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Filing # 100449348 E-Filed 12/17/2019 02:58:54 PM
IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
TOTAL CARE RESTORATION, LLC A/A/O
ANNIE GRIFFITHS,
Plaintiff,
Vv. Case No. COCE-19-023855
CITIZENS PROPERTY INSURANCE Division: 50
CORPORATION,
Defendant.
DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
Defendant, CITIZENS PROPERTY INSURANCE CORPORATION
(“Citizens”), by and through the undersigned counsel and pursuant to Fla. R. Civ. P. Rule 1.350,
propounds the following request for production to Plaintiff, TOTAL CARE RESTORATION,
LLC A/A/O ANNIE GRIFFITHS, as follows:
DEFINITIONS:
As used in these Requests, the terms listed below are defined as follows:
1 “You”, or “Your”, means the Plaintiff, TOTAL CARE RESTORATION, LLC
A/A/O ANNIE GRIFFITHS, your agents, representatives, and, unless privileged, your attorneys.
2. “Identify” or “identification”, when used with respect to an individual, means to
state that individual’s full name, telephone number, and present or last known address.
3 “Document” means any written, recorded or graphic matter however produced or
reproduced.
4. “Property” means 572 Dayton Circle, Ft. Lauderdale, FL 33312.
5 “Insured(s)” means Annie Griffiths.
Page 1 of 4
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/17/2019 02:58:54 PM.**##*
6 “Loss” refers to the water event alleged in the Plaintiff's Complaint.
7 “Policy” refers to the policy described in Plaintiff's Complaint with a policy
number of 01079780-3.
SCOPE OF PRODUCTION
If any documents are withheld under claim of privilege, furnish a list identifying each
document for which the privilege is claimed, together with the following information:
1 a brief description of the nature and subject matter;
the date;
the name and title of the author(s);
the name and title of the person(s) to whom the document was addressed;
the name and title of the persons(s) to whom the document was sent;
the number of pages;
the paragraph to which the document is otherwise responsive; and
the nature of the claimed privilege.
REQUESTS FOR PRODUCTION
1 Any and all estimates for repairs to damages at the Property related to the alleged
repairs completed at the Property.
2. Any and all documents reflecting repairs completed to the Property, whether
performed by you or third parties, in relation to the subject claim, including but not limited to
any and all estimates, receipts, invoices, drying logs, diagrams or lists of locations where repairs
or work was performed, and permits and plan specifications.
3 Any and all photographs of the Property before the repairs were completed.
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4 Any and all photographs of the Property after the repairs were completed.
5 Any and all documents reflecting prior payments issued to the Plaintiff by the
Defendant or any third parties, including, but not limited to, copies of checks.
6. Any and all inspection reports and/or certificates of completion generated after
the completion of the repairs, including accompanying photographs.
7 Any and all contracts between you and the named Insured for the alleged repairs
completed at the Property.
8 Any and all photographs, emails, letters and insurance policy documents provided
to you by the Insured.
9 Any and all documents related to any payments received or claims made by the
Insured.
10. Any and all correspondence between you and the Insured regarding the Loss.
11. All timesheets/records for each employee or contractor reflecting the time spent at
the Property.
12. Any and all documents, including estimates, photographs, and timesheets/records,
reflecting any repairs or services provided at the Property prior to June 10, 2018.
[>] Michael
D. Rue
MICHAEL D. RUEL, Fla. Bar No. 52835
mruel@gallowaylawfirm.com
EDWARD N. KRAKAUER, Fla Bar No. 117797
ekrakauer@gallowaylawfirm.com
Galloway, Johnson, Tompkins, Burr & Smith, PLC
110 E. Broward Blvd., Suite 1700
Fort Lauderdale, FL 33301
(954) 951-2200
(954) 951-4400 (facsimile)
FLLservice allowaylawfirm.com
Counsel for Citizens Property Insurance Corporation
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 17th day
of December, 2019:
Michael D. Redondo, Esq.
Redondo Law P.A.
2828 Coral Way, Suite 206
Miami, Florida 33145
mike@redondolawfirm.com
ervice@redondolawfirm.com
Counsel for Plaintiffs
[s| Michael
D. Ruel
MICHAEL D. RUEL
EDWARD N. KRAKAUER
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Filing # 100449348 E-Filed 12/17/2019 02:58:54 PM IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA TOTAL CARE RESTORATION, LLC A/A/O ANNIE GRIFFITHS, Plaintiff, Vv. Case No. COCE-19-023855 CITIZENS PROPERTY INSURANCE Division: 50 CORPORATION, Defendant. DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF Defendant, CITIZENS PROPERTY INSURANCE CORPORATION (“Citizens”), by and through the undersigned counsel and pursuant to Fla. R. Civ. P. Rule 1.350, propounds the following request for production to Plaintiff, TOTAL CARE RESTORATION, LLC A/A/O ANNIE GRIFFITHS, as follows: DEFINITIONS: As used in these Requests, the terms listed below are defined as follows: 1 “You”, or “Your”, means the Plaintiff, TOTAL CARE RESTORATION, LLC A/A/O ANNIE GRIFFITHS, your agents, representatives, and, unless privileged, your attorneys. 2. “Identify” or “identification”, when used with respect to an individual, means to state that individual’s full name, telephone number, and present or last known address. 3 “Document” means any written, recorded or graphic matter however produced or reproduced. 4. “Property” means 572 Dayton Circle, Ft. Lauderdale, FL 33312. 5 “Insured(s)” means Annie Griffiths. Page 1 of 4 #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/17/2019 02:58:54 PM.**##* 6 “Loss” refers to the water event alleged in the Plaintiff's Complaint. 7 “Policy” refers to the policy described in Plaintiff's Complaint with a policy number of 01079780-3. SCOPE OF PRODUCTION If any documents are withheld under claim of privilege, furnish a list identifying each document for which the privilege is claimed, together with the following information: 1 a brief description of the nature and subject matter; the date; the name and title of the author(s); the name and title of the person(s) to whom the document was addressed; the name and title of the persons(s) to whom the document was sent; the number of pages; the paragraph to which the document is otherwise responsive; and the nature of the claimed privilege. REQUESTS FOR PRODUCTION 1 Any and all estimates for repairs to damages at the Property related to the alleged repairs completed at the Property. 2. Any and all documents reflecting repairs completed to the Property, whether performed by you or third parties, in relation to the subject claim, including but not limited to any and all estimates, receipts, invoices, drying logs, diagrams or lists of locations where repairs or work was performed, and permits and plan specifications. 3 Any and all photographs of the Property before the repairs were completed. Page 2 of 4 4 Any and all photographs of the Property after the repairs were completed. 5 Any and all documents reflecting prior payments issued to the Plaintiff by the Defendant or any third parties, including, but not limited to, copies of checks. 6. Any and all inspection reports and/or certificates of completion generated after the completion of the repairs, including accompanying photographs. 7 Any and all contracts between you and the named Insured for the alleged repairs completed at the Property. 8 Any and all photographs, emails, letters and insurance policy documents provided to you by the Insured. 9 Any and all documents related to any payments received or claims made by the Insured. 10. Any and all correspondence between you and the Insured regarding the Loss. 11. All timesheets/records for each employee or contractor reflecting the time spent at the Property. 12. Any and all documents, including estimates, photographs, and timesheets/records, reflecting any repairs or services provided at the Property prior to June 10, 2018. [>] Michael D. Rue MICHAEL D. RUEL, Fla. Bar No. 52835 mruel@gallowaylawfirm.com EDWARD N. KRAKAUER, Fla Bar No. 117797 ekrakauer@gallowaylawfirm.com Galloway, Johnson, Tompkins, Burr & Smith, PLC 110 E. Broward Blvd., Suite 1700 Fort Lauderdale, FL 33301 (954) 951-2200 (954) 951-4400 (facsimile) FLLservice allowaylawfirm.com Counsel for Citizens Property Insurance Corporation Page 3 of 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 17th day of December, 2019: Michael D. Redondo, Esq. Redondo Law P.A. 2828 Coral Way, Suite 206 Miami, Florida 33145 mike@redondolawfirm.com ervice@redondolawfirm.com Counsel for Plaintiffs [s| Michael D. Ruel MICHAEL D. RUEL EDWARD N. KRAKAUER Page 4 of 4