On October 22, 2020 a
Request for Production - TO DEFENDANT
was filed
involving a dispute between
Hedge, Jean,
Hedge, Robert,
and
Omega Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
Preview
Case Number: CACE-20-017607 Division: 25
Filing # 115459812 E-Filed 10/22/2020 03:06:30 PM
IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY,
FLORIDA
JEAN HEDGE and ROBERT HEDGE, CASE NO:
Plaintiffs,
vs.
OMEGA INSURANCE COMPANY,
Defendant.
/
PLAINTIFFS’ REQUEST FOR PRODUCTION TO DEFENDANT
The Plaintiffs, JEAN HEDGE & ROBERT HEDGE, pursuant to Rule 1.350,
Florida Rules of Civil Procedure, propound this Request for Production to Defendant,
OMEGA INSURANCE COMPANY, to produce the items and materials hereinafter set
forth on or before the applicable time prescribed by said rule for inspection and/or
copying at the office of the undersigned attorney, the following items and/or documents:
1. Any and all insurance policies ever issued by the Defendant to the Plaintiffs,
including all declaration pages, applications, addenda and riders.
2. Any and all correspondence between you and Plaintiffs or anyone acting on the
Plaintiffs’ behalf.
3. Any and all correspondence, forms, reports or other documents between you and
any third party regarding the Plaintiffs or Plaintiffs’ claim.
4. Any and all surveillance reports, claims history reports or other investigative
reports prepared by you or on you behalf with regard to the Plaintiffs or Plaintiffs’ claim.
5. Any and all written or recorded statements of the Plaintiffs, their agents, and/or
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/22/2020 03:06:28 PM.****representatives.
6. Any and all statements taken by the Defendant or any witness with regards to any
fact relevant to any fact in this case.
7. Any and all police reports relating to the Plaintiffs’ claims which are the subject
of this litigation.
8. Any and all photographs and/or video of the Plaintiffs’ property and/or its
contents.
9. Any and all proof of loss forms, statements, notices of claim and/or any other
document submitted by the Plaintiffs pertaining to their claims that are the subject of this
litigation.
10. Any and all appraisals, estimates, or other documents pertaining to the value of
Plaintiffs’ claim.
11. Defendant’s entire underwriting file including, but not limited to, all 4 point
inspection reports and any and all wind mitigation reports for Plaintiffs residence.CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing was served upon the Defendant in
this action along with the Complaint.
JOHN A. SALCEDO
Florida Bar No: 14665
THE MINEO SALCEDO LAW FIRM, P.A.
Attorneys for Plaintiff
5600 Davie Road
Davie, FL 33314
T: (954) 463-8100
F; (954) 463-8106
Service@mineolaw.com
Preview
Case Number: CACE-20-017607 Division: 25 Filing # 115459812 E-Filed 10/22/2020 03:06:30 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JEAN HEDGE and ROBERT HEDGE, CASE NO: Plaintiffs, vs. OMEGA INSURANCE COMPANY, Defendant. / PLAINTIFFS’ REQUEST FOR PRODUCTION TO DEFENDANT The Plaintiffs, JEAN HEDGE & ROBERT HEDGE, pursuant to Rule 1.350, Florida Rules of Civil Procedure, propound this Request for Production to Defendant, OMEGA INSURANCE COMPANY, to produce the items and materials hereinafter set forth on or before the applicable time prescribed by said rule for inspection and/or copying at the office of the undersigned attorney, the following items and/or documents: 1. Any and all insurance policies ever issued by the Defendant to the Plaintiffs, including all declaration pages, applications, addenda and riders. 2. Any and all correspondence between you and Plaintiffs or anyone acting on the Plaintiffs’ behalf. 3. Any and all correspondence, forms, reports or other documents between you and any third party regarding the Plaintiffs or Plaintiffs’ claim. 4. Any and all surveillance reports, claims history reports or other investigative reports prepared by you or on you behalf with regard to the Plaintiffs or Plaintiffs’ claim. 5. Any and all written or recorded statements of the Plaintiffs, their agents, and/or *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/22/2020 03:06:28 PM.****representatives. 6. Any and all statements taken by the Defendant or any witness with regards to any fact relevant to any fact in this case. 7. Any and all police reports relating to the Plaintiffs’ claims which are the subject of this litigation. 8. Any and all photographs and/or video of the Plaintiffs’ property and/or its contents. 9. Any and all proof of loss forms, statements, notices of claim and/or any other document submitted by the Plaintiffs pertaining to their claims that are the subject of this litigation. 10. Any and all appraisals, estimates, or other documents pertaining to the value of Plaintiffs’ claim. 11. Defendant’s entire underwriting file including, but not limited to, all 4 point inspection reports and any and all wind mitigation reports for Plaintiffs residence.CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was served upon the Defendant in this action along with the Complaint. JOHN A. SALCEDO Florida Bar No: 14665 THE MINEO SALCEDO LAW FIRM, P.A. Attorneys for Plaintiff 5600 Davie Road Davie, FL 33314 T: (954) 463-8100 F; (954) 463-8106 Service@mineolaw.com