. Defendant’s entire claim file from the date of the initial notice of the loss until the day before Defendant knew that Defendant was going to deny any further payment or litigate the claim. 8. Defendant’s entire claim file for the entire time that the claim was being handled by Defendant not in anticipation of litigation of the loss. 9. Any and all correspondence or written communications from Defendant, or its agents to Plaintiff, or his agents, which in any manner pertain to Plaintiff’s alleged loss as described in the Compliant. 10. Any and all correspondence or written communications from Defendant, or its agents to insured, or his agents, which in any manner pertain to Plaintiff’s alleged loss as described in the Compliant. 11. Any and all correspondence or written communications from Plaintiff, or his agents to Defendant, or its agents, which in any manner pertain to Plaintiff’s alleged loss as described in the Complaint. 12. Any and all correspondence or written communications from insured, or his agents to Defendant, or its agents, which in any manner pertain to Plaintiff’s alleged loss as described in the Complaint. Page 34 of 36 2/15/2024 11:51 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 13. Any and all photographs taken by the Defendant or Defendant’s agents showing the extent of damage to the insured premises involved herein as were taken prior to the filing of this lawsuit. 14. Any and all tape recordings of any statements made by Plaintiff or Plaintiff’s agents or employees. 15. Any and all tape recordings of any statements made by insured or insured’s agents or employees. 16. Any and all transcripts or written statements from the Plaintiff(s) including, without limitation, transcripts of EUO. 17. Any and all transcripts or written statements from the Insured(s) including, without limitation, transcripts of EUO. 18. Copies of each and every bill or estimate for repair to the subject property submitted to Defendant by Plaintiff or Plaintiff’s agents or employees. 19. Copies of each and every bill or estimate for repair to the subject property submitted to Defendant by Insured or Insured’s agents or employees. 20. Any and all written estimates or reports reflecting examination or inspection by Defendant or Defendant’s agents of any of the alleged damage to the insured premises. 21. All documents relating to or supporting Defendant’s denial of any allegation of Plaintiff’s Complaint. 22. All documents relating to or supporting each of Defendant’s affirmative or general defenses asserted by Defendant. 23. All underwriting files pertaining to the policy of insurance described in the Complaint/Petition. Page 35 of 36 2/15/2024 11:51 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 24. Any and all documents related to any and all other insurance claims made by Plaintiff(s) which are not the subject of this action, including estimates, reports, pictures, cancelled checks, releases, proofs of loss, recorded statements, transcripts of EUO, and correspondence by and between the parties related to any and all said other claims. 25. Any and all documents related to any and all other insurance claims made by Insured(s) which are not the subject of this action, including estimates, reports, pictures, cancelled checks, releases, proofs of loss, recorded statements, transcripts of EUO, and correspondence by and between the parties related to any and all said other claims. 26. Any and all brochures, summary statements, pamphlets and advertising materials prepared by or on behalf of Defendant and disseminated to insurance agencies or policyholders which in any manner describe the coverages and/or exclusions under the same type of policy involved in this action. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the Defendant in this action along with the Complaint. By: /s/ Kevin Weisser KEVIN WEISSER Florida Bar No: 98828 WEISSER ELAZAR & KANTOR, PLLC Attorneys for Plaintiff 800 East Broward Boulevard, Suite 510 Fort Lauderdale, FL 33301 T: (954) 486-2623 F: (954) 572-8695 Email: KW@WEKLaw.com JK@WEKLaw.com Service@WEKLaw.com Page 36 of 36 2/15/2024 11:51 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4