Party Discovery: Michael Rose Plaintiff vs. American Security Ins Co Defendant

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                                Case Number: CACE-15-022275 Division: 03
Filing # 35709104 E-Filed 12/18/2015 11:18:39 AM

IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA

MICHAEL ROSE, CASE NO,

Plaintiff,
vs.

AMERICAN SECURITY INSURANCE
COMPANY,

Defendant.

 

REQUEST FOR PRODUCTION

COMES NOW Plaintiff, by and through the undersigned attorneys, and hereby requests the
Defendant to produce the following items for inspection and/or copying at the office of the
undersigned attorneys within the time prescribed by the applicable rules of civil procedure:

1, A true and correct certified copy of the insurance policy described in the complaint,

including all declaration sheet(s), addendums and attachments.

2. Any and all correspondence or written communications from Defendant, or its agents

to Plaintiff, or his agents, which in any manner pertain to Plaintiff's alleged loss as described in the

complaint.

3. Any and all correspondence or written communications from Plaintiff, or his agents

to Defendant, or its agents, which in any manner pertain to Plaintiff's alleged loss as described in

the complaint.

4, Any and all photographs taken by the Defendant or Defendant’s agents showing the

extent of damage to the insured premises involved herein as were taken prior to the filing of this

lawsuit.

5. Any and all tape recordings of any statements made by Plaintiff or Plaintiffs agents

or employees,

6. Any an all transcripts or written statements from the Plaintiff(s) including, without

limitation, transcripts of examinations under oath.

7. Copies of each and every bill or estimate for repair to the subject property submitted

to Defendant by Plaintiff or Plaintiffs agents or employees,

a DUBOFF

 

 

 

 

*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/18/2015 11:18:37 AM.****8. Any and all written estimates or reports reflecting examination or inspection by
Defendant or Defendant’s agents of any of the alleged damage to the insured premises.

9. Defendant's entire claim file up from the date of the initial notice of the loss until the
day before Defendant knew that Defendant was going to deny or litigate the claim.

10. Defendant’s entire claim file for the entire time that the claim was being handled by
Defendant not in anticipation of litigation for the claim.

11. All documents relating to or supporting Defendant’s denial of any allegation of
Plaintiffs complaint, and relating to or supporting each affirmative or general defense asserted by
Defendants,

12. All underwriting files pertaining to the policy of insurance described in the
complaint/petition.

13. Alldelivery receipts, written proof of mailing and all other records evidencing in any
manner the date and/or dates that the entire policy of insurance described in the complaint was
mailed or delivered to Plaintiff(s).

14. Any and all documents related to any and all other insurance claims made by
Plaintiff(s) which are not the subject of this action, including estimates, reports, pictures, cancelled
checks, releases, proofs of loss, recorded statements, transcripts of examinations under oath, and
correspondence by and between the parties related to any and all said other claims.

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon

Defendant by the Florida Department of Financial Services together with the initial service of

process in this action.
DUBOFF LAW FIRM
ATTORNEYS FOR PLAINTIFF
680 N.E. 127 STREET
NORTH MIAMI, FLORIDA 33161
TELEPHONE (305) 899-0085
FAX No. (305) 899-0091
CourtDocument@DuboffLawFirm.com
Robert@DuboffLawFirm.com

BY: ——_—_—_
Loy Ropert A. REYNOLDS
4

FLA, BAR # 747181
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