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Filing # 32052975 E-Filed 09/15/2015 11:54:37 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No, CACE 15-013539 21
BENJAMIN EDELL AND REBECCA
EDELL,
Plaintiffs,
vs.
HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
NOTICE OF FILING PROPERTY DAMAGE INTERROGATORIES TO PLAINTIFFS
TO: BENJAMIN EDELL AND REBECCA EDELL
The Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY,
propounds the attached Property Damage Interrogatories to Plaintiff, requesting and
requiring that the interrogatories be answered in writing, under oath, or objected to, within
the time and manner prescribed by law, in accordance with the applicable Rules of Civil
Procedure.
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
by e-mail to David Low, Esquire, eservice@davidlowpa.com David Low & Associates,
P.A,, 20195 Northeast 16 Place, Second Place, Miami, FL 33179, 305/935-8986, this 15"
day of September, 2015.
By. !sf Glenn H. Malin On
GLENN H. MALIN
Florida Bar # 974595
PETERSON BERNARD
Attorneys for Defendant
707 S.E. 3 Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
gmalin@ftllaw.com
iguarente@fillaw.com
2876.91250
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/15/2015 11:54:37 AM.****PROPERTY DAMAGE INTERROGATORIES TO PLAINTIFFS
Please identify your full name, your residence address, business
address, occupation, date of birth and social security number.
Please state the date you purchased the subject property, the name(s) of
the seller(s of the property and the amount you paid for the subject
property.
Describe the condition of the property at the time you purchased it,
including specifically any problems or defects in the property, whether
known at the time of purchase or discovered after purchase.
-Has your property ever been repaired prior to the claimed date of loss,
and if so, identify who repaired it, the nature of the repair, the cost of the
repair and the date performed.For any repairs made to the insured premises, state whether the repair
work described was covered under a manufacturers or home builder's
warranty. If so, state the name and address of the manufacturer or home
builder, and if the manufacturer tendered this payment.
Please identify all individuals or entities listed on the deed, title or
mortgage as owners or co-owners of the premises.
Please state the date and circumstances when you first noticed the
claimed damages and describe in detail the specific damages noted at
that time.
Please itemize in detail any damage existing at the insured premises prior
to the date of loss.10.
11.
12.
Please state whether you or any member of your household made any
repairs to the property since the date of the incident. If so, describe all
such repairs in detail, including the nature of the work performed and the
date such work was performed.
Please fist the name and address of each contractor, appraiser, estimator,
public adjuster, who has inspected your property since the date of the
incident.
Have you or any other person obtained photographs of your property in its
damaged condition? If so, who took the photographs, when were they
taken and what did the photographs depict?
Please state whether there is currently a mortgage for the insured
location, the lien holder for any such mortgage and the approximate
balance for such mortgage.13.
14.
15.
Please state whether you have been late or defaulted on any mortgage
payments for the insured premises and if so, the date(s) any such
payment(s) was due or such payment(s) was missed, and the amount
currently in arrears.
Have you ever placed the insured premises for sale? If so, please state
the date(s) when the property was listed for sale.
Have there been any prior claims or losses to the property prior to April
2015? If so, please state the following:
a. The date and type of loss (plumbing, roof, hurricane, etc.)
b. The areas of the property affected.
c. The name of the insurance company to whom the claim was made.
d. The amount of payment made.16.
17.
18.
19.
Have there been any subsequent claims or losses to the property
subsequent to April 2015? If so, please state the following:
a. The date, location and type of loss
b. The areas of the property affected.
c. The name of the insurance company to whom the claim was made.
d. The amount of payment made.
e. State the status of the claim, i.e. settled, litigated, withdrawn.
State with specificity each and every individual who has been on your roof
in the last 10 years, and the reason they were there, including dates.
State with specificity the age of the flat and main roofs on the subject
home, and any and all repairs conducted to the flat or main roof since the
date of purchase of the home to the present.
State with specificity each and every reason why you did not report the
alleged loss until three weeks after it allegedly occurred.| have read the foregoing Answers to Interrogatories and do swear that they are
true and correct to the best of my knowledge and belief.
STATE OF )
COUNTY OF Ep )
The foregoing Answers to Interrogatories were acknowledged before me by
, who is personally
known to me, or who produced as identification a
,and who{ )did ( )
did not take an oath.
Dated this day of , 2015.
Notary Public, State of
Printed/Typed Name of Notary
Notary Serial Number
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Filing # 32052975 E-Filed 09/15/2015 11:54:37 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No, CACE 15-013539 21 BENJAMIN EDELL AND REBECCA EDELL, Plaintiffs, vs. HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / NOTICE OF FILING PROPERTY DAMAGE INTERROGATORIES TO PLAINTIFFS TO: BENJAMIN EDELL AND REBECCA EDELL The Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, propounds the attached Property Damage Interrogatories to Plaintiff, requesting and requiring that the interrogatories be answered in writing, under oath, or objected to, within the time and manner prescribed by law, in accordance with the applicable Rules of Civil Procedure. WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by e-mail to David Low, Esquire, eservice@davidlowpa.com David Low & Associates, P.A,, 20195 Northeast 16 Place, Second Place, Miami, FL 33179, 305/935-8986, this 15" day of September, 2015. By. !sf Glenn H. Malin On GLENN H. MALIN Florida Bar # 974595 PETERSON BERNARD Attorneys for Defendant 707 S.E. 3 Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile gmalin@ftllaw.com iguarente@fillaw.com 2876.91250 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/15/2015 11:54:37 AM.****PROPERTY DAMAGE INTERROGATORIES TO PLAINTIFFS Please identify your full name, your residence address, business address, occupation, date of birth and social security number. Please state the date you purchased the subject property, the name(s) of the seller(s of the property and the amount you paid for the subject property. Describe the condition of the property at the time you purchased it, including specifically any problems or defects in the property, whether known at the time of purchase or discovered after purchase. -Has your property ever been repaired prior to the claimed date of loss, and if so, identify who repaired it, the nature of the repair, the cost of the repair and the date performed.For any repairs made to the insured premises, state whether the repair work described was covered under a manufacturers or home builder's warranty. If so, state the name and address of the manufacturer or home builder, and if the manufacturer tendered this payment. Please identify all individuals or entities listed on the deed, title or mortgage as owners or co-owners of the premises. Please state the date and circumstances when you first noticed the claimed damages and describe in detail the specific damages noted at that time. Please itemize in detail any damage existing at the insured premises prior to the date of loss.10. 11. 12. Please state whether you or any member of your household made any repairs to the property since the date of the incident. If so, describe all such repairs in detail, including the nature of the work performed and the date such work was performed. Please fist the name and address of each contractor, appraiser, estimator, public adjuster, who has inspected your property since the date of the incident. Have you or any other person obtained photographs of your property in its damaged condition? If so, who took the photographs, when were they taken and what did the photographs depict? Please state whether there is currently a mortgage for the insured location, the lien holder for any such mortgage and the approximate balance for such mortgage.13. 14. 15. Please state whether you have been late or defaulted on any mortgage payments for the insured premises and if so, the date(s) any such payment(s) was due or such payment(s) was missed, and the amount currently in arrears. Have you ever placed the insured premises for sale? If so, please state the date(s) when the property was listed for sale. Have there been any prior claims or losses to the property prior to April 2015? If so, please state the following: a. The date and type of loss (plumbing, roof, hurricane, etc.) b. The areas of the property affected. c. The name of the insurance company to whom the claim was made. d. The amount of payment made.16. 17. 18. 19. Have there been any subsequent claims or losses to the property subsequent to April 2015? If so, please state the following: a. The date, location and type of loss b. The areas of the property affected. c. The name of the insurance company to whom the claim was made. d. The amount of payment made. e. State the status of the claim, i.e. settled, litigated, withdrawn. State with specificity each and every individual who has been on your roof in the last 10 years, and the reason they were there, including dates. State with specificity the age of the flat and main roofs on the subject home, and any and all repairs conducted to the flat or main roof since the date of purchase of the home to the present. State with specificity each and every reason why you did not report the alleged loss until three weeks after it allegedly occurred.| have read the foregoing Answers to Interrogatories and do swear that they are true and correct to the best of my knowledge and belief. STATE OF ) COUNTY OF Ep ) The foregoing Answers to Interrogatories were acknowledged before me by , who is personally known to me, or who produced as identification a ,and who{ )did ( ) did not take an oath. Dated this day of , 2015. Notary Public, State of Printed/Typed Name of Notary Notary Serial Number