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Case Number: CACE-19-022618 Division: 02
Filing # 98212367 E-Filed 10/31/2019 05:38:02 PM
IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.:
LATOYA APPLETON
AND LADARIUS KINSEY,
Plaintiffs,
vs.
UNIVERSAL PROPERTY &
CASUALTY INSURANCE COMPANY,
Defendant.
/
PLANTIFFS’ FIRST REQUEST FOR PRODUCTION TO DEFENDANT
Plaintiffs, LATOYA APPLETON AND LADARIUS KINSEY, by and through
their undersigned attorney, and pursuant to Rule 1.350, Fla. R. Civ. P., request Defendant,
UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, to furnish copies
of the following documents to the offices of the undersigned attorney within forty-five (45)
days from the date of service of this request.
DEFINITIONS AND INSTRUCTIONS
1. The term “Plaintiffs” or “Insured” means named insured, Latoya Appleton
and Ladarius Kinsey, and his agents, employees, independent contractors, attorneys, and
all other persons acting or purporting to act on his behalf.
2. The term “You” or “Defendant” means Universal Property & Casualty
Insurance Company, and its agents, employees, independent contractors, subsidiaries,
divisions, parent company, holding company, directors, officers, attorneys, and all other
persons acting or purporting to act on its behalf.
3. The term “Policy” means the policy, number 1501-1604-2155, which
Defendant issued to Insured for the property located at 3057 SW 2nd Court, Fort
Lauderdale, Florida 33312 that was in effect on the date of loss alleged in Plaintiffs’
Complaint filed in this action.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2019 05:38:02 PM.****4. The term “Insured Building” or “Insured Property” means the insured.
structure and/or its contents located at the address described in Plaintiffs’ Complaint filed
in this action.
5. The term “Loss” means the event at issue in which the Named Insured
suffered property damage, on the date of loss alleged in Plaintiffs’ Complaint.
6. The term “Claim” means the Plaintiffs’ request, made pursuant to Plaintiffs’
insurance Policy, that Defendant pay Plaintiffs the amount of damages that Plaintiffs
sustained as a result of the Loss.
7. The term “person” means any natural person, individual, proprietorship,
partnership, corporation, association, organization, joint venture, firm, other business
enterprise, governmental body, group of natural persons or other entity.
8. The term “document” or “documents” means any written, typed, or graphic
matter or other means of preserving thought or expression and all tangible things from
which information can be processed or transcribed, including the originals and all non-
identical copies, whether different from the original by reason of any notation made on
such copy or otherwise, including, but not limited to, correspondence, emails, memoranda,
notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other
communications, interoffice and intraoffice telephone calls, diaries, claim diaries,
electronic claim notes, chronological data, minutes, books, reports, studies, summaries,
pamphlets, printed matter, charts, ledgers, invoices, worksheets, receipts, returns, computer
printouts, prospectuses, financial statements, schedules, affidavits, contracts, canceled
checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases
(and all drafts, alterations and modifications, changes and amendments of any of the
foregoing), graphic or natural records or representations of any kind (including without
limitation photographs, photographic negative, microfiche, microfilm, videotape,
recordings, motion pictures, phonograph recordings, transcripts or log of such recording,
projection), electronic, computer, mechanical, or electric records or representations of any
kind (including without limitation tapes, cassettes, discs and records), and binders, cover
notes, certificates, analysis, study memoranda, note lists, diaries, logs, questionnaires, bills,
purchase orders, shipping orders, memorandum of contract, agreements, licenses, permits,
orders, financial data, acknowledgements, computer or data procession cards, computer or
data processing discs, and all other data compilations from which information can be
obtained or translated, reports and/or summaries of investigations, drafts and revisions of
drafts of any documents and original preliminary notes or sketches, no matter how
produced or maintained, in your actual or constructive possession, custody or control,
ILG File #: 13135
Claim #: FL18-0128887
Case #f:whether prepared, published or released by you or by any other person. If data is stored on
computer or electronic media (inter-company email, for example), produce hard copies of
each such document.” “Documents” includes all attachments and enclosures.
9. The term “all documents” means every document or group of documents,
as above defined, that are known to you or that can be located or discovered by reasonably
diligent efforts.
10. The term “coverage letter(s)” means the correspondence from You to the
Named Insured throughout the claim at issue regarding Your position as to coverage for
the Loss.
11. As used herein, the singular shall include the plural, the plural shall include
the singular, and masculine feminine and neuter shall include each of the other genders.
12. The terms “relating to” or “in any way related to” means in whole or in part
constituting, containing, concerning, discussing, commending upon, describing, analyzing,
identifying, stating, pertaining to, referring to, or forming the basis of.
13. The term “Prior Claim” means all claims submitted by or on behalf of an
Insured for damage occurring prior to the date of loss alleged in Plaintiffs’ Complaint,
regarding the Insured Building or Insured Property.
14. The term “Subsequent Claim” means all claims submitted by or on behalf
of an Insured for damage occurring after the date of loss alleged in Plaintiffs’ Complaint,
regarding the Insured Building or Insured Property.
15. The term “Plaintiffs’ Complaint means the complaint filed by Plaintiffs in
this action.
16. This request shall be continuing in nature so as to require the filing of
supplemental answers to the extent required under Florida law.
Requests
1. A certified and complete copy of the Policy that Defendant issued to the
Insured that was in effect on or about December 10, 2018.
2. All documents reflecting Defendant’s inspection(s) of the Insured Property
after December 10, 2018.
ILG File #: 13135
Claim #: FL18-0128887
Case #f:3. All documents reflecting Defendant’s inspection(s) of the Insured Property
before December 10, 2018, covering the preceding five (5) years.
4. All documents reflecting Defendant’s inspection(s) of the Insured Property
during the Defendant’s underwriting of the Insured’s Policy.
5. All documents reflecting Defendant’s inspection(s) of the Insured Property
during Defendant’s underwriting of all insurance policies Defendant issued to the Insured
for the Insured Property prior to December 10, 2018.
6. All photographs and/or videos submitted by Plaintiffs to Defendant in any
way related to the Loss.
7. All photographs and/or videos submitted by Defendant to Plaintiffs in any
way related to the Loss.
8. All photographs and/or videos taken by Defendant in any way related to the
Loss.
9. All correspondence, emails and all other documents provided by Plaintiffs
to Defendant in any way related to the Loss.
10. All correspondence, emails and all other documents provided by Defendant
to Plaintiffs in any way related to the Loss.
11. All documents reflecting Defendant’s efforts to investigate the Loss.
12. All documents documenting or supporting Defendant’s affirmative
defenses, or that Defendant anticipates will support Defendant’s reasons for denying or
failing to pay the full amount of Plaintiffs’ Loss.
13. All documents, including but not limited to estimates, reports, testing,
photographs and/or videos created by Defendant, Defendant’s adjusters, Defendant’s loss
ILG File #: 13135
Claim #: FL18-0128887
Case #f:consultants, or by any expert retained by Defendant, including but not limited to plumbers,
engineers, and/or contractors in any way related to the Loss.
14. All documents identified in Defendant’s Answers to Plaintiffs’ First Set of
Interrogatories.
15. Accurrent curriculum vitae and all biographical information for all person(s)
who inspected the Insured Property for or on behalf of Defendant following the Loss.
16. All documents in any way related to the damage caused to the Insured
Property from the alleged Loss.
17. All documents related to the Insured Property that support how Defendant
determined whether to pay Plaintiffs’ Claim, and/or how much of Plaintiffs’ Claim to pay.
18. All documents reflecting the relationship between Defendant and the
adjuster (or any other person or entity) that assisted Defendant in investigating, adjusting,
and/or evaluating Plaintiffs’ Claim.
19. All documents that support any denials by Defendant of Plaintiffs’ First
Request for Admissions.
20. All reports relating to the damage to the Insured Property sustained during
or as a result of the Loss.
21. — All reports relating to the condition of the Insured Property before the Loss.
22. All reports relating to the condition of the Insured Property after the Loss.
23. All documents showing when Plaintiffs notified Defendant of the Loss.
24. All electronic claim notes made by or on behalf of Defendant in any way
relating to the Loss, or to the condition of Insured Property at the time of Loss.
ILG File #: 13135
Claim #: FL18-0128887
Case #f:25. The part of Defendant’s claim file that Defendant reasonably expects to rely
upon at trial in this action.
26. The part of Defendant’s claim file that Defendant reasonably expects to use
at trial in support of its affirmative defenses.
27. All documents that Defendant reasonably expects to rely upon at trial in this
action.
28. All documents that Defendant reasonably expects to use at trial in support
of its affirmative defenses.
29. The part of Defendant’s claim file that supports the action taken by
Defendant in paying or refusing to pay Plaintiffs’ Claim.
30. All documents that support the action taken by Defendant in paying or
refusing to pay Plaintiffs’ Claim.
31. All estimates prepared by Defendant in any way related to the amount
claimed by Plaintiffs in this action.
32. Allestimates prepared by Defendant, its agents or independent contractors,
contractors, loss consultants, or third parties, that Defendant may use to support its reason
for non-payment or partial payment of Plaintiffs’ Claim.
33. All documents Defendant provided to the person(s) who investigated,
adjusted or otherwise evaluated Plaintiffs’ Claim.
34. All documents reflecting any communication between Defendant, and any
of Defendant’s agents, independent adjusters, plumbers, engineers or any other person or
entity retained by Defendant, in any way related to Plaintiffs’ Claim.
ILG File #: 13135
Claim #: FL18-0128887
Case #f:35. All underwriting documents in any way relating to the condition of the
Insured Property before the Loss.
36. The underwriting file kept by Defendant regarding the Insured Property
dating from the inception of Defendant’s Policy on the Insured Premises through the
present time.
37. Allinsurance applications the Insured submitted to Defendant regarding the
Insured Property.
38. All documents containing any facts supporting any of Defendant’s
affirmative defenses.
39. All documents containing any facts supporting any of Defendant’s reasons
for failing to pay and/or paying only part of Plaintiffs’ Claim.
40. All documents supporting any allegation or contention by Defendant that
Plaintiffs’ Claim is related to damages involving a prior claim made by Insured or prior
damage sustained by an Insured.
41. All documents supporting any allegation or contention by Defendant that
Plaintiffs’ Claim is related to damages involving a subsequent claim made by Insured or
subsequent damage sustained by an Insured.
42. All documents supporting any allegation or contention by Defendant that
the Insured’s damages from the Loss are related to damages involving a prior claim made
by the Insured or prior damage sustained by an Insured.
43. All documents supporting any allegation or contention by Defendant that
Plaintiffs’ Claim is related to damages involving a subsequent claim made by the Insured
or subsequent damage sustained by an Insured.
ILG File #: 13135
Claim #: FL18-0128887
Case #f:44. All signed sworn proofs of loss submitted by the Insured to Defendant
regarding the Loss.
4S. Complete and legible copies of all building permits and all other records
obtained from the county or other municipality, applicable to the Insured Property covering
a five year span prior to the Loss.
46. All documents evidencing all payments made by Defendant to the Insured
and/or for the Insured’s benefit involving a Prior Claim made by Insured or prior damage
sustained by an Insured, involving the Insured Property.
47. All documents evidencing all payments made by Defendant to the Insured
and/or for the Insured’s benefit involving a Subsequent Claim made by Insured or
subsequent damage sustained by an Insured, involving the Insured Property.
48. All documents evidencing all payments made by Defendant to the Insured
and/or for the Insured’s benefit involving the claim for the same date of Loss alleged in the
Complaint.
49. All correspondence and documents between Defendant and any third
parties, excluding Defendant’s attomey, in any way related to (1) the condition of the
Insured Property before the Loss; or (2) the damage to the Insured Property sustained
during the Loss.
50. All reports relating to Plaintiffs’ Claim or to the damages sustained to
Insured Property during or as a result of the Loss.
51. All documents showing or pertaining to any repairs made to the Insured
Property by or on behalf of the Insured prior to the Loss, including but not limited to repair
invoices, estimates, canceled checks, credit card receipts, contracts for repair, receipts,
ILG File #: 13135
Claim #: FL18-0128887
Case #f:certificates of completion, notices of commencement, special assessment notices, payment
logs, building permits and building permit applications.
52. All documents showing or pertaining to any repairs made to the Insured
Property by or on behalf of the Insured after the Loss, including but not limited to repair
invoices, estimates, canceled checks, credit card receipts, contracts for repair, receipts,
certificates of completion, notices of commencement, special assessment notices, payment
logs, building permits and building permit applications.
53. All transcripts of any Examinations Under Oath given or provided by the
Insured regarding the Loss.
54. All transcripts of any Examinations Under Oath given or provided by
anyone besides the Insured regarding the Loss.
55. All recorded statements given or provided by the Insured regarding the
Loss. This request seeks a copy of the recording itself, not Defendant’s transcript of the
recorded statement.
56. All recorded statements given or provided by anyone besides the Insured
regarding the Loss. This request seeks a copy of the recording itself, not Defendant’s
transcript of the recorded statement.
57. All Coverage Letters sent by Defendant to the Insured in any way related to
the Loss.
58. All transcripts of Examinations Under Oath and/or recordings of all
recorded statements given by the Insured regarding any prior or subsequent claims which
Defendant may use at trial in this case.
ILG File #: 13135
Claim #: FL18-0128887
Case #f:CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing was served on Defendant with the
Complaint.
INSURANCE LITIGATION GROUP, P.A.
Attomey for Plaintiffs
1500 NE 162" Street
Miami, Florida 33162
Telephone: (786) 529-0090
Facsimile: (866) 239-9520
E-Mail: service@ilgpa.com
By: /s/ Milton Grey
MILTON GREY, ESQ.
FL Bar No. 0116560
ILG File #: 13135
Claim #: FL18-0128887
Case #f:
Preview
Case Number: CACE-19-022618 Division: 02 Filing # 98212367 E-Filed 10/31/2019 05:38:02 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: LATOYA APPLETON AND LADARIUS KINSEY, Plaintiffs, vs. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / PLANTIFFS’ FIRST REQUEST FOR PRODUCTION TO DEFENDANT Plaintiffs, LATOYA APPLETON AND LADARIUS KINSEY, by and through their undersigned attorney, and pursuant to Rule 1.350, Fla. R. Civ. P., request Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, to furnish copies of the following documents to the offices of the undersigned attorney within forty-five (45) days from the date of service of this request. DEFINITIONS AND INSTRUCTIONS 1. The term “Plaintiffs” or “Insured” means named insured, Latoya Appleton and Ladarius Kinsey, and his agents, employees, independent contractors, attorneys, and all other persons acting or purporting to act on his behalf. 2. The term “You” or “Defendant” means Universal Property & Casualty Insurance Company, and its agents, employees, independent contractors, subsidiaries, divisions, parent company, holding company, directors, officers, attorneys, and all other persons acting or purporting to act on its behalf. 3. The term “Policy” means the policy, number 1501-1604-2155, which Defendant issued to Insured for the property located at 3057 SW 2nd Court, Fort Lauderdale, Florida 33312 that was in effect on the date of loss alleged in Plaintiffs’ Complaint filed in this action. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2019 05:38:02 PM.****4. The term “Insured Building” or “Insured Property” means the insured. structure and/or its contents located at the address described in Plaintiffs’ Complaint filed in this action. 5. The term “Loss” means the event at issue in which the Named Insured suffered property damage, on the date of loss alleged in Plaintiffs’ Complaint. 6. The term “Claim” means the Plaintiffs’ request, made pursuant to Plaintiffs’ insurance Policy, that Defendant pay Plaintiffs the amount of damages that Plaintiffs sustained as a result of the Loss. 7. The term “person” means any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, group of natural persons or other entity. 8. The term “document” or “documents” means any written, typed, or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed, including the originals and all non- identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, emails, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other communications, interoffice and intraoffice telephone calls, diaries, claim diaries, electronic claim notes, chronological data, minutes, books, reports, studies, summaries, pamphlets, printed matter, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, canceled checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases (and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphic or natural records or representations of any kind (including without limitation photographs, photographic negative, microfiche, microfilm, videotape, recordings, motion pictures, phonograph recordings, transcripts or log of such recording, projection), electronic, computer, mechanical, or electric records or representations of any kind (including without limitation tapes, cassettes, discs and records), and binders, cover notes, certificates, analysis, study memoranda, note lists, diaries, logs, questionnaires, bills, purchase orders, shipping orders, memorandum of contract, agreements, licenses, permits, orders, financial data, acknowledgements, computer or data procession cards, computer or data processing discs, and all other data compilations from which information can be obtained or translated, reports and/or summaries of investigations, drafts and revisions of drafts of any documents and original preliminary notes or sketches, no matter how produced or maintained, in your actual or constructive possession, custody or control, ILG File #: 13135 Claim #: FL18-0128887 Case #f:whether prepared, published or released by you or by any other person. If data is stored on computer or electronic media (inter-company email, for example), produce hard copies of each such document.” “Documents” includes all attachments and enclosures. 9. The term “all documents” means every document or group of documents, as above defined, that are known to you or that can be located or discovered by reasonably diligent efforts. 10. The term “coverage letter(s)” means the correspondence from You to the Named Insured throughout the claim at issue regarding Your position as to coverage for the Loss. 11. As used herein, the singular shall include the plural, the plural shall include the singular, and masculine feminine and neuter shall include each of the other genders. 12. The terms “relating to” or “in any way related to” means in whole or in part constituting, containing, concerning, discussing, commending upon, describing, analyzing, identifying, stating, pertaining to, referring to, or forming the basis of. 13. The term “Prior Claim” means all claims submitted by or on behalf of an Insured for damage occurring prior to the date of loss alleged in Plaintiffs’ Complaint, regarding the Insured Building or Insured Property. 14. The term “Subsequent Claim” means all claims submitted by or on behalf of an Insured for damage occurring after the date of loss alleged in Plaintiffs’ Complaint, regarding the Insured Building or Insured Property. 15. The term “Plaintiffs’ Complaint means the complaint filed by Plaintiffs in this action. 16. This request shall be continuing in nature so as to require the filing of supplemental answers to the extent required under Florida law. Requests 1. A certified and complete copy of the Policy that Defendant issued to the Insured that was in effect on or about December 10, 2018. 2. All documents reflecting Defendant’s inspection(s) of the Insured Property after December 10, 2018. ILG File #: 13135 Claim #: FL18-0128887 Case #f:3. All documents reflecting Defendant’s inspection(s) of the Insured Property before December 10, 2018, covering the preceding five (5) years. 4. All documents reflecting Defendant’s inspection(s) of the Insured Property during the Defendant’s underwriting of the Insured’s Policy. 5. All documents reflecting Defendant’s inspection(s) of the Insured Property during Defendant’s underwriting of all insurance policies Defendant issued to the Insured for the Insured Property prior to December 10, 2018. 6. All photographs and/or videos submitted by Plaintiffs to Defendant in any way related to the Loss. 7. All photographs and/or videos submitted by Defendant to Plaintiffs in any way related to the Loss. 8. All photographs and/or videos taken by Defendant in any way related to the Loss. 9. All correspondence, emails and all other documents provided by Plaintiffs to Defendant in any way related to the Loss. 10. All correspondence, emails and all other documents provided by Defendant to Plaintiffs in any way related to the Loss. 11. All documents reflecting Defendant’s efforts to investigate the Loss. 12. All documents documenting or supporting Defendant’s affirmative defenses, or that Defendant anticipates will support Defendant’s reasons for denying or failing to pay the full amount of Plaintiffs’ Loss. 13. All documents, including but not limited to estimates, reports, testing, photographs and/or videos created by Defendant, Defendant’s adjusters, Defendant’s loss ILG File #: 13135 Claim #: FL18-0128887 Case #f:consultants, or by any expert retained by Defendant, including but not limited to plumbers, engineers, and/or contractors in any way related to the Loss. 14. All documents identified in Defendant’s Answers to Plaintiffs’ First Set of Interrogatories. 15. Accurrent curriculum vitae and all biographical information for all person(s) who inspected the Insured Property for or on behalf of Defendant following the Loss. 16. All documents in any way related to the damage caused to the Insured Property from the alleged Loss. 17. All documents related to the Insured Property that support how Defendant determined whether to pay Plaintiffs’ Claim, and/or how much of Plaintiffs’ Claim to pay. 18. All documents reflecting the relationship between Defendant and the adjuster (or any other person or entity) that assisted Defendant in investigating, adjusting, and/or evaluating Plaintiffs’ Claim. 19. All documents that support any denials by Defendant of Plaintiffs’ First Request for Admissions. 20. All reports relating to the damage to the Insured Property sustained during or as a result of the Loss. 21. — All reports relating to the condition of the Insured Property before the Loss. 22. All reports relating to the condition of the Insured Property after the Loss. 23. All documents showing when Plaintiffs notified Defendant of the Loss. 24. All electronic claim notes made by or on behalf of Defendant in any way relating to the Loss, or to the condition of Insured Property at the time of Loss. ILG File #: 13135 Claim #: FL18-0128887 Case #f:25. The part of Defendant’s claim file that Defendant reasonably expects to rely upon at trial in this action. 26. The part of Defendant’s claim file that Defendant reasonably expects to use at trial in support of its affirmative defenses. 27. All documents that Defendant reasonably expects to rely upon at trial in this action. 28. All documents that Defendant reasonably expects to use at trial in support of its affirmative defenses. 29. The part of Defendant’s claim file that supports the action taken by Defendant in paying or refusing to pay Plaintiffs’ Claim. 30. All documents that support the action taken by Defendant in paying or refusing to pay Plaintiffs’ Claim. 31. All estimates prepared by Defendant in any way related to the amount claimed by Plaintiffs in this action. 32. Allestimates prepared by Defendant, its agents or independent contractors, contractors, loss consultants, or third parties, that Defendant may use to support its reason for non-payment or partial payment of Plaintiffs’ Claim. 33. All documents Defendant provided to the person(s) who investigated, adjusted or otherwise evaluated Plaintiffs’ Claim. 34. All documents reflecting any communication between Defendant, and any of Defendant’s agents, independent adjusters, plumbers, engineers or any other person or entity retained by Defendant, in any way related to Plaintiffs’ Claim. ILG File #: 13135 Claim #: FL18-0128887 Case #f:35. All underwriting documents in any way relating to the condition of the Insured Property before the Loss. 36. The underwriting file kept by Defendant regarding the Insured Property dating from the inception of Defendant’s Policy on the Insured Premises through the present time. 37. Allinsurance applications the Insured submitted to Defendant regarding the Insured Property. 38. All documents containing any facts supporting any of Defendant’s affirmative defenses. 39. All documents containing any facts supporting any of Defendant’s reasons for failing to pay and/or paying only part of Plaintiffs’ Claim. 40. All documents supporting any allegation or contention by Defendant that Plaintiffs’ Claim is related to damages involving a prior claim made by Insured or prior damage sustained by an Insured. 41. All documents supporting any allegation or contention by Defendant that Plaintiffs’ Claim is related to damages involving a subsequent claim made by Insured or subsequent damage sustained by an Insured. 42. All documents supporting any allegation or contention by Defendant that the Insured’s damages from the Loss are related to damages involving a prior claim made by the Insured or prior damage sustained by an Insured. 43. All documents supporting any allegation or contention by Defendant that Plaintiffs’ Claim is related to damages involving a subsequent claim made by the Insured or subsequent damage sustained by an Insured. ILG File #: 13135 Claim #: FL18-0128887 Case #f:44. All signed sworn proofs of loss submitted by the Insured to Defendant regarding the Loss. 4S. Complete and legible copies of all building permits and all other records obtained from the county or other municipality, applicable to the Insured Property covering a five year span prior to the Loss. 46. All documents evidencing all payments made by Defendant to the Insured and/or for the Insured’s benefit involving a Prior Claim made by Insured or prior damage sustained by an Insured, involving the Insured Property. 47. All documents evidencing all payments made by Defendant to the Insured and/or for the Insured’s benefit involving a Subsequent Claim made by Insured or subsequent damage sustained by an Insured, involving the Insured Property. 48. All documents evidencing all payments made by Defendant to the Insured and/or for the Insured’s benefit involving the claim for the same date of Loss alleged in the Complaint. 49. All correspondence and documents between Defendant and any third parties, excluding Defendant’s attomey, in any way related to (1) the condition of the Insured Property before the Loss; or (2) the damage to the Insured Property sustained during the Loss. 50. All reports relating to Plaintiffs’ Claim or to the damages sustained to Insured Property during or as a result of the Loss. 51. All documents showing or pertaining to any repairs made to the Insured Property by or on behalf of the Insured prior to the Loss, including but not limited to repair invoices, estimates, canceled checks, credit card receipts, contracts for repair, receipts, ILG File #: 13135 Claim #: FL18-0128887 Case #f:certificates of completion, notices of commencement, special assessment notices, payment logs, building permits and building permit applications. 52. All documents showing or pertaining to any repairs made to the Insured Property by or on behalf of the Insured after the Loss, including but not limited to repair invoices, estimates, canceled checks, credit card receipts, contracts for repair, receipts, certificates of completion, notices of commencement, special assessment notices, payment logs, building permits and building permit applications. 53. All transcripts of any Examinations Under Oath given or provided by the Insured regarding the Loss. 54. All transcripts of any Examinations Under Oath given or provided by anyone besides the Insured regarding the Loss. 55. All recorded statements given or provided by the Insured regarding the Loss. This request seeks a copy of the recording itself, not Defendant’s transcript of the recorded statement. 56. All recorded statements given or provided by anyone besides the Insured regarding the Loss. This request seeks a copy of the recording itself, not Defendant’s transcript of the recorded statement. 57. All Coverage Letters sent by Defendant to the Insured in any way related to the Loss. 58. All transcripts of Examinations Under Oath and/or recordings of all recorded statements given by the Insured regarding any prior or subsequent claims which Defendant may use at trial in this case. ILG File #: 13135 Claim #: FL18-0128887 Case #f:CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing was served on Defendant with the Complaint. INSURANCE LITIGATION GROUP, P.A. Attomey for Plaintiffs 1500 NE 162" Street Miami, Florida 33162 Telephone: (786) 529-0090 Facsimile: (866) 239-9520 E-Mail: service@ilgpa.com By: /s/ Milton Grey MILTON GREY, ESQ. FL Bar No. 0116560 ILG File #: 13135 Claim #: FL18-0128887 Case #f: