On October 15, 2019 a
Request for Production - Party: Plaintiff Rodriguez, Paul
was filed
involving a dispute between
Rodriguez, Paul,
and
Citizens Property Insurance Corporation,
for Other - Insurance Claim
in the District Court of Broward County.
Preview
Case Number: CACE-19-021427 Division: 02
Filing # 97267822 E-Filed 10/15/2019 09:13:28 AM
IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA
PAUL RODRIGUEZ, CASE NO.
Plaintiff,
vs.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
COMES NOW Plaintiff, by and through the undersigned attorneys, and hereby requests
the Defendant to produce the following items for inspection and/or copying at the office of the
undersigned attorneys within the time prescribed by the applicable rules of civil procedure:
1, A true and correct certified copy of the insurance policy described in the
Complaint, including all declaration sheet(s), addendums and attachments.
2. All photographs taken during Defendant’s investigation conducted during the
normal business of evaluating the claim.
4. All estimates of damage prepared by or on behalf of Defendant that were made
during the normal business of evaluating the claim.
5. All letters, faxes, email communications, and log notes from Defendant's
adjusters or agents which in any manner references any and all damages or causes of loss
observed that were prepared or generated during Defendant’ s investigation conducted during the
normal business of evaluating the claim.
6. Defendants entire claim file from the date of the initial notice of the loss until
the day before Defendant knew that Defendant was going to deny any further payment or litigate
the claim.
7, Defendant’s entire claim file for the entire time that the claim was being handled
by Defendant not in anticipation of litigation for the loss.
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*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/15/2019 09:13:26 AM.****8. Any and all correspondence or written communications from Defendant, or its
agents to Plaintiff, or Plaintiff’s agents, which in any manner pertain to Plaintiff's alleged loss
as described in the Complaint.
9. Any and all correspondence or written communications from Plaintiff, or
Plaintiff's agents to Defendant, or its agents, which in any manner pertain to Plaintiff's alleged
loss as described in the Complaint.
10. Any and all tape recordings of any statements made by Plaintiff or Plaintiff's
agents or employees.
11. Any an all transcripts or written statements from the Plaintiff(s) including,
without limitation, transcripts of examinations under oath.
12. Copies of each and every bill or estimate for repair to the subject property
submitted to Defendant by Plaintiff or Plaintiff's agents or employees.
12. Any and all written estimates or reports reflecting examination or inspection by
Defendant or Defendant’s agents of any of the alleged damage to the insured premises.
13. All documents relating to or supporting Defendant’s denial of any allegation of
Plaintiff's Complaint.
14. Alldocuments relating to or supporting each of Defendant's affirmative or general
defenses asserted by Defendant.
15. All underwriting files pertaining to the policy of insurance described in the
Complaint.
16. Any and all documents related to any and all other insurance claims made by
Plaintiff(s) which are not the subject of this action, including estimates, reports, pictures,
cancelled checks, releases, proofs of loss, recorded statements, transcripts of examinations under
oath, and correspondence by and between the parties related to any and all said other claims.
17. Any and all brochures, summary statements, pamphlets and advertising materials
prepared by or on behalf of Defendant and disseminated to insurance agencies or policyholders
which in any manner describe the coverages and/or exclusions under the same type of policy
involved in this action.
18. All reports by engineers, general contractors and all other professional personsand entities which in any manner pertain to alleged loss at the subject property.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served
upon Defendant by the Florida Department of Financial Services together with the initial service
of process in this action.
DUBOFF LAW FIRM
ATTORNEYS FOR PLAINTIFF
680 N.E. 127 STREET
NORTH MIAMI, FLORIDA 33161
TELEPHONE (305) 899-0085
Fax No. (305) 899-0091
EMAIL: COURTDOCUMENT@DUBOFFLAWFIRM.COM
By: _/s KENNETH R. DUBOFF
KENNETH R. DuBOFF, EsQ.
FLA. BAR # 218261
Document Filed Date
October 15, 2019
Case Filing Date
October 15, 2019
Category
Other - Insurance Claim
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Case Number: CACE-19-021427 Division: 02 Filing # 97267822 E-Filed 10/15/2019 09:13:28 AM IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA PAUL RODRIGUEZ, CASE NO. Plaintiff, vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. COMES NOW Plaintiff, by and through the undersigned attorneys, and hereby requests the Defendant to produce the following items for inspection and/or copying at the office of the undersigned attorneys within the time prescribed by the applicable rules of civil procedure: 1, A true and correct certified copy of the insurance policy described in the Complaint, including all declaration sheet(s), addendums and attachments. 2. All photographs taken during Defendant’s investigation conducted during the normal business of evaluating the claim. 4. All estimates of damage prepared by or on behalf of Defendant that were made during the normal business of evaluating the claim. 5. All letters, faxes, email communications, and log notes from Defendant's adjusters or agents which in any manner references any and all damages or causes of loss observed that were prepared or generated during Defendant’ s investigation conducted during the normal business of evaluating the claim. 6. Defendants entire claim file from the date of the initial notice of the loss until the day before Defendant knew that Defendant was going to deny any further payment or litigate the claim. 7, Defendant’s entire claim file for the entire time that the claim was being handled by Defendant not in anticipation of litigation for the loss. oo *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/15/2019 09:13:26 AM.****8. Any and all correspondence or written communications from Defendant, or its agents to Plaintiff, or Plaintiff’s agents, which in any manner pertain to Plaintiff's alleged loss as described in the Complaint. 9. Any and all correspondence or written communications from Plaintiff, or Plaintiff's agents to Defendant, or its agents, which in any manner pertain to Plaintiff's alleged loss as described in the Complaint. 10. Any and all tape recordings of any statements made by Plaintiff or Plaintiff's agents or employees. 11. Any an all transcripts or written statements from the Plaintiff(s) including, without limitation, transcripts of examinations under oath. 12. Copies of each and every bill or estimate for repair to the subject property submitted to Defendant by Plaintiff or Plaintiff's agents or employees. 12. Any and all written estimates or reports reflecting examination or inspection by Defendant or Defendant’s agents of any of the alleged damage to the insured premises. 13. All documents relating to or supporting Defendant’s denial of any allegation of Plaintiff's Complaint. 14. Alldocuments relating to or supporting each of Defendant's affirmative or general defenses asserted by Defendant. 15. All underwriting files pertaining to the policy of insurance described in the Complaint. 16. Any and all documents related to any and all other insurance claims made by Plaintiff(s) which are not the subject of this action, including estimates, reports, pictures, cancelled checks, releases, proofs of loss, recorded statements, transcripts of examinations under oath, and correspondence by and between the parties related to any and all said other claims. 17. Any and all brochures, summary statements, pamphlets and advertising materials prepared by or on behalf of Defendant and disseminated to insurance agencies or policyholders which in any manner describe the coverages and/or exclusions under the same type of policy involved in this action. 18. All reports by engineers, general contractors and all other professional personsand entities which in any manner pertain to alleged loss at the subject property. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon Defendant by the Florida Department of Financial Services together with the initial service of process in this action. DUBOFF LAW FIRM ATTORNEYS FOR PLAINTIFF 680 N.E. 127 STREET NORTH MIAMI, FLORIDA 33161 TELEPHONE (305) 899-0085 Fax No. (305) 899-0091 EMAIL: COURTDOCUMENT@DUBOFFLAWFIRM.COM By: _/s KENNETH R. DUBOFF KENNETH R. DuBOFF, EsQ. FLA. BAR # 218261