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Filing # 32188705 E-Filed 09/17/2015 03:46:26 PM
IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO: CACE- 14-016655 (02)
DEBRA HINES,
Plaintiff,
VS.
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.,
a Florida corporation,
Defendants.
/
PLAINTIFF’S AMENDED RESPONSES TO DEFENDANT’S
INTERROGATORIES
COMES NOW, Plaintiff, DEBRA HINES, by and through her undersigned
counsel, and hereby Responds to Defendant’s Interrogatories as follows:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing instrument
was sent via email this 17" day of Septemaber, 2015, to: Jonathan Hall, Esq. and Robert
Schulte, Esq.; GROELLE & SALMON P.A., 11301 Okeechobee Blvd., Second Floor,
West Palm Beach, Florida 33411; Telephone: (561) 963-5500; Fax: (561) 963-2265;
email: gsweourldocs@gspalaw.com and gclausen@gspalaw.com,
Sherman Law, P.A.
4000 Hollywood Blvd., #265-S
Hollywood, FL 33021
Office: (954) 894-8000
Direct: (305) 494-6345
Fax: (305) 397-1725
By:_/s/ Julio Martinez
RYAN SHERMAN, Esq.
Florida Bar No.: 686271
JULIO MARTINEZ, Esq.
Florida Bar No.: 85128
Esetvice: EserviceSLPA@gmail.com
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/17/2015 3:46:26 PM.****INTERROGATORIES TO PLAINTIFF
1. Please describe with specificity the loss which occurred at your property. State
when it occurred, how it occurred, who discovered it, and how it was discovered.
ANSWER:
Plaintiffs first noticed “bubbling” and cracking on an interior
wall. Plaintiffs investigated further and discovered cracking in
walls and flooring inside and outside the subject home, as well
as damage in frame of house. Further investigation also
uncovered cracks in pool area.
2. Please identify all individuals that have an opinion about the presence of sinkhole
activity. Provide all known contact information.
ANSWER:
Carlos Nayor, Adjuster
Atlantic Coast Consultants, LLC
11900 Biscayne Blvd, Suite 502, North Miami Beach, FL 33181
Ahmed Said, Sinkhole Geotech, Inc.
21859 State Road 54, Lutz, FL 33549
Sam Upchurch, SDII Global Corporation.
4509 George Road, Tampa, FL 33634
Any agents and/or representatives of Homeowners Choice.
3. Please identify all individuals that have an opinion about the presence of
structural damage. Provide all known contact information.
ANSWER:
See Plaintiff's Response to Interrogatory #2.
4, Please identify all individuals that can support your claim that “on or about
February 20, 2012, the Plaintiff suffered a loss on account of a sinkhole causing damage
to Plaintiff's property”. Provide all known contact information.
ANSWER:
Carlos Nayor, Adjuster
Atlantic Coast Consultants, LLC
11900 Biscayne Blvd, Suite 502, North Miami Beach, FL 33181
Ahmed Said, Sinkhole Geotech, Inc.
21859 State Road 54, Lutz, FL 33549
25. Please identify all individuals that disagree with the causes of damage outlined in
the SDII Global Corporation report and provide all known contact information.
ANSWER: Carlos Nayor, Adjuster
Atlantic Coast Consultants, LLC
11900 Biscayne Blvd, Suite 502, North Miami Beach, FL 33181
Ahmed Said, Sinkhole Geotech, Inc.
21859 State Road 54, Lutz, FL 33549
6. Please identify and describe all contractual obligations you are alleging the
Defendant failed to comply with.
ANSWER: Objection, this interrogatory requires policy interpretation,
which is reserved for the trial court. Notwithstanding the
objection, Defendant failed to pay to repair damages associated
with the sink-hole which Plaintiff believes is covered under the
policy.
7. Please identify all portions of the policy and/or all statutes you are secking a
judicial interpretation of.
ANSWER: See Petition for Declaratory Relief Count found within
Complaint. Also, please refer to denial letter which cites the
following specific policy language Plaintiff is seeking judicial
interpretation of:
SECTION I —- PERILS INSURED AGAINST
COVERAGE A- DWELLING AND COVERAGE B - OTHER
STRUCTURES
We insure against risk of direct loss to property described in Coverages A and B
only if that loss is physical loss to property. We do not insure, however, for loss:
2. Caused by:
e. Any of the following:
(1) Wear and tear, marring
(6) Settling, shrinking, bulging or expansion, including resultant cracking, of
pavements, patios, foundations, walls, floors, roofs or ceilings;
SECTION I - EXCLUSIONS
we1. We do not insure for loss caused directly or indirectly by any of the following.
Such loss is excluded regardless of any other cause or event contributing
concurrently or in any sequence to the loss.
b. Earth Movement and Settlement, meaning:
(5) Earth sinking, rising or shifting;
(8) Settling, cracking or expansion of foundations;
2. We do not insure for loss to property described in Coverages A and B caused
by any of the following. However, any ensuing loss to property described in
Coverages A and B not excluded or excepted in this policy is covered.
c. Faulty, inadequate or defective:
(1) Planning, zoning, development, surveying, siting;
(2) Design, specifications, workmanship, repair, construction, renovation,
remodeling,
(3) Materials used in repair, construction, renovation or remodeling; or
(4) Maintenance;
of part or all of any property whether on or off the “residence” premises.
We insure the property covered under Section I for a “Sinkhole Loss” that occurs
during the policy period.
This endorsement is subject to the terms and conditions of the policy.
DEFINITIONS
The following definitions are added:
“Sinkhole activity” means settlement or systematic weakening of the earth
supporting property only when settlement or systematic weakening results from
movement or reveling of soils, sediments, or rock materials into subterranean
voids created by the effect of water on limestone or similar rock formation.
“Sinkhole loss” means “structural damage” to the building, including foundation,
caused by “sinkhole activity”. Contents coverage shall apply only if there is
“structural damage” to the building caused by “sinkhole activity”.
a. The settlement or systematic weakening must result from movement or
reveling of soils, sediments, or rock material into subterranean voids created by
the effect of water on limestone or similar rock formations.
2. “Sinkhole loss” means actual physical damage caused by “Sinkhole Activity”.
“Structural Damage” for purposes of “sinkhole Loss” coverage means:
1. Damage to a covered building, including the foundation, that prevents
the primary structural members and/or primary structural systems
from supporting the loads and forces that they were designed to
support; and
2. Atleast one of the following:
48.
a. For buildings utilizing a concrete slab foundation, that
horizontal surface mapping of the floor proves there is a
vertical variance within the floor resulting from sinkhole
related displacement that is greater than the maximum
allowable vertical variance permitted by the current Florida
Building Code of one half inch within a 10 foot horizontal
distance; or
b. For buildings utilizing wood floors members, that horizontal
surface mapping of the floors proves there is a vertical
variance within the floor resulting from sinkhole related
displacement that is greater than the maximum allowable
deflection permitted by current Florida Building Code.
3. “Structural Damage” for purposes of “Sinkhole Loss” coverage exists
only if both 1 and 2 above are satisfied.
Please identify and state all damages you are seeking to recover for and identify
all individuals that can support the amount.
10.
ANSWER: See estimate previously provided in response to Request for
Production. Specifically, the estimate totals $144,667.01 in
Coverage A damages, $684.03 in Contents damages. Also, per
the Complaint, Plaintiff is seeking damages owed as a result of
Florida Statute 627.428. This answer in now way should be
considered a waiver of potential Bad Faith damages which
Plaintiff would seek at the appropriate time.
Please state all conditions precedent to recovery you have performed.
ANSWER: Plaintiff, or representatives acting on her behalf, reported the
claim timely, exhibited the property, and otherwise fully
cooperated with Defendant’s investigation of the claim.
Please state all conditions you are alleging the Defendant waived.
ANSWER: Objection, this interrogatory seeks policy interpretation which
is reserved for the trial court. Notwithstanding the objection,
Plaintiff believes Defendant has waived all policy conditions it
is entitled to after it failed to provide coverage for the subject
loss.11. Please describe all actions you have done to protect the property from further
damage following the loss.
ANSWER: Plaintiff diligently reported the claim, acted promptly to
determine the cause of the problem, and mitigated as much as
possible. Unlike a plumbing loss or roof leak, sinkholes
nitigation is difficult absent an expertise.
12. Please describe how “the Plaintiff has been damaged monetarily in regard to their
SINKHOLE CLAIM by the failure of the Defendant to comply with its contractual
obligations”.
ANSWER: Plaintiffs property, insured by the subject policy, is damaged.
See estimate for repairs to damages caused by the loss at issue.
13. Please identify all dates you or your representatives had communication with the
Defendant or its representatives, including but not limited to ROL Insurance Consulting,
as it relates to this loss and for each date state the substance and form of the
communication.
ANSWER: Please see Documents attached with Plaintiff's Responses to
Defendant’s Request for Production.
14. Please describe all communication you ever had with Walter Tim Swope.
ANSWER: Please see Documents attached with Plaintiff's Responses to
Defendant’s Request for Production. Plaintiff does not recall
specific details about conversation(s) with Mr. Swope.
Investigation continues.
15. Please describe all actions you witnessed any individual doing while inspecting
your property as it relates to this loss. Identify the individual, the action, and the date.
ANSWER: Plaintiff cannot recall precisely what was done during the
objections; simply that the inspectors walked around the
interior and exterior of the home and took pictures. Plaintiff
also recalls on two occasions machines were used to check the
subsurface beneath the home.
616. Please describe all communication you have had with any employees of SDII
Global Corporation.
ANSWER: Plaintiff identified the damage she believes is caused by the
sink hole that were present at the time of their inspection. She
also described, to the best of her ability, how long those
damages were present for. Plaintiff does not recall the date of
SDII’s inspection.
17. Please state when and how the loss was reported to the Defendant, how the loss
was described, who reported the loss, who the loss was reported to (name of
individual(s), and what was said between whoever reported it and whoever it was
reported to.
ANSWER: Loss was reported by Plaintiff's husband (deceased since
September 2013).
18. Please state why the loss was reported on the day it was reported.
ANSWER: Loss was reported soon after Plaintiff's discovery of the
damage.
19. Please identify all other insurance claims you have had and state the outcome of
those claims.
ANSWER: Fire loss claim in approximately 2011/2012. Coverage was
extended. Plaintiff made all repairs; expended monies in excess
to payment by insurance company. Plaintiff cannot find
records relating to those repairs; investigation continues.
20. Please state whether the damage has changed in any way since April 9, 2012, the
day SDII Global Corporation completed a damage assessment, and if so describe how the
damage has changed, and when it changed.
ANSWER: _ Since the inspection, cracks in bedroom have become worse,
window by the side of the bed has become worse, cracks on the
outside have become worse, driveway cracks have
materialized, cracks by the garage have materialized. Plaintiff
7reserves the right to amend this response as damages continue
to get worse.
21. Please state whether you are aware of sinkhole activity in your neighborhood and
if so identify the addresses and any engineering or geological report you are aware of for
those properties.
ANSWER: Plaintiff under belief that neighbor across the street had
sinkhole issue in 2013, and neighbor 3 or 4 doors down had
recent sinkhole activity in 2014.
22. Please list all periods of time for which you have resided at the property.
ANSWER: Plaintiff has lived in home since purchased in 2000.
23. Please list all periods of time for which you have owned the property.
ANSWER: Property has been owned by Plaintiffs since 2000, although
property was deeded to Plaintiff's brother, Eugene McGirt
from 2003-2007.
24. Please describe why the property was deeded to Eugene McGirt from
approximately 2003 — 2007.
ANSWER: Objection, this interrogatory is irrelevant and not reasonably
calculated to lead to the discovery of admissible evidence.
Without waiving the objection, this was done in connection
with a foreclosure which has since been resolved.
25. Please state whether you have every attempted to sell the property.
ANSWER: No.26. Please describe all repairs, modifications, or renovations that have been done to
the property. State who did the work, when the work was done, and how much was spent
doing the work. Provide all known contact information for the individuals listed.
ANSWER: 2011/2012: Repairs made to kitchen following Fire Loss in
2011/2012.
2005/2006: Repairs and renovations in Kitchen; namely
counter, cabinetry and flooring.
Florida Insurance Restoration Experts completed repairs
however Plaintiff does not recall in connection with which loss
these repairs were completed. Contact information as follows
for subject repairman 2890 State Road 84, Suite 108, Fort
Lauderdale, Florida 33312
27. Please describe all communication with Tim Greene as it relates to this loss.
Provide all known contact information for him.
ANSWER: Tim Greene was contractor for repair following Fire Loss in
2011/2012. Mr. Greene discussed the potential of making the
repairs relating to the subject loss as well.
28. Please state whether you are claiming damage to any Other Structures or damage
that you believe would be covered under Coverage B in the policy and describe such
damage.
ANSWER: Not applicable, investigation continues.
29. Please describe all contractual and statutory duties which you allege the
Defendant failed to comply with and list all damages which have resulted from the failure
to comply with said duty.
ANSWER: Please see Complaint which speaks for itself.
30. Please describe why you believe the Defendant breached the contract and list all
damages which have resulted from the breach.
ANSWER: Objection, this interrogatory requests information protected
by the attorney client privilege.STATE OF FLORIDA __)
Ss:
COUNTY orBrowae )
mh
The foregoing instrument was acknowledged by me this It day of
Suptomber, 201 Id by Debra Hi NLS , who is personally known to me or
Drivers Cituse LO.
who has produced H520- (70-58 N, as identification and who did (did not) take an
oath,
BRENDA MINORS NOTARY PUBLIC
a Notary Public - State of Florida
=
Commission # FF 185923
F My Comm. Expires Dec 28, 2018
_Eoned through National Notary Assn Bron d h | E
(Name of Notary, typed,
written or stamped)
(Title)
(Serial Number, if any)
Preview
Filing # 32188705 E-Filed 09/17/2015 03:46:26 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE- 14-016655 (02) DEBRA HINES, Plaintiff, VS. HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC., a Florida corporation, Defendants. / PLAINTIFF’S AMENDED RESPONSES TO DEFENDANT’S INTERROGATORIES COMES NOW, Plaintiff, DEBRA HINES, by and through her undersigned counsel, and hereby Responds to Defendant’s Interrogatories as follows: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing instrument was sent via email this 17" day of Septemaber, 2015, to: Jonathan Hall, Esq. and Robert Schulte, Esq.; GROELLE & SALMON P.A., 11301 Okeechobee Blvd., Second Floor, West Palm Beach, Florida 33411; Telephone: (561) 963-5500; Fax: (561) 963-2265; email: gsweourldocs@gspalaw.com and gclausen@gspalaw.com, Sherman Law, P.A. 4000 Hollywood Blvd., #265-S Hollywood, FL 33021 Office: (954) 894-8000 Direct: (305) 494-6345 Fax: (305) 397-1725 By:_/s/ Julio Martinez RYAN SHERMAN, Esq. Florida Bar No.: 686271 JULIO MARTINEZ, Esq. Florida Bar No.: 85128 Esetvice: EserviceSLPA@gmail.com *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/17/2015 3:46:26 PM.****INTERROGATORIES TO PLAINTIFF 1. Please describe with specificity the loss which occurred at your property. State when it occurred, how it occurred, who discovered it, and how it was discovered. ANSWER: Plaintiffs first noticed “bubbling” and cracking on an interior wall. Plaintiffs investigated further and discovered cracking in walls and flooring inside and outside the subject home, as well as damage in frame of house. Further investigation also uncovered cracks in pool area. 2. Please identify all individuals that have an opinion about the presence of sinkhole activity. Provide all known contact information. ANSWER: Carlos Nayor, Adjuster Atlantic Coast Consultants, LLC 11900 Biscayne Blvd, Suite 502, North Miami Beach, FL 33181 Ahmed Said, Sinkhole Geotech, Inc. 21859 State Road 54, Lutz, FL 33549 Sam Upchurch, SDII Global Corporation. 4509 George Road, Tampa, FL 33634 Any agents and/or representatives of Homeowners Choice. 3. Please identify all individuals that have an opinion about the presence of structural damage. Provide all known contact information. ANSWER: See Plaintiff's Response to Interrogatory #2. 4, Please identify all individuals that can support your claim that “on or about February 20, 2012, the Plaintiff suffered a loss on account of a sinkhole causing damage to Plaintiff's property”. Provide all known contact information. ANSWER: Carlos Nayor, Adjuster Atlantic Coast Consultants, LLC 11900 Biscayne Blvd, Suite 502, North Miami Beach, FL 33181 Ahmed Said, Sinkhole Geotech, Inc. 21859 State Road 54, Lutz, FL 33549 25. Please identify all individuals that disagree with the causes of damage outlined in the SDII Global Corporation report and provide all known contact information. ANSWER: Carlos Nayor, Adjuster Atlantic Coast Consultants, LLC 11900 Biscayne Blvd, Suite 502, North Miami Beach, FL 33181 Ahmed Said, Sinkhole Geotech, Inc. 21859 State Road 54, Lutz, FL 33549 6. Please identify and describe all contractual obligations you are alleging the Defendant failed to comply with. ANSWER: Objection, this interrogatory requires policy interpretation, which is reserved for the trial court. Notwithstanding the objection, Defendant failed to pay to repair damages associated with the sink-hole which Plaintiff believes is covered under the policy. 7. Please identify all portions of the policy and/or all statutes you are secking a judicial interpretation of. ANSWER: See Petition for Declaratory Relief Count found within Complaint. Also, please refer to denial letter which cites the following specific policy language Plaintiff is seeking judicial interpretation of: SECTION I —- PERILS INSURED AGAINST COVERAGE A- DWELLING AND COVERAGE B - OTHER STRUCTURES We insure against risk of direct loss to property described in Coverages A and B only if that loss is physical loss to property. We do not insure, however, for loss: 2. Caused by: e. Any of the following: (1) Wear and tear, marring (6) Settling, shrinking, bulging or expansion, including resultant cracking, of pavements, patios, foundations, walls, floors, roofs or ceilings; SECTION I - EXCLUSIONS we1. We do not insure for loss caused directly or indirectly by any of the following. Such loss is excluded regardless of any other cause or event contributing concurrently or in any sequence to the loss. b. Earth Movement and Settlement, meaning: (5) Earth sinking, rising or shifting; (8) Settling, cracking or expansion of foundations; 2. We do not insure for loss to property described in Coverages A and B caused by any of the following. However, any ensuing loss to property described in Coverages A and B not excluded or excepted in this policy is covered. c. Faulty, inadequate or defective: (1) Planning, zoning, development, surveying, siting; (2) Design, specifications, workmanship, repair, construction, renovation, remodeling, (3) Materials used in repair, construction, renovation or remodeling; or (4) Maintenance; of part or all of any property whether on or off the “residence” premises. We insure the property covered under Section I for a “Sinkhole Loss” that occurs during the policy period. This endorsement is subject to the terms and conditions of the policy. DEFINITIONS The following definitions are added: “Sinkhole activity” means settlement or systematic weakening of the earth supporting property only when settlement or systematic weakening results from movement or reveling of soils, sediments, or rock materials into subterranean voids created by the effect of water on limestone or similar rock formation. “Sinkhole loss” means “structural damage” to the building, including foundation, caused by “sinkhole activity”. Contents coverage shall apply only if there is “structural damage” to the building caused by “sinkhole activity”. a. The settlement or systematic weakening must result from movement or reveling of soils, sediments, or rock material into subterranean voids created by the effect of water on limestone or similar rock formations. 2. “Sinkhole loss” means actual physical damage caused by “Sinkhole Activity”. “Structural Damage” for purposes of “sinkhole Loss” coverage means: 1. Damage to a covered building, including the foundation, that prevents the primary structural members and/or primary structural systems from supporting the loads and forces that they were designed to support; and 2. Atleast one of the following: 48. a. For buildings utilizing a concrete slab foundation, that horizontal surface mapping of the floor proves there is a vertical variance within the floor resulting from sinkhole related displacement that is greater than the maximum allowable vertical variance permitted by the current Florida Building Code of one half inch within a 10 foot horizontal distance; or b. For buildings utilizing wood floors members, that horizontal surface mapping of the floors proves there is a vertical variance within the floor resulting from sinkhole related displacement that is greater than the maximum allowable deflection permitted by current Florida Building Code. 3. “Structural Damage” for purposes of “Sinkhole Loss” coverage exists only if both 1 and 2 above are satisfied. Please identify and state all damages you are seeking to recover for and identify all individuals that can support the amount. 10. ANSWER: See estimate previously provided in response to Request for Production. Specifically, the estimate totals $144,667.01 in Coverage A damages, $684.03 in Contents damages. Also, per the Complaint, Plaintiff is seeking damages owed as a result of Florida Statute 627.428. This answer in now way should be considered a waiver of potential Bad Faith damages which Plaintiff would seek at the appropriate time. Please state all conditions precedent to recovery you have performed. ANSWER: Plaintiff, or representatives acting on her behalf, reported the claim timely, exhibited the property, and otherwise fully cooperated with Defendant’s investigation of the claim. Please state all conditions you are alleging the Defendant waived. ANSWER: Objection, this interrogatory seeks policy interpretation which is reserved for the trial court. Notwithstanding the objection, Plaintiff believes Defendant has waived all policy conditions it is entitled to after it failed to provide coverage for the subject loss.11. Please describe all actions you have done to protect the property from further damage following the loss. ANSWER: Plaintiff diligently reported the claim, acted promptly to determine the cause of the problem, and mitigated as much as possible. Unlike a plumbing loss or roof leak, sinkholes nitigation is difficult absent an expertise. 12. Please describe how “the Plaintiff has been damaged monetarily in regard to their SINKHOLE CLAIM by the failure of the Defendant to comply with its contractual obligations”. ANSWER: Plaintiffs property, insured by the subject policy, is damaged. See estimate for repairs to damages caused by the loss at issue. 13. Please identify all dates you or your representatives had communication with the Defendant or its representatives, including but not limited to ROL Insurance Consulting, as it relates to this loss and for each date state the substance and form of the communication. ANSWER: Please see Documents attached with Plaintiff's Responses to Defendant’s Request for Production. 14. Please describe all communication you ever had with Walter Tim Swope. ANSWER: Please see Documents attached with Plaintiff's Responses to Defendant’s Request for Production. Plaintiff does not recall specific details about conversation(s) with Mr. Swope. Investigation continues. 15. Please describe all actions you witnessed any individual doing while inspecting your property as it relates to this loss. Identify the individual, the action, and the date. ANSWER: Plaintiff cannot recall precisely what was done during the objections; simply that the inspectors walked around the interior and exterior of the home and took pictures. Plaintiff also recalls on two occasions machines were used to check the subsurface beneath the home. 616. Please describe all communication you have had with any employees of SDII Global Corporation. ANSWER: Plaintiff identified the damage she believes is caused by the sink hole that were present at the time of their inspection. She also described, to the best of her ability, how long those damages were present for. Plaintiff does not recall the date of SDII’s inspection. 17. Please state when and how the loss was reported to the Defendant, how the loss was described, who reported the loss, who the loss was reported to (name of individual(s), and what was said between whoever reported it and whoever it was reported to. ANSWER: Loss was reported by Plaintiff's husband (deceased since September 2013). 18. Please state why the loss was reported on the day it was reported. ANSWER: Loss was reported soon after Plaintiff's discovery of the damage. 19. Please identify all other insurance claims you have had and state the outcome of those claims. ANSWER: Fire loss claim in approximately 2011/2012. Coverage was extended. Plaintiff made all repairs; expended monies in excess to payment by insurance company. Plaintiff cannot find records relating to those repairs; investigation continues. 20. Please state whether the damage has changed in any way since April 9, 2012, the day SDII Global Corporation completed a damage assessment, and if so describe how the damage has changed, and when it changed. ANSWER: _ Since the inspection, cracks in bedroom have become worse, window by the side of the bed has become worse, cracks on the outside have become worse, driveway cracks have materialized, cracks by the garage have materialized. Plaintiff 7reserves the right to amend this response as damages continue to get worse. 21. Please state whether you are aware of sinkhole activity in your neighborhood and if so identify the addresses and any engineering or geological report you are aware of for those properties. ANSWER: Plaintiff under belief that neighbor across the street had sinkhole issue in 2013, and neighbor 3 or 4 doors down had recent sinkhole activity in 2014. 22. Please list all periods of time for which you have resided at the property. ANSWER: Plaintiff has lived in home since purchased in 2000. 23. Please list all periods of time for which you have owned the property. ANSWER: Property has been owned by Plaintiffs since 2000, although property was deeded to Plaintiff's brother, Eugene McGirt from 2003-2007. 24. Please describe why the property was deeded to Eugene McGirt from approximately 2003 — 2007. ANSWER: Objection, this interrogatory is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the objection, this was done in connection with a foreclosure which has since been resolved. 25. Please state whether you have every attempted to sell the property. ANSWER: No.26. Please describe all repairs, modifications, or renovations that have been done to the property. State who did the work, when the work was done, and how much was spent doing the work. Provide all known contact information for the individuals listed. ANSWER: 2011/2012: Repairs made to kitchen following Fire Loss in 2011/2012. 2005/2006: Repairs and renovations in Kitchen; namely counter, cabinetry and flooring. Florida Insurance Restoration Experts completed repairs however Plaintiff does not recall in connection with which loss these repairs were completed. Contact information as follows for subject repairman 2890 State Road 84, Suite 108, Fort Lauderdale, Florida 33312 27. Please describe all communication with Tim Greene as it relates to this loss. Provide all known contact information for him. ANSWER: Tim Greene was contractor for repair following Fire Loss in 2011/2012. Mr. Greene discussed the potential of making the repairs relating to the subject loss as well. 28. Please state whether you are claiming damage to any Other Structures or damage that you believe would be covered under Coverage B in the policy and describe such damage. ANSWER: Not applicable, investigation continues. 29. Please describe all contractual and statutory duties which you allege the Defendant failed to comply with and list all damages which have resulted from the failure to comply with said duty. ANSWER: Please see Complaint which speaks for itself. 30. Please describe why you believe the Defendant breached the contract and list all damages which have resulted from the breach. ANSWER: Objection, this interrogatory requests information protected by the attorney client privilege.STATE OF FLORIDA __) Ss: COUNTY orBrowae ) mh The foregoing instrument was acknowledged by me this It day of Suptomber, 201 Id by Debra Hi NLS , who is personally known to me or Drivers Cituse LO. who has produced H520- (70-58 N, as identification and who did (did not) take an oath, BRENDA MINORS NOTARY PUBLIC a Notary Public - State of Florida = Commission # FF 185923 F My Comm. Expires Dec 28, 2018 _Eoned through National Notary Assn Bron d h | E (Name of Notary, typed, written or stamped) (Title) (Serial Number, if any)