Preview
Filing # 68100531 E-Filed 02/16/2018 04:18:03 PM
IN THE COUNTY COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: COSO 18-000150
EASY DRY RESTORATION, INC.
a/a/o ELIDA BADAY,
Plaintiff,
vs.
TOWER HILL SIGNATURE
INSURANCE COMPANY,
Defendant.
DEFENDANT’S FIRST REQUEST TO PRODUCE TO PLAINTIFF
COMES NOW, Defendant, Tower Hill Signature Insurance Company, by and through
undersigned counsel, and respectfully requests Plaintiff, pursuant to Rule 1.350, Florida Rules of
Civil Procedure, produce the following within thirty (30) days from the date of this Request to
Produce.
I. DEFINITIONS
1. The term “you” or “your” means EASY DRY RESTORATION, INC.
2. “Document” or “documents” as used herein shall mean the original and any copy,
regardless of its original and location, of any writing or other tangible thing containing written or
graphic matter, whether printed, recorded, reproduced by any process, or written or produced by
hand, including, but not limited to the following: all abstracts, accounting journals, accounting
ledgers, advertisements, affidavits, agendas, agreements or proposed agreements (including drafts,
proposals and any and all exhibits thereto), analyses, appointment books, appraisals, articles,
agreements, articles of incorporation, balance sheets, bank checks, bank deposit or withdrawal
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/16/2018 4:18:02 PM.****slips, bank credit or debt memoranda, bank statements, books, books of account, brochures,
budgets, bylaws, canceled checks, certificates, charts, checks, circulars, codes, communications,
communications with governmental entities or agencies, computer data or printouts, conferences,
contracts, corporate severance documents, correspondence, data processing materials, data sheets,
desk calendars, diaries, disks or data compilations from which information can be obtained or
translated, drafts of any documents and revisions of drafts of any documents, drawings,
electromagnetic tapes, electronic mail, electronic files, expressions or statements of policy, files,
films, financial calculations, financial projections, financial statements, graphs, graphics,
forecasts, handwritten notes or comments however produced or reproduced, indexes, insertions,
inspections, instructions, internal accounting records, interoffice communications, intra-office
communications, invoices, laboratory and engineering reports, ledgers, letters, lists, lists of persons
attending meetings or conferences, logbooks, manuals, memoranda, minutes, minutes of meetings,
models, newspaper or magazine articles, nonconforming copies which contain deletions, notations
or records of meetings, notes, notebooks, notices of wire transfer of funds, opinions or reports of
consultants, outlines, pamphlets, papers, passbooks, periodicals, photocopies, photographs,
pictures, plans, preliminary drafts, press releases, proposals, publications, punch cards, purchase
orders, raw and refined data, receipts, recommendations, records, recordings, records of
conferences, conversations or meetings, records of payment, reports, reports and/or summaries of
investigations, resolutions, results of investigations, schedules, shipping papers, software,
specifications, speeches, statements of account, statistical statements, stock certificates, studies,
summaries, summaries of interviews, surveys, tabulations, tape recordings, tax returns, telegrams,
telephone logs and records, telephone and other conversations or communications, teletypes,
telexes, transcripts, transcripts of tape recordings, trade letters, voice records, vouchers, work
papers, worksheets, written notations, and any and all other papers similar to any of the foregoing.
The term “document” shall include data stored, maintained or organized electronically,
2magnetically or through the use of computer equipment, translated, if necessary, by you into
reasonably usable form. Any document containing any alterations, comments, notes or other
material not included in the copies or originals referred to in the preceding definition shall be
deemed a separate document within said definition. A document shall include all exhibits,
schedules or other writings affected by or referenced in any such document or other writings
necessary to complete the information contained therein or to assume that the document is not
misleading.
3. “Communication” means any oral, electronic, or written utterance, notation or
statement of any nature whatsoever, by or whomsoever made, including, but not limited to,
correspondence, conversations, dialogues, discussions, interviews, consultations, agreements, and
other understandings between or among two or more persons.
4, “And” and “or” as used herein are terms of inclusion and not of exclusion, and shall
be construed either disjunctively or conjunctively as necessary to bring within the scope of the
Request for Production of documents any document or information that might otherwise be
construed to be outside its scope.
5. “Any” means one or more.
6. “Describe,” “discuss,” “analyze,” “describing,” “discussing,” or “analyzing” mean
any document that, in whole or in part, characterizes, delineates, explicates, deliberates, evaluates,
appraises, assesses or provides a general explanation of the specified subject.
7. “Person” means any natural person, corporation, partnership, company, sole
proprietorship, association, trust, institute, joint venture, firm, governmental body, or other legal
or business entity, whether privately or publicly owned or controlled, for profit or not-for-profit,
or partially or fully government owned or controlled.
8. “Relate to,” “related to” and “relating to” mean to make a statement about, refer to,
concern, contain, comprise, consist, discuss, define, describe, evidence, identify, mention, pertain,
3reflect, or in any way logically or factually connected with the matter discussed or to which
reference is made, in whole or in part, or otherwise to be used, considered, or reviewed in any way
in connection with the specified subject. Thus, documents that "relate to" a subject also include
those which were specifically rejected and those which were not relied or acted upon.
9. The singular form of a noun or pronoun shall be considered to include within its
meaning the plural form of the noun or pronoun, and vice versa. The masculine form of a noun or
pronoun shall be considered to include within its meaning the feminine form of the noun or
pronoun, and vice versa.
10. Regardless of the tense employed, all verbs shall be read as applying to the past,
present and future as is necessary to make any paragraph more, rather than less, inclusive.
11. Unless otherwise specified, “year” means calendar year.
II. INSTRUCTIONS
With respect to this Request for Production, the following instructions shall apply:
1, Answers to this Request for Production shall be submitted in a form so that the
answer follows the retyped Request for Production to which it applies.
2. This Request for Production is continuing and you are requested to supplement its
response as necessary.
3. You are notified that your duty to respond includes the duty to supply all documents
and materials in your physical possession, as well as those which can be obtained from additional
sources, pursuant to the applicable Rules of Civil Procedure.
4. In the event that any document or item called for by this request is withheld on the
basis of claim of privilege, please identify that document or item stating: (a) any addressor or
addressee, (b) subject matter, number of pages, date and title of the document, if any, and
attachments or appendices, (c) all persons to whom the document or item was distributed, shown
or explained, (d) its present custodian, and (e) the nature of the privilege asserted. You should
4produce the balance of the documents or things not subject to a claim of privilege which fall within
the scope of the request. Additionally, to the extent information subject to a claim of privilege is
contained within responsive documents or things that also contain discoverable information, you
should produce a redacted version of the document or thing containing the discoverable
information with a notation on the produced document or thing indicating that it is being produced
in redacted form.
5. In the event that any document or item requested is not presently in your possession
or subject to your control, please identify each person you have reason to believe had or has
knowledge of its contents.
6. In the event that any documents or items called for by this request has been
destroyed or discarded, please identify that document or item by stating: (a) any addressor or
addressee, (b) any indicated or blind copies, (c) the document’s date, subject matter, number of
pages, and attachments or appendices, (d) description of the item, (e) all persons to whom the
document or item was distributed, shown or explained, (f) the date of destruction or discard, and
(g) the persons authorizing or carrying out such destruction or discard.
I. REQUES'
PRODUCTION
Any and all estimates obtained by the Plaintiff for repairs, water mitigation services, mold
assessments, mold remediation, or other services related to the underlying loss which is the
subject of this lawsuit (“the loss”).
2. Project monitoring log or any other document(s) that identifies, but is not limited to, the
following
a. The name of the project;
b. The dates and times of service;
c. The person(s) performing the service;
d. The instrumentation used;
e. The appropriate psychrometric readings (e.g., temperature, RH) in affected areas;
unaffected areas and inlets/outlets of dehumidifiers, or HVAC systems, if present;
f. Moisture level or content measurements of representative materials in the affected and
unaffected areas;
g. Drying goals and standards for the affected areas/materials;10.
11.
12.
14.
15.
16.
h. Location(s) of the moisture level or content readings
Any and all estimates, invoices, photographs or other documents submitted by Plaintiff to
Defendant or an agent thereof, in relation to the loss.
A copy of any and all bills, invoices, receipts, cancelled checks, credit card receipts, or other
documentation relating to payments made or expenses incurred as it relates to the loss.
A copy of any and all documents reflecting the date in which you entered into an Assignment
of Benefits with the Insured.
A copy of any and all communications (including letters, e-mails, faxes, etc.) sent to the
Plaintiff and/or Insured by the Defendant and which relate to the Plaintiff's claim with the
Defendant.
A copy of the Assignment of Benefits and any other documentation or contracts signed by the
Plaintiff (or an employee thereof) with the Insured or with any other individuals as a result of
the loss.
A copy of any and all spreadsheets, logs or other documents reflecting the number of hours
any of the machines that were used at the subject property had run prior to the loss.
A copy of any and all spreadsheets, logs or other documents reflecting the number of hours
each of the machines that were used at the insured property were run as a result of the
subject loss(es).
Any and all photographs which in any way depict the portions of the Insured’s Residence that
were allegedly damaged, affected by water or mold, or which required repair and/or
remediation.
A copy of any and all contracts entered into by the Plaintiff and/or the Insured and any
contractors/handymen/painters/plumbers or other company regarding work to be performed
at the Residence for the damages associated with the loss.
Documents regarding, related or referring to relevant details of the water intrusion (e.g.,
source, date of intrusion, date of discovery).
Moisture map for the area to be serviced.
Psychrometric records regarding the work performed.
Documents regarding, related or referring to the scope of work and work plan.
Documents regarding, related or referring to project limitations or deviations form17.
18.
20.
21.
22.
25.
27.
28.
29.
compliance with IICRC S-500 standards.
Written recommendations or technical specifications from specialized experts.
Inventory of contents/personal property that are being removed from the job site, or are in
need of restoration or remediation.
A copy of any certifications or other licensure(s) of employees of Prodamage, Inc., received
or obtained in association with services that are provided by Prodamage, Inc. This includes
certifications related to water mitigation, plumbing, contracting work, etc. This includes
certifications related to water mitigation, plumbing, contracting work, mold assessments,
mold evaluation, mold remediation, cause and origin determination, etc.
A document that reflects the names of all employees and technicians employed by
Prodamage, Inc.
A copy of the updated resume for any individuals on behalf of Prodamage, Inc., who were at
the Residence following the loss.
A copy of any and all documentation in the Plaintiffs possession which in any way evidences
any repair work performed at the Residence on and subsequent to the date(s) of loss alleged
in the Complaint.
Any and all documentation identifying the names and contact information/phone numbers
for any and all individuals who performed work at the property following the loss.
A copy of any and all photographs taken by any individuals employed by Prodamage, Inc.,
showing the subject property following the loss.
Any and all mold assessments that you reviewed, created, considered or were provided as it
relates to the damages at the subject property.
Any and all mold samples, mold results or measurements related to mold observed or
remediated at the insured property.
Any and all information, documents, resources, spreadsheets or other data you relied on in
structuring the rates charged by Prodamage, Inc. in the instant action.
Any and all spreadsheets, notes, logs or other documents reflecting the time spent by
Prodamage, Inc. in monitoring any and all equipment placed in the insured property as a
result of the subject loss.
Any and all spreadsheets, notes, logs or other documents reflecting the total number of
labor hours spent at the subject property as it relates to services performed by Prodamage,
Inc.30.
31.
33.
34.
35.
36.
37.
38.
Any and all documents evidencing the total number of trades engaged and/or enlisted by
Prodamage, Inc. or on its behalf for the services rendered to the insured property as a result
of the subject loss.
Inventory of other items removed from the job site but which are not considered
contents/personal property, including, but not limited to, baseboards and plumbing
components.
Inventory of unsalvageable or unsuccessfully restored contents/personal property that will
be disposed.
Permits and permit applications regarding any work performed at the subject property.
Detailed work or activity logs, including a description of who did what, when, where, how,
and for what duration, including entry and exit logs, where applicable.
Any and all documents that are related to the amount you charged for the services
performed.
Equipment logs or similar documents that include a description of all equipment, materials,
supplies and products used on the project, the quantity and length of time used (where
applicable) and other relevant information.
Documents regarding, related or referring to client approval for the use of antimicrobial
agents (biocides), including consumer “Right to Know” information.
Records of pressure readings in and out of containment erected for the purpose of
remediation.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served by e-mail
via the Florida Courts E-filing Portal system on this 16" day of February, 2018, to Rafael Garcia,
Esq. MSPG Law Group of Central Florida, PLLC, 220 Palmetto Avenue, Orlando, Florida 32801,
Attorneys for Plaintiffs, Service E-mail: ralph(@émspingurancelaw.com,
BRESSLER, AMERY & Ross, P.C.
200 East Las Olas Boulevard
Suite 1500
Fort Lauderdale, Florida 33301
T: 954.499.7979
F: 954.499.7969
E-Mail: miainsurance@bressler.com
mmonteverde@bressler.com
pvicary@bressler.com
jgbarnes@bressler.com
By: /s/ Paul S. Vicary
Michael A. Monteverde, Esq.
Florida Bar No.: 0048154
Paul S. Vicary, Esq.
Florida Bar No.: 021317
Preview
Filing # 68100531 E-Filed 02/16/2018 04:18:03 PM IN THE COUNTY COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: COSO 18-000150 EASY DRY RESTORATION, INC. a/a/o ELIDA BADAY, Plaintiff, vs. TOWER HILL SIGNATURE INSURANCE COMPANY, Defendant. DEFENDANT’S FIRST REQUEST TO PRODUCE TO PLAINTIFF COMES NOW, Defendant, Tower Hill Signature Insurance Company, by and through undersigned counsel, and respectfully requests Plaintiff, pursuant to Rule 1.350, Florida Rules of Civil Procedure, produce the following within thirty (30) days from the date of this Request to Produce. I. DEFINITIONS 1. The term “you” or “your” means EASY DRY RESTORATION, INC. 2. “Document” or “documents” as used herein shall mean the original and any copy, regardless of its original and location, of any writing or other tangible thing containing written or graphic matter, whether printed, recorded, reproduced by any process, or written or produced by hand, including, but not limited to the following: all abstracts, accounting journals, accounting ledgers, advertisements, affidavits, agendas, agreements or proposed agreements (including drafts, proposals and any and all exhibits thereto), analyses, appointment books, appraisals, articles, agreements, articles of incorporation, balance sheets, bank checks, bank deposit or withdrawal *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/16/2018 4:18:02 PM.****slips, bank credit or debt memoranda, bank statements, books, books of account, brochures, budgets, bylaws, canceled checks, certificates, charts, checks, circulars, codes, communications, communications with governmental entities or agencies, computer data or printouts, conferences, contracts, corporate severance documents, correspondence, data processing materials, data sheets, desk calendars, diaries, disks or data compilations from which information can be obtained or translated, drafts of any documents and revisions of drafts of any documents, drawings, electromagnetic tapes, electronic mail, electronic files, expressions or statements of policy, files, films, financial calculations, financial projections, financial statements, graphs, graphics, forecasts, handwritten notes or comments however produced or reproduced, indexes, insertions, inspections, instructions, internal accounting records, interoffice communications, intra-office communications, invoices, laboratory and engineering reports, ledgers, letters, lists, lists of persons attending meetings or conferences, logbooks, manuals, memoranda, minutes, minutes of meetings, models, newspaper or magazine articles, nonconforming copies which contain deletions, notations or records of meetings, notes, notebooks, notices of wire transfer of funds, opinions or reports of consultants, outlines, pamphlets, papers, passbooks, periodicals, photocopies, photographs, pictures, plans, preliminary drafts, press releases, proposals, publications, punch cards, purchase orders, raw and refined data, receipts, recommendations, records, recordings, records of conferences, conversations or meetings, records of payment, reports, reports and/or summaries of investigations, resolutions, results of investigations, schedules, shipping papers, software, specifications, speeches, statements of account, statistical statements, stock certificates, studies, summaries, summaries of interviews, surveys, tabulations, tape recordings, tax returns, telegrams, telephone logs and records, telephone and other conversations or communications, teletypes, telexes, transcripts, transcripts of tape recordings, trade letters, voice records, vouchers, work papers, worksheets, written notations, and any and all other papers similar to any of the foregoing. The term “document” shall include data stored, maintained or organized electronically, 2magnetically or through the use of computer equipment, translated, if necessary, by you into reasonably usable form. Any document containing any alterations, comments, notes or other material not included in the copies or originals referred to in the preceding definition shall be deemed a separate document within said definition. A document shall include all exhibits, schedules or other writings affected by or referenced in any such document or other writings necessary to complete the information contained therein or to assume that the document is not misleading. 3. “Communication” means any oral, electronic, or written utterance, notation or statement of any nature whatsoever, by or whomsoever made, including, but not limited to, correspondence, conversations, dialogues, discussions, interviews, consultations, agreements, and other understandings between or among two or more persons. 4, “And” and “or” as used herein are terms of inclusion and not of exclusion, and shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the Request for Production of documents any document or information that might otherwise be construed to be outside its scope. 5. “Any” means one or more. 6. “Describe,” “discuss,” “analyze,” “describing,” “discussing,” or “analyzing” mean any document that, in whole or in part, characterizes, delineates, explicates, deliberates, evaluates, appraises, assesses or provides a general explanation of the specified subject. 7. “Person” means any natural person, corporation, partnership, company, sole proprietorship, association, trust, institute, joint venture, firm, governmental body, or other legal or business entity, whether privately or publicly owned or controlled, for profit or not-for-profit, or partially or fully government owned or controlled. 8. “Relate to,” “related to” and “relating to” mean to make a statement about, refer to, concern, contain, comprise, consist, discuss, define, describe, evidence, identify, mention, pertain, 3reflect, or in any way logically or factually connected with the matter discussed or to which reference is made, in whole or in part, or otherwise to be used, considered, or reviewed in any way in connection with the specified subject. Thus, documents that "relate to" a subject also include those which were specifically rejected and those which were not relied or acted upon. 9. The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun, and vice versa. The masculine form of a noun or pronoun shall be considered to include within its meaning the feminine form of the noun or pronoun, and vice versa. 10. Regardless of the tense employed, all verbs shall be read as applying to the past, present and future as is necessary to make any paragraph more, rather than less, inclusive. 11. Unless otherwise specified, “year” means calendar year. II. INSTRUCTIONS With respect to this Request for Production, the following instructions shall apply: 1, Answers to this Request for Production shall be submitted in a form so that the answer follows the retyped Request for Production to which it applies. 2. This Request for Production is continuing and you are requested to supplement its response as necessary. 3. You are notified that your duty to respond includes the duty to supply all documents and materials in your physical possession, as well as those which can be obtained from additional sources, pursuant to the applicable Rules of Civil Procedure. 4. In the event that any document or item called for by this request is withheld on the basis of claim of privilege, please identify that document or item stating: (a) any addressor or addressee, (b) subject matter, number of pages, date and title of the document, if any, and attachments or appendices, (c) all persons to whom the document or item was distributed, shown or explained, (d) its present custodian, and (e) the nature of the privilege asserted. You should 4produce the balance of the documents or things not subject to a claim of privilege which fall within the scope of the request. Additionally, to the extent information subject to a claim of privilege is contained within responsive documents or things that also contain discoverable information, you should produce a redacted version of the document or thing containing the discoverable information with a notation on the produced document or thing indicating that it is being produced in redacted form. 5. In the event that any document or item requested is not presently in your possession or subject to your control, please identify each person you have reason to believe had or has knowledge of its contents. 6. In the event that any documents or items called for by this request has been destroyed or discarded, please identify that document or item by stating: (a) any addressor or addressee, (b) any indicated or blind copies, (c) the document’s date, subject matter, number of pages, and attachments or appendices, (d) description of the item, (e) all persons to whom the document or item was distributed, shown or explained, (f) the date of destruction or discard, and (g) the persons authorizing or carrying out such destruction or discard. I. REQUES' PRODUCTION Any and all estimates obtained by the Plaintiff for repairs, water mitigation services, mold assessments, mold remediation, or other services related to the underlying loss which is the subject of this lawsuit (“the loss”). 2. Project monitoring log or any other document(s) that identifies, but is not limited to, the following a. The name of the project; b. The dates and times of service; c. The person(s) performing the service; d. The instrumentation used; e. The appropriate psychrometric readings (e.g., temperature, RH) in affected areas; unaffected areas and inlets/outlets of dehumidifiers, or HVAC systems, if present; f. Moisture level or content measurements of representative materials in the affected and unaffected areas; g. Drying goals and standards for the affected areas/materials;10. 11. 12. 14. 15. 16. h. Location(s) of the moisture level or content readings Any and all estimates, invoices, photographs or other documents submitted by Plaintiff to Defendant or an agent thereof, in relation to the loss. A copy of any and all bills, invoices, receipts, cancelled checks, credit card receipts, or other documentation relating to payments made or expenses incurred as it relates to the loss. A copy of any and all documents reflecting the date in which you entered into an Assignment of Benefits with the Insured. A copy of any and all communications (including letters, e-mails, faxes, etc.) sent to the Plaintiff and/or Insured by the Defendant and which relate to the Plaintiff's claim with the Defendant. A copy of the Assignment of Benefits and any other documentation or contracts signed by the Plaintiff (or an employee thereof) with the Insured or with any other individuals as a result of the loss. A copy of any and all spreadsheets, logs or other documents reflecting the number of hours any of the machines that were used at the subject property had run prior to the loss. A copy of any and all spreadsheets, logs or other documents reflecting the number of hours each of the machines that were used at the insured property were run as a result of the subject loss(es). Any and all photographs which in any way depict the portions of the Insured’s Residence that were allegedly damaged, affected by water or mold, or which required repair and/or remediation. A copy of any and all contracts entered into by the Plaintiff and/or the Insured and any contractors/handymen/painters/plumbers or other company regarding work to be performed at the Residence for the damages associated with the loss. Documents regarding, related or referring to relevant details of the water intrusion (e.g., source, date of intrusion, date of discovery). Moisture map for the area to be serviced. Psychrometric records regarding the work performed. Documents regarding, related or referring to the scope of work and work plan. Documents regarding, related or referring to project limitations or deviations form17. 18. 20. 21. 22. 25. 27. 28. 29. compliance with IICRC S-500 standards. Written recommendations or technical specifications from specialized experts. Inventory of contents/personal property that are being removed from the job site, or are in need of restoration or remediation. A copy of any certifications or other licensure(s) of employees of Prodamage, Inc., received or obtained in association with services that are provided by Prodamage, Inc. This includes certifications related to water mitigation, plumbing, contracting work, etc. This includes certifications related to water mitigation, plumbing, contracting work, mold assessments, mold evaluation, mold remediation, cause and origin determination, etc. A document that reflects the names of all employees and technicians employed by Prodamage, Inc. A copy of the updated resume for any individuals on behalf of Prodamage, Inc., who were at the Residence following the loss. A copy of any and all documentation in the Plaintiffs possession which in any way evidences any repair work performed at the Residence on and subsequent to the date(s) of loss alleged in the Complaint. Any and all documentation identifying the names and contact information/phone numbers for any and all individuals who performed work at the property following the loss. A copy of any and all photographs taken by any individuals employed by Prodamage, Inc., showing the subject property following the loss. Any and all mold assessments that you reviewed, created, considered or were provided as it relates to the damages at the subject property. Any and all mold samples, mold results or measurements related to mold observed or remediated at the insured property. Any and all information, documents, resources, spreadsheets or other data you relied on in structuring the rates charged by Prodamage, Inc. in the instant action. Any and all spreadsheets, notes, logs or other documents reflecting the time spent by Prodamage, Inc. in monitoring any and all equipment placed in the insured property as a result of the subject loss. Any and all spreadsheets, notes, logs or other documents reflecting the total number of labor hours spent at the subject property as it relates to services performed by Prodamage, Inc.30. 31. 33. 34. 35. 36. 37. 38. Any and all documents evidencing the total number of trades engaged and/or enlisted by Prodamage, Inc. or on its behalf for the services rendered to the insured property as a result of the subject loss. Inventory of other items removed from the job site but which are not considered contents/personal property, including, but not limited to, baseboards and plumbing components. Inventory of unsalvageable or unsuccessfully restored contents/personal property that will be disposed. Permits and permit applications regarding any work performed at the subject property. Detailed work or activity logs, including a description of who did what, when, where, how, and for what duration, including entry and exit logs, where applicable. Any and all documents that are related to the amount you charged for the services performed. Equipment logs or similar documents that include a description of all equipment, materials, supplies and products used on the project, the quantity and length of time used (where applicable) and other relevant information. Documents regarding, related or referring to client approval for the use of antimicrobial agents (biocides), including consumer “Right to Know” information. Records of pressure readings in and out of containment erected for the purpose of remediation.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by e-mail via the Florida Courts E-filing Portal system on this 16" day of February, 2018, to Rafael Garcia, Esq. MSPG Law Group of Central Florida, PLLC, 220 Palmetto Avenue, Orlando, Florida 32801, Attorneys for Plaintiffs, Service E-mail: ralph(@émspingurancelaw.com, BRESSLER, AMERY & Ross, P.C. 200 East Las Olas Boulevard Suite 1500 Fort Lauderdale, Florida 33301 T: 954.499.7979 F: 954.499.7969 E-Mail: miainsurance@bressler.com mmonteverde@bressler.com pvicary@bressler.com jgbarnes@bressler.com By: /s/ Paul S. Vicary Michael A. Monteverde, Esq. Florida Bar No.: 0048154 Paul S. Vicary, Esq. Florida Bar No.: 021317