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Filing # 44517365 E-Filed 07/27/2016 06:20:09 PM
IN THE COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
TULLY BRYKS AND HINDY BRYKS,
Case No.:
Plaintiff,
vs.
LIBERTY MUTUAL FIRE INSURANCE COMPANY,
Defendant.
PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION
The plaintiffs, Tully Bryks and Hindy Bryks (“Plaintiffs”), by and through undersigned
counsel, and pursuant to Fla. R. Civ. P. 1.350, hereby requests that the defendant, Liberty Mutual
(“Defendant”), produce the following items for inspection and copying at the offices of its
counsel within the timeframe specified by the Florida Rules of Civil Procedure
1. All policies of insurance to which any of the Plaintiffs is a named insured or
additional payee, together with any declaration of coverage pages, and any additional addendums
thereto.
2 Any and all correspondence to or from any attorney representing any of the
Plaintiffs, and any and all documents attached to said correspondence, pertaining to Plaintiffs’
insurance claims with Defendant, including but not limited to Claim Number 031720313
3. Any and all correspondence to or from any public adjuster representing any of the
Plaintiffs, and any and all documents attached to said correspondence, pertaining to any of the
Plaintiffs’ insurance claims with Defendant, including but not limited to Claim Number
031720313
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 - 305-760-2314 - 305-760-2498 (fax)4 Any and all correspondence to or from the any of the Plaintiffs, and any and all
documents attached to said correspondence, pertaining to Plaintiffs insurance claims with
Defendant, including but not limited to Claim Number 031720313
5. Any and all documents of whatever nature and kind submitted by any of the
Plaintiffs and/or their agents, public adjusters and/or attorneys, etc., to the Defendant, its agents,
servants and/or employees in regard to the subject loss
6 Any and all documents which Defendant considered or relied upon in determining
the benefits due or not due to the Plaintiffs in regards to each claim forming the subject of this
action.
7. Any and all photographs, recordings, charts, graphs, sketches and any other
tangible items or documentary evidence relating to the Plaintiffs’ insurance claims with
Defendant, including but not limited to Claim Number 031720313.
8. Any and all photographs, recordings, charts, graphs, sketches and any other
tangible items or documentary evidence which Defendant intends to use during the trial in this
cause and which have not been produced in response to any of the preceding paragraphs.
9 Copy of the Defendant's entire claim file, including front and back cover, for the
Plaintiff's claim number 031720313 as it is kept in the normal course of business, excluding any
documents to which Defendant claims a privilege. ALL DOCUMENTS FOR WHICH
DEFENDANT ALLEGES A PRIVILEGE SHALL BE LISTED IN THE MANNER
DESCRIBED IN F.R.C.P. 1.350.
10. The Defendant's entire claim file up from the date of the initial notice of the loss
until the day before the Defendants knew that Defendant was going to deny or litigate the
claim
Page 2 of 4
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 - 305-760-2314 - 305-760-2498 (fax)11. Any and all documents relating to or supporting Defendant's denial of any
allegation of the Plaintiffs’ complaint, and relating to or supporting each affirmative or general
defense asserted by Defendant.
12 Any and all statements, whether written, oral or recorded in whatever fashion,
including transcripts thereof or electronic recordings of same, taken of any or all witnesses or
other persons by the Defendant or its agents, with regard to the subject matter of this lawsuit.
13. A list and/or documents showing the names, addresses and telephone numbers of
any and all witnesses whose statements have been taken, indicating their full legal name,
residential address, business address and telephone number, in regard to the subject matter of this
litigation
14. Any and all documents by and between the Defendant and its investigators,
insurance adjusters and appraisers relating to the subject matter of the Complaint.
15 Any and all expert reports including but not limited to reports regarding cause and
origin, estimates for repair and/or replacement, damage to the Plaintiff's property in question, or
any other subject matter concerning this litigation prepared by any experts who may be, or will
be, utilized at the time of trial on behalf of the Defendant.
16. Copies of any and all sworn Proofs of Loss submitted by or on behalf of any of
the Plaintiffs relative to the subject claim and documentation accepting and/or rejecting said
Proofs of Loss and, any and all documentation of any kind or nature relied upon relative to the
Defendant’s acceptance or rejection of said Proofs of Loss.
17. Any and all documentation or other tangible evidence which Defendant contends
supports its claim that all conditions precedent to bringing this action have not been met (if
applicable).
Page 3 of 4
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 + 305-760-23 14 - 305-760-2498 (fax)18. A copy of any and all reports by any general contractor, roofer, electrician, or
other construction personnel hired by the Defendant to examine and/or evaluate any of the claims
asserted by any of the Plaintiffs.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing will be served upon
the Defendant with the effectuation of service of process in this action.
Respectfully submitted July 20, 2016.
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18th Avenue
Suite 321
North Miami Beach, Florida 33162
Phone: (305) 760-2314
Fax (305) 760-2498
Direct email: alex@losslitigators.com
Pleading email: service@losslitigators.com
By: __/s/ Alex Stern___
Alex Stern, Esquire
Fla. Bar No: 19592
Page 4 of 4
LITIGATION & RECOVERY LAW CENTER, PL
16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 + 305-760-23 14 - 305-760-2498 (fax)
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Filing # 44517365 E-Filed 07/27/2016 06:20:09 PM IN THE COUNTY COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA TULLY BRYKS AND HINDY BRYKS, Case No.: Plaintiff, vs. LIBERTY MUTUAL FIRE INSURANCE COMPANY, Defendant. PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION The plaintiffs, Tully Bryks and Hindy Bryks (“Plaintiffs”), by and through undersigned counsel, and pursuant to Fla. R. Civ. P. 1.350, hereby requests that the defendant, Liberty Mutual (“Defendant”), produce the following items for inspection and copying at the offices of its counsel within the timeframe specified by the Florida Rules of Civil Procedure 1. All policies of insurance to which any of the Plaintiffs is a named insured or additional payee, together with any declaration of coverage pages, and any additional addendums thereto. 2 Any and all correspondence to or from any attorney representing any of the Plaintiffs, and any and all documents attached to said correspondence, pertaining to Plaintiffs’ insurance claims with Defendant, including but not limited to Claim Number 031720313 3. Any and all correspondence to or from any public adjuster representing any of the Plaintiffs, and any and all documents attached to said correspondence, pertaining to any of the Plaintiffs’ insurance claims with Defendant, including but not limited to Claim Number 031720313 LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 - 305-760-2314 - 305-760-2498 (fax)4 Any and all correspondence to or from the any of the Plaintiffs, and any and all documents attached to said correspondence, pertaining to Plaintiffs insurance claims with Defendant, including but not limited to Claim Number 031720313 5. Any and all documents of whatever nature and kind submitted by any of the Plaintiffs and/or their agents, public adjusters and/or attorneys, etc., to the Defendant, its agents, servants and/or employees in regard to the subject loss 6 Any and all documents which Defendant considered or relied upon in determining the benefits due or not due to the Plaintiffs in regards to each claim forming the subject of this action. 7. Any and all photographs, recordings, charts, graphs, sketches and any other tangible items or documentary evidence relating to the Plaintiffs’ insurance claims with Defendant, including but not limited to Claim Number 031720313. 8. Any and all photographs, recordings, charts, graphs, sketches and any other tangible items or documentary evidence which Defendant intends to use during the trial in this cause and which have not been produced in response to any of the preceding paragraphs. 9 Copy of the Defendant's entire claim file, including front and back cover, for the Plaintiff's claim number 031720313 as it is kept in the normal course of business, excluding any documents to which Defendant claims a privilege. ALL DOCUMENTS FOR WHICH DEFENDANT ALLEGES A PRIVILEGE SHALL BE LISTED IN THE MANNER DESCRIBED IN F.R.C.P. 1.350. 10. The Defendant's entire claim file up from the date of the initial notice of the loss until the day before the Defendants knew that Defendant was going to deny or litigate the claim Page 2 of 4 LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 - 305-760-2314 - 305-760-2498 (fax)11. Any and all documents relating to or supporting Defendant's denial of any allegation of the Plaintiffs’ complaint, and relating to or supporting each affirmative or general defense asserted by Defendant. 12 Any and all statements, whether written, oral or recorded in whatever fashion, including transcripts thereof or electronic recordings of same, taken of any or all witnesses or other persons by the Defendant or its agents, with regard to the subject matter of this lawsuit. 13. A list and/or documents showing the names, addresses and telephone numbers of any and all witnesses whose statements have been taken, indicating their full legal name, residential address, business address and telephone number, in regard to the subject matter of this litigation 14. Any and all documents by and between the Defendant and its investigators, insurance adjusters and appraisers relating to the subject matter of the Complaint. 15 Any and all expert reports including but not limited to reports regarding cause and origin, estimates for repair and/or replacement, damage to the Plaintiff's property in question, or any other subject matter concerning this litigation prepared by any experts who may be, or will be, utilized at the time of trial on behalf of the Defendant. 16. Copies of any and all sworn Proofs of Loss submitted by or on behalf of any of the Plaintiffs relative to the subject claim and documentation accepting and/or rejecting said Proofs of Loss and, any and all documentation of any kind or nature relied upon relative to the Defendant’s acceptance or rejection of said Proofs of Loss. 17. Any and all documentation or other tangible evidence which Defendant contends supports its claim that all conditions precedent to bringing this action have not been met (if applicable). Page 3 of 4 LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 + 305-760-23 14 - 305-760-2498 (fax)18. A copy of any and all reports by any general contractor, roofer, electrician, or other construction personnel hired by the Defendant to examine and/or evaluate any of the claims asserted by any of the Plaintiffs. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing will be served upon the Defendant with the effectuation of service of process in this action. Respectfully submitted July 20, 2016. LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18th Avenue Suite 321 North Miami Beach, Florida 33162 Phone: (305) 760-2314 Fax (305) 760-2498 Direct email: alex@losslitigators.com Pleading email: service@losslitigators.com By: __/s/ Alex Stern___ Alex Stern, Esquire Fla. Bar No: 19592 Page 4 of 4 LITIGATION & RECOVERY LAW CENTER, PL 16375 NE 18" Avenue - Suite 321 - North Miami Beach, Florida 33162 + 305-760-23 14 - 305-760-2498 (fax)