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Filing # 54480392 E-Filed 03/31/2017 11:58:53 AM
IN THE CIRCUIT COURT, OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
DEBRA HINES, BROWARD COUNTY, FLORIDA
Plaintiff, CASE NO.: CACE-14-016655 DIV. 02
vs.
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.
a Florida Corporation,
Defendant.
/
DEFENDANT’S FOURTH REQUEST FOR PRODUCTION TO PLAINTIFF
COMES NOW, the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY
INSURANCE COMPANY, by and through its undersigned attorneys, and hereby requests the
Plaintiff, DEBRA HINES, to produce the following documents pursuant to Florida Rule of Civil
Procedure 1.350:
I. DEFINITIONS AND INSTRUCTIONS:
A. As used herein, “Plaintiff,” “you,” or “your,” shall mean the Plaintiff, DEBRA HINES,
her attorneys, and any/all persons or entities over which they have control, have hired,
have retained, or have employed for any purpose, whether directly or through any other
person or entity.
B. As used herein, “Defendant,” “shall mean the Defendant, HOMEOWNERS CHOICE
PROPERTY & CASUALTY INSURANCE COMPANY, its affiliates, partners,
agents, adjusters, whether independent or in house, servants, employees, attorneys, expert
witnesses, accountants, auditors, and any other persons or entities over which you believe
Defendant has control over or has hired, retained or employed for any purpose, whether
directly by it or through any other person or entity.
C. As used herein, the "Property," means the building located at 3816 S. Lake Terrace,
Miramar, FL 33023.
D. As used herein, the term “document” or “documents” shall be defined to include any and
all documents, memoranda (including written memoranda of telephone conversations,
oral communications, discussions, agreements, acts or activities), pictures letters,
postcards, telegrams, messages (including telephone messages), facsimiles, intra- and
interoffice communications, correspondence, handwritten and/or typewritten notes,
pamphlets, diaries, records of any kind, sound recordings, contracts, agreements, books,
letters, reports, catalogues, financial statements, receipts, invoices, billing statements
(including credit card and telephone statements), purchase orders, proposals, affidavits,
advertisements, solicitations, indices, data processing cards, other data processing
*4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/31/2017 11:58:52 AM.****materials, data, maps, directives, desk pads, calendars, scrap books, notebooks, drawings,
diagrams, sketches, statistical records, appointment books, diaries, computer printouts,
data processing input and output, computer input and output, e-mail, microfilms, other
records kept by electronic, photographic or mechanical means, and writing of every kind
and character, including preliminary drafts and other copies of the foregoing, however
produced or reproduced. If multiple copies of a document exist, each copy which is any
way not completely identical to a copy which is being produced should also be produced.
E. As employed herein, “all documents” shall refer to and shall include every document as
above-defined, known to you and every such document or thing that can be located or
discovered by reasonable diligent efforts, whether or not originally in your custody,
possession or control.
F. When producing the requested documents and things, please produce same as they are
kept in the usual course or business or label them to correspond with the categories of this
request for production.
G. If you claim a privilege as to anything requested for production herein, you are requested
to provide a privilege log pursuant to Fla. R. Civ. P. 1.280(b)(5).
Il. DOCUMENT REQUESTS:
33. Any and all time sheets/records and invoices reflecting dates, amount of time spent, and
charges for professional services rendered by employees of Florida Testing and
Environmental, Inc., in connection with the alleged loss at 3816 S. LAKE TERRACE,
MIRAMAR, FLORIDA, 33023 that is the subject of this lawsuit.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
forwarded by electronic mail to: Ryan H. Sherman at eserviceSLPA@ gmail.com, and Morgan
Barfield at Mbarfield@@CorlessBarficld.com on this 31° day of March, 2017.
GROELLE & SALMON, P.A.
Attorneys for Defendant
Waterford Plaza
7650 W. Courtney Campbell Causeway
Suite 800
Tampa, FL 33607
(813) 849-7200 (telephone)
(813) 849-7201 (fax)
py, Pat 1 Lebecbe>
ROBERT T. SCHULTE, ESQ.
14211 FBN: 88819
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Filing # 54480392 E-Filed 03/31/2017 11:58:53 AM IN THE CIRCUIT COURT, OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR DEBRA HINES, BROWARD COUNTY, FLORIDA Plaintiff, CASE NO.: CACE-14-016655 DIV. 02 vs. HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. a Florida Corporation, Defendant. / DEFENDANT’S FOURTH REQUEST FOR PRODUCTION TO PLAINTIFF COMES NOW, the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, by and through its undersigned attorneys, and hereby requests the Plaintiff, DEBRA HINES, to produce the following documents pursuant to Florida Rule of Civil Procedure 1.350: I. DEFINITIONS AND INSTRUCTIONS: A. As used herein, “Plaintiff,” “you,” or “your,” shall mean the Plaintiff, DEBRA HINES, her attorneys, and any/all persons or entities over which they have control, have hired, have retained, or have employed for any purpose, whether directly or through any other person or entity. B. As used herein, “Defendant,” “shall mean the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, its affiliates, partners, agents, adjusters, whether independent or in house, servants, employees, attorneys, expert witnesses, accountants, auditors, and any other persons or entities over which you believe Defendant has control over or has hired, retained or employed for any purpose, whether directly by it or through any other person or entity. C. As used herein, the "Property," means the building located at 3816 S. Lake Terrace, Miramar, FL 33023. D. As used herein, the term “document” or “documents” shall be defined to include any and all documents, memoranda (including written memoranda of telephone conversations, oral communications, discussions, agreements, acts or activities), pictures letters, postcards, telegrams, messages (including telephone messages), facsimiles, intra- and interoffice communications, correspondence, handwritten and/or typewritten notes, pamphlets, diaries, records of any kind, sound recordings, contracts, agreements, books, letters, reports, catalogues, financial statements, receipts, invoices, billing statements (including credit card and telephone statements), purchase orders, proposals, affidavits, advertisements, solicitations, indices, data processing cards, other data processing *4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/31/2017 11:58:52 AM.****materials, data, maps, directives, desk pads, calendars, scrap books, notebooks, drawings, diagrams, sketches, statistical records, appointment books, diaries, computer printouts, data processing input and output, computer input and output, e-mail, microfilms, other records kept by electronic, photographic or mechanical means, and writing of every kind and character, including preliminary drafts and other copies of the foregoing, however produced or reproduced. If multiple copies of a document exist, each copy which is any way not completely identical to a copy which is being produced should also be produced. E. As employed herein, “all documents” shall refer to and shall include every document as above-defined, known to you and every such document or thing that can be located or discovered by reasonable diligent efforts, whether or not originally in your custody, possession or control. F. When producing the requested documents and things, please produce same as they are kept in the usual course or business or label them to correspond with the categories of this request for production. G. If you claim a privilege as to anything requested for production herein, you are requested to provide a privilege log pursuant to Fla. R. Civ. P. 1.280(b)(5). Il. DOCUMENT REQUESTS: 33. Any and all time sheets/records and invoices reflecting dates, amount of time spent, and charges for professional services rendered by employees of Florida Testing and Environmental, Inc., in connection with the alleged loss at 3816 S. LAKE TERRACE, MIRAMAR, FLORIDA, 33023 that is the subject of this lawsuit. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been forwarded by electronic mail to: Ryan H. Sherman at eserviceSLPA@ gmail.com, and Morgan Barfield at Mbarfield@@CorlessBarficld.com on this 31° day of March, 2017. GROELLE & SALMON, P.A. Attorneys for Defendant Waterford Plaza 7650 W. Courtney Campbell Causeway Suite 800 Tampa, FL 33607 (813) 849-7200 (telephone) (813) 849-7201 (fax) py, Pat 1 Lebecbe> ROBERT T. SCHULTE, ESQ. 14211 FBN: 88819