Preview
Filing # 49431234 E-Filed 11/30/2016 11:23:37 AM
IN THE CIRCUIT COURT, OF THE 17™
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. CACE-14-016655 DIV. 02
DEBRA HINES,
Plaintiff,
vs.
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.
a Florida Corporation,
Defendant.
/
DEFENDANT’S MOTION FOR LEAVE TO SERVE ADDITIONAL
INTERROGATORIES
COMES NOW, the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY
INSURANCE COMPANY, by and through undersigned counsel, and pursuant to Fla. R. Civ. P.
1,340 and hereby files this Motion for Leave to Serve Additional Interrogatories and in support
thereof states:
1, Standard of Appellate Review: “In the case of an order regarding discovery, the
trial court has broad discretion. Only when an order allowing discovery constitutes an abuse of
discretion which would cause irreparable damage should the ruling be set aside.” Baker by and
through Baker v. Eckerd Corp., 697 So. 2d 970 (Fla. 2d Dist. Ct. App. 1997).
2. Florida Rules of Civil Procedure 1.340 permits each party to serve thirty (30)
interrogatories to an opposing party. This rule is not meant as an absolute bar to limit the number
of interrogatories in every case to thirty (30). Instead, the purpose of this rule, as of the other
discovery rules, is to avoid unnecessary costs, minimize delay and narrow the issues at trial, to
the extent the request is consistent with Rule 1.340.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/30/2016 11:23:35 AM.****3. This is an action regarding an insurance claim for sinkhole loss to Plaintiff's
property where the parties dispute whether a sinkhole loss has occurred.
4, On September 18, 2015, the Defendant requested to be afforded the opportunity to
be present for any destructive testing to the property.
5. Subsequently, in June of 2016, Plaintiffs’ retained Florida Testing &
Environmental, Inc. who performed destructive testing at the property.
6. On June 24, 2016, Defendant served six (6) requests for admissions upon
Plaintiffs, numbered 22 through 27, attached hereto as Exhibit A.
7. On June 28, 2016, Plaintiff responded to Defendant’s requests, admitting requests
nos. 22 through 25 and responding to requests nos. 26 and 27 as follows: “Denied as phrased”.
See Exhibit B.
8. Seeking an explanation for Plaintiff's denials to requests nos. 26 and 27,
Defendant propounded interrogatories nos. 38 and 39 upon the Plaintiff. See Exhibit C.
9. In response, Plaintiff objected to interrogatories nos. 38 and 39 on the basis that
they exceeded the allowable number of interrogatories pursuant to Rule 1.340, Florida Rule of
Civil Procedure. See Exhibit D.
10. The Florida Second District Court of appeals has held that “a party would be well
advised to follow up a denial of a request for admission with an interrogatory seeking an
explanation of the denial.” Anthony v. Schmitt, 557 So. 2d 656, 660 n.9 (Fla. 2nd DCA 1990).
11. These interrogatories seek information that is relevant to the subject matter of the
pending action and reasonably calculated to lead the discovery of admissible evidence.
12. The information sought in these interrogatories is required by Defendant in
preparation of a defense to Plaintiff's claims.13. The information requested is not frivolous, nor is it intended to harass the
Plaintiff.
14. Defendant requests the objections be overruled, grant leave to propound
additional Interrogatories nos. 38 and 39, nunc pro tunc, and that Plaintiff be compelled to file
full and complete responsive answers to interrogatories nos. 38 and 39.
15. | WHEREFORE, the Defendant, HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, requests this Court grant leave to propound additional
Interrogatories nos. 38 and 39, nunc pro tunc, and compelling Plaintiffs to file full and complete
responses, and any such other relief as deemed appropriate.
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, Esq. at eserviceSLPA@ gmail.com and
Morgan Barfield at Service@corlessbarfield.com on this 30" day of November, 2016.
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)
rstcourtdo!
com
rschulte@gspalaw.com
Mn T Lbede-
ROBERT T. SCHULTE, ESQ.
HCP.14211 FBN: 88819
By:14211 IN THE CIRCUIT COURT, OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-14-016655 DIV. 02
DEBRA HINES,
Plaintiff,
- EXHIBIT A
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.
a Florida Corporation,
Defendant.
/
DEFENDANT’S NOTICE OF SERVING
DEFENDANT’S SECOND REQUEST FOR ADMISSIONS TO THE PLAINTIFFS
COMES NOW the Defendant, HOMEOWNERS CHOICE PROPERTY AND
CASUALTY INSURANCE COMPANY, by and through its undersigned attorneys, requests that
Plaintiff, DEBRA HINES, admit or deny the following pursuant to Rule 1.370, Florida Rules of
Civil Procedure:
22. Your lawyers received the correspondence attached hereto as EXHIBIT A on or about
September 18, 2015.
23. Your lawyers sent the e-mail correspondence attached hereto as EXHIBIT B on January
4, 2016.
24. You were provided the opportunity to observe the performance of the hand auger borings
reported in the attached COMPOSITE EXHIBIT C.
25. You were provided the opportunity to observe the performance of the SPT borings
reported in the attached COMPOSITE EXHIBIT D.
26. You did not provide the Defendant with the opportunity to observe the performance of
the hand auger borings reported in the attached EXHIBIT E.
27. You did not provide the Defendant with the opportunity to observe the performance of
the SPT borings reported in the attached EXHIBIT F.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@gimail.com, and Morgan
Barfield at Mbarfield@CorlessBarfield.com on this 24" day of June, 2016.
By:
14211
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)
Tefhut 1 Lebete
ROBERT T. SCHULTE, ESQ.
FBN: 888197650 W. Courtney Campbell Causeway | Suite 800
GROELLE Tampa, FL 33607
&
P: 813-849-7200
SALMON F; 813-849-7201
Case
September 18, 2015 CACE-14-016655
Via Electronic Mail Exhibit
Ryan Sherman, Esquire A
Sherman Law, P.A.
4000 Hollywood Blvd., Ste 265-S
Hollywood, FL 33021
RE: Insured: Debra Hines
Claim No.: 821089
Policy No.: 1HPC1540319
Date of Loss: 2/20/2012
Our File No.:. HCP.14211-CL
Dear Mr. Sherman:
As you know, this firm represents Homeowners Choice with respect to litigation concerning to
the above referenced claim under policy 1HPC1540319 for an alleged “sinkhole loss” occurring
on or about February 20, 2012.
Many of the testing methodologies utilized by experts in the field(s) of geology and/or
engineering are inherently destructive testing, the results of which cannot be verified or
reproduced once the testing has been performed. Therefore, Homeowners Choice is demanding
it be afforded the opportunity to be present for any and all destructive testing performed.
Homeowners Choice will be prejudiced if it is foreclosed from observing any additional testing.
Please govern yourself accordingly.
None of the foregoing is to be interpreted as a concession by Homeowners Choice that
geological, geotechnical, or geophysical testing performed at the present date is relevant to show
the cause of the February 20, 2012 loss or the conditions of the subject property during the
relevant policy period. This correspondence is a good faith effort to preserve evidence.
If you have any questions, please contact the undersigned.
Very truly yours,
GROELLE & SALMON, P.A.
Tifa T, Lebecber
Robert T. Schulte
For the Firm
RTS/tms
OC. spoliation.091715
WWW.GSPALAW.COM
WEST PALM BEACH | TAMPA | VERO BEACH | SARASOTA | MIAMI | ORLANDO | ST, PETERSBURGFrom:
Sent:
To:
Ce:
Subject:
Morgan Barfield Case
Monday, January 04, 2016 5:25 PM CACE-14-016655
Jonathan Hall
Julio Martinez; Robert Schulte; Ryan Sherman; Brenda minors ae
Re: Hines v. HOC - Inspection aaa
Jon thats ok if its only hand augers and nothing further, especially spts. So you guys think this is an organic
issue huh?
Sent from my iPhone
On Jan 4, 2016, at 5:22 PM, Jonathan Hall wrote:
Good afternoon Mr Martinez. Sorry for the delay. I thought Mr. Schulte responded to you and
he thought I had. Our expert wants to do some hand auger borings. Please confirm your
consent.
Sent from my iPad
On Dec 31, 2015, at 1:51 PM, Julio Martinez wrote:
Gentlemen,
We're in receipt of your motion. Unfortunately we had a mixup on our end
filing the timely objection. Thus, will will not need to proceed with a
hearing on your motion. Please ask your staff to coordinate the site
inspection with Brenda Minors (cc'ed).
That said, please do remind me who will be inspecting and the scope
thereof. If memory serves, there was no destructive testing involvement. If
so, we may in fact need to have Judge Bowman consider the issue. Thank
you, have a save and happy new year.
Best Regards,
Julio Martinez, Esq.
Sherman Law PA
4000 Hollywood Blvd. Suite 265-S
Hollywood, FL 33021
Tel: 954-894-8000
Fax: 305-397-1725
The information contained in this e-mail message is intended only for the personal and confidential
use of the recipient(s) named above. This message and its attachments may be an attorney-client
communication and, as such, is privileged and confidential. If the reader of this message is not the
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0z wim pues Zuenb wnipaw | | SL uum pues Zuenb whipew oz
Zuenb wnipow oy pues zyenb wnipow 0} ouy (1/9 HAOL) ABD 0} auy (1/9 YAOL) Kes
(Lip YAOL) Aes6 0} ouy Auts (1/5 HAOL) WS-dS) LIS HLIM 2(WS-dS) 11S HLIM
=ueq (WS) GNVS ALTIS Kei (WS) ONVS ALIS ONVS G30VYeS ATHOOd NVS G30VeS ATHOOd
0 0 0 0
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10 10
15 15)
20 20
25 2.5]
3.0 3.0
3.5 v v v 3.5]
40 vy 4.0)
48 v 45
5.0 5.0
LEGEND
aS rine SAND wth ne sano (SP) Unie So Classiicaton System iH
rane & 10 Hand Gone Penetometer Value ker)
¥__ Groundwater encountered
Hines Residence Groelle & Salmon
Miramar, FL
ENVIRONMENTAL + GEOTECHNICAL B SCALE AS| Figure 3
BUILOING SCIENCES » MATERIALS TESTING SHOWN Hand Auger Logs come= wid COMMENTS
= PENETRATION BLOW > |90 Water Tabl.
z= n DESCRIPTION 2 2 za ater ; able
oa blows per foot COUNTS > |£| Drilling Fluid Losses
wl Z |%| ft. =ft. bls (typical)
9 Hi
POORLY GRADED SAND WITH land auger boring from 0-4 ft.
SILT (SP-SM): Gray (10YR 6/1) fine ; ;
f ppt resistances @ 1,2,3,4 ft:
to medium quartz sand with silt ley Serato teen
5 SILTY SAND WITH ORGANICS
(SM-PT): Black (10YR 2/1) silty fine 4Mi2i7 3 NoEV from 4-8 ft.
to medium quartz sand
approximately 65.5% organics
(app ly ganics) 771716 14 Niesishal alcatel
POORLY GRADED SAND (SP): wormwounn {4
10 Very loose to medium dense EFR @ 8 ft. @ 15 gpm
Very-pale-brown (10YR 8/2) fine to
medium quartz sand
NoEV from 13.5 ft. to end of boring
15 20 40 60 80100 s/S/6 4
Case
20 beh a CACE-14-016655
| Exhibit
25 P entint 22 D
30 2040-60 80100] 5/6/7 13
35 4132 5
40 fn 31/616 12
LIMESTONE: Strong to extremely RLOC @ 42.5 ft.
45-1 strong
White (10YR 8/1) limestone gravel 20°40 60 80100 11/14/14 28
and granules, with calcareous clay I. che bea felts telat
boring
50 50 blows for 5 inches of penetration
_/}20130150+ too] | Dace
/
J
/
555 47121130 51 TOB @ 55 ft. bs.
] Grouted borehole
60
ROL Insurance Consulting
Tampa, Florida
SPT BORING LOG
SITE NAME: Hines Residence
SITE LOCATION: Miramar, Florida
DESIGNED BY: JMW
CHECKED BY: MLF
DRAWN BY: MVK
PROJECT NO: 80116654 BORING
BORING DATE: 05/24/12 B-1
PAGE NO: 1 of 1 7= wid COMMENTS
= PENETRATION BLOW 2/9 Water Table
Zo DESCRIPTION 272 er
oa blows per foot COUNTS > |£| Drilling Fluid Losses
wi 7 7
a z/|9 ft. = ft. bls (typical)
0
POORLY GRADED SAND (SP): Hand auger boring from 0-4 ft.
White (10YR 8/1) fine to medium ,
ppt resistances @ 1,2,3,4 ft:
quartz sand 30/20/30/10 kg/sq cm
5 SILTY SAND WITH ORGANICS
(SM-PT): Very loose 4217 3 NEV tron 28.
Dark-brown (10YR 3/3) fine to
medium quartz sand with silt 718/718 18
(approximately 7% organics) EFR @ 8 ft. @ 15 gpm
10 worniwon 2 MODMOR from 8-8.5 ft., then 1/1,
POORLY GRADED SAND (SP): then MODWOH from 9.5-10
Very loose to medium dense
Very-pale-brown (10YR 8/2) fine to
medium quartz sand NoEV from 13.5-33.5 ft.
15 80 100 2/3/5 8
20 4/416 10
25 4I617 13
30 80 100 7/8/12 20
35 4/2WOH 2 MODMOH from 34.5-35 ft.
LIMESTONE: Moderately strong to aug art
strong
40-5 White (10YR 8/1) limestone gravel 3/8/7 15 Beg teers ieee
and granules, with calcareous clay Neat from 38.5 ft. to end of boring
45 80 100 6/7/9 16
50 1403/14 27 TOB @ 50 ft. bls.
Grouted borehole
ROL Insurance Consulting
Tampa, Florida
SPT BORING LOG
SITE NAME: Hines Residence
SITE LOCATION: Miramar, Florida
DESIGNED BY: JMW
CHECKED BY: MLF
DRAWN BY: MVK
PROJECT NO: 80116654 BORING
BORING DATE: 05/24/12
B-2
PAGE NO: 1 of 1= wid COMMENTS
= PENETRATION BLOW 2/9 Water Table
Zo DESCRIPTION 272 er
oa blows per foot COUNTS > |£| Drilling Fluid Losses
wl Z |%| ft. =ft. bls (typical)
9 Hand boring from 0-4 ft
POORLY GRADED SAND (SP): Ree a een
White (10YR 8/1) fine to medium ,
ppt resistances @ 1,2,3,4 ft.
quartz sand 30/25/8/7 kg/sq cm
5 POORLY GRADED SAND WITH
SILT (SP-SM): Very loose « aan 4 NoEV from 4-33.5 ft
Dark-brown (10YR 3/3) fine to \
medium quartz sand with silt and ’ TITI716 14 EFR @ 6 ft. @ 15 gpm
trace organics !
10 1 314168 8
POORLY GRADED SAND (SP): '
Loose to medium dense
Very-pale-brown (10YR 8/2) fine to |
medium quartz sand |
15 lo" 20 40 60 80100 4/5/6 4
cai , 5/818 16
I
25 + eri? 14
i
30 lo’ 204060 80100 a/asa 8
'
To] LIMESTONE: Moderately strong to ' RLOC @ 33 ft
35 very strong 4
I L) White (10¥R 8/4) limestone gravel WoR/2i4 6 MODAWOR from 33.5-34 ft.
[] 2nd granules, with calcareous clay
4 I NoEV from 38.5 ft. to end of boring
40-1] : , 6/9/11 20
a
I
4+7T
45 I lo 20° 40 60 80100 10/12/15 27
tT
4
I
505 7 15/20/24 44 TOB @ 50 ft. bls.
1 Grouted borehole
55
60
SPT BORING LOG
ROL Insurance Consulting SITE NAME: Hines Residence
Tampa, Florida SITE LOCATION: Miramar, Florida
DESIGNED BY: JMW PROJECT NO: 8011665A BORING
CHECKED BY: MLF BORING DATE: 05/24/12 B-3
DRAWNBY: = MVK PAGE NO: 1 of 4 7B-1
20
25
30.
35;
40
45.
50 ————_
Groundwater
level deeper
than 10 feet
—LEGEND_
Baas
Tan and brown fine SAND (SP)
Block ORGANIC silty SAND (OL)
Light ton weathered LIMESTONE (LS)
Light tan LIMESTONE (LS)
HA Hand Auger
4 % Circulation Loss
¥ Groundwater Level
—NOTES _
>
Located 12 feet east and 3 feet north of
northwest corner of home
HINES RESIDENCE
3816 S. Lake Terrace
Miramar, Florida
=o | COE
HHO OH Haneckl Consulting Engineers, In.
17633 Gunn Highway, Suite 119
SCALE: Odessa, Florida 33555
N/A
PROJ. NO:
ONE: 319-2013 130019 FIGURE: 4
—Report of Settlement Investigation & Structural Damage Evaluation
Hines Residence ‘Miramar, Broward County, Florida Case
Corless Barfield Trial Grou
June 8.2016 ° CACE-14-016655
Page 7
FTE Project No.: 16-15615 -_
Exhibit
The shallow subsoil lithology has been tabulated below: E
Auger Boring No: HAB-1
Location: See Boring Location Plan
Existing G.W.T.: Not Encountered
Soil Lithology:
0.0 - 6.0" Grey, Fine Sand (SP)
6.0 - 18.0" Light Grey, Sand with Rock (SP)
Boring Terminated at 18.0 inches Below Existing Land Surface,
JERI IOC AIO III IIIA TORO IAT IO IOI OOO TAA ITA ISIS A SASS A IA TI III SER eh eee
Auger Boring No: HAB-2
Location: See Boring Location Plan
Existing G.W.T.: Not Encountered
Soil Lithology:
0.0 -6.0" Dark Grey, Fine sand with Rocks with trace of Organics (SP-OL)
Boring Terminated at 6.0 inches Below Existing Land Surface.
JRA III EIEIO III III IIIA TTI IO IATA II IAT IIIT IIIS AA RAO de ek teh ke
Auger Boring No: HAB-3
Location: See Boring Location Plan
Existing G.W.T.: 60.0" B.L.S.
Soil Lithology:
0.0 - 6.0" Grey, Fine Sand (SP)
6.0 - 48.0" Light Tan, Sand (SP)
48.0 - 60.0" Tan and Grey, Sand (SP)
Boring Terminated at 60.0 inches Below Existing Land Surface.
SHRI SSDI IRIS ISI DO DI I IORI IDOI IGT OI IOO IIA ITI OT IIIT AISA ISAT ASIII ASA I eee ee
Auger Boring No: HAB-4
Location: See Boring Location Plan
Existing G.W.T.: 60.0" B.L.S.
Soil Lithology:
0.0 - 12.0" Grey, Fine Sand with Roots and Rocks (SP)
12.0 - 48.0" Light Tan, Sand (SP)
48.0 - 60.0" Tan and Grey, Sand (SP)
Boring Terminated at 60.0 inches Below Existing Land Surface.
JERE OBIE IID IO OECTA SI AIT SOIT AAI TA I IA III IS beh eeReport of Settlement Investigation & Structural Damage Evaluation
Hines Residence -Miramar, Broward County, Florida
Corless Barfield Trial Group
June 9, 2016
Page 8
FTE Project No.: 16-15615
Auger Boring No: HAB-5
Location: See Boring Location Plan
Existing G.W.T.: 60.0 Inches B.L.S.
Soil Lithology:
0.0 - 12.0" Dark Grey, Fine sand with Roots (SP)
12.0 - 48.0" Light Tan, Sand (SP)
48.0 - 60.0" Tan and Grey, Sand (SP)
Boring Terminated at 60.0 inches Below Existing Land Surface.
THROATS IIIT II IOI ORION IIIT III IIIT ITI TIA TS II OSI ISIS I Ao dei etch ee
Auger Boring No: HAB-6
Location: See Boring Location Plan
Existing G.W.T.: 60.0 Inches B.L.S.
Soil Lithology:
0.0 - 12.0" Grey, Fine Sand with Rock (SP)
12.0 - 42.0" Light Tan, Sand (SP)
42.0 - 60.0" Tan and Grey, Sand with Organics (SP-OL)
Boring Terminated at 60.0 inches Below Existing Land Surface.
ZEEE IRSA IIIA IIIA IER IIIT IIIT IIIA III ITO ISIS A GAAS IA IRI I IAS ehh
Auger Boring No: HAB-7
Location: See Boring Location Plan
Existing G.W.T.: 54.0 Inches B.L.S.
Soil Lithology:
0.0 - 6.0" Grey, Fine Sand with Rock (SP)
6.0 - 36.0" Light Tan, Sand (SP)
36.0 - 48.0" Tan and Grey, Sand with Roots (SP)
48.0 - 54.0" Tan, Grey and Brown, Sand with Organics (SP-OL)
Boring Terminated at 54.0 inches Below Existing Land Surface.
TEES IO TIE IIT IT II III TAT IATA I SITIO IO SIO IAI AT OASIS UO DONO AI IRI A I
Auger Boring No: HAB-8
Location: See Boring Location Plan
Existing G.W.T.: Not Encountered
Soil Lithology:
0.0 - 6.0" Grey, Fine Sand (SP)
Boring Terminated at 6.0 inches Below Existing Land Surface.
JERSE II IOI I III AT STII I IOI SOO SISO SI DOSS SIS OA SOA AA AS AAA A hk ekeReport of Settlement Investigation & Structural Damage Evaluation
Hines Residence -Miramar, Broward County, Florida
Corless Barfield Trial Group
dune 9, 2016
Page 9
FTE Project No.: 16-15615
Auger Boring No: HAB-9.
Location: See Boring Location Plan
Existing G.W.T.: 60.0 Inches B.L.S.
Soil Lithology:
0.0 - 6.0" Grey, Fine Sand (SP)
6.0 - 48.0" Light Tan, Sand (SP)
48.0 - 60.0" Tan and Grey, Sand (SP)
Boring Terminated at 60.0 inches Below Existing Land Surface.
FEB IIE III SIDI III III IOI III IIIA IIS OO I IIIS OS IIA III AISI IIA AS OSE ASAI IS et A ehGENERALIZED SUBSURFACE PROFILE
; Penetration
Soil Description BLOWS PER FOOT
0 10 20 30 40 60 80 100
LOOSE TO VERY LOOSE, GREY, FINE SAND | chad
(SP) 69(2,313,4)
56(4,3,2,2)
jot = = 7 7 6.0 FT) 44(2,1,1,4)
MEDIUM DENSE, GREY TO LIGHT GREY,
FINE SAND (SP)
LOOSE TO VERY LOOSE, LIGHT GREY,
COARSE, SAND (SP)
Case
CACE-14-016655
Exhibit ___ 79(3,8.4)
F
35.0 FTI,
LOOSE, LIMESTONE FRAGMENTS WITH —
LIGHT GREY, SAND (SP-LS)
LUTION OF LIMESTONE
40.0 FT}
NO RECOVERY
PS
BORING TERMINATED AT 46,0 FEET 46.0 F| “59 450/0")
NOTE: 100% LOSS OF CIRCULATION AT 40.0 FEET
Project: UIINUS RESIDENCE Client: CORLESS BARFIELD TRIAL GROUP
Address: MIRAMAR, FLORIDA Ground Water: 4.0- 6.04 PEE
Project No. !5-15615 Date: JUNE 2016 Boring No.: SPT-i
=“
Boring and Sampling meet ASTM D-1586 Core
Drilling meets ASTM D-2113
Penetration is the number of blows of 140 Florida Testing &
pound hammer falling 30 inches required to
drive 1.4 inch I.D. sampler 1 foot. Environmental, Inc.GENERALIZED SUBSURFACE PROFILE
Penetration
Soil Description BLOWS PER FOOT
0 10 20 30 40 60 80 100
LOOSE, DARK BROWN, FINE SAND WITH l ] > 8
ORGANICS (SP-OL) a 2,43) eS
4.0 FT| 69(43.3.2)
LOOSE TO MEDIUM DENSE, GREY TO 7
LIGHT GREY, FINE SAND (SP)
| = ae Pere 10.0 FT
LOOSE, LIGHT GREY, COARSE SAND (SP)
643.313)
| 944,4,5)
| as a 7 a 25.0FT 6(4,3/3) |
LOOSE TO VERY LOOSE, LIGHT GREY,
COARSE SAND WITH LIMESTONE
FRAGMENTS (SP-LS)
D Hg er MES TONE, 2,24) ar
BOREHOLE COLLAPSED
BORING TERMINATED AT 33.0 FEET 33.0 FTL 29 (4/12"2) |
Project: HINUS RESIDENCE Client: ~=CORLESS BARFIELD TRIAL GROUP
Address: MIRAMAR, FLORIDA Ground Water: 4.0- 6.02 PEF
Project No. 15-!S615
Boring and Sampling meet ASTM D-1586 Core
Drilling meets ASTM D-2113
Penetration is the number of blows of 140
pound hammer falling 30 inches required to
drive 1.4 inch I.D. sampler 1 foot.
Date: JUNF 2016
Boring No.: Spy-2
FTE
Florida Testing &
Environmental, Inc.Filing # 43313741 E-Filed 06/28/2016 12:56:33 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA.
CIVIL DIVISION
DEBRA HINES
Plaintiff,
CASE NO.: CACE-14-016655
vs. DIVISION: 02
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC. EXHIBIT B
a Florida Corporation
Defendant.
/
/
PLAINTIFF’S_ RESPONSES TO DEFENDANT’S
SECOND REQUEST FOR ADMISSIONS
Plaintiff, DEBRA HINES, by and through the undersigned counsel, and pursuant to rule
1.370 of the Florida Rules and Civil Procedures, hereby responds to Defendant’s Second Request
for Admissions dated June 24, 2016. The Plaintiff responds as follows:
22. ANSWER: Admitted.
23. ANSWER: Admitted.
24. ANSWER: Admitted.
25. ANSWER: Admitted.
26. ANSWER: Denied as phrased.
27. ANSWER: Denied as phrased.CERTIFICATE _OF SERVICE
IT HEREBY CERTIFY that a true and correct copy of the foregoing document has been
electronically filed with the Clerk of Court using the Florida Courts E-Filing Portal and served
via Florida Courts E-Filing Portal Electronic Mail to: Jonathan T. Hall, Esq.,
grobinson@ gspalaw.com and gstcourtdocs@ gspalaw.com, Groelle & Salmon, PA, 7650 Courtney
Campbell Cswy., Ste. 800, Tampa, FL 33067 and Ryan H. Sherman, Esq.,
com on this 28th day of June 2016.
eserviceslpa@ gmail.
/s/ Morgan Barfield
Morgan Barfield, Esq.
Co-Counsel for Plaintiffs
Corless Barfield Trial Group, LLC
6812 W. Linebaugh Avenue
Tampa, Florida 33625
(813) 258-4998
(813) 258-4988 — Facsimile
MBarfield@CorlessBarfield.comIN 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 & EXHIBIT Cc
CASUALTY INSURANCE COMPANY, INC.
a Florida Corporation,
Defendant.
/
DEFENDANT’S NOTICE OF SERVING
THIRD SET OF INTERROGATORIES TO PLAINTIFF
Defendant, by and through undersigned counsel, and serves the following attached
Interrogatories, numbered 38 — 39, to Plaintiff to be answered in writing and under oath pursuant
to Rule 1.340, Florida Rules of Civil Procedure.
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 Mbarficld@oCorlessBarficld.com on this 29" day of June, 2016.
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: Stout 1. Aebeste-
ROBERT T. SCHULTE, ESQ.
14211 FBN: 88819IN 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.
/
INTERROGATORIES TO PLAINTIFF
38. Please explain the complete factual basis for Plaintiff's response to the Defendant’s
Request for Admission no. 26; inclusive of all ways in which Plaintiff provided the
Defendant the opportunity to observe the performance of the hand auger borings in
question.
39. Please explain the complete factual basis for Plaintiff's response to the Defendant’s
Request for Admission no. 27; inclusive of all ways in which Plaintiff provided the
Defendant the opportunity to observe the performance of the SPT borings in question.STATE OF FLORIDA. )
COUNTY OF )
DEBRA HINES, duly sworn upon oath, deposes and says that the foregoing answers to
interrogatories are true and correct to the best of my knowledge, information, and belief at this
time.
By:
DEBRA HINES
The foregoing instrument was acknowledged before me this day of 7
2016 by DEBRA HINES who is personally known to me or who has produced
as identification and who did/did not take an oath.
Notary Public
Commission No.:
My commission expires:IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CIVIL DIVISION
DEBRA HINES
Plaintifé
CASE NO.: CACE-14-016655
vs. DIVISION: 02
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC. EXHIBIT D
a Florida Corporation.
Defendant.
/
PLAINTIFI’S NOTICE OF SERVING ANSWERS TO
DEFENDANT'S THIRD SET OF INTERROGATORIES
Plaintiff DEBRA HINES, by and through the undersigned counsel and pursuant to Rule
1.340 of the Florida Rules of Civil Procedure, hereby gives notice that Plaintiffs answers to
Defendant's Third Set of Interrogatories, have been served upon Defendant, HOMEOWNERS
CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document has been.
electronically filed with the Clerk of Court using the Florida Courts E-Filing Portal and served
via Florida Courts E-Filing Portal Electronic Mail to: Jonathan T. Hall, Esq.,
gobinson@gspalaw.com and gstcourtdocs@gspalaw.com, Groelle & Salmon, PA, 7650 Courmey
Campbell Cswy., Ste. 800, Tampa, FL 33067 and Ryan H. Sherman, Esq.,
eserviceslpa@emailcom on this 25th day of July 2016.
/s/ Morgan Barfield
Morgan Barfield, Esq.
Co-Counsel for Plaintiffs
Corless Barfield Trial Group, LLC
4350 W. Cypress Street, Suite 910
Tampa, Florida 33607
(813) 258-4998
(813) 258-4988 — Facsimile
MBarfield@CorlessBarfield.comPLAINTIFF’S ANSWERS AND OBJECTIONS TO
DEFENDANT’S THIRD SET OF INTERROGATORIES
Plaintiff DEBRA HINES, by and through the undersigned counsel, and pursuant to rule
1.340 of the Florida Rules and Civil Procedures, hereby answers Defendant’s Third Set of
Interrogatories dated June 29, 2016. The Plaintiff answers the interrogatories as follows:
38. Please explain the complete factual basis for Plaintiff's response to the Defendant’s
Request for Admission no. 26; inclusive of all ways in which Plaintiff provided the
Defendant the opportunity to observe the performance of the hand auger boring in question.
ANSWER: Plaintiff objects to Interrogatory No.38 on the grounds that Defendant
bas exceeded the allowable number of Interrogatories, including subparts, pursuant
to Rule 1.340, Florida Rule of Civil Procedure.
39. Please explain the complete factual basis for Plaintiffs response to the Defendant’s
Request for Admission no. 27; inclusive of all ways in which Plaintiff provided the
Defendant the opportunity to observe the performance of the SPT borings in question.
ANSWER: Plaintiff objects to Interrogatory No.38 on the grounds that Defendant
has exceeded the allowable number of Interrogatories, including subparts, pursuant
to Rule 1.340, Florida_Rule of Civil Procedure.STATE OF FLORIDA )
county oF Dr award )
DEBRA HINES, duly sworn upon oath, deposes and says that the foregoing answers to
interrogatories are true and correct to the best of my knowledge, information, and belief at this
time. oo™
By: EM)
DEBRA S
The foregoing instrument was acknowledged before me this 2 dX day of July 7
2016 by DEBRA HINES who is personally known to me or who has produced
FL Drivers License
HS 20 -170-5% - 4-0 as identification and who did/did not take an oath.
i"
BRENDA MINORS
Notary Public - State of Florida
Commission # FF 185923
My Comm. Expires Dec 28, 2018
Bonded through National Notary Assn.
Notary Public
Commission No.: FF IR S 4 a 3
My commission expires:
Preview
Filing # 49431234 E-Filed 11/30/2016 11:23:37 AM IN THE CIRCUIT COURT, OF THE 17™ JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE-14-016655 DIV. 02 DEBRA HINES, Plaintiff, vs. HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. a Florida Corporation, Defendant. / DEFENDANT’S MOTION FOR LEAVE TO SERVE ADDITIONAL INTERROGATORIES COMES NOW, the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, by and through undersigned counsel, and pursuant to Fla. R. Civ. P. 1,340 and hereby files this Motion for Leave to Serve Additional Interrogatories and in support thereof states: 1, Standard of Appellate Review: “In the case of an order regarding discovery, the trial court has broad discretion. Only when an order allowing discovery constitutes an abuse of discretion which would cause irreparable damage should the ruling be set aside.” Baker by and through Baker v. Eckerd Corp., 697 So. 2d 970 (Fla. 2d Dist. Ct. App. 1997). 2. Florida Rules of Civil Procedure 1.340 permits each party to serve thirty (30) interrogatories to an opposing party. This rule is not meant as an absolute bar to limit the number of interrogatories in every case to thirty (30). Instead, the purpose of this rule, as of the other discovery rules, is to avoid unnecessary costs, minimize delay and narrow the issues at trial, to the extent the request is consistent with Rule 1.340. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/30/2016 11:23:35 AM.****3. This is an action regarding an insurance claim for sinkhole loss to Plaintiff's property where the parties dispute whether a sinkhole loss has occurred. 4, On September 18, 2015, the Defendant requested to be afforded the opportunity to be present for any destructive testing to the property. 5. Subsequently, in June of 2016, Plaintiffs’ retained Florida Testing & Environmental, Inc. who performed destructive testing at the property. 6. On June 24, 2016, Defendant served six (6) requests for admissions upon Plaintiffs, numbered 22 through 27, attached hereto as Exhibit A. 7. On June 28, 2016, Plaintiff responded to Defendant’s requests, admitting requests nos. 22 through 25 and responding to requests nos. 26 and 27 as follows: “Denied as phrased”. See Exhibit B. 8. Seeking an explanation for Plaintiff's denials to requests nos. 26 and 27, Defendant propounded interrogatories nos. 38 and 39 upon the Plaintiff. See Exhibit C. 9. In response, Plaintiff objected to interrogatories nos. 38 and 39 on the basis that they exceeded the allowable number of interrogatories pursuant to Rule 1.340, Florida Rule of Civil Procedure. See Exhibit D. 10. The Florida Second District Court of appeals has held that “a party would be well advised to follow up a denial of a request for admission with an interrogatory seeking an explanation of the denial.” Anthony v. Schmitt, 557 So. 2d 656, 660 n.9 (Fla. 2nd DCA 1990). 11. These interrogatories seek information that is relevant to the subject matter of the pending action and reasonably calculated to lead the discovery of admissible evidence. 12. The information sought in these interrogatories is required by Defendant in preparation of a defense to Plaintiff's claims.13. The information requested is not frivolous, nor is it intended to harass the Plaintiff. 14. Defendant requests the objections be overruled, grant leave to propound additional Interrogatories nos. 38 and 39, nunc pro tunc, and that Plaintiff be compelled to file full and complete responsive answers to interrogatories nos. 38 and 39. 15. | WHEREFORE, the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, requests this Court grant leave to propound additional Interrogatories nos. 38 and 39, nunc pro tunc, and compelling Plaintiffs to file full and complete responses, and any such other relief as deemed appropriate. 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, Esq. at eserviceSLPA@ gmail.com and Morgan Barfield at Service@corlessbarfield.com on this 30" day of November, 2016. 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) rstcourtdo! com rschulte@gspalaw.com Mn T Lbede- ROBERT T. SCHULTE, ESQ. HCP.14211 FBN: 88819 By:14211 IN THE CIRCUIT COURT, OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-14-016655 DIV. 02 DEBRA HINES, Plaintiff, - EXHIBIT A HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. a Florida Corporation, Defendant. / DEFENDANT’S NOTICE OF SERVING DEFENDANT’S SECOND REQUEST FOR ADMISSIONS TO THE PLAINTIFFS COMES NOW the Defendant, HOMEOWNERS CHOICE PROPERTY AND CASUALTY INSURANCE COMPANY, by and through its undersigned attorneys, requests that Plaintiff, DEBRA HINES, admit or deny the following pursuant to Rule 1.370, Florida Rules of Civil Procedure: 22. Your lawyers received the correspondence attached hereto as EXHIBIT A on or about September 18, 2015. 23. Your lawyers sent the e-mail correspondence attached hereto as EXHIBIT B on January 4, 2016. 24. You were provided the opportunity to observe the performance of the hand auger borings reported in the attached COMPOSITE EXHIBIT C. 25. You were provided the opportunity to observe the performance of the SPT borings reported in the attached COMPOSITE EXHIBIT D. 26. You did not provide the Defendant with the opportunity to observe the performance of the hand auger borings reported in the attached EXHIBIT E. 27. You did not provide the Defendant with the opportunity to observe the performance of the SPT borings reported in the attached EXHIBIT F.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@gimail.com, and Morgan Barfield at Mbarfield@CorlessBarfield.com on this 24" day of June, 2016. By: 14211 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) Tefhut 1 Lebete ROBERT T. SCHULTE, ESQ. FBN: 888197650 W. Courtney Campbell Causeway | Suite 800 GROELLE Tampa, FL 33607 & P: 813-849-7200 SALMON F; 813-849-7201 Case September 18, 2015 CACE-14-016655 Via Electronic Mail Exhibit Ryan Sherman, Esquire A Sherman Law, P.A. 4000 Hollywood Blvd., Ste 265-S Hollywood, FL 33021 RE: Insured: Debra Hines Claim No.: 821089 Policy No.: 1HPC1540319 Date of Loss: 2/20/2012 Our File No.:. HCP.14211-CL Dear Mr. Sherman: As you know, this firm represents Homeowners Choice with respect to litigation concerning to the above referenced claim under policy 1HPC1540319 for an alleged “sinkhole loss” occurring on or about February 20, 2012. Many of the testing methodologies utilized by experts in the field(s) of geology and/or engineering are inherently destructive testing, the results of which cannot be verified or reproduced once the testing has been performed. Therefore, Homeowners Choice is demanding it be afforded the opportunity to be present for any and all destructive testing performed. Homeowners Choice will be prejudiced if it is foreclosed from observing any additional testing. Please govern yourself accordingly. None of the foregoing is to be interpreted as a concession by Homeowners Choice that geological, geotechnical, or geophysical testing performed at the present date is relevant to show the cause of the February 20, 2012 loss or the conditions of the subject property during the relevant policy period. This correspondence is a good faith effort to preserve evidence. If you have any questions, please contact the undersigned. Very truly yours, GROELLE & SALMON, P.A. Tifa T, Lebecber Robert T. Schulte For the Firm RTS/tms OC. spoliation.091715 WWW.GSPALAW.COM WEST PALM BEACH | TAMPA | VERO BEACH | SARASOTA | MIAMI | ORLANDO | ST, PETERSBURGFrom: Sent: To: Ce: Subject: Morgan Barfield Case Monday, January 04, 2016 5:25 PM CACE-14-016655 Jonathan Hall Julio Martinez; Robert Schulte; Ryan Sherman; Brenda minors ae Re: Hines v. HOC - Inspection aaa Jon thats ok if its only hand augers and nothing further, especially spts. So you guys think this is an organic issue huh? Sent from my iPhone On Jan 4, 2016, at 5:22 PM, Jonathan Hall wrote: Good afternoon Mr Martinez. Sorry for the delay. I thought Mr. Schulte responded to you and he thought I had. Our expert wants to do some hand auger borings. Please confirm your consent. Sent from my iPad On Dec 31, 2015, at 1:51 PM, Julio Martinez wrote: Gentlemen, We're in receipt of your motion. Unfortunately we had a mixup on our end filing the timely objection. Thus, will will not need to proceed with a hearing on your motion. Please ask your staff to coordinate the site inspection with Brenda Minors (cc'ed). That said, please do remind me who will be inspecting and the scope thereof. If memory serves, there was no destructive testing involvement. If so, we may in fact need to have Judge Bowman consider the issue. Thank you, have a save and happy new year. Best Regards, Julio Martinez, Esq. Sherman Law PA 4000 Hollywood Blvd. Suite 265-S Hollywood, FL 33021 Tel: 954-894-8000 Fax: 305-397-1725 The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message and its attachments may be an attorney-client communication and, as such, is privileged and confidential. If the reader of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 1No virus found in this message. Checked by AVG - www.a Version: 2015.0.6176 / Virus Database: 4489/11321 - Release Date: 01/04/16epyojy ‘edwe, pou 1sOL “ON AOVd WAN >A NMVUG uasee ZuEliro «= ‘aLva ONTOS SN :A@ G3493HO (anavonday auaHM) NVH vsggLlog “ON LOarOud MWP = Ag GSNOISSG zwo/64 NI SAN TVA NOILVALANSd eplojy sew INOILV901 ALIS HSNd ALVINIXOUddV SALVOIGNI 1431 WOUd NWN109 GNOD3S eouepisey SeulH :SINWN ALIS $9507 ONINO”E YAONV GNVH 6uyinsuog eouesnsu| 104 "SION ONINOS AO NOILVNINYAL SOL NOZINOH 10S GAZATWNV XOUddv ly 319VL YaLVM HOIH IWNOSWAS XOUddv z S1aV.l YALVM XOUddy = aie) sayem alge) sem eet a jonei8auorsou fo @ wiponeo ajpvoiog o © w poreo aurea o. lesnyoy “siIq-Y O'y © GOL lesnyoy “sq 4 0'€ © GOL pesejunooue pesejunooue | Jou aiqe) JEM you age} 1812 re g 8 uo wo o =| 2 Lo sojueBso 89eJ) YIM. 9 9 oso ‘So pues zyenb wnipaw o} et £0 (bp YAO}) Aes6 °o na a WS) GNVS ALIS g (soiebso oO %62z Alaveurxosdde) ys sz ss L, UyIM pues zuenb wnipaw | | OL ’ os ’ oy uN (1/Z HAOL) BIG | > (Ld-WS) SOINVONO RLY pues zyenb winipew ov HLIMGNYS ALIS |] 4) 7 0} auy (L/2 YAOL) pues pues Kes6-\y617 (dS) GNVS “yee jenes6 Zuenb wnipaw 0} auy. Zuenb wnipew o} auy. a3qvyo ATHOOd 0z eu0}SeUUl] YUM pues (1/8 MAOL) eum (aS) oe (1/8 HAOL) eHUM (ds) 0z Zyenb winipaw oF auy (L/L z GNVS G3dVYO ATHOOd z GNVS G3avuo ATHOOd @ YAOL) AesB4y6r7 (aS) GNVS G3GVvu9 ATHOOd us D 0z wim pues Zuenb wnipaw | | SL uum pues Zuenb whipew oz Zuenb wnipow oy pues zyenb wnipow 0} ouy (1/9 HAOL) ABD 0} auy (1/9 YAOL) Kes (Lip YAOL) Aes6 0} ouy Auts (1/5 HAOL) WS-dS) LIS HLIM 2(WS-dS) 11S HLIM =ueq (WS) GNVS ALTIS Kei (WS) ONVS ALIS ONVS G30VYeS ATHOOd NVS G30VeS ATHOOd 0 0 0 0 v-VH €-VWH e-WH --VH sia (4) HidaaHA HAS HAT HAS HA-10 Hast HAA2 ° Hao 5 ocs ; Soe os og os Sam 10 10 15 15) 20 20 25 2.5] 3.0 3.0 3.5 v v v 3.5] 40 vy 4.0) 48 v 45 5.0 5.0 LEGEND aS rine SAND wth ne sano (SP) Unie So Classiicaton System iH rane & 10 Hand Gone Penetometer Value ker) ¥__ Groundwater encountered Hines Residence Groelle & Salmon Miramar, FL ENVIRONMENTAL + GEOTECHNICAL B SCALE AS| Figure 3 BUILOING SCIENCES » MATERIALS TESTING SHOWN Hand Auger Logs come= wid COMMENTS = PENETRATION BLOW > |90 Water Tabl. z= n DESCRIPTION 2 2 za ater ; able oa blows per foot COUNTS > |£| Drilling Fluid Losses wl Z |%| ft. =ft. bls (typical) 9 Hi POORLY GRADED SAND WITH land auger boring from 0-4 ft. SILT (SP-SM): Gray (10YR 6/1) fine ; ; f ppt resistances @ 1,2,3,4 ft: to medium quartz sand with silt ley Serato teen 5 SILTY SAND WITH ORGANICS (SM-PT): Black (10YR 2/1) silty fine 4Mi2i7 3 NoEV from 4-8 ft. to medium quartz sand approximately 65.5% organics (app ly ganics) 771716 14 Niesishal alcatel POORLY GRADED SAND (SP): wormwounn {4 10 Very loose to medium dense EFR @ 8 ft. @ 15 gpm Very-pale-brown (10YR 8/2) fine to medium quartz sand NoEV from 13.5 ft. to end of boring 15 20 40 60 80100 s/S/6 4 Case 20 beh a CACE-14-016655 | Exhibit 25 P entint 22 D 30 2040-60 80100] 5/6/7 13 35 4132 5 40 fn 31/616 12 LIMESTONE: Strong to extremely RLOC @ 42.5 ft. 45-1 strong White (10YR 8/1) limestone gravel 20°40 60 80100 11/14/14 28 and granules, with calcareous clay I. che bea felts telat boring 50 50 blows for 5 inches of penetration _/}20130150+ too] | Dace / J / 555 47121130 51 TOB @ 55 ft. bs. ] Grouted borehole 60 ROL Insurance Consulting Tampa, Florida SPT BORING LOG SITE NAME: Hines Residence SITE LOCATION: Miramar, Florida DESIGNED BY: JMW CHECKED BY: MLF DRAWN BY: MVK PROJECT NO: 80116654 BORING BORING DATE: 05/24/12 B-1 PAGE NO: 1 of 1 7= wid COMMENTS = PENETRATION BLOW 2/9 Water Table Zo DESCRIPTION 272 er oa blows per foot COUNTS > |£| Drilling Fluid Losses wi 7 7 a z/|9 ft. = ft. bls (typical) 0 POORLY GRADED SAND (SP): Hand auger boring from 0-4 ft. White (10YR 8/1) fine to medium , ppt resistances @ 1,2,3,4 ft: quartz sand 30/20/30/10 kg/sq cm 5 SILTY SAND WITH ORGANICS (SM-PT): Very loose 4217 3 NEV tron 28. Dark-brown (10YR 3/3) fine to medium quartz sand with silt 718/718 18 (approximately 7% organics) EFR @ 8 ft. @ 15 gpm 10 worniwon 2 MODMOR from 8-8.5 ft., then 1/1, POORLY GRADED SAND (SP): then MODWOH from 9.5-10 Very loose to medium dense Very-pale-brown (10YR 8/2) fine to medium quartz sand NoEV from 13.5-33.5 ft. 15 80 100 2/3/5 8 20 4/416 10 25 4I617 13 30 80 100 7/8/12 20 35 4/2WOH 2 MODMOH from 34.5-35 ft. LIMESTONE: Moderately strong to aug art strong 40-5 White (10YR 8/1) limestone gravel 3/8/7 15 Beg teers ieee and granules, with calcareous clay Neat from 38.5 ft. to end of boring 45 80 100 6/7/9 16 50 1403/14 27 TOB @ 50 ft. bls. Grouted borehole ROL Insurance Consulting Tampa, Florida SPT BORING LOG SITE NAME: Hines Residence SITE LOCATION: Miramar, Florida DESIGNED BY: JMW CHECKED BY: MLF DRAWN BY: MVK PROJECT NO: 80116654 BORING BORING DATE: 05/24/12 B-2 PAGE NO: 1 of 1= wid COMMENTS = PENETRATION BLOW 2/9 Water Table Zo DESCRIPTION 272 er oa blows per foot COUNTS > |£| Drilling Fluid Losses wl Z |%| ft. =ft. bls (typical) 9 Hand boring from 0-4 ft POORLY GRADED SAND (SP): Ree a een White (10YR 8/1) fine to medium , ppt resistances @ 1,2,3,4 ft. quartz sand 30/25/8/7 kg/sq cm 5 POORLY GRADED SAND WITH SILT (SP-SM): Very loose « aan 4 NoEV from 4-33.5 ft Dark-brown (10YR 3/3) fine to \ medium quartz sand with silt and ’ TITI716 14 EFR @ 6 ft. @ 15 gpm trace organics ! 10 1 314168 8 POORLY GRADED SAND (SP): ' Loose to medium dense Very-pale-brown (10YR 8/2) fine to | medium quartz sand | 15 lo" 20 40 60 80100 4/5/6 4 cai , 5/818 16 I 25 + eri? 14 i 30 lo’ 204060 80100 a/asa 8 ' To] LIMESTONE: Moderately strong to ' RLOC @ 33 ft 35 very strong 4 I L) White (10¥R 8/4) limestone gravel WoR/2i4 6 MODAWOR from 33.5-34 ft. [] 2nd granules, with calcareous clay 4 I NoEV from 38.5 ft. to end of boring 40-1] : , 6/9/11 20 a I 4+7T 45 I lo 20° 40 60 80100 10/12/15 27 tT 4 I 505 7 15/20/24 44 TOB @ 50 ft. bls. 1 Grouted borehole 55 60 SPT BORING LOG ROL Insurance Consulting SITE NAME: Hines Residence Tampa, Florida SITE LOCATION: Miramar, Florida DESIGNED BY: JMW PROJECT NO: 8011665A BORING CHECKED BY: MLF BORING DATE: 05/24/12 B-3 DRAWNBY: = MVK PAGE NO: 1 of 4 7B-1 20 25 30. 35; 40 45. 50 ————_ Groundwater level deeper than 10 feet —LEGEND_ Baas Tan and brown fine SAND (SP) Block ORGANIC silty SAND (OL) Light ton weathered LIMESTONE (LS) Light tan LIMESTONE (LS) HA Hand Auger 4 % Circulation Loss ¥ Groundwater Level —NOTES _ > Located 12 feet east and 3 feet north of northwest corner of home HINES RESIDENCE 3816 S. Lake Terrace Miramar, Florida =o | COE HHO OH Haneckl Consulting Engineers, In. 17633 Gunn Highway, Suite 119 SCALE: Odessa, Florida 33555 N/A PROJ. NO: ONE: 319-2013 130019 FIGURE: 4 —Report of Settlement Investigation & Structural Damage Evaluation Hines Residence ‘Miramar, Broward County, Florida Case Corless Barfield Trial Grou June 8.2016 ° CACE-14-016655 Page 7 FTE Project No.: 16-15615 -_ Exhibit The shallow subsoil lithology has been tabulated below: E Auger Boring No: HAB-1 Location: See Boring Location Plan Existing G.W.T.: Not Encountered Soil Lithology: 0.0 - 6.0" Grey, Fine Sand (SP) 6.0 - 18.0" Light Grey, Sand with Rock (SP) Boring Terminated at 18.0 inches Below Existing Land Surface, JERI IOC AIO III IIIA TORO IAT IO IOI OOO TAA ITA ISIS A SASS A IA TI III SER eh eee Auger Boring No: HAB-2 Location: See Boring Location Plan Existing G.W.T.: Not Encountered Soil Lithology: 0.0 -6.0" Dark Grey, Fine sand with Rocks with trace of Organics (SP-OL) Boring Terminated at 6.0 inches Below Existing Land Surface. JRA III EIEIO III III IIIA TTI IO IATA II IAT IIIT IIIS AA RAO de ek teh ke Auger Boring No: HAB-3 Location: See Boring Location Plan Existing G.W.T.: 60.0" B.L.S. Soil Lithology: 0.0 - 6.0" Grey, Fine Sand (SP) 6.0 - 48.0" Light Tan, Sand (SP) 48.0 - 60.0" Tan and Grey, Sand (SP) Boring Terminated at 60.0 inches Below Existing Land Surface. SHRI SSDI IRIS ISI DO DI I IORI IDOI IGT OI IOO IIA ITI OT IIIT AISA ISAT ASIII ASA I eee ee Auger Boring No: HAB-4 Location: See Boring Location Plan Existing G.W.T.: 60.0" B.L.S. Soil Lithology: 0.0 - 12.0" Grey, Fine Sand with Roots and Rocks (SP) 12.0 - 48.0" Light Tan, Sand (SP) 48.0 - 60.0" Tan and Grey, Sand (SP) Boring Terminated at 60.0 inches Below Existing Land Surface. JERE OBIE IID IO OECTA SI AIT SOIT AAI TA I IA III IS beh eeReport of Settlement Investigation & Structural Damage Evaluation Hines Residence -Miramar, Broward County, Florida Corless Barfield Trial Group June 9, 2016 Page 8 FTE Project No.: 16-15615 Auger Boring No: HAB-5 Location: See Boring Location Plan Existing G.W.T.: 60.0 Inches B.L.S. Soil Lithology: 0.0 - 12.0" Dark Grey, Fine sand with Roots (SP) 12.0 - 48.0" Light Tan, Sand (SP) 48.0 - 60.0" Tan and Grey, Sand (SP) Boring Terminated at 60.0 inches Below Existing Land Surface. THROATS IIIT II IOI ORION IIIT III IIIT ITI TIA TS II OSI ISIS I Ao dei etch ee Auger Boring No: HAB-6 Location: See Boring Location Plan Existing G.W.T.: 60.0 Inches B.L.S. Soil Lithology: 0.0 - 12.0" Grey, Fine Sand with Rock (SP) 12.0 - 42.0" Light Tan, Sand (SP) 42.0 - 60.0" Tan and Grey, Sand with Organics (SP-OL) Boring Terminated at 60.0 inches Below Existing Land Surface. ZEEE IRSA IIIA IIIA IER IIIT IIIT IIIA III ITO ISIS A GAAS IA IRI I IAS ehh Auger Boring No: HAB-7 Location: See Boring Location Plan Existing G.W.T.: 54.0 Inches B.L.S. Soil Lithology: 0.0 - 6.0" Grey, Fine Sand with Rock (SP) 6.0 - 36.0" Light Tan, Sand (SP) 36.0 - 48.0" Tan and Grey, Sand with Roots (SP) 48.0 - 54.0" Tan, Grey and Brown, Sand with Organics (SP-OL) Boring Terminated at 54.0 inches Below Existing Land Surface. TEES IO TIE IIT IT II III TAT IATA I SITIO IO SIO IAI AT OASIS UO DONO AI IRI A I Auger Boring No: HAB-8 Location: See Boring Location Plan Existing G.W.T.: Not Encountered Soil Lithology: 0.0 - 6.0" Grey, Fine Sand (SP) Boring Terminated at 6.0 inches Below Existing Land Surface. JERSE II IOI I III AT STII I IOI SOO SISO SI DOSS SIS OA SOA AA AS AAA A hk ekeReport of Settlement Investigation & Structural Damage Evaluation Hines Residence -Miramar, Broward County, Florida Corless Barfield Trial Group dune 9, 2016 Page 9 FTE Project No.: 16-15615 Auger Boring No: HAB-9. Location: See Boring Location Plan Existing G.W.T.: 60.0 Inches B.L.S. Soil Lithology: 0.0 - 6.0" Grey, Fine Sand (SP) 6.0 - 48.0" Light Tan, Sand (SP) 48.0 - 60.0" Tan and Grey, Sand (SP) Boring Terminated at 60.0 inches Below Existing Land Surface. FEB IIE III SIDI III III IOI III IIIA IIS OO I IIIS OS IIA III AISI IIA AS OSE ASAI IS et A ehGENERALIZED SUBSURFACE PROFILE ; Penetration Soil Description BLOWS PER FOOT 0 10 20 30 40 60 80 100 LOOSE TO VERY LOOSE, GREY, FINE SAND | chad (SP) 69(2,313,4) 56(4,3,2,2) jot = = 7 7 6.0 FT) 44(2,1,1,4) MEDIUM DENSE, GREY TO LIGHT GREY, FINE SAND (SP) LOOSE TO VERY LOOSE, LIGHT GREY, COARSE, SAND (SP) Case CACE-14-016655 Exhibit ___ 79(3,8.4) F 35.0 FTI, LOOSE, LIMESTONE FRAGMENTS WITH — LIGHT GREY, SAND (SP-LS) LUTION OF LIMESTONE 40.0 FT} NO RECOVERY PS BORING TERMINATED AT 46,0 FEET 46.0 F| “59 450/0") NOTE: 100% LOSS OF CIRCULATION AT 40.0 FEET Project: UIINUS RESIDENCE Client: CORLESS BARFIELD TRIAL GROUP Address: MIRAMAR, FLORIDA Ground Water: 4.0- 6.04 PEE Project No. !5-15615 Date: JUNE 2016 Boring No.: SPT-i =“ Boring and Sampling meet ASTM D-1586 Core Drilling meets ASTM D-2113 Penetration is the number of blows of 140 Florida Testing & pound hammer falling 30 inches required to drive 1.4 inch I.D. sampler 1 foot. Environmental, Inc.GENERALIZED SUBSURFACE PROFILE Penetration Soil Description BLOWS PER FOOT 0 10 20 30 40 60 80 100 LOOSE, DARK BROWN, FINE SAND WITH l ] > 8 ORGANICS (SP-OL) a 2,43) eS 4.0 FT| 69(43.3.2) LOOSE TO MEDIUM DENSE, GREY TO 7 LIGHT GREY, FINE SAND (SP) | = ae Pere 10.0 FT LOOSE, LIGHT GREY, COARSE SAND (SP) 643.313) | 944,4,5) | as a 7 a 25.0FT 6(4,3/3) | LOOSE TO VERY LOOSE, LIGHT GREY, COARSE SAND WITH LIMESTONE FRAGMENTS (SP-LS) D Hg er MES TONE, 2,24) ar BOREHOLE COLLAPSED BORING TERMINATED AT 33.0 FEET 33.0 FTL 29 (4/12"2) | Project: HINUS RESIDENCE Client: ~=CORLESS BARFIELD TRIAL GROUP Address: MIRAMAR, FLORIDA Ground Water: 4.0- 6.02 PEF Project No. 15-!S615 Boring and Sampling meet ASTM D-1586 Core Drilling meets ASTM D-2113 Penetration is the number of blows of 140 pound hammer falling 30 inches required to drive 1.4 inch I.D. sampler 1 foot. Date: JUNF 2016 Boring No.: Spy-2 FTE Florida Testing & Environmental, Inc.Filing # 43313741 E-Filed 06/28/2016 12:56:33 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. CIVIL DIVISION DEBRA HINES Plaintiff, CASE NO.: CACE-14-016655 vs. DIVISION: 02 HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. EXHIBIT B a Florida Corporation Defendant. / / PLAINTIFF’S_ RESPONSES TO DEFENDANT’S SECOND REQUEST FOR ADMISSIONS Plaintiff, DEBRA HINES, by and through the undersigned counsel, and pursuant to rule 1.370 of the Florida Rules and Civil Procedures, hereby responds to Defendant’s Second Request for Admissions dated June 24, 2016. The Plaintiff responds as follows: 22. ANSWER: Admitted. 23. ANSWER: Admitted. 24. ANSWER: Admitted. 25. ANSWER: Admitted. 26. ANSWER: Denied as phrased. 27. ANSWER: Denied as phrased.CERTIFICATE _OF SERVICE IT HEREBY CERTIFY that a true and correct copy of the foregoing document has been electronically filed with the Clerk of Court using the Florida Courts E-Filing Portal and served via Florida Courts E-Filing Portal Electronic Mail to: Jonathan T. Hall, Esq., grobinson@ gspalaw.com and gstcourtdocs@ gspalaw.com, Groelle & Salmon, PA, 7650 Courtney Campbell Cswy., Ste. 800, Tampa, FL 33067 and Ryan H. Sherman, Esq., com on this 28th day of June 2016. eserviceslpa@ gmail. /s/ Morgan Barfield Morgan Barfield, Esq. Co-Counsel for Plaintiffs Corless Barfield Trial Group, LLC 6812 W. Linebaugh Avenue Tampa, Florida 33625 (813) 258-4998 (813) 258-4988 — Facsimile MBarfield@CorlessBarfield.comIN 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 & EXHIBIT Cc CASUALTY INSURANCE COMPANY, INC. a Florida Corporation, Defendant. / DEFENDANT’S NOTICE OF SERVING THIRD SET OF INTERROGATORIES TO PLAINTIFF Defendant, by and through undersigned counsel, and serves the following attached Interrogatories, numbered 38 — 39, to Plaintiff to be answered in writing and under oath pursuant to Rule 1.340, Florida Rules of Civil Procedure. 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 Mbarficld@oCorlessBarficld.com on this 29" day of June, 2016. 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: Stout 1. Aebeste- ROBERT T. SCHULTE, ESQ. 14211 FBN: 88819IN 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. / INTERROGATORIES TO PLAINTIFF 38. Please explain the complete factual basis for Plaintiff's response to the Defendant’s Request for Admission no. 26; inclusive of all ways in which Plaintiff provided the Defendant the opportunity to observe the performance of the hand auger borings in question. 39. Please explain the complete factual basis for Plaintiff's response to the Defendant’s Request for Admission no. 27; inclusive of all ways in which Plaintiff provided the Defendant the opportunity to observe the performance of the SPT borings in question.STATE OF FLORIDA. ) COUNTY OF ) DEBRA HINES, duly sworn upon oath, deposes and says that the foregoing answers to interrogatories are true and correct to the best of my knowledge, information, and belief at this time. By: DEBRA HINES The foregoing instrument was acknowledged before me this day of 7 2016 by DEBRA HINES who is personally known to me or who has produced as identification and who did/did not take an oath. Notary Public Commission No.: My commission expires:IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION DEBRA HINES Plaintifé CASE NO.: CACE-14-016655 vs. DIVISION: 02 HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. EXHIBIT D a Florida Corporation. Defendant. / PLAINTIFI’S NOTICE OF SERVING ANSWERS TO DEFENDANT'S THIRD SET OF INTERROGATORIES Plaintiff DEBRA HINES, by and through the undersigned counsel and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby gives notice that Plaintiffs answers to Defendant's Third Set of Interrogatories, have been served upon Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document has been. electronically filed with the Clerk of Court using the Florida Courts E-Filing Portal and served via Florida Courts E-Filing Portal Electronic Mail to: Jonathan T. Hall, Esq., gobinson@gspalaw.com and gstcourtdocs@gspalaw.com, Groelle & Salmon, PA, 7650 Courmey Campbell Cswy., Ste. 800, Tampa, FL 33067 and Ryan H. Sherman, Esq., eserviceslpa@emailcom on this 25th day of July 2016. /s/ Morgan Barfield Morgan Barfield, Esq. Co-Counsel for Plaintiffs Corless Barfield Trial Group, LLC 4350 W. Cypress Street, Suite 910 Tampa, Florida 33607 (813) 258-4998 (813) 258-4988 — Facsimile MBarfield@CorlessBarfield.comPLAINTIFF’S ANSWERS AND OBJECTIONS TO DEFENDANT’S THIRD SET OF INTERROGATORIES Plaintiff DEBRA HINES, by and through the undersigned counsel, and pursuant to rule 1.340 of the Florida Rules and Civil Procedures, hereby answers Defendant’s Third Set of Interrogatories dated June 29, 2016. The Plaintiff answers the interrogatories as follows: 38. Please explain the complete factual basis for Plaintiff's response to the Defendant’s Request for Admission no. 26; inclusive of all ways in which Plaintiff provided the Defendant the opportunity to observe the performance of the hand auger boring in question. ANSWER: Plaintiff objects to Interrogatory No.38 on the grounds that Defendant bas exceeded the allowable number of Interrogatories, including subparts, pursuant to Rule 1.340, Florida Rule of Civil Procedure. 39. Please explain the complete factual basis for Plaintiffs response to the Defendant’s Request for Admission no. 27; inclusive of all ways in which Plaintiff provided the Defendant the opportunity to observe the performance of the SPT borings in question. ANSWER: Plaintiff objects to Interrogatory No.38 on the grounds that Defendant has exceeded the allowable number of Interrogatories, including subparts, pursuant to Rule 1.340, Florida_Rule of Civil Procedure.STATE OF FLORIDA ) county oF Dr award ) DEBRA HINES, duly sworn upon oath, deposes and says that the foregoing answers to interrogatories are true and correct to the best of my knowledge, information, and belief at this time. oo™ By: EM) DEBRA S The foregoing instrument was acknowledged before me this 2 dX day of July 7 2016 by DEBRA HINES who is personally known to me or who has produced FL Drivers License HS 20 -170-5% - 4-0 as identification and who did/did not take an oath. i" BRENDA MINORS Notary Public - State of Florida Commission # FF 185923 My Comm. Expires Dec 28, 2018 Bonded through National Notary Assn. Notary Public Commission No.: FF IR S 4 a 3 My commission expires: