Request for Production - Party: Defendant First Community Ins Co - Michael Diaz Plaintiff vs. Citizens Property Ins Corp, et al Defendant

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On August 15, 2014 contract and indebtedness case was filed by Diaz, Michael, represented by Jaramillo, Julio C, against Citizens Property Ins Corp, and First Community Ins Co, represented by Dugan, Robert O, and Julmiste, Wilner J, in the jurisdiction of Broward County. Judge Perlman, Sandra presiding.

                        
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                          Filing # 31903390 E-Filed 09/10/2015 01:56:59 PM

IN THE CIRCUIT COURT OF THE 17" JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY,
FLORIDA
MICHAEL DIAZ,
CASE NO: CACE 14 15822 (04)
Plaintiff,
ve.

FIRST COMMUNITY INSURANCE
COMPANY,

Defendant.

DEFENDANT, FIRST COMMUNITY INSURANCE COMPANY’S
INITIAL REQUESTS FOR PRODUCTION TO PLAINTIFF

Defendant, FIRST COMMUNITY INSURANCE COMPANY, by and through
undersigned counsel and pursuant to Florida Rule of Civil Procedure 1,350, hereby files its
Initial Requests for Production to Plaintiff.

It is requested that the documents and materials be produced within thirty (30) days of the
date of service. Plaintiff's responses should correspond, number by number to this request. The
documents and/or materials requested are believed to be in the possession, custody or control of
the Plaintiff. The information sought by this request is relevant to the subject of this action and
cannot otherwise be obtained without undue hardship. In the event all or part of …