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.
Preview
Case Number: CACE-15-013511 Division: 25
Filing # 30274988 E-Filed 07/30/2015 10:53:29 AM
IN THE CIRCUIT COURT OF THE 17!"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.:
MARIA BARBAT,
Plaintiffs,
vs.
UNITED PROPERTY &
CASUALTY INSURANCE COMPANY,
Defendant.
/
REQUEST TO PRODUCE
Plaintiffs, MARIA BARBAT, by and through the undersigned attorneys, pursuant to Fla.
R. Civ. P. 1.350, requests that the Defendant, UNITED PROPERTY & CASUALTY
INSURANCE COMPANY produce for inspection or copying the documents set forth below.
Pursuant to Fla. R. Civ. P. 1.350, Defendant shall serve a written response or production within
forty-five (45) days after service of this Request to Produce.
DEFENDANT SHALL PRODUCE THE FOLLOWING ITEMS AND MATTERS:
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.
2. All documents reflecting any payment made to any person or entity for any reason as a
result of plaintiffs claim for property damage.
3. All transcripts of Examinations Under Oath taken regarding Plaintiffs’ claims for
benefits.
4. Tapes and/or transcripts of all statements taken of any person regarding Plaintiffs’ claims
for benefits.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/30/2015 10:53:27 AM.****5. All correspondence between Plaintiffs, or any representatives of Plaintiffs, and any
representative of Defendant regarding Plaintiffs’ claims for benefits.
6. All documents which defendant contents support any affirmative defense raised in
Defendant’s Answer in this case.
7. All reports from any expert retained for any reason in this claim
8. All current curriculum vitae from any individual who prepared and/or signed a written
report produced in response to paragraph 7, above.
9. All photographs, video depiction of Plaintiffs’ properties in the possession of the
Defendant or any agent of the Defendant.
10. All Proofs of Loss received by Defendant from Plaintiff or any representative of
Plaintiffs’.
11. All estimates received by Defendant from any source for repairs to Plaintiffs’ structures.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished to the Defendant along with the Summons and Complaint.
Jaramillo, Correa & Martinez
Attorneys for Plaintiff
7700 N. Kendall Drive, Suite 805
Miami, FL 33156
Tel: (305) 598-7739; Fax: (305) 598-5034
ee SS See
ANDRES J. CORREA (FBN 89790)
2
JARAMILLO, CORREA & MARTINEZ, 7700 N, KENDALL DRIVE, SUITE 805, MIAMI, FL 33156
TELEPHONE 305-598-7739 FACSIMILE 305-598-5034 EMAIL: COURTMAIL@JCMLAWGROUP.COM
Category
Contract and Indebtedness
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Case Number: CACE-15-013511 Division: 25 Filing # 30274988 E-Filed 07/30/2015 10:53:29 AM IN THE CIRCUIT COURT OF THE 17!" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: MARIA BARBAT, Plaintiffs, vs. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / REQUEST TO PRODUCE Plaintiffs, MARIA BARBAT, by and through the undersigned attorneys, pursuant to Fla. R. Civ. P. 1.350, requests that the Defendant, UNITED PROPERTY & CASUALTY INSURANCE COMPANY produce for inspection or copying the documents set forth below. Pursuant to Fla. R. Civ. P. 1.350, Defendant shall serve a written response or production within forty-five (45) days after service of this Request to Produce. DEFENDANT SHALL PRODUCE THE FOLLOWING ITEMS AND MATTERS: 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. 2. All documents reflecting any payment made to any person or entity for any reason as a result of plaintiffs claim for property damage. 3. All transcripts of Examinations Under Oath taken regarding Plaintiffs’ claims for benefits. 4. Tapes and/or transcripts of all statements taken of any person regarding Plaintiffs’ claims for benefits. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/30/2015 10:53:27 AM.****5. All correspondence between Plaintiffs, or any representatives of Plaintiffs, and any representative of Defendant regarding Plaintiffs’ claims for benefits. 6. All documents which defendant contents support any affirmative defense raised in Defendant’s Answer in this case. 7. All reports from any expert retained for any reason in this claim 8. All current curriculum vitae from any individual who prepared and/or signed a written report produced in response to paragraph 7, above. 9. All photographs, video depiction of Plaintiffs’ properties in the possession of the Defendant or any agent of the Defendant. 10. All Proofs of Loss received by Defendant from Plaintiff or any representative of Plaintiffs’. 11. All estimates received by Defendant from any source for repairs to Plaintiffs’ structures. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the Defendant along with the Summons and Complaint. Jaramillo, Correa & Martinez Attorneys for Plaintiff 7700 N. Kendall Drive, Suite 805 Miami, FL 33156 Tel: (305) 598-7739; Fax: (305) 598-5034 ee SS See ANDRES J. CORREA (FBN 89790) 2 JARAMILLO, CORREA & MARTINEZ, 7700 N, KENDALL DRIVE, SUITE 805, MIAMI, FL 33156 TELEPHONE 305-598-7739 FACSIMILE 305-598-5034 EMAIL: COURTMAIL@JCMLAWGROUP.COM