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Filing # 39323458 E-Filed 03/22/2016 02:58:49 PM
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,
vs.
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.,
Defendant.
/
DEFENDANT’S MOTION FOR RULING ON PLAINTIFF’S OBJECTIONS TO
DEFENDANT’S FIRST REQUEST FOR ADMISSIONS
COMES NOW the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY
INSURANCE COMPANY, by and through undersigned counsel, pursuant to Florida Rule of
Civil Procedure 1.370, and hereby files this Motion for Ruling on Plaintiff's Objections to
Defendant's First Request for Admissions, and in support thereof states:
1. This is a lawsuit for breach of contract brought by Plaintiff against Defendant for
damages exceeding $15,000.00, alleging Defendant has breached a policy of insurance by failing
to pay the benefits due.
2. On February 3, 2016, Defendant served its First Request for Admissions upon
Plaintiff, a true and correct copy of which is attached hereto as Exhibit A.
3. On March 18, 2016, Plaintiff served Responses to Defendant’s First Request for
Admissions, a true and correct copy of which is attached hereto as Exhibit B.
4, Plaintiff objected to the following Requests:
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 3/22/2016 2:58:48 PM.****Request No. 18:
18. You allege there are no alternative causes, apart from sinkhole loss, of the damages at
issue in this lawsuit,
Response No. 18:
18. RESPONSE: Objection, calls far a legal and expert conclusion.
This request does not call for a legal and expert conclusion; rather, it seeks an admission
or denial as to whether Plaintiff alleges there are no alternative causes of the damages at issue in
this lawsuit, apart from the sinkhole loss. While an opinion as to whether there are/may be
alternative causes of the damages may be an expert opinion/conclusion, Defendant is certainly
entitled to discover what the Plaintiff's allegations are in effort to narrow the issues in this
matter. Plaintiffs objection to this request should be overruled.
Request No. 19:
19. You do not dispute that earth movement due to organic soils is a viable alternative cause
of the damages at issue in this lawsuit.
Response No. 19:
19. RESPONSE: Objection, calls for a legal and expert conclusion.
As with the foregoing, this request does not call for a legal and expert conclusion; rather,
it seeks an admission or denial as to whether Plaintiff disputes that earth movement due to
organic soils is a viable alternative cause of the damages at issue in this lawsuit. While an
opinion as to whether earth movement due to organic soils is a viable alternative cause of the
damages may be an expert opinion/conclusion, Defendant is certainly entitled to discover what
the disputed issues are vis-a-vis the Plaintiff's position in this case with respect to causation ineffort to narrow the issues in this matter. Plaintiff's objection to this request should be
overruled.
Request No. 20:
20. You do not dispute that earth movement duc to organic soils is a viable concurrent cause
of the damages at issue in this lawsuit.
Response No. 20:
20. RESPONSE: Objection, calls for a legal and expert conclusion.
As with the foregoing, this request does not call for a legal and expert conclusion; rather,
it seeks an admission or denial as to whether Plaintiff disputes that earth movement due to
organic soils is a viable concurrent cause of the damages at issue in this lawsuit. While an
opinion as to whether earth movement due to organic soils is a viable alternative cause of the
damages may be an expert opinion/conclusion, Defendant is certainly entitled to discover what
the disputed issues are vis-a-vis the Plaintiff's position in this case with respect to causation in
effort to narrow the issues in this matter. Plaintiff's objection to this request should be
overruled.
5. Pursuant to Florida Rule of Civil Procedure 1.370(a), “A party may serve upon
any other party a written request for the admission of the truth of any matters within the scope of
rule 1.280(b) set forth in the request that relate to statements or opinions of fact or of the
application of law to fact, including the genuineness of any documents described in the request.”
6. The Second District Court of Appeal has recently analyzed the shifting
evidentiary burdens with respect to sinkhole cases where alternative and/or multiple causation is
at issue in Citizens v. Salkey, (Fla. 2" DCA February 26, 2016).7. Defendant is entitled to know whether Plaintiff alleges there exists no alternative
causes for the damages claimed in this lawsuit, or concedes that although alternative causes exist,
they were not the efficient proximate cause of the damages.
8. The information sought in Defendant’s foregoing Request for Admissions is
required by Defendant in preparation of a defense to Plaintiffs claims and Defendant is
prejudiced by Plaintiff's failure to provide adequate responses.
9. The information requested is not frivolous, nor is it intended to harass the
Plaintiffs.
10. The Defendant has incurred attorneys’ fees and costs as a result of Plaintiffs
failure to cooperate with the discovery process and having to bring this Motion before the Court.
ll. The Defendant certifies that it has conferred in good faith with Plaintiff's counsel
in an attempt to obtain the discovery without court action. See Exhibit C.
WHEREFORE, Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY
INSURANCE COMPANY, respectfully requests that this Court enter an Order overruling
Plaintiff's Objections to Defendant’s First Request for Admissions, and award such further relief
as this Court deems 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 at eserviceSLPA@gmail.com, and
Morgan Barfield at Mbarfield@CorlessBarfield.com on this 22" day of March, 2016.
By:
HCP.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)
Wher T Ddbebe>
ROBERT T. SCHULTE, ESQ.
FBN: 8881914211 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,
vs.
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.
a Florida Corporation,
Defendant.
/
- DEFENDANT’S NOTICE OF SERVING
DEFENDANT’S FIRST 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:
1, The document attached hereto as EXHIBIT A is the only policy of insurance in effect on
or about February 20, 2012 with respect to the damages at issue in this lawsuit.
2. You retained public adjusters to represent you with respect to the claim for sinkhole loss
which is the subject of this lawsuit.
3. Your public adjusters and attorneys were authorized to send and receive correspondence
on your behalf.
4. You do not have any photos or other documentation which depict the condition of the
property at any time prior to your observation of damage you contend was caused by
caused by sinkhole on or about February 20, 2012.
5. You observed damage to the property which is the subject of this lawsuit prior to your
observation of damage you contend was caused by caused by sinkhole on or about
February 20, 2012.
6. You observed cracking damage to the property which is the subject of this lawsuit prior
to July 20, 2011.
EXHIBIT
A12.
13.
15,
You did not notice the damage you contend was caused by caused by sinkhole on or
about February 20, 2012 until it was pointed out to you by a third party.
You cannot provide the specific locations upon the building which is the subject of this
lawsuit where you observed damage occur prior to July 20, 2011.
You cannot provide the specific locations upon the building which is the subject of this
lawsuit where you observed damage occur between July 20, 2011 and July 20, 2012.
. You cannot provide the specific locations upon the building which is the subject of this
lawsuit where you observed damage to have increased in size (length, width, or
otherwise), or otherwise worsened between July 20, 2011 and July 20, 2012.
. You cannot provide the specific locations upon the building which is the subject of this
lawsuit where you observed damage to have increased in size (length, width, or
otherwise), or otherwise worsened since July 20, 2012.
Neither you, nor your representatives, have submitted the opinion of a “professional
engineer” or “professional geologist” that “sinkhole activity” has been verified at the
property which is the subject of this lawsuit. For all terms in quotations utilize the
definitions contained within the attached EXHIBIT A and EXHIBIT B.
Neither you, nor your representatives, have submitted the opinion of a “professional
engineer” or “professional geologist” that a “structural damage” condition exists at the
property which is the subject of this lawsuit. For all terms in quotations utilize the
definitions contained within the attached EXHIBIT A and EXHIBIT B.
. Neither you, nor your representatives, have submitted the opinion of a “professional
engineer” or “professional geologist” that a “sinkhole loss” has been verified at the
property which is the subject of this lawsuit. For all terms in quotations utilize the
definitions contained within the attached EXHIBIT A and EXHIBIT B.
The repair estimate attached hereto as EXHIBIT C does not represent the actual cash
value of the sinkhole loss, not including underpinning or grouting or any other repair
technique performed below the existing foundation of the building.
The repair estimate attached hereto as EXHIBIT D does not represent the actual cash
value of the sinkhole loss, not including underpinning or grouting or any other repair
technique performed below the existing foundation of the building.
.In this lawsuit you are alleging the Defendant breached the contract of insurance by
failing to provide coverage for a sinkhole loss.
. You allege there are no alternative causes, apart from sinkhole loss, of the damages at
issue in this lawsuit.19. You do not dispute that earth movement due to organic soils is a viable alternative cause
of the damages at issue in this lawsuit.
20. You do not dispute that earth movement due to organic soils is a viable concurrent cause
of the damages at issue in this lawsuit.
21. In this lawsuit the only relief you are seeking is money damages for the sinkhole loss you
are alleging occurred.
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@CorlessBarfield.com on this 3 day of February, 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)
Mut 7 Dtbecbe-
ROBERT T. SCHULTE, ESQ.
HCP.14211 FBN: 88819
By:EXHIBIT
A
‘tables
Consus CHOICE
Property & CASUALTY
INsuRaANCE Company, INC.
This is a true and correct certified copy of the Declaration page and applicable forms for
James Hines, Policy Number 1HPC1540319
Maween Garwey
Signed:
State of Florida
County of Hillsborough
With respect to the above:
The above named signatory has sworn to and subscribed before me by Maureen Garvey, the
information contained within this document is accurate and true. The above signatory is personally
known to me Robin Hill.
Robin — xtezs~"
‘2Homeowners Chale Propeny
and Casualty ne ou-CSR.
1 ‘emait=shillehepelcom, ceUS
i see
Signature of Notary
Notary Public for the State of Florida
Commission # EE848231
Expires October 31, 2016
HoMEowners CHoIce PRoPERTy & CASUALTY INSURANCE COMPANY, INC.
Post Office Box 22967 | Tampa, Florida 33622
Claims Phone: 877.235.5076 | Claims Fax: 813.443.0830 | www.hepci.comBruening Insurance Agency, inc.
2700 S. Commerce Parkway
Ste. 309
Weston, FL 33331
JAMES HINES
3816 S LAKE TER
MIRAMAR, FL 33023-4948Ty ° PO Box 9181
- Marlborough, MA 01752-9181
www. homewiseinsurance.com
Insurance Company
05/23/2011
Dear Policyholder:
Enclosed is your renewal policy with Home Wise Insurance Company (Rated “A”, Exceptional, from
Demotech, Inc). Depending on where your property is located, your policy premium may have been
affected by an approved rate increase. While HomeWise tries to avoid raising rates, sometimes it is
necessary. Tacreasing frequency of claims, higher costs to repair or replace damaged items and higher
incidences of fraud al] contribute to higher premiums.
In today’s economy we know it is difficult to manage expenses, so we would like to remind you of
various cost saving options that may be available to you such as:
¢ Centrally monitored fire and burglar alarms
* Mitigation or loss prevention devices
¢ Increasing your basic or hurricane policy deductibles
If you think you may qualify, please contact your agent to discuss these cost saving options. Your
renewal time is an excellent opportunity to make changes in policy deductibles and evaluate your need
for other coverages that may only be made effective on the renewal date, Possible coverage changes to
consider (increases or decreases) include:
© Ordinance or Law — Increased Amount of Coverage
e Limited Hurricane Coverage - Screened Enclosures
* Water Back Up and Sump Discharge or Overflow
Tf you pay the policy premium yourself, the bill for your policy is attached. If your insurance premium
is paid from an escrow account, we will bil] your mortgage company. Jn the event that you have
recently refinanced or if the mortgagee or servicing agent has changed within the last several months,
please verify that the correct mortgage holder is listed on your Declarations page to ensure timely
payment and continuation of your HomeWise policy.
Thank you for the trust you have placed in us and renewing your insurance with Home Wise.
bil ~—Q
Dale S. Hammond
President and Chief Executive Officer
Home Wise Insurance Company
HW 2010**Policyholder Notice of Coverage Changes. Please Read Carefully**
Dear Policyholder:
This Notice of Coverage Changes is for informational purposes only, \t is your responsibility to understand the
coverages provided in your insuratice policy and the options available to you. For a complete explanation and
understanding of the coverages provided by your policy, please contact your agent. Your agent can provide you
with further details and to discuss how you can customize your policy to suit your insurance needs. Some policy
changes may only be made on the effective date of the policy. All coverages are subject to the terms, provisions
and conditions of the policy and any endorsements,
Your policy may not include all of the coverages changes or forms changes described in this document. See
endorsement for coverage details.
Different deductible options may be available
Optional coverage for Personal Injury protection is available
Additional Living Expense is covered up to 365 days
Screened pool enclosures are not automatically covered for losses due to hurricane. If you have a pool
enclosure, and you wish to purchase coverage, please contact your agent
Loss of Use coverage includes a 20% co-payment for Hurricane losses. The revised Loss of Use
endorsement (HW 01 10 02 10) provides Loss of Use coverage when the premises where you reside is
“uninhabitable”
Certain fiability coverages, such as Animal Liability, are excluded. Limited coverage is sometimes
available for purchase
For an additional premium, subject to underwriting review, the new Domestic Dog(s) and Cat(s)
endorsement (HW 91 02 10) may be available. The form provides limited coverage for liability arising
out of the ownership and care of domestic dog(s) and cat(s)
Revised Special Provisions ~ Florida (HW 01 09 02 10)
o Coverages moved to separate endorsements: Collapse, Fungi, Sinkhole Loss and Ordinance or Law
o Addition of up to $10,000 as a Special Limit of Liability for Damage to Floors
© Addition of off premises power failure, up to $500 under Refrigerated Property Coverage
o Damage caused by seepage and leakage of water or steam is excluded
Ordinance Or Law Coverage Endorsement (HW 04 77 02 10) will be attached to policies with 25% OR
50% coverage options. Tlie limit will be reflected on the Declarations
For an additional premium, subject to underwriting review, Sinkhole Loss Coverage (HW 07 07 04 11)
endorsement may be added to provide coverage for sinkhole loss to covered property
Thank you for tusnring your property with HomeWise — we appreciate your business!
NOC 0910 Page 4 of 1Wise To mako Inquires, obtaln information or for HOMEOWNERS POLICY DECLARATIONS |
Heme ise assistance in reselving complains abou his
Trourense Gompohy polley, please call your Agent or HomeWise Declaration Effective
P.O, Box 9181 ‘Customer Service at: 07/20/2011
Marlborough, MA 01752-9181 42:01 AM Standard Time
DIRECT BILL 1-866-496-1781
POLICY NUMBER POLICY PERIOD, AGENT CODE
HPC1540319 07/2012011 to 07/202012 862548
| NAMED INSURED AND ADDRESS AGENT |
VAMES HINES Bruening Insurance Agency, Inc.
3816 S LAKE TER 2700 8. Commerce Parkway
MIRAMAR, FL 33023-4948 Ste, 309
Weston, FL 33331
(954) 473-1406
- ~PREMIUM SUMMARY--- moor
BASIC ATTACHED DISCOUNTS MGA FEES / TOTAL
COVERAGES ENDORSEMENTS AND SURCHARGES POLICY
PREMIUM PREMIUM CREDITS PREMIUM
$3,102.00 $482.00 $0.00 $121.00 $3,705.00
FORM CONST YEAR USE NUMFAM OCCUP PROT TERRITORY BCEG
7 CLASS:
HO-3 Masonry 1964 Primary 1 Owner Occupled 5 314 98
WINDSTORM COUNTY TAX REPLACEMENT PRIOR PROOF
LOSS CREDIT CODE CODE COST ON CONTENTS OF INSURANCE
0% 014 Y Y
COVERAGES SECTION! LIMITS PREMIUMS
Coverage -A- Dwelllng $171,000 $3,211.00
Coverage -B- Other Structures $17,100 INCLUDED
Coverage -C- Personal Property $85,500 $0.00
Coverage -D- Loss of Use $34,200 INCLUDED
Section | coverages subject to $2,500 non-hurricane deductible per loss.
Section | sinkhole loss coverage subject to a $2,500 non-hurricane deductible per loss.
Section | coverages subject to a 2% HURRICANE
DEDUCTIBLE (equal to $3,420).
COVERAGES SECTION I PREMIUMS
Coverage -E- Personal Liability $300,000 $18.00
Coverage -F- Medical Payments $2,000 INCLUDED
LOCATION(S) OF PROPERTY INSURED
3816 S LAKE TER, MIRAMAR, FL 33023
THIS POLICY CONTAINS A SEPARATE DEDUCTIBLE
FOR HURRICANE LOSSES, WHICH MAY RESULT IN
HIGH OUT-OF-POCKET EXPENSES TO YOU.
FLOOD COVERAGE IS NOT PROVIDED BY THIS POLICY.
(ay fo —~
Authorlzod Signaturo
HW HO3 01 03 Policy Number: HPC1540319 Insured Copy‘To make inquiries, oblain Information or for = HOMEOWNERS POLICY DECLARATIONS
Hesme \X/ 1sé assistance In resolving complaints about this Declaratlon Effective
Treurance Coumpony policy, please call your Agent or HomeWise
P.O, Box 9181 Customer Service al: 07/20/2014
Marlborough, MA 01752-9181 42:01 AM Standard Time
DIRECT BILL 1-866-496-1781
POLICY NUMBER POLICY PERIOD AGENT CODE
HPC1640319 07/20/2014 to 07/20/2012 86254H
Stelter POLICY FORMS AND ENDORSEMENTS---------- —
NUMBER EDITION DESCRIPTION PREMIUM
HO 00 03 (04/31) Homeowners 3 Special Form
HO 04 96 (04/91) No Sec I] - Llab for Home Day Care Business Limited Sec I
HO 23 70 (04/91) Windstorm Exterior Paint or Waterproofing Exclusions - FL.
HW 00 01 07 09 Signature Page
HW 00 06 02 10 - Existing Damage Exclusion
HW 00 11 05 Important Notice Ordinance and Law and RCC
HW 00 33 02 10 Limited Fungi or Bacterla Coverage Wet or Dry Rot .
Total Limit $10,000 Section |: Each Covered Loss
Total Limit $50,000 Section Il; Aggregate
Total Limit $10,000 Section |: Polley Aggregate
HW 01 09 02 10 Special Provisions - Florida
HW 01 10 02 10 Special Provisions - Loss of Use
HW 03 51 (05/05) Calendar Year Hurricane Deductible - Florida
HW 04 77 02 10 Ordinance or Law Coverage
Total Limit of Liability 25%
HW 07 07 04 11 Sinkhole Loss Endorsement
HW 13 07 09 Standard Pollcy Coverage - Agreement
HW 38 02 10 Special Provisions - Llabllity
HW 39 02 10 - Collapse Coverage Endorsement
HW HO 07 05 Adjusted Bullding Cost Endorsement
HW-365 02 01 (08/05) Personal Property Replacement Cost $482.00
HW03 (03/07) Homeowners 00 03 Special Form :
HW24 (12/06) - Privacy Policy j
HWP 22 (06/06)- Hurricane Exclusion - Screened Enclosures
HWP E 14 (01/08) Important Notice Hurricane Deductible
HWP E10 (02/09) Option to Remove Windstorm Coverage
HWP E11 (07/07) -Option to Remove Contents Coverage
HWP E13 (01/08) Important Notice All Other Perils Deductible Options
OIR-B1-1655 02/10 Notice of Premium Discounts for Hurricane Mitigation
OIR-B1-1670 (1-1-06) Checklist of Coverage
INCLUDED
EMERGENCY ASSESSMENT, CITIZENS PROPERTY INSURANCE CORPORATION $36.00
MGA FEE $25.00
FLORIDA HURRICANE CATASTROPHE FUND $47.00
EMERGENCY MANAGEMENT PREPAREDNESS $2.00
ASSISTANCE TRUST FUND SURCHARGE
2009 FLORIDA INSURANCE GUARANTY ASSOCIATION ASSESSMENT $11,00
Portion of the Total Premium for Hurricane Coverage $1,557.34
Portion of the Total Premium for Non-Hurricane Coverage $1,654.00
This replaces all proviously (sued policy declarations, If any, This policy appiles only to accidents, occurrences, or losses which
happen during the policy period shown above. In case of foss under Section J, only that part of loss ovar stated deductibles applies.
This dactaration pege together with all policy provisions and any olher applicable endorsements complates your policy.
HW HO3 01 03 Policy Number: HPC1540319 Insured CopyOe ‘To make inquiles, obtain Information or for HOMEOWNERS POLICY DECLARATIONS
HeymeWise — Eateriimatenmimaacg., Nonror ae
Toeuronce Cinapany policy, please call your Agent or HomeWiso eclaration Effective
P.O, Box 9181 Customer Service at: 07/20/2011
Marlborough, MA 01752-9181 42:01 AM Standard Time
DIRECT BILL 1-866-496-1781
(POLICY NUMBER POLICY PERIOD AGENT CODE
([HPct640319 07/20/2011 to 07/20/2012 862544
“LAW AND ORDINANCE COVERAGE IS AN
IMPORTANT COVERAGE THAT YOU MAY WISH TO
PURCHASE. YOU MAY ALSO NEED TO CONSIDER
THE PURCHASE OF FLOOD INSURANCE FROM THE
NATIONAL FLOOD INSURANCE PROGRAM. WITHOUT
THIS COVERAGE, YOU MAY HAVE UNCOVERED
LOSSES. PLEASE DISCUSS THESE COVERAGES
WITH YOUR INSURANCE AGENT."
Mortgagee Information
1 BAC HOME LOANS SERVICING LP
ISAOA/ATIMA,
INSURANCE DEPARTMENT 1X2-977-01-03 Loan Number
PO BOX 961206 172583357
FORT WORTH, TX 76161-0206
HW HO3 01 03 Policy Number: HPCI540319 Insured CopyChecklist of Coverage
Policy Type: Homeowner's
(Indicate: Homeowner's, Condominium Unit Qwners, Tenant's, Dwelling, or Mobile Home Owner's)
The following checkilst Is for informational purposes only. Florida law prohibits this checkltst from changing any of
the provisions of the insurance contract which is the subject of this checklist, Any endorsement regarding changes
In types of coverage, exclusions, limitations, reductions, deduclibles, coinsurance, renewal provisions, cancellation
provisions, surcharges, or credits will be sent separately.
Reviewing (his checklist together with your polley can help you gain a belter understanding of your policy's actual
coverages and limitations, and may even generate questions. By addressing any questions now, you will be more
Prepared laler In the event of a claim. Experience has shown that many questions lend to arise regarding the
coverage of allached or detached screened pool enclosures, screened porches, and other lypes of enclosures.
Likewise, If your pollcy insures a condominium unit, questions may arise regarding the coverage of eartain ilerns,
such as individual heating and air conditioning unils; individual water healers; floor, wall, and ceiling coverings; butll-
In cabinets and counter tops; appllances; window trealments and hardware; and electrical fixtures, A clear
understanding of your policy's coverages and limitations will reduce confusion that may arise during claims
settlement,
Please refer to the policy for detalis and any exceptions to (he coverages listed in this checklist, All coverages are
subject to the provisions and conditions of the policy and any endorsements. If you have questions regarding your
policy, please contact your agent or company. Consumer assistance is avallable from the Department of Financial
Services, Division of Consumer Services’ Helpline at (800) 342-2762 or www.fidfs.com.
‘This form was adopted by the Florida Financial Services Commission.
Dwelling Structure Coverage (Place of Residence)
Loss Settlement Basis: Replacement Cost
(.0.: Replacement Cost, Actual Cash Valuo, or Stated
Limit of Insurance; $_171,000 Valu, ole.)
Other Structures Coverage (Detached from Dwelling)
Loss Settlement Basis: Replacement Cost
(.e.: Replacemant Cost, Actual Cash Value, or Stated
Limit of Insurance; ¢_17,100 Valuo, etc.)
Personal Property Coverage
Loss Settlement Basis: Replacement Cost
{Le.: Replacement Cost, Actual Cash Value, or
Limit of insurance: $_85,500 Slated Value, etc.)
Deductibles
Annual Hurricane; _ $3,420 All Perils (Other Than Hurricane); $2,500
OIR-B1-1670 (1-14-06) Page 1 of 4Checklist of Coverage
The above Limit of Insurance, Deductibles, and Loss Seltlement Basis apply to the following perils insured
agalnst: (Items below marked Y (Yes) indicate coverage |S included, Those marked N(No) indicate coverage
IS NOT Included).
Fire or Lightning
Hurricane
Flood {including storm surge)
Windstorm or Hall (other than hurricane)
Explosion
Riot or Clvll Commotion
Aircraft
Vehicles
Smoke
Vandalism or Malicious Mischief
Theft
Falling Objects
Weight of Ice, Snow or Sleet
Accidental Discharge or Overflow of Water or Steam
‘Sudden and Accidental Tearing Apart, Cracking, Burning or Bulging
Freezing
‘Sudden and Accidental Damage from Arilfically Generated Electrical Current
Voleanic Eruption
Sinknole
Any Other Peril Not Specifically Excluded (dwelling and other structures only)
Spoclal limits and loss settlement exceptions may apply to certain items, Refer to your policy for detalls.
Z| <|<| 29.21
49, Mask and prep for paint - plastic, paper, wpe (per LF) 20.83 LF@ 0.90% 18,75
50, Seal then paint part of the walls (2 coats) 109.37 SF@ 16.56
51. Paint casing - nwo couts 17.00 LF @ 15,98
52. Paint door/window trim & jamb - 2 coals (per side) 1.00 EA@ 20,46
53, Paint baseboard twocoats 13.00 LF@ 12.22
54, Content Manipulation charge - per hour 1.00 HR @ 38.59
5S. Clean floor 27.08 SF@ a
Dining Room LxWxH 10'7" x 9" 4" x8"
DESCRIPTION QNTY UNIT COST TOTAL
56. Detach & Reset Cold air return cover 1.00 EA @ (461= 14.61
57. Detach & Reset Ceiling fan & light Lou EA @ 158,75 = 158.75
58. Alarm Pad - Detach & reset 1.00 EA@ 34.57= 34,57
59, Detach & Reset Thermostat 1.00 EA @ 35.77 35.77
60. Window blind - horizantal or vertical - Detach & reset 1.00 EA@ 3447= 3447
61. Floor protection - scl-adhesive plastic film 98.78 SF@ 0.37= 36,55
62, Texture drywall - heavy hand texture 98.78 SF@ onR= 712
63, Mask and prep for paint - plastic, paper, tape (per LF) 39.83 LF@ 0.90= 35.85
64, Paint crown molding - one cout 39.83 LF@ 0.65= 25.89
65, Seal then paiut the ceiling @ coats) 98.78 SF@ 0.70= 69.15
66. Scal then puint part of the walls (2 coats) 239.00 SF@ 0.70= 167.30
67. Paint baseboard - wo coats. 30.00 LF @ 0.94= 28.20
68. Contents - move out then resct - Large room. 1.00 EA@ 61.98= 61.98
212-05-08-2055 17015 Page: 4ATLANTIC COAST CONSULTANTS, LLC.
11900 BISCAYNE BLVD, SUITE 502
NORTH MIAMI, FLORTDA 33181
877-561-2524 FAX 305-354-2880
TAX LD,
CONTINUED - Diaing Room
DESCRIPTION QNTY UNIT COST TOTAL
69. Clean floor 98.78 SF@ 0.27 = 26.67
Hallway LxWsH 4! £0" 3 3° 1 x 8
DESCRIPTION QNTY UNIT COST TOTAL
70. Smoke detector - Detach & reset 1.00 EA@ 3457> 34.57
71, Mask and prep for paint - plastic, paper, tape (per LF) 15.83 LF@ 0.91 14,25
72, Seal then puint purt of the walls (2 oats) 94.99 SF@ 0.7 66.49
73. Paint casing - two coats 34.00 LF@ Lig 40,12
74, Paint doarhvindow trim & jamb - 2. coats (per side) 2.00 EA@ 2551= 51.02
75, Content Manipulation charge - per hour 1.00 HR@ 38.59 = 38,59
76. Clean floor 14.90 SF@ 0.27= 4.02
MASTERBED ‘Lx Wel (5? x 108 4x 8?
Subroom 1: OFFSET LxWaR 6° 10" x 5' 5" x 8!
DESCRIPTION QnTY UNIT. CosT TOTAL
77. Detach & Reset Cold air retum cover 1.00 EA @ 14.615 1461
78, Detach & Reset Ceiling fan & light 1,00 FA@ 158.75 = (58,75
79, Light fixture - Detach & reset 1.00 EA@ 35.69= 35.69
80. Detach & Reser Window blind - fubric/woven - up to 7 SF 2.00 EA @ 58.42
81. Window blind ~ horizontal or vertical - Detach & reset 2.00 EA@ 58.42
82, Alarm Sensor - Detach & resct 1.00 EA@ 34,57
83, Floar protection- selCadhesive plastic film 19201 SF@ 71.04
84, R&R Wallpaper border 15.17 LF @ 178.15
85. Prep wall for wallpaper 15.17 SE@ 24.05
86. Floor protection - sel adhesive plastic fitm 192.01 SE@ 71.04
87. R&R Two coat plaster over 5/3” gypsum core blueboard 32.00 SF@ 227.20
88. R&R Acoustic ceiling (popcorn) texture 192.01 SE@ 4
89. Glitter application to acoustic ceiling 19201 SF@
90. R&R Two coat plaster over 1/2" gypsum core bluebuard 64.00 SF@
2012-05-08-2055ATLANTIC COAST CONSULTANTS, LLC.
11900 BISCAYNE BLYD, SUITE 502
NORTH MIAMI, FLORIDA 33181
877-561-2524 ¥, 54-2880
TAX LD,
CONTINUED - MASTERBED
DESCRIPTION QNTY —-UNIT COST TOTAL
91. Texture drywall - sinooth / skim coat (21.00 SF@ ize
92. R&R Bascboard - 3 1/4" 59,00 LE@ 2.95=
93, R&R Ceramic tile 192.01 SF@ 1025
94, R&R Mortar bed for tile 192.01 SF@ 483=
95, Remove Additional labor to remove tile from conerete slab 192.01 SF@
96. Floor leveling coment - Heavy 192.01 SF@
97, Dust control barrier per square foot 48.00 SF@
98. Mask and prep for paint ~ plastic, paper, tape (per LF) 15.17 LF@
99. Seal/prime the ceiling - one coat (white pigmented shellac) 192.01 SF@
100. Seal then paint the walls (2 coats) 601.33 SF@
101. Paint casing - two coats 34.00 LF @
102, Paint doochvindow trim & jamb - 2 coats (per side) 2.00 EA@
103, Contents ~ move out then reset ~ Large roam 1.00 EA@ 61.98=
104. Clean floor 7 192.01 SF@ 0.275
MASTERBATH LxWsHf 10° 3" y 5!2"" x 8°
DESCRIPTION QNTY —-UNITCOsT TOTAL
105. interior door=Welach & reset - slab only 2.00 EA @ 1508= 316
106, Detach & Reset Light bar- 8 lights 1.00 EA @ 65.64 65.64
107, Window blind - horizontal or vertical - Detach & reset 1,00 EA@ 3447
108. Recessed light fixture - Detach & reset trim only, 1.00 EA@ 236
109, Detuch & Reset Shower curtain rod 1.00 EA@ 13,66
10, Detach & Resel Medicine cabinet 1.00 EA@ 35.00
111, Shelving - Detach & reset 1.00 LF@ 8.00
112, Light fixture ~ Detuch & reser 1,00 EA@ 35.69
113, Detach & Reset Sink faucet - Bathroom 1.00 EA@ 82.24
114, Detach & Reset Sink- single 1.00 EA@ 103.97
115, R&R Countertop - Tile 8.00 SF@ 155.92
116, R&R 1/4" Cement board 8.00 SF@ 27.92
147. R&R Underlayment - 5/8" BC plywood 8.00 SF@ 2032
118, Waterproof membrane - tile underlayment 8.00 SF@ 24,00
119, Detach & Reset Vanity 417 LF@ 166,47
120, P-trap assembly - Detach & reset 1.00 EA@ 28.33
2012-05-08-2055 Page: 67 ATLANTIC COAST CONSULTANTS, LLC.
11900 BISCAYNE BLVD, SUITE 502
NORTH MIAMI, FLORIDA 33181
CONTINUED - MASTERBATH
DESCRIPTION QNTY UNIT COST TOTAL
12}, R&R Angle stop 2,00 EA@ 29.93 = 59.86
122. Detach & Resct Shower faucet 1.00 EA @ 54.59 = 54.59
123, Detach & Reset Toiler 1.00 EA@ 170.35 = 170.35
124, R&R Towel bar - Ceramic 1.00 EA @ 53.78 = 53.78
(25, R&R Soap dish - surface mounted ~ Ceramic . 100 EA@ 45.71
126, R&R Casing - 2/4" 34.00 LF@ 66.64
127, R&R Ceramic tile - bullnose - 2" x 6" 18.17 LF@ IS1.SL
128. R&R Tile shower - up fo 60 SF 1.00 EA@ 845.80
129. R&R 1/2" Cement board 52.00 SF@ 177.84
130. R&R Ceramic tile for wall 26.00 SF@ 266,50
131, R&R 1/2" Cement board 26.00 SF@ 88.92
132, R&R Ceramic tile floors 52.96 SF@ 542.84
133. R&R Mortar bed for tile floors 52.96 SF@ 215.02
134, Remove Additionat labor to remove tile from concrete slab 52.96 SF@ 144
135, Floor leveling cement - Heavy 52.96 SF@ 102,21
136, Mask and prep for puint - plastic, puper, tape (per LF) 30.83 LF@ 27.75
137, Seal then paint the surface area (2 coats) 194.00 SF@ 135.80
138. Paint casing - two coats 34.00 LF@ AOA2
139. Paint doorAvindow trim & jamb - 2 coats (per side) 2.00 EA @ 51.02
140, Content Manipulation charge - per hour 1.00 HR@ 38.59
MAST/CLOSET UW 10° 9" x BUG 78
DESCRIPTION QNTY UNIT COST TOTAL
141, Closct shelfand rod package - Detach & reset 18.50 LF@ 1231= 227.74
142. Detach & Reset Closet Organizer - Melamine 5.67 LF@ 47.80 = 271.03
143. Detach & Reset Carpet 86.90 SF@ 0,66 = 57.35
144, Remove Carpet pad 86.90 SF@ 0.09 = 7.82
145, (Install) Carpet pad 86.90 SE@ 9.07= 6.08
146, Floor leveling cement - Heavy 86.90 SF@ 216= 187,70
147, R&R Ceramic tile 8.00 SF@ _ 1025= 82.00
148. R&R Morar bed for tile floors 800 SF@ 4.06 = 32.48
149. Remove Additional labor to remove tile frum conerete slab 8.00 SF@ 1.40= 11.20
150. Dust control bartier per square foot 45.00 SF@ 0.50 = 24.00
2012-05-08-2055 1/7/2015 Page: 7ATLANTIC COAST CONSULTANTS, LLC.
11900 BISCAYNE BLVD, SUITE 502
NORTH MIAMI, FLORIDA 33181
877-561-2524 FAX 305-354-2880
TAXI
CONTINUED - MAST/CLOSET
DESCRIPTION QNTY UNIT COST TOTAL
151, Mask and prep for paint - plastic, paper, tape (per LIF) 37.67 LF@ 0,90= 33,90
152, Seul then paint the walls (2 cuats) 288.75 SF@ 0.70 = 202.13
153, Contents - move out then reset - Extra large room 1.00 EA @ 115,76= 115.76
FOUNDATION
DESCRIPTION QNTY UNIT COST TOTAL
154, Foundation Repair 1.00 EA@ 64,160.00 = 64,160.00
Foundation proposal was provided by Sinkhole Geotech, Inc,
GENERALS
“DESCRIPTION QNTY UNIT COST TOTAL
155, Packaging, Handling, Storege (Bid Item) 2.00 EA@ 284.02 = S6R.04
156, Dumpster load - Approx. 20 yards, 4 tons of debris 1,00 EA@ 516.69= 516.69
157, Taxes, insurance, permits & feos (Bid item) 2.00 EA@ 500,00 = 4,000.00
158. General Laborer - per hour for final clean, 25.00 HR@ 30.62 = 765.50
Adjustments for Buse Service Charges Adjustment
Camenter - Finish, Trim/Cabinet 126.36
Coverage Dwelling @ 100.00 %= 126.36
Carpenter - Mechanic 123.62
Coverage Dwelling @ 100.00 %= 123.62
Cleaning Techniciun 46.66
Coverage Dwelling @ 100.00 %= 46.66
Floor Cleaning Technician 6432
Coverage welling @ 100.00 %= 64.32
Cleaning Remediation Teclnieian 97.84
2012-05-08-2055 172015 Page: &ATLANTIC COAST CONSULTANTS, LLC.
11900 BISCAYNE BLVD, SUITE 502
NORTH MIAMI, FLORIDA 33181
Adjustments for Base Service Charges Adjustment
Coverage Dwelling @ 100.00%= 97.84
Concrete Mason 126.18
Coverage Dwelling @ 100.00 %= 126.18
Drywall Installer/Finisher 291.20
Coverage Dwelling @ 100.00%= 291.20
Electrician 158.54
Coverage Dwelling @ w000%= * 198,54
Flooring Installer 110.30
Coverage Dwelling @ 100.00%= 110,30
Wood Flooring Installer 128.16
Coverage Dwelling @ 100.00 %= 128.16
Hardware Installer 116,60
Covernge Dwelling @ 100.00%= 116.60
Heuting / A.C. Mechanic 170.08
Coverage Dwelling @ 100.00%= 170.08
General Luborer 30.62
Coverage Dwelling @ 100.00%= 30.62
Plasterer 308.68
Coverage Dwelling @ 100.00%= 308.68
Plumber 136.52
Coverage Dwelling @ 100.00 %= 386.52
Painter 106.36
Covernge Dwelling @ 100.00 %= 106.36
‘Stucco Installer 186.96
Coverage Dwelling @ 100.00%= 186.96
Tile/Cultired Marble Installer 84.52
Coverage Dwelling @ 100.00%= 84.52
Wallpaper Hanger 84.42
Coverage Dwelling @ 10.00%= 84.42
Total Adjustments for Base Scrvicc Charges: 2,547.94
Line Ttem Totals; 2012-05-08-2055 120,314.67
2012-05-08-2055 W72015 Page: 9ATLANTIC COAST CONSULTANTS, LLC.
11900 BISCAYNE BLVD, SUITE 502
NORTH MIAMI, FLORIDA 33181
877-561-2524 FAX 305-354-2880
TAX LD.
Grand Total Areas:
2,290.58 SF Walls TAT SF Celling 3,062.35 SF Walls and Ceiling
T1717 SF Floor 85.75. SY Flooring 290.50 LF Floor Perimeter
666.33 SF Long Wall 478.96 SF Shor. Wall 290.50 UF Cell, Perimeter
0.00 Floor Arca 0.00 Total Arca 0.00 Interior Wall Arca
0.00 Exterior Wall Arca 0,00 Exterior Perimater of
‘Walls
0.00 Surface Area 0.00, Number of Squares 0.00 Total Perimeter Length
= 0,00 Total Ridge Length 0.00 Total Hip Length
Coverage Amount % Grand Total %
Dwelling 117,198.69 99.52% 144,667.01 99.53%
Other Structures : 0.00 0.00% 0,00 o.n0%
Contents 568,04 048% 684.03 0.47%
Total 117,166.73 100.0% 145,351.04 100.0%
2012-05-08-2055 VIROs Page: 10ATLANTIC COAST CONSULTANTS, LLC.
11960 BISCAYNE BLVD, SUITE 502
NORTH MIAMI, FLORIDA 33181
$77-561-2524 FAX 305-354-2880
TAX 1D.
Summary for Dwelling
Line Ttem Total 117,198.69
Total Adjustments for Base Service Charges 2,547.94
‘Material Sales Tax. @ 7.000% x 11,560.24 809,22
Subtotal, 120,555.85
‘Overhead @ 10.0% x 120,555.85 12,055.58
Profit @ 10.0% x 120,555.85 12,055.58
Replacement Cost Valuc $144,667.01
Net Chaim ‘$144,667.01
Carlos A. Nayor
2012-05-08-2055 VI2015 Page: 11ATLANTIC COAST CONSULTANTS, LLC.
11900 BISCAYNE BLVD, SUITE 502
NORTH MIAMI, FLORIDA 33181
0
877-561-2:
TAXAD,
Line Item Total
Material Sales Tax
Subtotal
Overhead
Profit
Replacement Cost Value
Net Claim
2012-05-08-2055
Be
Summary for Contents
@ = 7.000% x
@ 10.0% x
@ 10.0% x
Gaitos A. Nayor
28.40
570.03
570.03
568.04
1.99
570,03
57.00
57,00
72015
8684.03,
3684.03,
Page: 12@TRI (AD Triad Construction & Management Services
€BC1252452
2708 Alt 19 N Suite #501
Palm Harbor, FL 34683 EXHIBIT
727-216-6350
866-359-3331 FAX ’ D
Client: Hines, Debra
Home: 3816 South Lake Terrace
Miramar, FL 33023
Property: 3816 South Lake Terrace
Miramar, FL 33023
Operator Info:
Operator: OFFICE
Estimator: George Zobrist (CBC1258258)
Type of Estimate: Sinkhole Activity
Date Entered: — 12/27/2015 Date Assigned:
Date Est. Completed: 12/29/2015 Date Job Completed:
Price List: © FLFL7X_DEC2015
Labor Efficiency: | Restoration/Service/Remodel
Estimate: 201 5-HINES-DEBRA
GENERAL NOTES:
This above ground repair estimate is based on the visible damages observed during the non-destructive site inspection completed
by George Zobrist (CBC1258258) on December 19, 2015. The site inspection was conducted at 9:00 A.M. and the following
person(s) were present during the inspection:
Debra Hines
This above ground repair estimate may include some additional repairs (in addition to the visible damage scope of repairs) that
will be required based upon our review of the recommended stabilization methods contained within the following engineering
report(s):
Sinkhole Geotech, Inc. (August 22, 2014)
This above ground repair estimate is based on our visual observations and the proposed stabilization repairs listed in the above
referenced reports. The estimate specifically does not include any repairs for hidden damages or other damages that may occur
during the stabilization process. If additional damages occur and/or additional relevant documentation becomes available, please
contact our office to schedule a follow up inspection to revise the estimate as needed,
Dennis James
State of Florida Certified Building Contractor (CBC1252452)
State of Florida Mold Remediator (MRSR764)
State of Tennessee Licensed Contractor (00067277)@TRIAD Triad Construction & Management Services
CBC1252452
2708 Alt 19 N Suite #501
Palm Harbor, FL 34683
727-216-6350
866-359-3331 FAX
Entry/Foyer
SE
2015-HINES-DEBRA
104.42 SF Walls
130.15 SF Walls & Ceiling
2.86. SY Flooring
37.92 SF Long Wall
14,92 LF Ceil, Perimeter
LxWxH 5'5"x4'9" x7!
25.73 SF Ceiling
25.73 SF Floor
14.92 LF Floor Perimeter
33.25 SF Short Wall
Missing Wall - Goes to Floor/Ceiling SS" X7 Opens into Exterior
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Window blind - horizontal or vertical - 1.00 EA 0.00 29.38 29.38
Detach & reset
Paint the walls and ceiling - two coats 130.15 SF 0.00 0.61 79.39
Paint baseboard, oversized - two coats 14.92 LF 0.00 0.94 14.02
Paint door or window opening - 2 coats (per 1,00 EA 0.00 18.93 18.93
side)
Floor protection - self-adhesive plastic film 25.73 SF 0.40 0.00 10.29
152.01
Totals: Entry/Foyer
Living Room
LE
430.42 SF Walls
731.29 SF Walls & Ceiling
33.43 SY Flooring
166,00 SF Long Wall
61.17 LF Ceil. Perimeter
LxWxH 20' 9" x 14'6" x 8"
300.88 SF Ceiling
300.88 SF Floor
52.75 LF Floor Perimeter
116.00 SF Short Wall
Missing Wall - Goes to Floor ssh x7 Opens into Exterior
Missing Wall - Goes to Floor BxT Opens into Exterior
Missing Wall - Goes to Floor/Ceiling 94" x8" Opens into Exterior
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Window blind - horizontal or vertical - 2,00 BA 0.00 29.38 58.76
Detach & reset
Mask per square foot for drywall or plaster 731.29 SF 0.00 0.14 102.38
work
2015-HINES-DEBRA 12/29/2015 Page: 2@TRIAD Triad Construction & Management Services
CBC1252452
2708 Alt 19 N Suite #501
Palm Harbor, FL 34683
727-236-6350
866-359-3331 FAX
CONTINUED - Living Room
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Plasterer - per hour 4.00 HR 0.00 62.51 250.04
Texture drywall - smooth / skim coat 300.88 SF 0.00 0.71 213.62
Texture drywall - heavy hand texture 300.88 SF 0.00 0.54 162.48
Seal the ceiling w/latex based stain blocker - 300.88 SF 0.00 0.36 108.32
‘one coat
Paint the ceiling - two coats 300.88 SF 0.00 0.61 183.54
Thin coat plaster (no lath) 116.00 SF 0.00 2.96 343.36
Seal the short wall w/latex based stain. 116.00 SF 0.00 0.36 41.76
blocker - one coat
Paint the walls - two coats 430.42 SF 0.00 0.61 262.56
Paint crown molding - two coats 61.17LF 0.00 0.88 53.83
Paint chair rail - two coats 52.75 LF 0.00 0.85 44.84
R&R Baseboard - 3 1/4" 52.75 LF 0.37 2.64 158.78
Paint baseboard, oversized - two coats 52.75 LF 0.00 0.94 49.59
Floor protection - self-adhesive plastic film 300.88 SF 0.40 0.00 120.35
Totals: Living Room 2,154.21
Dining Room LxWxH 16°10" x9' 4" x 8
192.00 SF Walls 101.11 SF Ceiling
SS 293.11 SF Walls & Ceiling 101.11 SF Floor
RS 11.23 SY Flooring 23.00 LF Floor Perimeter
86.67 SF Long Wall 74.67 SF Short Wall
31.00 LF Ceil. Perimeter
Missing Wall - Goes to Floor/Cciling. oa" XB Opens into Exterior
Missing Wall - Goes to Floor S'X7! Opens into Exterior
Missing Wall - Goes to Floor 3X7 Opens into Exterior
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Ceiling fan - Detach & reset 1.00 EA 0.00 155.25 155.25
Window blind - horizontal or vertical - 1.00 EA 0.00 29.38 29.38
Detach & reset
2015-HINES-DEBRA 12/29/2015 Page: 3@TRIAD Triad Construction & Management Services
CBC1252452
2708 Alt 19 N Suite #501
Palm Harbor, FL 34683
727-216-6350
866-359-3331 FAX
CONTINUED - Dining Room
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Mask per square foot for drywall or plaster 293.11 SF 0.00 0.14 41.04
work
Texture drywall - smooth / skim coal 101.11 SF 0.00 0.7) 71.79
Texture drywall - heavy hand texture 101.11 SF 0,00 0.54 54.60
Seal the ceiling w/latex based stain blocker - 101.11 SF 0.00 0.36 36.40
one coat
Paint the ceiling - two coats 101.11 SF 0.00 0.61 61.68
Plasterer - per hour 1.00 HR. 0.00 62.51 62.51
Thin coat plaster (no lath) 86.67 SF 0.00 2.96 256.54
Seal the long wall w/latex based stain 86.67 SF 0.00 0.36 31.20
blocker - one coat
Paint the walls - two coats 192.00 SF 0.00 0.61 117.42
Paint crown molding - two coats 31.00 LF . 0.00 0.88 27.28
Paint chair rail - two coats 23.00 LF 0.00 0.85 19.55
Paint baseboard, oversized - two coats 23.00 LF 0.00 0.94 21.62
Floor protection - self-adhesive plastic film 101.11 SF 0.40 0.00 40.44
Totals: Dining Room 1,026.40
Kitchen
DESCRIPTION QNTY REMOVE REPLACE TOTAL
NOTE: There were no visible damages observed at the time of the inspection.
Totals: Kitchen 0.00
2015-HINES-DEBRA 12/29/2015 Page: 4@TRIAD Triad Construction & Management Services
CBC1252452
2708 Alt 19 N Suite #501
Palm Harbor, FL 34683
727-216-6350
866-359-3331 FAX
Family Room
EP
400.94 SF Walls
578.03 SF Walls & Ceiling
19.68 SY Flooring
141.67 SF Long Wall
54.83 LF Ceil. Perimeter
LxWxH 17'x 10'S" x 8'4"
177.08 SF Ceiling
177.08 SF Floor
46.83 LF Floor Perimeter
86.81 SF Short Wall
Missing Wall - Goes to Floor Bx7 Opens into Exterior
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Finish carpentry repairs - per hour 6.00HR 0.00 55.00 330.00
R&R Exterior door - metal - insulated - flush 1.00 EA 17.16 21.72 288.88
or panel style
Paint door slab only - 2 coats (per side) 2.00 EA 0.00 19.47 38.94
Paint door or window opening - 2 coats (per 1.00EA 0.00 18.93 18.93
side)
Door lockset - Detach & reset 1.00 EA 0.00 19.61 19.61
Painter - per hour 4.00HR 0.00 42.15 168.60
Acoustical Treatments Installer - per hour 4.00 HR 0.00 48.75 195.00
R&R Paneling 400.94 SF 0.24 2.10 938.20
Framing repairs - per hour 2.00 HR 0.00 70.00 140.00
Floor protection - self-adhesive plastic film 177.08 SF 0.40 0.00 70.83
Totals: Family Room 2,208.99
Hallway LxWxH 4! 10" x3" x 8"
104.33 SF Walls 14,50 SF Ceiling
118,83 SF Walls & Ceiling 14,50 SF Floor
ES
1.61 SY Flooring
38.67 SF Long Wall
15.67 LF Ceil. Perimeter
12.67 LF Floor Perimeter
24.00 SF Short Wall
Missing Wall - Goes to Floor vx Opens into Exterior
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Mask per square foot for drywall or plaster 104.33 SF 0.00 0.14 14.61
work
2015-HINES-DEBRA 12/29/2015 Page: 5@TRIAD Triad Construction & Management Services
CBC1252452
2708 Alt 19 N Suite #501
Palm Harbor, FL 34683
727-216-6350
866-359-3331 FAX
CONTINUED - Hallway
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Plasterer - per hour 1.00 HR. 0.00 62.51 62.51
Thin coat plaster (no lath) 38.67 SF 0.00 2.96 114.46
Seal the long wall w/latex based stain 38.67 SF 0.00 0.36 13.92
blocker - one coat
Paint the walls and ceiling - two coats 118.83 SF 0.00 0.61 72.49
Paint baseboard, oversized - two coats 12.67 LF 0.00 0.94 11.91
na door or window opening - 2 coats (per 3.00 BA 0.00 18.93 56.79
side)
Floor protection - self-adhesive plastic film 14.50 SF 0.40 0.00 5.80
352.49
Totals: Hallway
Master Bedroom
ZB
353.34 SF Walls
510.06 SF Walls & Ceiling
17.41 SY Flooring
121.33 SF Long Wall
44.17 LF Ceil. Perimeter
Subroom 1: Offset 1
SP
140.01 SF Walls
176.45 SF Walls & Ceiling
4.05 SY Flooring
54.67 SF Long Wall
17.50 LF Ceil. Perimeter
LxWxH 15'2" x 10'4" x 8!
156.72 SF Ceiting
156.72 SF Floor
44.17 LF Floor Perimeter
82.67 SF Short Wall
LxWxH 6' 10" x 5' 4" x 8"
36.44 SF Ceiling
36.44 SF Floor
17.50 LF Floor Perimeter
42.67 SF Short Wall
Missing Wall - Goes to Floor/Ceiling 610" Xs" Opens into Master Bedroom
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Ceiling fan - Detach & reset 1.00 EA 0.00 155.25 155,25
Light fixture - Detach & reset 1.00 EA 0.00 39.38 39,38
Window blind - horizontal or vertical - 2.00 EA 0.00 29.38 58.76
Detach & reset
2015-HINES-DEBRA 12/29/2015 Page: 6@TRIAD Triad Construction & Management Services
CBC1252452
2708 Alt 19 N Suite #501
Palm Harbor, FL 34683
727-216-6350
866-359-3331 FAX
CONTINUED - Master Bedroom
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Mask per square foot for drywall or plaster 686.51 SF 0.00 0.14 96.11
work
R&R 5/8" blueboard - hung only (no tape or 96.58 SF 0.33 1.05 133.28
finish)
Plasterer - per hour 4.00 HR 0.00 62.51 250.04
Remove Tear off painted acoustic ceiling 96.58 SF 0.73 0.00 70.50
(popcorn) texture
Seal the ceiling w/latex based stain blocker - 193.17 SF 0.00 0.36 69.54
one coat
Acoustic ceiling (popcorn) texture 193.17 SF 0.00 0.56 108.18
R&R 1/2" blueboard - hung only (no tape or 246.67 SF 0.33 0.99 325.60
finish)
Thin coat plaster (no tath) 493.34 SF 0.00 2.96 1,460.29
Seal the walls w/latex based stain blocker - 493.34 SF 0.00 0.36 177.60
one coat
Paint the walls - two coats 493.34 SF 0.00 0.61 300.94
R&R Wallpaper border 15,00 LF 0.54 2.26 42.00
Prep wall for wallpaper 15.00 SF 0.00 0.41 6.15
R&R Baseboard - 3 1/4" 61.67 LF 037 2.64 185.63
Paint baseboard - two coats 61.67 LF 0.00 0.85 52.42
Detach & Reset Interior door - Colonist - 1.00 BA 0.00 0.00 1715
slab only
Paint door or window opening - 2 coats (per 2.00 EA 0.00 18.93, 37.86
side)
R&R Aluminum window - jalousie, 12-23 sf 2.00 EA 18.08 411.49 859.14
R&R Marble sill 6.00 LF 0.90 8.00 53.40
Floor leveling cement - Heavy 193.17 SF 0.00 1.98 382.48
R&R Tile floor covering 193,17 SF 2.00 6.63 1,667.06
Remove Additional labor to remove tile 193.17 SF 1.43 0.00 216.23
from conerete slab
Electrician - per hour 2.00 HR 0.00 80.00 160.00
Framing repairs - per hour 8.00 HR 0.00 70.00 560.00
Floor protection - self-adhesive plastic film 193.17 SF 0.40 0.00 71.21
Totals: Master Bedroom 7,622.26
2015-HINES-DEBRA 12/29/2015 Page: 7@TRIAD Triad Construction & Management Services
CBC1252452
2708 Alt 19 N Suite #501
Palm Harbor, FL 34683
727-216-6350
866-359-3331 FAX
Master Bathroom
2
242.67 SF Walls
293.50 SF Walls & Ceiling
5.65 SY Flooring
81.33 SF Long Wall
30.33 LF Ceil. Perimeter
LxWxH 10' 2" x 5'x 8"
50.83 SF Ceiling
50.83 SF Floor
30.33 LF Floor Perimeter
40.00 SF Short Wall
DESCRIPTION QNTY REMOVE REPLACE TOTAL
Light fixture - Detach & reset 1.00 EA 0.00 39.38 39.38
Mask per square foot for drywall or plaster 293.50 SF 0.00 0.14 41.09
work
Plasterer - per hour 2.00 HR 0.00 62.51 125.02
Thin coat plaster (no lath) 50.83 SF 0.00 2.96 150.46
Seal the ceiling w/latex based stain blocker - 50.83 SF 0.00 0.36 18.30
one coat
Paint the ceiling - two coats 50.83 SF 0.00 0.61 31.01
Thin coat plaster (no lath) 40.00 SF 0.00 2.96 118.40
Seal part of the walls w/latex based stain 40.00 SF 0.00 0.36 14.40
blocker - one coat
Paint part of the walls - two coats 40.00 SF 0.00 0.61 24.40
R&R Interior door unit 2.00 EA 15.00 144.83 319.66
Paint door slab only - 2 coats (per side)
Preview
Filing # 39323458 E-Filed 03/22/2016 02:58:49 PM 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, vs. HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC., Defendant. / DEFENDANT’S MOTION FOR RULING ON PLAINTIFF’S OBJECTIONS TO DEFENDANT’S FIRST REQUEST FOR ADMISSIONS COMES NOW the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, by and through undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.370, and hereby files this Motion for Ruling on Plaintiff's Objections to Defendant's First Request for Admissions, and in support thereof states: 1. This is a lawsuit for breach of contract brought by Plaintiff against Defendant for damages exceeding $15,000.00, alleging Defendant has breached a policy of insurance by failing to pay the benefits due. 2. On February 3, 2016, Defendant served its First Request for Admissions upon Plaintiff, a true and correct copy of which is attached hereto as Exhibit A. 3. On March 18, 2016, Plaintiff served Responses to Defendant’s First Request for Admissions, a true and correct copy of which is attached hereto as Exhibit B. 4, Plaintiff objected to the following Requests: *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 3/22/2016 2:58:48 PM.****Request No. 18: 18. You allege there are no alternative causes, apart from sinkhole loss, of the damages at issue in this lawsuit, Response No. 18: 18. RESPONSE: Objection, calls far a legal and expert conclusion. This request does not call for a legal and expert conclusion; rather, it seeks an admission or denial as to whether Plaintiff alleges there are no alternative causes of the damages at issue in this lawsuit, apart from the sinkhole loss. While an opinion as to whether there are/may be alternative causes of the damages may be an expert opinion/conclusion, Defendant is certainly entitled to discover what the Plaintiff's allegations are in effort to narrow the issues in this matter. Plaintiffs objection to this request should be overruled. Request No. 19: 19. You do not dispute that earth movement due to organic soils is a viable alternative cause of the damages at issue in this lawsuit. Response No. 19: 19. RESPONSE: Objection, calls for a legal and expert conclusion. As with the foregoing, this request does not call for a legal and expert conclusion; rather, it seeks an admission or denial as to whether Plaintiff disputes that earth movement due to organic soils is a viable alternative cause of the damages at issue in this lawsuit. While an opinion as to whether earth movement due to organic soils is a viable alternative cause of the damages may be an expert opinion/conclusion, Defendant is certainly entitled to discover what the disputed issues are vis-a-vis the Plaintiff's position in this case with respect to causation ineffort to narrow the issues in this matter. Plaintiff's objection to this request should be overruled. Request No. 20: 20. You do not dispute that earth movement duc to organic soils is a viable concurrent cause of the damages at issue in this lawsuit. Response No. 20: 20. RESPONSE: Objection, calls for a legal and expert conclusion. As with the foregoing, this request does not call for a legal and expert conclusion; rather, it seeks an admission or denial as to whether Plaintiff disputes that earth movement due to organic soils is a viable concurrent cause of the damages at issue in this lawsuit. While an opinion as to whether earth movement due to organic soils is a viable alternative cause of the damages may be an expert opinion/conclusion, Defendant is certainly entitled to discover what the disputed issues are vis-a-vis the Plaintiff's position in this case with respect to causation in effort to narrow the issues in this matter. Plaintiff's objection to this request should be overruled. 5. Pursuant to Florida Rule of Civil Procedure 1.370(a), “A party may serve upon any other party a written request for the admission of the truth of any matters within the scope of rule 1.280(b) set forth in the request that relate to statements or opinions of fact or of the application of law to fact, including the genuineness of any documents described in the request.” 6. The Second District Court of Appeal has recently analyzed the shifting evidentiary burdens with respect to sinkhole cases where alternative and/or multiple causation is at issue in Citizens v. Salkey, (Fla. 2" DCA February 26, 2016).7. Defendant is entitled to know whether Plaintiff alleges there exists no alternative causes for the damages claimed in this lawsuit, or concedes that although alternative causes exist, they were not the efficient proximate cause of the damages. 8. The information sought in Defendant’s foregoing Request for Admissions is required by Defendant in preparation of a defense to Plaintiffs claims and Defendant is prejudiced by Plaintiff's failure to provide adequate responses. 9. The information requested is not frivolous, nor is it intended to harass the Plaintiffs. 10. The Defendant has incurred attorneys’ fees and costs as a result of Plaintiffs failure to cooperate with the discovery process and having to bring this Motion before the Court. ll. The Defendant certifies that it has conferred in good faith with Plaintiff's counsel in an attempt to obtain the discovery without court action. See Exhibit C. WHEREFORE, Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, respectfully requests that this Court enter an Order overruling Plaintiff's Objections to Defendant’s First Request for Admissions, and award such further relief as this Court deems 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 at eserviceSLPA@gmail.com, and Morgan Barfield at Mbarfield@CorlessBarfield.com on this 22" day of March, 2016. By: HCP.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) Wher T Ddbebe> ROBERT T. SCHULTE, ESQ. FBN: 8881914211 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, vs. HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. a Florida Corporation, Defendant. / - DEFENDANT’S NOTICE OF SERVING DEFENDANT’S FIRST 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: 1, The document attached hereto as EXHIBIT A is the only policy of insurance in effect on or about February 20, 2012 with respect to the damages at issue in this lawsuit. 2. You retained public adjusters to represent you with respect to the claim for sinkhole loss which is the subject of this lawsuit. 3. Your public adjusters and attorneys were authorized to send and receive correspondence on your behalf. 4. You do not have any photos or other documentation which depict the condition of the property at any time prior to your observation of damage you contend was caused by caused by sinkhole on or about February 20, 2012. 5. You observed damage to the property which is the subject of this lawsuit prior to your observation of damage you contend was caused by caused by sinkhole on or about February 20, 2012. 6. You observed cracking damage to the property which is the subject of this lawsuit prior to July 20, 2011. EXHIBIT A12. 13. 15, You did not notice the damage you contend was caused by caused by sinkhole on or about February 20, 2012 until it was pointed out to you by a third party. You cannot provide the specific locations upon the building which is the subject of this lawsuit where you observed damage occur prior to July 20, 2011. You cannot provide the specific locations upon the building which is the subject of this lawsuit where you observed damage occur between July 20, 2011 and July 20, 2012. . You cannot provide the specific locations upon the building which is the subject of this lawsuit where you observed damage to have increased in size (length, width, or otherwise), or otherwise worsened between July 20, 2011 and July 20, 2012. . You cannot provide the specific locations upon the building which is the subject of this lawsuit where you observed damage to have increased in size (length, width, or otherwise), or otherwise worsened since July 20, 2012. Neither you, nor your representatives, have submitted the opinion of a “professional engineer” or “professional geologist” that “sinkhole activity” has been verified at the property which is the subject of this lawsuit. For all terms in quotations utilize the definitions contained within the attached EXHIBIT A and EXHIBIT B. Neither you, nor your representatives, have submitted the opinion of a “professional engineer” or “professional geologist” that a “structural damage” condition exists at the property which is the subject of this lawsuit. For all terms in quotations utilize the definitions contained within the attached EXHIBIT A and EXHIBIT B. . Neither you, nor your representatives, have submitted the opinion of a “professional engineer” or “professional geologist” that a “sinkhole loss” has been verified at the property which is the subject of this lawsuit. For all terms in quotations utilize the definitions contained within the attached EXHIBIT A and EXHIBIT B. The repair estimate attached hereto as EXHIBIT C does not represent the actual cash value of the sinkhole loss, not including underpinning or grouting or any other repair technique performed below the existing foundation of the building. The repair estimate attached hereto as EXHIBIT D does not represent the actual cash value of the sinkhole loss, not including underpinning or grouting or any other repair technique performed below the existing foundation of the building. .In this lawsuit you are alleging the Defendant breached the contract of insurance by failing to provide coverage for a sinkhole loss. . You allege there are no alternative causes, apart from sinkhole loss, of the damages at issue in this lawsuit.19. You do not dispute that earth movement due to organic soils is a viable alternative cause of the damages at issue in this lawsuit. 20. You do not dispute that earth movement due to organic soils is a viable concurrent cause of the damages at issue in this lawsuit. 21. In this lawsuit the only relief you are seeking is money damages for the sinkhole loss you are alleging occurred. 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@CorlessBarfield.com on this 3 day of February, 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) Mut 7 Dtbecbe- ROBERT T. SCHULTE, ESQ. HCP.14211 FBN: 88819 By:EXHIBIT A ‘tables Consus CHOICE Property & CASUALTY INsuRaANCE Company, INC. This is a true and correct certified copy of the Declaration page and applicable forms for James Hines, Policy Number 1HPC1540319 Maween Garwey Signed: State of Florida County of Hillsborough With respect to the above: The above named signatory has sworn to and subscribed before me by Maureen Garvey, the information contained within this document is accurate and true. The above signatory is personally known to me Robin Hill. Robin — xtezs~" ‘2Homeowners Chale Propeny and Casualty ne ou-CSR. 1 ‘emait=shillehepelcom, ceUS i see Signature of Notary Notary Public for the State of Florida Commission # EE848231 Expires October 31, 2016 HoMEowners CHoIce PRoPERTy & CASUALTY INSURANCE COMPANY, INC. Post Office Box 22967 | Tampa, Florida 33622 Claims Phone: 877.235.5076 | Claims Fax: 813.443.0830 | www.hepci.comBruening Insurance Agency, inc. 2700 S. Commerce Parkway Ste. 309 Weston, FL 33331 JAMES HINES 3816 S LAKE TER MIRAMAR, FL 33023-4948Ty ° PO Box 9181 - Marlborough, MA 01752-9181 www. homewiseinsurance.com Insurance Company 05/23/2011 Dear Policyholder: Enclosed is your renewal policy with Home Wise Insurance Company (Rated “A”, Exceptional, from Demotech, Inc). Depending on where your property is located, your policy premium may have been affected by an approved rate increase. While HomeWise tries to avoid raising rates, sometimes it is necessary. Tacreasing frequency of claims, higher costs to repair or replace damaged items and higher incidences of fraud al] contribute to higher premiums. In today’s economy we know it is difficult to manage expenses, so we would like to remind you of various cost saving options that may be available to you such as: ¢ Centrally monitored fire and burglar alarms * Mitigation or loss prevention devices ¢ Increasing your basic or hurricane policy deductibles If you think you may qualify, please contact your agent to discuss these cost saving options. Your renewal time is an excellent opportunity to make changes in policy deductibles and evaluate your need for other coverages that may only be made effective on the renewal date, Possible coverage changes to consider (increases or decreases) include: © Ordinance or Law — Increased Amount of Coverage e Limited Hurricane Coverage - Screened Enclosures * Water Back Up and Sump Discharge or Overflow Tf you pay the policy premium yourself, the bill for your policy is attached. If your insurance premium is paid from an escrow account, we will bil] your mortgage company. Jn the event that you have recently refinanced or if the mortgagee or servicing agent has changed within the last several months, please verify that the correct mortgage holder is listed on your Declarations page to ensure timely payment and continuation of your HomeWise policy. Thank you for the trust you have placed in us and renewing your insurance with Home Wise. bil ~—Q Dale S. Hammond President and Chief Executive Officer Home Wise Insurance Company HW 2010**Policyholder Notice of Coverage Changes. Please Read Carefully** Dear Policyholder: This Notice of Coverage Changes is for informational purposes only, \t is your responsibility to understand the coverages provided in your insuratice policy and the options available to you. For a complete explanation and understanding of the coverages provided by your policy, please contact your agent. Your agent can provide you with further details and to discuss how you can customize your policy to suit your insurance needs. Some policy changes may only be made on the effective date of the policy. All coverages are subject to the terms, provisions and conditions of the policy and any endorsements, Your policy may not include all of the coverages changes or forms changes described in this document. See endorsement for coverage details. Different deductible options may be available Optional coverage for Personal Injury protection is available Additional Living Expense is covered up to 365 days Screened pool enclosures are not automatically covered for losses due to hurricane. If you have a pool enclosure, and you wish to purchase coverage, please contact your agent Loss of Use coverage includes a 20% co-payment for Hurricane losses. The revised Loss of Use endorsement (HW 01 10 02 10) provides Loss of Use coverage when the premises where you reside is “uninhabitable” Certain fiability coverages, such as Animal Liability, are excluded. Limited coverage is sometimes available for purchase For an additional premium, subject to underwriting review, the new Domestic Dog(s) and Cat(s) endorsement (HW 91 02 10) may be available. The form provides limited coverage for liability arising out of the ownership and care of domestic dog(s) and cat(s) Revised Special Provisions ~ Florida (HW 01 09 02 10) o Coverages moved to separate endorsements: Collapse, Fungi, Sinkhole Loss and Ordinance or Law o Addition of up to $10,000 as a Special Limit of Liability for Damage to Floors © Addition of off premises power failure, up to $500 under Refrigerated Property Coverage o Damage caused by seepage and leakage of water or steam is excluded Ordinance Or Law Coverage Endorsement (HW 04 77 02 10) will be attached to policies with 25% OR 50% coverage options. Tlie limit will be reflected on the Declarations For an additional premium, subject to underwriting review, Sinkhole Loss Coverage (HW 07 07 04 11) endorsement may be added to provide coverage for sinkhole loss to covered property Thank you for tusnring your property with HomeWise — we appreciate your business! NOC 0910 Page 4 of 1Wise To mako Inquires, obtaln information or for HOMEOWNERS POLICY DECLARATIONS | Heme ise assistance in reselving complains abou his Trourense Gompohy polley, please call your Agent or HomeWise Declaration Effective P.O, Box 9181 ‘Customer Service at: 07/20/2011 Marlborough, MA 01752-9181 42:01 AM Standard Time DIRECT BILL 1-866-496-1781 POLICY NUMBER POLICY PERIOD, AGENT CODE HPC1540319 07/2012011 to 07/202012 862548 | NAMED INSURED AND ADDRESS AGENT | VAMES HINES Bruening Insurance Agency, Inc. 3816 S LAKE TER 2700 8. Commerce Parkway MIRAMAR, FL 33023-4948 Ste, 309 Weston, FL 33331 (954) 473-1406 - ~PREMIUM SUMMARY--- moor BASIC ATTACHED DISCOUNTS MGA FEES / TOTAL COVERAGES ENDORSEMENTS AND SURCHARGES POLICY PREMIUM PREMIUM CREDITS PREMIUM $3,102.00 $482.00 $0.00 $121.00 $3,705.00 FORM CONST YEAR USE NUMFAM OCCUP PROT TERRITORY BCEG 7 CLASS: HO-3 Masonry 1964 Primary 1 Owner Occupled 5 314 98 WINDSTORM COUNTY TAX REPLACEMENT PRIOR PROOF LOSS CREDIT CODE CODE COST ON CONTENTS OF INSURANCE 0% 014 Y Y COVERAGES SECTION! LIMITS PREMIUMS Coverage -A- Dwelllng $171,000 $3,211.00 Coverage -B- Other Structures $17,100 INCLUDED Coverage -C- Personal Property $85,500 $0.00 Coverage -D- Loss of Use $34,200 INCLUDED Section | coverages subject to $2,500 non-hurricane deductible per loss. Section | sinkhole loss coverage subject to a $2,500 non-hurricane deductible per loss. Section | coverages subject to a 2% HURRICANE DEDUCTIBLE (equal to $3,420). COVERAGES SECTION I PREMIUMS Coverage -E- Personal Liability $300,000 $18.00 Coverage -F- Medical Payments $2,000 INCLUDED LOCATION(S) OF PROPERTY INSURED 3816 S LAKE TER, MIRAMAR, FL 33023 THIS POLICY CONTAINS A SEPARATE DEDUCTIBLE FOR HURRICANE LOSSES, WHICH MAY RESULT IN HIGH OUT-OF-POCKET EXPENSES TO YOU. FLOOD COVERAGE IS NOT PROVIDED BY THIS POLICY. (ay fo —~ Authorlzod Signaturo HW HO3 01 03 Policy Number: HPC1540319 Insured Copy‘To make inquiries, oblain Information or for = HOMEOWNERS POLICY DECLARATIONS Hesme \X/ 1sé assistance In resolving complaints about this Declaratlon Effective Treurance Coumpony policy, please call your Agent or HomeWise P.O, Box 9181 Customer Service al: 07/20/2014 Marlborough, MA 01752-9181 42:01 AM Standard Time DIRECT BILL 1-866-496-1781 POLICY NUMBER POLICY PERIOD AGENT CODE HPC1640319 07/20/2014 to 07/20/2012 86254H Stelter POLICY FORMS AND ENDORSEMENTS---------- — NUMBER EDITION DESCRIPTION PREMIUM HO 00 03 (04/31) Homeowners 3 Special Form HO 04 96 (04/91) No Sec I] - Llab for Home Day Care Business Limited Sec I HO 23 70 (04/91) Windstorm Exterior Paint or Waterproofing Exclusions - FL. HW 00 01 07 09 Signature Page HW 00 06 02 10 - Existing Damage Exclusion HW 00 11 05 Important Notice Ordinance and Law and RCC HW 00 33 02 10 Limited Fungi or Bacterla Coverage Wet or Dry Rot . Total Limit $10,000 Section |: Each Covered Loss Total Limit $50,000 Section Il; Aggregate Total Limit $10,000 Section |: Polley Aggregate HW 01 09 02 10 Special Provisions - Florida HW 01 10 02 10 Special Provisions - Loss of Use HW 03 51 (05/05) Calendar Year Hurricane Deductible - Florida HW 04 77 02 10 Ordinance or Law Coverage Total Limit of Liability 25% HW 07 07 04 11 Sinkhole Loss Endorsement HW 13 07 09 Standard Pollcy Coverage - Agreement HW 38 02 10 Special Provisions - Llabllity HW 39 02 10 - Collapse Coverage Endorsement HW HO 07 05 Adjusted Bullding Cost Endorsement HW-365 02 01 (08/05) Personal Property Replacement Cost $482.00 HW03 (03/07) Homeowners 00 03 Special Form : HW24 (12/06) - Privacy Policy j HWP 22 (06/06)- Hurricane Exclusion - Screened Enclosures HWP E 14 (01/08) Important Notice Hurricane Deductible HWP E10 (02/09) Option to Remove Windstorm Coverage HWP E11 (07/07) -Option to Remove Contents Coverage HWP E13 (01/08) Important Notice All Other Perils Deductible Options OIR-B1-1655 02/10 Notice of Premium Discounts for Hurricane Mitigation OIR-B1-1670 (1-1-06) Checklist of Coverage INCLUDED EMERGENCY ASSESSMENT, CITIZENS PROPERTY INSURANCE CORPORATION $36.00 MGA FEE $25.00 FLORIDA HURRICANE CATASTROPHE FUND $47.00 EMERGENCY MANAGEMENT PREPAREDNESS $2.00 ASSISTANCE TRUST FUND SURCHARGE 2009 FLORIDA INSURANCE GUARANTY ASSOCIATION ASSESSMENT $11,00 Portion of the Total Premium for Hurricane Coverage $1,557.34 Portion of the Total Premium for Non-Hurricane Coverage $1,654.00 This replaces all proviously (sued policy declarations, If any, This policy appiles only to accidents, occurrences, or losses which happen during the policy period shown above. In case of foss under Section J, only that part of loss ovar stated deductibles applies. This dactaration pege together with all policy provisions and any olher applicable endorsements complates your policy. HW HO3 01 03 Policy Number: HPC1540319 Insured CopyOe ‘To make inquiles, obtain Information or for HOMEOWNERS POLICY DECLARATIONS HeymeWise — Eateriimatenmimaacg., Nonror ae Toeuronce Cinapany policy, please call your Agent or HomeWiso eclaration Effective P.O, Box 9181 Customer Service at: 07/20/2011 Marlborough, MA 01752-9181 42:01 AM Standard Time DIRECT BILL 1-866-496-1781 (POLICY NUMBER POLICY PERIOD AGENT CODE ([HPct640319 07/20/2011 to 07/20/2012 862544 “LAW AND ORDINANCE COVERAGE IS AN IMPORTANT COVERAGE THAT YOU MAY WISH TO PURCHASE. YOU MAY ALSO NEED TO CONSIDER THE PURCHASE OF FLOOD INSURANCE FROM THE NATIONAL FLOOD INSURANCE PROGRAM. WITHOUT THIS COVERAGE, YOU MAY HAVE UNCOVERED LOSSES. PLEASE DISCUSS THESE COVERAGES WITH YOUR INSURANCE AGENT." Mortgagee Information 1 BAC HOME LOANS SERVICING LP ISAOA/ATIMA, INSURANCE DEPARTMENT 1X2-977-01-03 Loan Number PO BOX 961206 172583357 FORT WORTH, TX 76161-0206 HW HO3 01 03 Policy Number: HPCI540319 Insured CopyChecklist of Coverage Policy Type: Homeowner's (Indicate: Homeowner's, Condominium Unit Qwners, Tenant's, Dwelling, or Mobile Home Owner's) The following checkilst Is for informational purposes only. Florida law prohibits this checkltst from changing any of the provisions of the insurance contract which is the subject of this checklist, Any endorsement regarding changes In types of coverage, exclusions, limitations, reductions, deduclibles, coinsurance, renewal provisions, cancellation provisions, surcharges, or credits will be sent separately. Reviewing (his checklist together with your polley can help you gain a belter understanding of your policy's actual coverages and limitations, and may even generate questions. By addressing any questions now, you will be more Prepared laler In the event of a claim. Experience has shown that many questions lend to arise regarding the coverage of allached or detached screened pool enclosures, screened porches, and other lypes of enclosures. Likewise, If your pollcy insures a condominium unit, questions may arise regarding the coverage of eartain ilerns, such as individual heating and air conditioning unils; individual water healers; floor, wall, and ceiling coverings; butll- In cabinets and counter tops; appllances; window trealments and hardware; and electrical fixtures, A clear understanding of your policy's coverages and limitations will reduce confusion that may arise during claims settlement, Please refer to the policy for detalis and any exceptions to (he coverages listed in this checklist, All coverages are subject to the provisions and conditions of the policy and any endorsements. If you have questions regarding your policy, please contact your agent or company. Consumer assistance is avallable from the Department of Financial Services, Division of Consumer Services’ Helpline at (800) 342-2762 or www.fidfs.com. ‘This form was adopted by the Florida Financial Services Commission. Dwelling Structure Coverage (Place of Residence) Loss Settlement Basis: Replacement Cost (.0.: Replacement Cost, Actual Cash Valuo, or Stated Limit of Insurance; $_171,000 Valu, ole.) Other Structures Coverage (Detached from Dwelling) Loss Settlement Basis: Replacement Cost (.e.: Replacemant Cost, Actual Cash Value, or Stated Limit of Insurance; ¢_17,100 Valuo, etc.) Personal Property Coverage Loss Settlement Basis: Replacement Cost {Le.: Replacement Cost, Actual Cash Value, or Limit of insurance: $_85,500 Slated Value, etc.) Deductibles Annual Hurricane; _ $3,420 All Perils (Other Than Hurricane); $2,500 OIR-B1-1670 (1-14-06) Page 1 of 4Checklist of Coverage The above Limit of Insurance, Deductibles, and Loss Seltlement Basis apply to the following perils insured agalnst: (Items below marked Y (Yes) indicate coverage |S included, Those marked N(No) indicate coverage IS NOT Included). Fire or Lightning Hurricane Flood {including storm surge) Windstorm or Hall (other than hurricane) Explosion Riot or Clvll Commotion Aircraft Vehicles Smoke Vandalism or Malicious Mischief Theft Falling Objects Weight of Ice, Snow or Sleet Accidental Discharge or Overflow of Water or Steam ‘Sudden and Accidental Tearing Apart, Cracking, Burning or Bulging Freezing ‘Sudden and Accidental Damage from Arilfically Generated Electrical Current Voleanic Eruption Sinknole Any Other Peril Not Specifically Excluded (dwelling and other structures only) Spoclal limits and loss settlement exceptions may apply to certain items, Refer to your policy for detalls. Z| <|<| 29.21 49, Mask and prep for paint - plastic, paper, wpe (per LF) 20.83 LF@ 0.90% 18,75 50, Seal then paint part of the walls (2 coats) 109.37 SF@ 16.56 51. Paint casing - nwo couts 17.00 LF @ 15,98 52. Paint door/window trim & jamb - 2 coals (per side) 1.00 EA@ 20,46 53, Paint baseboard twocoats 13.00 LF@ 12.22 54, Content Manipulation charge - per hour 1.00 HR @ 38.59 5S. Clean floor 27.08 SF@ a Dining Room LxWxH 10'7" x 9" 4" x8" DESCRIPTION QNTY UNIT COST TOTAL 56. Detach & Reset Cold air return cover 1.00 EA @ (461= 14.61 57. Detach & Reset Ceiling fan & light Lou EA @ 158,75 = 158.75 58. Alarm Pad - Detach & reset 1.00 EA@ 34.57= 34,57 59, Detach & Reset Thermostat 1.00 EA @ 35.77 35.77 60. Window blind - horizantal or vertical - Detach & reset 1.00 EA@ 3447= 3447 61. Floor protection - scl-adhesive plastic film 98.78 SF@ 0.37= 36,55 62, Texture drywall - heavy hand texture 98.78 SF@ onR= 712 63, Mask and prep for paint - plastic, paper, tape (per LF) 39.83 LF@ 0.90= 35.85 64, Paint crown molding - one cout 39.83 LF@ 0.65= 25.89 65, Seal then paiut the ceiling @ coats) 98.78 SF@ 0.70= 69.15 66. Scal then puint part of the walls (2 coats) 239.00 SF@ 0.70= 167.30 67. Paint baseboard - wo coats. 30.00 LF @ 0.94= 28.20 68. Contents - move out then resct - Large room. 1.00 EA@ 61.98= 61.98 212-05-08-2055 17015 Page: 4ATLANTIC COAST CONSULTANTS, LLC. 11900 BISCAYNE BLVD, SUITE 502 NORTH MIAMI, FLORTDA 33181 877-561-2524 FAX 305-354-2880 TAX LD, CONTINUED - Diaing Room DESCRIPTION QNTY UNIT COST TOTAL 69. Clean floor 98.78 SF@ 0.27 = 26.67 Hallway LxWsH 4! £0" 3 3° 1 x 8 DESCRIPTION QNTY UNIT COST TOTAL 70. Smoke detector - Detach & reset 1.00 EA@ 3457> 34.57 71, Mask and prep for paint - plastic, paper, tape (per LF) 15.83 LF@ 0.91 14,25 72, Seal then puint purt of the walls (2 oats) 94.99 SF@ 0.7 66.49 73. Paint casing - two coats 34.00 LF@ Lig 40,12 74, Paint doarhvindow trim & jamb - 2. coats (per side) 2.00 EA@ 2551= 51.02 75, Content Manipulation charge - per hour 1.00 HR@ 38.59 = 38,59 76. Clean floor 14.90 SF@ 0.27= 4.02 MASTERBED ‘Lx Wel (5? x 108 4x 8? Subroom 1: OFFSET LxWaR 6° 10" x 5' 5" x 8! DESCRIPTION QnTY UNIT. CosT TOTAL 77. Detach & Reset Cold air retum cover 1.00 EA @ 14.615 1461 78, Detach & Reset Ceiling fan & light 1,00 FA@ 158.75 = (58,75 79, Light fixture - Detach & reset 1.00 EA@ 35.69= 35.69 80. Detach & Reser Window blind - fubric/woven - up to 7 SF 2.00 EA @ 58.42 81. Window blind ~ horizontal or vertical - Detach & reset 2.00 EA@ 58.42 82, Alarm Sensor - Detach & resct 1.00 EA@ 34,57 83, Floar protection- selCadhesive plastic film 19201 SF@ 71.04 84, R&R Wallpaper border 15.17 LF @ 178.15 85. Prep wall for wallpaper 15.17 SE@ 24.05 86. Floor protection - sel adhesive plastic fitm 192.01 SE@ 71.04 87. R&R Two coat plaster over 5/3” gypsum core blueboard 32.00 SF@ 227.20 88. R&R Acoustic ceiling (popcorn) texture 192.01 SE@ 4 89. Glitter application to acoustic ceiling 19201 SF@ 90. R&R Two coat plaster over 1/2" gypsum core bluebuard 64.00 SF@ 2012-05-08-2055ATLANTIC COAST CONSULTANTS, LLC. 11900 BISCAYNE BLYD, SUITE 502 NORTH MIAMI, FLORIDA 33181 877-561-2524 ¥, 54-2880 TAX LD, CONTINUED - MASTERBED DESCRIPTION QNTY —-UNIT COST TOTAL 91. Texture drywall - sinooth / skim coat (21.00 SF@ ize 92. R&R Bascboard - 3 1/4" 59,00 LE@ 2.95= 93, R&R Ceramic tile 192.01 SF@ 1025 94, R&R Mortar bed for tile 192.01 SF@ 483= 95, Remove Additional labor to remove tile from conerete slab 192.01 SF@ 96. Floor leveling coment - Heavy 192.01 SF@ 97, Dust control barrier per square foot 48.00 SF@ 98. Mask and prep for paint ~ plastic, paper, tape (per LF) 15.17 LF@ 99. Seal/prime the ceiling - one coat (white pigmented shellac) 192.01 SF@ 100. Seal then paint the walls (2 coats) 601.33 SF@ 101. Paint casing - two coats 34.00 LF @ 102, Paint doochvindow trim & jamb - 2 coats (per side) 2.00 EA@ 103, Contents ~ move out then reset ~ Large roam 1.00 EA@ 61.98= 104. Clean floor 7 192.01 SF@ 0.275 MASTERBATH LxWsHf 10° 3" y 5!2"" x 8° DESCRIPTION QNTY —-UNITCOsT TOTAL 105. interior door=Welach & reset - slab only 2.00 EA @ 1508= 316 106, Detach & Reset Light bar- 8 lights 1.00 EA @ 65.64 65.64 107, Window blind - horizontal or vertical - Detach & reset 1,00 EA@ 3447 108. Recessed light fixture - Detach & reset trim only, 1.00 EA@ 236 109, Detuch & Reset Shower curtain rod 1.00 EA@ 13,66 10, Detach & Resel Medicine cabinet 1.00 EA@ 35.00 111, Shelving - Detach & reset 1.00 LF@ 8.00 112, Light fixture ~ Detuch & reser 1,00 EA@ 35.69 113, Detach & Reset Sink faucet - Bathroom 1.00 EA@ 82.24 114, Detach & Reset Sink- single 1.00 EA@ 103.97 115, R&R Countertop - Tile 8.00 SF@ 155.92 116, R&R 1/4" Cement board 8.00 SF@ 27.92 147. R&R Underlayment - 5/8" BC plywood 8.00 SF@ 2032 118, Waterproof membrane - tile underlayment 8.00 SF@ 24,00 119, Detach & Reset Vanity 417 LF@ 166,47 120, P-trap assembly - Detach & reset 1.00 EA@ 28.33 2012-05-08-2055 Page: 67 ATLANTIC COAST CONSULTANTS, LLC. 11900 BISCAYNE BLVD, SUITE 502 NORTH MIAMI, FLORIDA 33181 CONTINUED - MASTERBATH DESCRIPTION QNTY UNIT COST TOTAL 12}, R&R Angle stop 2,00 EA@ 29.93 = 59.86 122. Detach & Resct Shower faucet 1.00 EA @ 54.59 = 54.59 123, Detach & Reset Toiler 1.00 EA@ 170.35 = 170.35 124, R&R Towel bar - Ceramic 1.00 EA @ 53.78 = 53.78 (25, R&R Soap dish - surface mounted ~ Ceramic . 100 EA@ 45.71 126, R&R Casing - 2/4" 34.00 LF@ 66.64 127, R&R Ceramic tile - bullnose - 2" x 6" 18.17 LF@ IS1.SL 128. R&R Tile shower - up fo 60 SF 1.00 EA@ 845.80 129. R&R 1/2" Cement board 52.00 SF@ 177.84 130. R&R Ceramic tile for wall 26.00 SF@ 266,50 131, R&R 1/2" Cement board 26.00 SF@ 88.92 132, R&R Ceramic tile floors 52.96 SF@ 542.84 133. R&R Mortar bed for tile floors 52.96 SF@ 215.02 134, Remove Additionat labor to remove tile from concrete slab 52.96 SF@ 144 135, Floor leveling cement - Heavy 52.96 SF@ 102,21 136, Mask and prep for puint - plastic, puper, tape (per LF) 30.83 LF@ 27.75 137, Seal then paint the surface area (2 coats) 194.00 SF@ 135.80 138. Paint casing - two coats 34.00 LF@ AOA2 139. Paint doorAvindow trim & jamb - 2 coats (per side) 2.00 EA @ 51.02 140, Content Manipulation charge - per hour 1.00 HR@ 38.59 MAST/CLOSET UW 10° 9" x BUG 78 DESCRIPTION QNTY UNIT COST TOTAL 141, Closct shelfand rod package - Detach & reset 18.50 LF@ 1231= 227.74 142. Detach & Reset Closet Organizer - Melamine 5.67 LF@ 47.80 = 271.03 143. Detach & Reset Carpet 86.90 SF@ 0,66 = 57.35 144, Remove Carpet pad 86.90 SF@ 0.09 = 7.82 145, (Install) Carpet pad 86.90 SE@ 9.07= 6.08 146, Floor leveling cement - Heavy 86.90 SF@ 216= 187,70 147, R&R Ceramic tile 8.00 SF@ _ 1025= 82.00 148. R&R Morar bed for tile floors 800 SF@ 4.06 = 32.48 149. Remove Additional labor to remove tile frum conerete slab 8.00 SF@ 1.40= 11.20 150. Dust control bartier per square foot 45.00 SF@ 0.50 = 24.00 2012-05-08-2055 1/7/2015 Page: 7ATLANTIC COAST CONSULTANTS, LLC. 11900 BISCAYNE BLVD, SUITE 502 NORTH MIAMI, FLORIDA 33181 877-561-2524 FAX 305-354-2880 TAXI CONTINUED - MAST/CLOSET DESCRIPTION QNTY UNIT COST TOTAL 151, Mask and prep for paint - plastic, paper, tape (per LIF) 37.67 LF@ 0,90= 33,90 152, Seul then paint the walls (2 cuats) 288.75 SF@ 0.70 = 202.13 153, Contents - move out then reset - Extra large room 1.00 EA @ 115,76= 115.76 FOUNDATION DESCRIPTION QNTY UNIT COST TOTAL 154, Foundation Repair 1.00 EA@ 64,160.00 = 64,160.00 Foundation proposal was provided by Sinkhole Geotech, Inc, GENERALS “DESCRIPTION QNTY UNIT COST TOTAL 155, Packaging, Handling, Storege (Bid Item) 2.00 EA@ 284.02 = S6R.04 156, Dumpster load - Approx. 20 yards, 4 tons of debris 1,00 EA@ 516.69= 516.69 157, Taxes, insurance, permits & feos (Bid item) 2.00 EA@ 500,00 = 4,000.00 158. General Laborer - per hour for final clean, 25.00 HR@ 30.62 = 765.50 Adjustments for Buse Service Charges Adjustment Camenter - Finish, Trim/Cabinet 126.36 Coverage Dwelling @ 100.00 %= 126.36 Carpenter - Mechanic 123.62 Coverage Dwelling @ 100.00 %= 123.62 Cleaning Techniciun 46.66 Coverage Dwelling @ 100.00 %= 46.66 Floor Cleaning Technician 6432 Coverage welling @ 100.00 %= 64.32 Cleaning Remediation Teclnieian 97.84 2012-05-08-2055 172015 Page: &ATLANTIC COAST CONSULTANTS, LLC. 11900 BISCAYNE BLVD, SUITE 502 NORTH MIAMI, FLORIDA 33181 Adjustments for Base Service Charges Adjustment Coverage Dwelling @ 100.00%= 97.84 Concrete Mason 126.18 Coverage Dwelling @ 100.00 %= 126.18 Drywall Installer/Finisher 291.20 Coverage Dwelling @ 100.00%= 291.20 Electrician 158.54 Coverage Dwelling @ w000%= * 198,54 Flooring Installer 110.30 Coverage Dwelling @ 100.00%= 110,30 Wood Flooring Installer 128.16 Coverage Dwelling @ 100.00 %= 128.16 Hardware Installer 116,60 Covernge Dwelling @ 100.00%= 116.60 Heuting / A.C. Mechanic 170.08 Coverage Dwelling @ 100.00%= 170.08 General Luborer 30.62 Coverage Dwelling @ 100.00%= 30.62 Plasterer 308.68 Coverage Dwelling @ 100.00%= 308.68 Plumber 136.52 Coverage Dwelling @ 100.00 %= 386.52 Painter 106.36 Covernge Dwelling @ 100.00 %= 106.36 ‘Stucco Installer 186.96 Coverage Dwelling @ 100.00%= 186.96 Tile/Cultired Marble Installer 84.52 Coverage Dwelling @ 100.00%= 84.52 Wallpaper Hanger 84.42 Coverage Dwelling @ 10.00%= 84.42 Total Adjustments for Base Scrvicc Charges: 2,547.94 Line Ttem Totals; 2012-05-08-2055 120,314.67 2012-05-08-2055 W72015 Page: 9ATLANTIC COAST CONSULTANTS, LLC. 11900 BISCAYNE BLVD, SUITE 502 NORTH MIAMI, FLORIDA 33181 877-561-2524 FAX 305-354-2880 TAX LD. Grand Total Areas: 2,290.58 SF Walls TAT SF Celling 3,062.35 SF Walls and Ceiling T1717 SF Floor 85.75. SY Flooring 290.50 LF Floor Perimeter 666.33 SF Long Wall 478.96 SF Shor. Wall 290.50 UF Cell, Perimeter 0.00 Floor Arca 0.00 Total Arca 0.00 Interior Wall Arca 0.00 Exterior Wall Arca 0,00 Exterior Perimater of ‘Walls 0.00 Surface Area 0.00, Number of Squares 0.00 Total Perimeter Length = 0,00 Total Ridge Length 0.00 Total Hip Length Coverage Amount % Grand Total % Dwelling 117,198.69 99.52% 144,667.01 99.53% Other Structures : 0.00 0.00% 0,00 o.n0% Contents 568,04 048% 684.03 0.47% Total 117,166.73 100.0% 145,351.04 100.0% 2012-05-08-2055 VIROs Page: 10ATLANTIC COAST CONSULTANTS, LLC. 11960 BISCAYNE BLVD, SUITE 502 NORTH MIAMI, FLORIDA 33181 $77-561-2524 FAX 305-354-2880 TAX 1D. Summary for Dwelling Line Ttem Total 117,198.69 Total Adjustments for Base Service Charges 2,547.94 ‘Material Sales Tax. @ 7.000% x 11,560.24 809,22 Subtotal, 120,555.85 ‘Overhead @ 10.0% x 120,555.85 12,055.58 Profit @ 10.0% x 120,555.85 12,055.58 Replacement Cost Valuc $144,667.01 Net Chaim ‘$144,667.01 Carlos A. Nayor 2012-05-08-2055 VI2015 Page: 11ATLANTIC COAST CONSULTANTS, LLC. 11900 BISCAYNE BLVD, SUITE 502 NORTH MIAMI, FLORIDA 33181 0 877-561-2: TAXAD, Line Item Total Material Sales Tax Subtotal Overhead Profit Replacement Cost Value Net Claim 2012-05-08-2055 Be Summary for Contents @ = 7.000% x @ 10.0% x @ 10.0% x Gaitos A. Nayor 28.40 570.03 570.03 568.04 1.99 570,03 57.00 57,00 72015 8684.03, 3684.03, Page: 12@TRI (AD Triad Construction & Management Services €BC1252452 2708 Alt 19 N Suite #501 Palm Harbor, FL 34683 EXHIBIT 727-216-6350 866-359-3331 FAX ’ D Client: Hines, Debra Home: 3816 South Lake Terrace Miramar, FL 33023 Property: 3816 South Lake Terrace Miramar, FL 33023 Operator Info: Operator: OFFICE Estimator: George Zobrist (CBC1258258) Type of Estimate: Sinkhole Activity Date Entered: — 12/27/2015 Date Assigned: Date Est. Completed: 12/29/2015 Date Job Completed: Price List: © FLFL7X_DEC2015 Labor Efficiency: | Restoration/Service/Remodel Estimate: 201 5-HINES-DEBRA GENERAL NOTES: This above ground repair estimate is based on the visible damages observed during the non-destructive site inspection completed by George Zobrist (CBC1258258) on December 19, 2015. The site inspection was conducted at 9:00 A.M. and the following person(s) were present during the inspection: Debra Hines This above ground repair estimate may include some additional repairs (in addition to the visible damage scope of repairs) that will be required based upon our review of the recommended stabilization methods contained within the following engineering report(s): Sinkhole Geotech, Inc. (August 22, 2014) This above ground repair estimate is based on our visual observations and the proposed stabilization repairs listed in the above referenced reports. The estimate specifically does not include any repairs for hidden damages or other damages that may occur during the stabilization process. If additional damages occur and/or additional relevant documentation becomes available, please contact our office to schedule a follow up inspection to revise the estimate as needed, Dennis James State of Florida Certified Building Contractor (CBC1252452) State of Florida Mold Remediator (MRSR764) State of Tennessee Licensed Contractor (00067277)@TRIAD Triad Construction & Management Services CBC1252452 2708 Alt 19 N Suite #501 Palm Harbor, FL 34683 727-216-6350 866-359-3331 FAX Entry/Foyer SE 2015-HINES-DEBRA 104.42 SF Walls 130.15 SF Walls & Ceiling 2.86. SY Flooring 37.92 SF Long Wall 14,92 LF Ceil, Perimeter LxWxH 5'5"x4'9" x7! 25.73 SF Ceiling 25.73 SF Floor 14.92 LF Floor Perimeter 33.25 SF Short Wall Missing Wall - Goes to Floor/Ceiling SS" X7 Opens into Exterior DESCRIPTION QNTY REMOVE REPLACE TOTAL Window blind - horizontal or vertical - 1.00 EA 0.00 29.38 29.38 Detach & reset Paint the walls and ceiling - two coats 130.15 SF 0.00 0.61 79.39 Paint baseboard, oversized - two coats 14.92 LF 0.00 0.94 14.02 Paint door or window opening - 2 coats (per 1,00 EA 0.00 18.93 18.93 side) Floor protection - self-adhesive plastic film 25.73 SF 0.40 0.00 10.29 152.01 Totals: Entry/Foyer Living Room LE 430.42 SF Walls 731.29 SF Walls & Ceiling 33.43 SY Flooring 166,00 SF Long Wall 61.17 LF Ceil. Perimeter LxWxH 20' 9" x 14'6" x 8" 300.88 SF Ceiling 300.88 SF Floor 52.75 LF Floor Perimeter 116.00 SF Short Wall Missing Wall - Goes to Floor ssh x7 Opens into Exterior Missing Wall - Goes to Floor BxT Opens into Exterior Missing Wall - Goes to Floor/Ceiling 94" x8" Opens into Exterior DESCRIPTION QNTY REMOVE REPLACE TOTAL Window blind - horizontal or vertical - 2,00 BA 0.00 29.38 58.76 Detach & reset Mask per square foot for drywall or plaster 731.29 SF 0.00 0.14 102.38 work 2015-HINES-DEBRA 12/29/2015 Page: 2@TRIAD Triad Construction & Management Services CBC1252452 2708 Alt 19 N Suite #501 Palm Harbor, FL 34683 727-236-6350 866-359-3331 FAX CONTINUED - Living Room DESCRIPTION QNTY REMOVE REPLACE TOTAL Plasterer - per hour 4.00 HR 0.00 62.51 250.04 Texture drywall - smooth / skim coat 300.88 SF 0.00 0.71 213.62 Texture drywall - heavy hand texture 300.88 SF 0.00 0.54 162.48 Seal the ceiling w/latex based stain blocker - 300.88 SF 0.00 0.36 108.32 ‘one coat Paint the ceiling - two coats 300.88 SF 0.00 0.61 183.54 Thin coat plaster (no lath) 116.00 SF 0.00 2.96 343.36 Seal the short wall w/latex based stain. 116.00 SF 0.00 0.36 41.76 blocker - one coat Paint the walls - two coats 430.42 SF 0.00 0.61 262.56 Paint crown molding - two coats 61.17LF 0.00 0.88 53.83 Paint chair rail - two coats 52.75 LF 0.00 0.85 44.84 R&R Baseboard - 3 1/4" 52.75 LF 0.37 2.64 158.78 Paint baseboard, oversized - two coats 52.75 LF 0.00 0.94 49.59 Floor protection - self-adhesive plastic film 300.88 SF 0.40 0.00 120.35 Totals: Living Room 2,154.21 Dining Room LxWxH 16°10" x9' 4" x 8 192.00 SF Walls 101.11 SF Ceiling SS 293.11 SF Walls & Ceiling 101.11 SF Floor RS 11.23 SY Flooring 23.00 LF Floor Perimeter 86.67 SF Long Wall 74.67 SF Short Wall 31.00 LF Ceil. Perimeter Missing Wall - Goes to Floor/Cciling. oa" XB Opens into Exterior Missing Wall - Goes to Floor S'X7! Opens into Exterior Missing Wall - Goes to Floor 3X7 Opens into Exterior DESCRIPTION QNTY REMOVE REPLACE TOTAL Ceiling fan - Detach & reset 1.00 EA 0.00 155.25 155.25 Window blind - horizontal or vertical - 1.00 EA 0.00 29.38 29.38 Detach & reset 2015-HINES-DEBRA 12/29/2015 Page: 3@TRIAD Triad Construction & Management Services CBC1252452 2708 Alt 19 N Suite #501 Palm Harbor, FL 34683 727-216-6350 866-359-3331 FAX CONTINUED - Dining Room DESCRIPTION QNTY REMOVE REPLACE TOTAL Mask per square foot for drywall or plaster 293.11 SF 0.00 0.14 41.04 work Texture drywall - smooth / skim coal 101.11 SF 0.00 0.7) 71.79 Texture drywall - heavy hand texture 101.11 SF 0,00 0.54 54.60 Seal the ceiling w/latex based stain blocker - 101.11 SF 0.00 0.36 36.40 one coat Paint the ceiling - two coats 101.11 SF 0.00 0.61 61.68 Plasterer - per hour 1.00 HR. 0.00 62.51 62.51 Thin coat plaster (no lath) 86.67 SF 0.00 2.96 256.54 Seal the long wall w/latex based stain 86.67 SF 0.00 0.36 31.20 blocker - one coat Paint the walls - two coats 192.00 SF 0.00 0.61 117.42 Paint crown molding - two coats 31.00 LF . 0.00 0.88 27.28 Paint chair rail - two coats 23.00 LF 0.00 0.85 19.55 Paint baseboard, oversized - two coats 23.00 LF 0.00 0.94 21.62 Floor protection - self-adhesive plastic film 101.11 SF 0.40 0.00 40.44 Totals: Dining Room 1,026.40 Kitchen DESCRIPTION QNTY REMOVE REPLACE TOTAL NOTE: There were no visible damages observed at the time of the inspection. Totals: Kitchen 0.00 2015-HINES-DEBRA 12/29/2015 Page: 4@TRIAD Triad Construction & Management Services CBC1252452 2708 Alt 19 N Suite #501 Palm Harbor, FL 34683 727-216-6350 866-359-3331 FAX Family Room EP 400.94 SF Walls 578.03 SF Walls & Ceiling 19.68 SY Flooring 141.67 SF Long Wall 54.83 LF Ceil. Perimeter LxWxH 17'x 10'S" x 8'4" 177.08 SF Ceiling 177.08 SF Floor 46.83 LF Floor Perimeter 86.81 SF Short Wall Missing Wall - Goes to Floor Bx7 Opens into Exterior DESCRIPTION QNTY REMOVE REPLACE TOTAL Finish carpentry repairs - per hour 6.00HR 0.00 55.00 330.00 R&R Exterior door - metal - insulated - flush 1.00 EA 17.16 21.72 288.88 or panel style Paint door slab only - 2 coats (per side) 2.00 EA 0.00 19.47 38.94 Paint door or window opening - 2 coats (per 1.00EA 0.00 18.93 18.93 side) Door lockset - Detach & reset 1.00 EA 0.00 19.61 19.61 Painter - per hour 4.00HR 0.00 42.15 168.60 Acoustical Treatments Installer - per hour 4.00 HR 0.00 48.75 195.00 R&R Paneling 400.94 SF 0.24 2.10 938.20 Framing repairs - per hour 2.00 HR 0.00 70.00 140.00 Floor protection - self-adhesive plastic film 177.08 SF 0.40 0.00 70.83 Totals: Family Room 2,208.99 Hallway LxWxH 4! 10" x3" x 8" 104.33 SF Walls 14,50 SF Ceiling 118,83 SF Walls & Ceiling 14,50 SF Floor ES 1.61 SY Flooring 38.67 SF Long Wall 15.67 LF Ceil. Perimeter 12.67 LF Floor Perimeter 24.00 SF Short Wall Missing Wall - Goes to Floor vx Opens into Exterior DESCRIPTION QNTY REMOVE REPLACE TOTAL Mask per square foot for drywall or plaster 104.33 SF 0.00 0.14 14.61 work 2015-HINES-DEBRA 12/29/2015 Page: 5@TRIAD Triad Construction & Management Services CBC1252452 2708 Alt 19 N Suite #501 Palm Harbor, FL 34683 727-216-6350 866-359-3331 FAX CONTINUED - Hallway DESCRIPTION QNTY REMOVE REPLACE TOTAL Plasterer - per hour 1.00 HR. 0.00 62.51 62.51 Thin coat plaster (no lath) 38.67 SF 0.00 2.96 114.46 Seal the long wall w/latex based stain 38.67 SF 0.00 0.36 13.92 blocker - one coat Paint the walls and ceiling - two coats 118.83 SF 0.00 0.61 72.49 Paint baseboard, oversized - two coats 12.67 LF 0.00 0.94 11.91 na door or window opening - 2 coats (per 3.00 BA 0.00 18.93 56.79 side) Floor protection - self-adhesive plastic film 14.50 SF 0.40 0.00 5.80 352.49 Totals: Hallway Master Bedroom ZB 353.34 SF Walls 510.06 SF Walls & Ceiling 17.41 SY Flooring 121.33 SF Long Wall 44.17 LF Ceil. Perimeter Subroom 1: Offset 1 SP 140.01 SF Walls 176.45 SF Walls & Ceiling 4.05 SY Flooring 54.67 SF Long Wall 17.50 LF Ceil. Perimeter LxWxH 15'2" x 10'4" x 8! 156.72 SF Ceiting 156.72 SF Floor 44.17 LF Floor Perimeter 82.67 SF Short Wall LxWxH 6' 10" x 5' 4" x 8" 36.44 SF Ceiling 36.44 SF Floor 17.50 LF Floor Perimeter 42.67 SF Short Wall Missing Wall - Goes to Floor/Ceiling 610" Xs" Opens into Master Bedroom DESCRIPTION QNTY REMOVE REPLACE TOTAL Ceiling fan - Detach & reset 1.00 EA 0.00 155.25 155,25 Light fixture - Detach & reset 1.00 EA 0.00 39.38 39,38 Window blind - horizontal or vertical - 2.00 EA 0.00 29.38 58.76 Detach & reset 2015-HINES-DEBRA 12/29/2015 Page: 6@TRIAD Triad Construction & Management Services CBC1252452 2708 Alt 19 N Suite #501 Palm Harbor, FL 34683 727-216-6350 866-359-3331 FAX CONTINUED - Master Bedroom DESCRIPTION QNTY REMOVE REPLACE TOTAL Mask per square foot for drywall or plaster 686.51 SF 0.00 0.14 96.11 work R&R 5/8" blueboard - hung only (no tape or 96.58 SF 0.33 1.05 133.28 finish) Plasterer - per hour 4.00 HR 0.00 62.51 250.04 Remove Tear off painted acoustic ceiling 96.58 SF 0.73 0.00 70.50 (popcorn) texture Seal the ceiling w/latex based stain blocker - 193.17 SF 0.00 0.36 69.54 one coat Acoustic ceiling (popcorn) texture 193.17 SF 0.00 0.56 108.18 R&R 1/2" blueboard - hung only (no tape or 246.67 SF 0.33 0.99 325.60 finish) Thin coat plaster (no tath) 493.34 SF 0.00 2.96 1,460.29 Seal the walls w/latex based stain blocker - 493.34 SF 0.00 0.36 177.60 one coat Paint the walls - two coats 493.34 SF 0.00 0.61 300.94 R&R Wallpaper border 15,00 LF 0.54 2.26 42.00 Prep wall for wallpaper 15.00 SF 0.00 0.41 6.15 R&R Baseboard - 3 1/4" 61.67 LF 037 2.64 185.63 Paint baseboard - two coats 61.67 LF 0.00 0.85 52.42 Detach & Reset Interior door - Colonist - 1.00 BA 0.00 0.00 1715 slab only Paint door or window opening - 2 coats (per 2.00 EA 0.00 18.93, 37.86 side) R&R Aluminum window - jalousie, 12-23 sf 2.00 EA 18.08 411.49 859.14 R&R Marble sill 6.00 LF 0.90 8.00 53.40 Floor leveling cement - Heavy 193.17 SF 0.00 1.98 382.48 R&R Tile floor covering 193,17 SF 2.00 6.63 1,667.06 Remove Additional labor to remove tile 193.17 SF 1.43 0.00 216.23 from conerete slab Electrician - per hour 2.00 HR 0.00 80.00 160.00 Framing repairs - per hour 8.00 HR 0.00 70.00 560.00 Floor protection - self-adhesive plastic film 193.17 SF 0.40 0.00 71.21 Totals: Master Bedroom 7,622.26 2015-HINES-DEBRA 12/29/2015 Page: 7@TRIAD Triad Construction & Management Services CBC1252452 2708 Alt 19 N Suite #501 Palm Harbor, FL 34683 727-216-6350 866-359-3331 FAX Master Bathroom 2 242.67 SF Walls 293.50 SF Walls & Ceiling 5.65 SY Flooring 81.33 SF Long Wall 30.33 LF Ceil. Perimeter LxWxH 10' 2" x 5'x 8" 50.83 SF Ceiling 50.83 SF Floor 30.33 LF Floor Perimeter 40.00 SF Short Wall DESCRIPTION QNTY REMOVE REPLACE TOTAL Light fixture - Detach & reset 1.00 EA 0.00 39.38 39.38 Mask per square foot for drywall or plaster 293.50 SF 0.00 0.14 41.09 work Plasterer - per hour 2.00 HR 0.00 62.51 125.02 Thin coat plaster (no lath) 50.83 SF 0.00 2.96 150.46 Seal the ceiling w/latex based stain blocker - 50.83 SF 0.00 0.36 18.30 one coat Paint the ceiling - two coats 50.83 SF 0.00 0.61 31.01 Thin coat plaster (no lath) 40.00 SF 0.00 2.96 118.40 Seal part of the walls w/latex based stain 40.00 SF 0.00 0.36 14.40 blocker - one coat Paint part of the walls - two coats 40.00 SF 0.00 0.61 24.40 R&R Interior door unit 2.00 EA 15.00 144.83 319.66 Paint door slab only - 2 coats (per side)