Request to Produce - Party: Defendant Heritage Property And Casualty Ins Comp - Benjamin Edell, et al Plaintiff vs. Heritage Property And Casualty Ins Comp Defendant

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On July 30, 2015 contract and indebtedness case was filed by Edell, Benjamin, and Edell, Rebecca, represented by Low, David, Esq., against Heritage Property And Casualty Ins Comp, represented by Malin, Glenn H, in the jurisdiction of Broward County. Judge Singer, Michele Towbin presiding.

                        
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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.

REQUEST TO PRODUCE

The Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY,
in accordance with the applicable Rules of Civil Procedure, requires the Plaintiffs to
produce, within the time prescribed by law, at the offices of the undersigned attorneys, the
following:

1. All documents related to the construction of any and all structures on and
improvements to the insured property including, without limitation: contracts, plans,
blueprints, drawings, and specifications for the construction, permits and applications for
permits, punch lists and certificates of occupancy.

2. All documents related to the Plaintiffs’ purchase of the insured property,
including but not limited to the contract for the purchase …