Preview
Case Number: CACE-21-007584 Division: 12
Filing # 124964304 E-Filed 04/15/2021 09:34:55 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
JEREMY CUPO and JUSTINE CUPO, GENERAL JURISDICTION DIVISION
CASE NO.
Plaintiffs,
Vv.
FLORIDA INSURANCE GUARANTY
ASSOCIATION, INC. AND FLORIDA
SPECIALTY INSURANCE COMPANY IS NOW
FLORIDA INSURANCE GUARANTY
ASSOCIATION, INC., a Florida corporation,
Defendant.
/
PLAINTIFFS' FIRST RE! UEST FOR PRODUCTION OF DOCUME Ss
JEREMY CUPO AND JUSTINE CUPO (“Plaintiffs”), by and through the undersigned
counsel, and pursuant to Fla. R. Civ. P. Rules 1.200, 1.280, and 1.340, hereby request the following
documents be produced by FLORIDA INSURANCE GUARANTY ASSOCIATION, INC.
(“Defendant”), at Florida Professional Law Group, PLLC, 4600 Sheridan St., Suite 303,
Hollywood, FL 33021, within thirty (30) days from the date of service hereof, or such other time
as ordered by the Court. You may serve a response within forty-five (45) days after service of the
process and initial pleading on you.
[The rest of this page is intentionally left blank.]
Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 1 of 9
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/15/2021 09:34:53 AM.*##*
1 DEFINITIONS
CASE SPECIFIC DEFINITIONS
1 “Plaintiffs” or “Insureds” means Jeremy Cupo and Justine Cupo, including their
officers, directors, shareholders, employees, agents, attorneys, accountants and representatives.
2. “Defendant,” “Insurer,” “You,” or “Your” means Florida Insurance Guaranty
Association, Inc., including its officers, directors, shareholders, employees, agents, attorneys,
accountants and representatives.
3 “Policy” means the homeowners’ insurance policy issued to Plaintiffs by
Defendant, bearing Policy Number FSIH1082576-01-0001, with a Policy Effective Date of
January 30, 2017, a Policy Expiration Date of January 30, 2018, and all related Forms, Notices
and Endorsements.
4 “Certified Policy” means the certified copy of the Policy, certified by Jimmy
Patronis, on or about April 1, 2021.
5 “Denial Letter” means the letter regarding denial of coverage, dated January 27,
2020, purportedly prepared by Linda Otero, and sent to the Insureds.
6. “Claim” means the Claim submitted pursuant to the Policy by Plaintiffs to
Defendant, in regard to damage which occurred on or about September 10, 2017 and bearing Claim
Number RECMS0871.
7
“Date of Loss” means on or about September 10, 2017.
8 “Property” or “Real Property” means the real property located at 5889 NW 120th
Terrace, Pompano Beach, FL 33076.
9 Unless otherwise provided, the applicable scope of time is from a year prior to
September 10, 2017 to the present.
GENERAL DEFINITIONS
10. “Adjuster” means the Property & Casualty Adjuster, working on or associated with
or having responsibility for the Insurer’s coverage evaluation or the Insurer’s handling of the
subject Claim.
11. “Agent” shall mean any agent, employee, officer, director, attorney, independent
contractor or any other person acting at the direction of or on behalf of another.
12. “And” and “or” as used herein are terms of inclusion and not of exclusion and shall
Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 2 of 9
be construed either disjunctively or conjunctively as necessary to bring within the scope of the
Production to Defendant any document or information that might otherwise be construed to be
outside its scope.
13. “Any” means one or more.
14. “Complaint” means the most recent Complaint filed in the instant case, which has
been or will be served on the Defendant.
15. “Date” shall mean the exact date, month and year, if ascertainable or, if not, the
best approximation of the date (based upon relationship with other events).
ee,
16. “Describe,” “discuss, analyze,” “describing,” “discussion,” “analyzing,” when
used in reference to a Document, 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.
17. “Document” or “documents” as used herein shall mean any writing, recording,
electronically stored information or photograph in your actual or constructive possession, custody,
care or control, which pertain directly or indirectly, in whole or in part, either to any of the subjects
listed below or to any other matter relevant to the issues in this action, or which are themselves
listed below as specific documents, including, but not limited to: correspondence, memoranda,
notes, messages, diaries, minutes, books, reports, charts, ledgers, invoices, computer printouts,
microfilms, video tapes or tape recordings.
18. “Identify,” when used in reference to a document (including electronically stored
information), means and includes the name and address of the custodian of the document, the
location of the document, and a general description of the document, including (1) the type of
document (e.g., letter or memorandum) and, if electronically stored information, the software
application used to create it (e.g, MS Word or MS Excel Spreadsheet); (2) the general subject
matter of the document or electronically stored information; (3) the date of the document or
electronically stored information; (4) the author of the document or electronically stored
information; (5) the addressee of the document or electronically stored information; and (6) the
relationship of the author and addressee to each other.
19. “Person” shall mean any individual, corporation, proprietorship, partnership, trust,
association or any other entity.
20. “Pertain to” x “pertaining to” means relates to, refers to, contains, concerns,
describes, embodies, mentions, constitutes, constituting, supports, corroborates, demonstrates,
proves, evidences, shows, refutes, disputes, rebuts, controverts or contradicts.
21. “Relate to” and “relating to” mean to make a statement about, refer to, discuss,
Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 3 of 9
describe, reflect, contain, comprise, identify, or in any way to pertain to, 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.
22. “Year” means calendar year.
23. 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.
24. 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.
Il. INSTRUCTIONS
With respect to this Request for Production of Documents, the following instructions shall
apply:
A Answers to this Request for Production of Documents shall be submitted in form
so that the answer follows the re-typed Request for Production of Documents to which it applies.
B This Request for Production of Documents is continuing and Defendant is
requested to supplement its responses hereto.
C Defendant is hereby notified that its duty to respond includes the duty to supply any
and all documents and materials in Defendant’s physical possession, as well as those which can
be obtained from additional sources, pursuant to Fla. R. Civ. P. Rule 1.350.
D. In the event that any document called for by a request is withheld on the basis of
Claim of privilege, please identify that document by stating: (a) any addressor or addressee;
(b) any indicated or blind copies; (c) matter, number of pages, and attachments or appendices;
(d) all persons to whom the document was distributed, shown or explained; (e) its present
custodian; and (f) the nature of the privilege asserted.
E In the event that any document requested herein 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.
F. In the event that any document called for by a request has been destroyed or
discarded, please identify that document by stating: (a) any address or and addressee; (b) any
indicated or blind copies; (c) the document’s date, subject matter, number of pages, and
attachments or appendices; (d) all persons to whom the document was distributed, shown or
Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 4 of 9
explained; (e) its date and destruction or discard, manner of destruction or discard, and reason for
destruction or discard; and (f) the persons authorizing or carrying out such destruction or discard.
G Unless otherwise specified, the requests contained in this Request for Production
of Documents are limited to documents authored, created, received, revised or sent between a year
prior to September 10, 2017 and the date that this Request for Production of Documents is
responded to by Defendant.
H. In producing documents requested herein, You shall produce documents in full,
without abridgment, abbreviation, and expurgation of any sort.
I Any and all documents shall be segregated in accordance with the numbered and
lettered paragraphs and subparagraphs herein.
J. Plaintiffs seek documents that are responsive to this Request but are not the
duplication of any documents already produced in response to prior subpoenas served on
Defendant.
Ill. REQUEST FOR PRODUCTION OF DOCUMENTS
If any of the material requested is protected by the work product or attorney client
privileges, Plaintiffs requests that Defendant provide a redacted version of the requested
documents.
Please provide true and correct copies of the following:
1 Pursuant to Fla. R. Civ. P. 1.310(b)(6), please produce three (3) alternative date:
for the deposition of the representative(s) with the most knowledge of the claim asserted by the
Plaintiffs’ Complaint as well as the individual who was primarily responsible for the decision to
denial Plaintiffs' insurance claim. A designation of the information upon which such examination
will proceed will be provided under separate cover.
2. All policies of insurance, including, but not limited to umbrella and excess coverage
policies, declaration pages, policy forms, endorsements, which insure to the benefit of the Insureds
that were in effect during the Date of Loss.
3 Copies of any and all ISO Claims searches regarding any claims filed, prior to the
Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 5 of 9
subject claim, by Plaintiffs and/or Insureds.
4 Copies of any and all ISO Claims searches regarding any claims filed, prior to the
subject claim, for the subject Property.
5 Copies of any and all notices sent by you or your representatives (defined above)
to Plaintiffs and/or Insureds to participate in a mediation program under Fla. Stat.§627.7015 and
copies of any and all PORS. Proof of Mailing and other documents (defined above) which reflect
in any way mailings made by you to Plaintiffs and/or Insureds regarding the same.
6. Any and all documents or things that You contend supports each and any of Your
affirmative defenses or coverage defenses/positions.
7
Any and all documents which support any of your denials of any allegations in the
Complaint.
8 Any and all documents supporting any denials made in response to Plaintiffs First
Request for Admissions.
9. Any and all documents which You relied upon in preparing Your responses to
Plaintiffs' First Set of Interrogatories to Defendant.
10. Any and all documents evidencing, showing, reflecting or relating to
correspondence, communication or contact of any kind between (a) You and/or Defendant and (b)
Plaintiffs, regarding the Claim.
11. Any and all documents that pertain to the damages related to this loss being sought
in this case.
12. Any and all documents (or a description by category and location), electronically
stored information, and tangible things that Defendant has in its possession, custody, or control
and may use to support its claims or defenses.
Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 6 of 9
13. Any and all documents reflecting any scientific or other authority (e.g., treatises,
books, studies, software programs, etc.) relied upon by Defendant in adjusting the Claim or
determining any amount Defendant would or would not pay.
14. Any and all documents upon which Defendant is relying or intends to rely to prove
that it is not obligated to tender monies for the loss sustained by Plaintiffs.
15. Any and all repair estimates concerning any of the damages relating to the loss at
issue in this matter.
16. Any and all expert reports which have been obtained from any expert regarding the
Claim.
17. Any and all reports and current curriculum vitae from any expert(s) retained for any
reason regarding the Claim.
18. Any and all documents, reports, including drafts, submitted by any expert witness
or potential expert witness retained or consulted by Defendant with respect to the issues raised in
this proceeding.
19. Any and all documents, reports or other written records pertaining to any inspection
and/or investigation to the loss which is the basis of this lawsuit.
20. Plaintiffs' underwriting file, and documents contained in Plaintiffs' underwriting
file.
21. Any and all documents You intend to rely upon or introduce at trial in this
proceeding.
22. Any and all photographs or video depictions of the Real Property in the possession
of Defendant or any agent of Defendant, both before and after the Date of Loss.
23. Any and all correspondence between Defendant and Plaintiffs' relating to the loss,
Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 7 of 9
which is basis of this lawsuit.
24. Any and all correspondence between Defendant and any non-party (not including
consultants or experts) relating to the loss, which is the basis of this lawsuit.
25. Any and all tapes and/or transcripts of statements taken of any person, including
but not limited to Examinations Under Oath, regarding the Claim.
26. Copies of any and all statements, and any transcripts from any person who has
knowledge of the facts in this matter including any expert witness or the Defendant (defined above)
herein.
27. Copies of any and all recorded statement(s) and telephone conversations, as well as
any transcripts including but not limited to Examinations Under Oath, which were taken of or
provided by Insureds which are in your possession or control, regarding the Claim.
28. Copies of any and all recorded statement(s) and telephone conversations, as well as
any transcripts for the same which have been reduced to writing and/or transcribed, including but
not limited to Examinations Under Oath, which were taken of or provided by Plaintiffs or its
representatives (defined above) which are in your possession or control, regarding the Claim.
29. Copies of any and all recorded statement(s) and telephone conversations, as well as
any transcripts for the same which have been reduced to writing and/or transcribed, which were
taken of or provided by any witness to the loss and/or work performed or to be performed by
Plaintiffs which are in your possession or control, regarding the Claim.
30. All proofs of loss received by Defendant from Plaintiff, Insureds or their
representatives (defined above), regarding the Claim.
Plaintiffs reserve the right to request additional documents as their investigation
continues, as additional issues are uncovered, and as clarifications are required.
Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 8 of 9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 15, 2021, a true and correct copy of the foregoing
has been or will be furnished by delivery to the Defendant along with service of the Complaint.
Respectfully submitted,
/s/ Caroline Donawa, Esq.
Florida Professional Law Group, PLLC
Caroline Donawa, Esq.
Florida Bar No. 125526
4600 Sheridan St., Suite 303
Hollywood, FL 33021
Tel. (954) 284-0900
Fax. (954) 284-0747
E-mail: cdonawa@flplg.com
E-mail: eservice@flplg.com
Attorneys for Plaintiffs, Jeremy Cupo and Justine
Cupo
Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 9 of 9
Preview
Case Number: CACE-21-007584 Division: 12 Filing # 124964304 E-Filed 04/15/2021 09:34:55 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JEREMY CUPO and JUSTINE CUPO, GENERAL JURISDICTION DIVISION CASE NO. Plaintiffs, Vv. FLORIDA INSURANCE GUARANTY ASSOCIATION, INC. AND FLORIDA SPECIALTY INSURANCE COMPANY IS NOW FLORIDA INSURANCE GUARANTY ASSOCIATION, INC., a Florida corporation, Defendant. / PLAINTIFFS' FIRST RE! UEST FOR PRODUCTION OF DOCUME Ss JEREMY CUPO AND JUSTINE CUPO (“Plaintiffs”), by and through the undersigned counsel, and pursuant to Fla. R. Civ. P. Rules 1.200, 1.280, and 1.340, hereby request the following documents be produced by FLORIDA INSURANCE GUARANTY ASSOCIATION, INC. (“Defendant”), at Florida Professional Law Group, PLLC, 4600 Sheridan St., Suite 303, Hollywood, FL 33021, within thirty (30) days from the date of service hereof, or such other time as ordered by the Court. You may serve a response within forty-five (45) days after service of the process and initial pleading on you. [The rest of this page is intentionally left blank.] Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 1 of 9 #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/15/2021 09:34:53 AM.*##* 1 DEFINITIONS CASE SPECIFIC DEFINITIONS 1 “Plaintiffs” or “Insureds” means Jeremy Cupo and Justine Cupo, including their officers, directors, shareholders, employees, agents, attorneys, accountants and representatives. 2. “Defendant,” “Insurer,” “You,” or “Your” means Florida Insurance Guaranty Association, Inc., including its officers, directors, shareholders, employees, agents, attorneys, accountants and representatives. 3 “Policy” means the homeowners’ insurance policy issued to Plaintiffs by Defendant, bearing Policy Number FSIH1082576-01-0001, with a Policy Effective Date of January 30, 2017, a Policy Expiration Date of January 30, 2018, and all related Forms, Notices and Endorsements. 4 “Certified Policy” means the certified copy of the Policy, certified by Jimmy Patronis, on or about April 1, 2021. 5 “Denial Letter” means the letter regarding denial of coverage, dated January 27, 2020, purportedly prepared by Linda Otero, and sent to the Insureds. 6. “Claim” means the Claim submitted pursuant to the Policy by Plaintiffs to Defendant, in regard to damage which occurred on or about September 10, 2017 and bearing Claim Number RECMS0871. 7 “Date of Loss” means on or about September 10, 2017. 8 “Property” or “Real Property” means the real property located at 5889 NW 120th Terrace, Pompano Beach, FL 33076. 9 Unless otherwise provided, the applicable scope of time is from a year prior to September 10, 2017 to the present. GENERAL DEFINITIONS 10. “Adjuster” means the Property & Casualty Adjuster, working on or associated with or having responsibility for the Insurer’s coverage evaluation or the Insurer’s handling of the subject Claim. 11. “Agent” shall mean any agent, employee, officer, director, attorney, independent contractor or any other person acting at the direction of or on behalf of another. 12. “And” and “or” as used herein are terms of inclusion and not of exclusion and shall Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 2 of 9 be construed either disjunctively or conjunctively as necessary to bring within the scope of the Production to Defendant any document or information that might otherwise be construed to be outside its scope. 13. “Any” means one or more. 14. “Complaint” means the most recent Complaint filed in the instant case, which has been or will be served on the Defendant. 15. “Date” shall mean the exact date, month and year, if ascertainable or, if not, the best approximation of the date (based upon relationship with other events). ee, 16. “Describe,” “discuss, analyze,” “describing,” “discussion,” “analyzing,” when used in reference to a Document, 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. 17. “Document” or “documents” as used herein shall mean any writing, recording, electronically stored information or photograph in your actual or constructive possession, custody, care or control, which pertain directly or indirectly, in whole or in part, either to any of the subjects listed below or to any other matter relevant to the issues in this action, or which are themselves listed below as specific documents, including, but not limited to: correspondence, memoranda, notes, messages, diaries, minutes, books, reports, charts, ledgers, invoices, computer printouts, microfilms, video tapes or tape recordings. 18. “Identify,” when used in reference to a document (including electronically stored information), means and includes the name and address of the custodian of the document, the location of the document, and a general description of the document, including (1) the type of document (e.g., letter or memorandum) and, if electronically stored information, the software application used to create it (e.g, MS Word or MS Excel Spreadsheet); (2) the general subject matter of the document or electronically stored information; (3) the date of the document or electronically stored information; (4) the author of the document or electronically stored information; (5) the addressee of the document or electronically stored information; and (6) the relationship of the author and addressee to each other. 19. “Person” shall mean any individual, corporation, proprietorship, partnership, trust, association or any other entity. 20. “Pertain to” x “pertaining to” means relates to, refers to, contains, concerns, describes, embodies, mentions, constitutes, constituting, supports, corroborates, demonstrates, proves, evidences, shows, refutes, disputes, rebuts, controverts or contradicts. 21. “Relate to” and “relating to” mean to make a statement about, refer to, discuss, Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 3 of 9 describe, reflect, contain, comprise, identify, or in any way to pertain to, 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. 22. “Year” means calendar year. 23. 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. 24. 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. Il. INSTRUCTIONS With respect to this Request for Production of Documents, the following instructions shall apply: A Answers to this Request for Production of Documents shall be submitted in form so that the answer follows the re-typed Request for Production of Documents to which it applies. B This Request for Production of Documents is continuing and Defendant is requested to supplement its responses hereto. C Defendant is hereby notified that its duty to respond includes the duty to supply any and all documents and materials in Defendant’s physical possession, as well as those which can be obtained from additional sources, pursuant to Fla. R. Civ. P. Rule 1.350. D. In the event that any document called for by a request is withheld on the basis of Claim of privilege, please identify that document by stating: (a) any addressor or addressee; (b) any indicated or blind copies; (c) matter, number of pages, and attachments or appendices; (d) all persons to whom the document was distributed, shown or explained; (e) its present custodian; and (f) the nature of the privilege asserted. E In the event that any document requested herein 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. F. In the event that any document called for by a request has been destroyed or discarded, please identify that document by stating: (a) any address or and addressee; (b) any indicated or blind copies; (c) the document’s date, subject matter, number of pages, and attachments or appendices; (d) all persons to whom the document was distributed, shown or Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 4 of 9 explained; (e) its date and destruction or discard, manner of destruction or discard, and reason for destruction or discard; and (f) the persons authorizing or carrying out such destruction or discard. G Unless otherwise specified, the requests contained in this Request for Production of Documents are limited to documents authored, created, received, revised or sent between a year prior to September 10, 2017 and the date that this Request for Production of Documents is responded to by Defendant. H. In producing documents requested herein, You shall produce documents in full, without abridgment, abbreviation, and expurgation of any sort. I Any and all documents shall be segregated in accordance with the numbered and lettered paragraphs and subparagraphs herein. J. Plaintiffs seek documents that are responsive to this Request but are not the duplication of any documents already produced in response to prior subpoenas served on Defendant. Ill. REQUEST FOR PRODUCTION OF DOCUMENTS If any of the material requested is protected by the work product or attorney client privileges, Plaintiffs requests that Defendant provide a redacted version of the requested documents. Please provide true and correct copies of the following: 1 Pursuant to Fla. R. Civ. P. 1.310(b)(6), please produce three (3) alternative date: for the deposition of the representative(s) with the most knowledge of the claim asserted by the Plaintiffs’ Complaint as well as the individual who was primarily responsible for the decision to denial Plaintiffs' insurance claim. A designation of the information upon which such examination will proceed will be provided under separate cover. 2. All policies of insurance, including, but not limited to umbrella and excess coverage policies, declaration pages, policy forms, endorsements, which insure to the benefit of the Insureds that were in effect during the Date of Loss. 3 Copies of any and all ISO Claims searches regarding any claims filed, prior to the Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 5 of 9 subject claim, by Plaintiffs and/or Insureds. 4 Copies of any and all ISO Claims searches regarding any claims filed, prior to the subject claim, for the subject Property. 5 Copies of any and all notices sent by you or your representatives (defined above) to Plaintiffs and/or Insureds to participate in a mediation program under Fla. Stat.§627.7015 and copies of any and all PORS. Proof of Mailing and other documents (defined above) which reflect in any way mailings made by you to Plaintiffs and/or Insureds regarding the same. 6. Any and all documents or things that You contend supports each and any of Your affirmative defenses or coverage defenses/positions. 7 Any and all documents which support any of your denials of any allegations in the Complaint. 8 Any and all documents supporting any denials made in response to Plaintiffs First Request for Admissions. 9. Any and all documents which You relied upon in preparing Your responses to Plaintiffs' First Set of Interrogatories to Defendant. 10. Any and all documents evidencing, showing, reflecting or relating to correspondence, communication or contact of any kind between (a) You and/or Defendant and (b) Plaintiffs, regarding the Claim. 11. Any and all documents that pertain to the damages related to this loss being sought in this case. 12. Any and all documents (or a description by category and location), electronically stored information, and tangible things that Defendant has in its possession, custody, or control and may use to support its claims or defenses. Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 6 of 9 13. Any and all documents reflecting any scientific or other authority (e.g., treatises, books, studies, software programs, etc.) relied upon by Defendant in adjusting the Claim or determining any amount Defendant would or would not pay. 14. Any and all documents upon which Defendant is relying or intends to rely to prove that it is not obligated to tender monies for the loss sustained by Plaintiffs. 15. Any and all repair estimates concerning any of the damages relating to the loss at issue in this matter. 16. Any and all expert reports which have been obtained from any expert regarding the Claim. 17. Any and all reports and current curriculum vitae from any expert(s) retained for any reason regarding the Claim. 18. Any and all documents, reports, including drafts, submitted by any expert witness or potential expert witness retained or consulted by Defendant with respect to the issues raised in this proceeding. 19. Any and all documents, reports or other written records pertaining to any inspection and/or investigation to the loss which is the basis of this lawsuit. 20. Plaintiffs' underwriting file, and documents contained in Plaintiffs' underwriting file. 21. Any and all documents You intend to rely upon or introduce at trial in this proceeding. 22. Any and all photographs or video depictions of the Real Property in the possession of Defendant or any agent of Defendant, both before and after the Date of Loss. 23. Any and all correspondence between Defendant and Plaintiffs' relating to the loss, Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 7 of 9 which is basis of this lawsuit. 24. Any and all correspondence between Defendant and any non-party (not including consultants or experts) relating to the loss, which is the basis of this lawsuit. 25. Any and all tapes and/or transcripts of statements taken of any person, including but not limited to Examinations Under Oath, regarding the Claim. 26. Copies of any and all statements, and any transcripts from any person who has knowledge of the facts in this matter including any expert witness or the Defendant (defined above) herein. 27. Copies of any and all recorded statement(s) and telephone conversations, as well as any transcripts including but not limited to Examinations Under Oath, which were taken of or provided by Insureds which are in your possession or control, regarding the Claim. 28. Copies of any and all recorded statement(s) and telephone conversations, as well as any transcripts for the same which have been reduced to writing and/or transcribed, including but not limited to Examinations Under Oath, which were taken of or provided by Plaintiffs or its representatives (defined above) which are in your possession or control, regarding the Claim. 29. Copies of any and all recorded statement(s) and telephone conversations, as well as any transcripts for the same which have been reduced to writing and/or transcribed, which were taken of or provided by any witness to the loss and/or work performed or to be performed by Plaintiffs which are in your possession or control, regarding the Claim. 30. All proofs of loss received by Defendant from Plaintiff, Insureds or their representatives (defined above), regarding the Claim. Plaintiffs reserve the right to request additional documents as their investigation continues, as additional issues are uncovered, and as clarifications are required. Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 8 of 9 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 15, 2021, a true and correct copy of the foregoing has been or will be furnished by delivery to the Defendant along with service of the Complaint. Respectfully submitted, /s/ Caroline Donawa, Esq. Florida Professional Law Group, PLLC Caroline Donawa, Esq. Florida Bar No. 125526 4600 Sheridan St., Suite 303 Hollywood, FL 33021 Tel. (954) 284-0900 Fax. (954) 284-0747 E-mail: cdonawa@flplg.com E-mail: eservice@flplg.com Attorneys for Plaintiffs, Jeremy Cupo and Justine Cupo Matter ID: 12563;Plaintiffs' First Request for Production of Documents Page 9 of 9