On July 30, 2015 a
Party Discovery
was filed
involving a dispute between
Barbat, Maria,
and
United Property & Casualty Ins Co,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 34478688 E-Filed 11/16/2015 11:46:26 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY, FLORIDA
MARIA BARBAT, CASE NO.: CACE 15-013511 DIV 25
Plaintiff,
Vv.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY, INC.
Defendant.
/
DEFENDANT’S RESPONSES TO PLAINTIFF’S
FIRST REQUEST FOR PRODUCTION
Defendant, UNITED PROPERTY & CASUALTY INSURANCE COMPANY, by and
through undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.350, hereby serves
its Responses to Plaintiff's First Request for Production served with Complaint.
1. All insurance policies which would provide coverage to the Plaintiffs herein,
together with any declaration of coverage pages, and a sworn statement of a corporate officer of
Defendant attesting to the coverage and authenticity of the policy.
RESPONSE: See attached Declaration page as UPC0001-UPC0005. A request has
already been made to obtain a full copy of the policy. Once the policy has been
received, it will be provided.
2. All documents reflecting any payment made to any person or entity for any reason
as a result of plaintiff's claim for property damage.
RESPONSE: See attached as UPC0006-UPC00012; UPC000124-UPC000129;
UPC000141-UPC000144.
3. All transcripts of Examinations Under Oath taken regarding Plaintiffs’’ claims for
benefits.
RESPONSE: None.
4. Tapes and/or transcripts of all statements taken of any person regarding Plaintiffs’
claims for benefits.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/16/2015 11:46:26 AM.****CASE NO.: CACE 15-013511 DIV 25
Page 2
RESPONSE: None.
5. All correspondence between Plaintiffs, or any representatives of Plaintiffs, and
any representative of Defendant regarding Plaintiffs’ claims for benefits.
RESPONSE: See attached as UPC0006-UPC00034; UPC00096-UPC00048;
UPC000163.
6. All documents which defendant contents support any affirmative defense raised in
Defendant’s Answer in this case.
RESPONSE: See attached as UPC0001-UPC000163.
7. All reports from any expert retained for any reason in this claim.
RESPONSE: None
8. All current curriculum vitae from any individual who prepared and/or signed a
written report produced in response to paragraph 7, above.
RESPONSE: None.
9. All photographs, video depiction of Plaintiffs’ properties in the possession of the
Defendant or any agent of the Defendant.
RESPONSE: See attached as UPC00041; UPC00095; UPC000150-UPC000162.
10. All Proofs of Loss received by Defendant from Plaintiff or any representative of
Plaintiffs’.
RESPONSE: See attached as UPC00021;UPC00097.
11. All estimates received by Defendant from any source for repairs to Plaintiffs’
structures.
RESPONSE: See attached as UPC00022-UPC000123; UPC000130-UPC000133;
UPC000137-UPC000140; UPC000145-UPC000162.CASE NO.: CACE 15-013511 DIV 25
Page 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 16th day of November, 2015, a true and correct copy
hereof was e-filed and served via E-Mail to: Manuel J. Mari, Esq.,
manuel(@manueljmaripa.com and ada@manueljmaripa.com.
KOLEOS, ROSENBERG & McMAHON, P.L.
717 N. Magnolia Avenue
Orlando, Florida 32803
Telephone: (407) 637-8788
Facsimile: (407) 637-8789
s/Gregory P. McMahon
GREGORY P. MCMAHON
Florida Bar No.: 0149977
Email: gom@krmlegalgroup.com
Counsel for Defendant United Property
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Filing # 34478688 E-Filed 11/16/2015 11:46:26 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA MARIA BARBAT, CASE NO.: CACE 15-013511 DIV 25 Plaintiff, Vv. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, INC. Defendant. / DEFENDANT’S RESPONSES TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION Defendant, UNITED PROPERTY & CASUALTY INSURANCE COMPANY, by and through undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.350, hereby serves its Responses to Plaintiff's First Request for Production served with Complaint. 1. All insurance policies which would provide coverage to the Plaintiffs herein, together with any declaration of coverage pages, and a sworn statement of a corporate officer of Defendant attesting to the coverage and authenticity of the policy. RESPONSE: See attached Declaration page as UPC0001-UPC0005. A request has already been made to obtain a full copy of the policy. Once the policy has been received, it will be provided. 2. All documents reflecting any payment made to any person or entity for any reason as a result of plaintiff's claim for property damage. RESPONSE: See attached as UPC0006-UPC00012; UPC000124-UPC000129; UPC000141-UPC000144. 3. All transcripts of Examinations Under Oath taken regarding Plaintiffs’’ claims for benefits. RESPONSE: None. 4. Tapes and/or transcripts of all statements taken of any person regarding Plaintiffs’ claims for benefits. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/16/2015 11:46:26 AM.****CASE NO.: CACE 15-013511 DIV 25 Page 2 RESPONSE: None. 5. All correspondence between Plaintiffs, or any representatives of Plaintiffs, and any representative of Defendant regarding Plaintiffs’ claims for benefits. RESPONSE: See attached as UPC0006-UPC00034; UPC00096-UPC00048; UPC000163. 6. All documents which defendant contents support any affirmative defense raised in Defendant’s Answer in this case. RESPONSE: See attached as UPC0001-UPC000163. 7. All reports from any expert retained for any reason in this claim. RESPONSE: None 8. All current curriculum vitae from any individual who prepared and/or signed a written report produced in response to paragraph 7, above. RESPONSE: None. 9. All photographs, video depiction of Plaintiffs’ properties in the possession of the Defendant or any agent of the Defendant. RESPONSE: See attached as UPC00041; UPC00095; UPC000150-UPC000162. 10. All Proofs of Loss received by Defendant from Plaintiff or any representative of Plaintiffs’. RESPONSE: See attached as UPC00021;UPC00097. 11. All estimates received by Defendant from any source for repairs to Plaintiffs’ structures. RESPONSE: See attached as UPC00022-UPC000123; UPC000130-UPC000133; UPC000137-UPC000140; UPC000145-UPC000162.CASE NO.: CACE 15-013511 DIV 25 Page 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 16th day of November, 2015, a true and correct copy hereof was e-filed and served via E-Mail to: Manuel J. Mari, Esq., manuel(@manueljmaripa.com and ada@manueljmaripa.com. KOLEOS, ROSENBERG & McMAHON, P.L. 717 N. Magnolia Avenue Orlando, Florida 32803 Telephone: (407) 637-8788 Facsimile: (407) 637-8789 s/Gregory P. McMahon GREGORY P. MCMAHON Florida Bar No.: 0149977 Email: gom@krmlegalgroup.com Counsel for Defendant United Property