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Filing # 61427318 E-Filed 09/07/2017 11:26:58 AM
IN THE CIRCUIT COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
LISE BAPTISTE, CASE NO.: 2017-14299 CA 01
Plaintiff(s),
vs.
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
/
DEFENDANT'S RESPONSE TO PLAINTIFF’S
REQUEST FOR PRODUCTION
COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION,
by and through its undersigned counsel, and respectfully responds to Plaintiff's Request for
Production served with the Complaint, as follows:
1, Any and all insurance policies ever issued by the Defendant to the Plaintiff, including all
declaration pages, applications, addenda and riders.
Response: — Objection, overly broad, unduly burdensome and not reasonably calculated
to lead to the discovery of admissible evidence. Notwithstanding said
objections, see attached certified Policy subject of Plaintiffs Complaint.
2. Any and all correspondence between you and Plaintiff or anyone acting on the Plaintiffs
behalf.
Response: _—_ See attached correspondence.
3. Any and all correspondence, forms, reports or other documents between you and any third
party regarding the Plaintiff or Plaintiffs claim.
Response: — Objection, overly broad and subject to the work product privilege.
Notwithstanding said objections, see attached non-privileged
correspondence.
4. Any and all surveillance reports, claims history reports or other investigative reports10.
prepared by you or on you behalf with regard to the Plaintiff or Plaintiffs claim.
Response: — Objection, overly broad and subject to the work product privilege.
Notwithstanding said objections, Defendant yet to determine its expert for
this matter. Defendant will disclose its expert report in accordance with
the Trial Order.
Any and all written or recorded statements of the Plaintiff, his/her agents, and/or
representatives.
Response: — Objection, overly broad and subject to the work product privilege.
Notwithstanding said objections, see attached recorded statement taken of
the Insured on February 20, 2017.
Any and all statements taken by the Defendant or any witness with regards to any fact
relevant to any fact in this case.
Response: — Objection, overly broad and subject to the work product privilege.
Notwithstanding said objections, see attached recorded statement taken of
the Insured on February 20, 2017.
Any and all police reports relating to the Plaintiffs claims which are the subject of this
litigation.
Response: None.
Any and all photographs and/or video of the Plaintiffs property and/or its contents.
Response: —_ Objection, overly broad, not limited in time and scope and subject to the
work product privilege. Notwithstanding said objections, see attached
Citizens’ redacted photographs taken at the time of the inspection and
photographs provided by the Insured’s public adjuster.
Any and all proof of loss forms, statements, notices of claim and/or any other document
submitted by the Plaintiff pertaining to his/her claims that are the subject of this litigation.
Response: — Objection, overly broad and subject to the work product privilege.
Notwithstanding said objections, see attached documents received from
the Plaintiff regarding the subject loss.
Any and all appraisals, estimates, or other documents pertaining to the value of Plaintiffs
claim.
Response: — Objection, overly broad and subject to the work product privilege.
Notwithstanding said objections, see attached Citizens’ estimate outliningits basis for payment and documents regarding the appraisal of the water
mitigation services performed as a result of the subject loss.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed this _
7" day of September, 2017 to all counsel on the attached
Kubicki Draper
25 West Flagler Street, Penthouse
Miami, Florida 33130
Direct Line: (305) 982-6606
CW-KD@Kubickidraper.com - pleadings only
BY:__/s/ QSarah R_ Goldberg
SARAH R. GOLDBERG
Florida Bar No. 92085
SERVICE LIST
Peter Mineo, Esq.
The Mineo Salcedo Law Firm, P.A.
5400 S. University Drive, Suite 502
Davie, Florida 33328
pimineo@mineolaw.com
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Filing # 61427318 E-Filed 09/07/2017 11:26:58 AM IN THE CIRCUIT COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA LISE BAPTISTE, CASE NO.: 2017-14299 CA 01 Plaintiff(s), vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / DEFENDANT'S RESPONSE TO PLAINTIFF’S REQUEST FOR PRODUCTION COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by and through its undersigned counsel, and respectfully responds to Plaintiff's Request for Production served with the Complaint, as follows: 1, Any and all insurance policies ever issued by the Defendant to the Plaintiff, including all declaration pages, applications, addenda and riders. Response: — Objection, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding said objections, see attached certified Policy subject of Plaintiffs Complaint. 2. Any and all correspondence between you and Plaintiff or anyone acting on the Plaintiffs behalf. Response: _—_ See attached correspondence. 3. Any and all correspondence, forms, reports or other documents between you and any third party regarding the Plaintiff or Plaintiffs claim. Response: — Objection, overly broad and subject to the work product privilege. Notwithstanding said objections, see attached non-privileged correspondence. 4. Any and all surveillance reports, claims history reports or other investigative reports10. prepared by you or on you behalf with regard to the Plaintiff or Plaintiffs claim. Response: — Objection, overly broad and subject to the work product privilege. Notwithstanding said objections, Defendant yet to determine its expert for this matter. Defendant will disclose its expert report in accordance with the Trial Order. Any and all written or recorded statements of the Plaintiff, his/her agents, and/or representatives. Response: — Objection, overly broad and subject to the work product privilege. Notwithstanding said objections, see attached recorded statement taken of the Insured on February 20, 2017. Any and all statements taken by the Defendant or any witness with regards to any fact relevant to any fact in this case. Response: — Objection, overly broad and subject to the work product privilege. Notwithstanding said objections, see attached recorded statement taken of the Insured on February 20, 2017. Any and all police reports relating to the Plaintiffs claims which are the subject of this litigation. Response: None. Any and all photographs and/or video of the Plaintiffs property and/or its contents. Response: —_ Objection, overly broad, not limited in time and scope and subject to the work product privilege. Notwithstanding said objections, see attached Citizens’ redacted photographs taken at the time of the inspection and photographs provided by the Insured’s public adjuster. Any and all proof of loss forms, statements, notices of claim and/or any other document submitted by the Plaintiff pertaining to his/her claims that are the subject of this litigation. Response: — Objection, overly broad and subject to the work product privilege. Notwithstanding said objections, see attached documents received from the Plaintiff regarding the subject loss. Any and all appraisals, estimates, or other documents pertaining to the value of Plaintiffs claim. Response: — Objection, overly broad and subject to the work product privilege. Notwithstanding said objections, see attached Citizens’ estimate outliningits basis for payment and documents regarding the appraisal of the water mitigation services performed as a result of the subject loss. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed this _ 7" day of September, 2017 to all counsel on the attached Kubicki Draper 25 West Flagler Street, Penthouse Miami, Florida 33130 Direct Line: (305) 982-6606 CW-KD@Kubickidraper.com - pleadings only BY:__/s/ QSarah R_ Goldberg SARAH R. GOLDBERG Florida Bar No. 92085 SERVICE LIST Peter Mineo, Esq. The Mineo Salcedo Law Firm, P.A. 5400 S. University Drive, Suite 502 Davie, Florida 33328 pimineo@mineolaw.com