Document for Edmonde Jacques Plaintiff vs. Avatar Property & Casualty Insurance Company Defendant

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                                Case Number: CACE-21-007804 Division: 12
Filing # 125098176 E-Filed 04/16/2021 04:21:36 PM

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA

EDMONDE JACQUES,

Plaintiff,
v. CASE NO.:

AVATAR PROPERTY & CASUALTY
INSURANCE COMPANY,

Defendant.
/

PLAINTIFF’S REQUEST FOR PRODUCTION TO DEFENDANT

COMES NOW, the Plaintiff, EDMONDE JACQUES, pursuant to Rule 1.350, Florida Rules

of Civil Procedure, propound this Request for Production to Defendant, AVATAR PROPERTY

& CASUALTY 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. A true and correct certified copy of the insurance policy issued described in the

complaint, including all declaration sheet(s), addendums, and attachments.

2. All photographs taken by Defendant’s adjuster during the initial inspection of the

claimed loss.

3. Copies of all photographs taken during Defendant’s investigation conducted during

the normal business of evaluating the claim.

4. All estimates of damage prepared by or on behalf of Defendant after its initial

inspection of the claimed loss.

5. Copies of all damage estimates prepared during Defendant’s investigation

conducted during the normal business of evaluating the claim.

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/16/2021 04:21:34 PM.****6. All letters, faxes, email communications, and log notes from Defendant’s adjusters
or agents which in any manner references any and all damages or causes of loss observed that were
prepared or generated during Defendant’s investigation conducted during the normal business of
evaluating the claim.

7. Defendant’s entire claim file from the date of the initial notice of the loss until the
day before Defendant knew that Defendant was going to deny any further payment or litigate the
claim.

8. Defendant’s entire claim file for the entire time that the claim was being handled
by Defendant not in anticipation of litigation of the loss.

9. Any and all correspondence or written communications from Defendant, or its
agents to Plaintiff, or their agents, which in any manner pertain to Plaintiff's alleged loss as
described in the Compliant.

10. Any and all correspondence or written communications from Plaintiff, or his agents
to Defendant, or its agents, which in any manner pertain to Plaintiffs alleged loss as described in
the Complaint.

11. Any and all photographs taken by the Defendant or Defendant’s agents showing
the extent of damage to the insured premises involved herein as were taken prior to the filing of
this lawsuit.

12. Any and all tape recordings of any statements made by Plaintiff or Plaintiff's agents
or employees.

13. Any and all transcripts or written statements from the Plaintiff(s) including, without

limitation, transcripts of EUO.14. Copies of each and every bill or estimate for repair to the subject property submitted
to Defendant by Plaintiff or Plaintiff's agents or employees.

15. Any and all written estimates or reports reflecting examination or inspection by
Defendant or Defendant’s agents of any of the alleged damage to the insured premises.

16. — All documents relating to or supporting Defendant’s denial of any allegation of
Plaintiffs Complaint.

17. _ All documents relating to or supporting each of Defendant’s affirmative or general
defenses asserted by Defendant.

18. All underwriting files pertaining to the policy of insurance described in the
Complaint/Petition.

19. Any and all documents related to any and all other insurance claims made by
Plaintiff(s) which are not the subject of this action, including estimates, reports, pictures, cancelled
checks, releases, proofs of loss, recorded statements, transcripts of EUO, and correspondence by
and between the parties related to any and all said other claims.

20. Any and all brochures, summary statements, pamphlets and advertising materials
prepared by or on behalf of Defendant and disseminated to insurance agencies or policyholders
which in any manner describe the coverages and/or exclusions under the same type of policy

involved in this action.CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon
the Defendant in this action along with the Complaint.

Respectfully Submitted,

By: — /s/ Aaron D. Silvers
AARON D. SILVERS, ESQ.
Florida Bar No: 104811
JEREMY T. SCHILLING, ESQ.
Florida Bar No: 0098111
Schilling & Silvers PLLC
1314 E. Las Olas Blvd., Unit #2191
Fort Lauderdale, FL 33301
T: 508-237-3256/215-932-8466

Email: asilvers@schillingsilvers.com
dariste@schillingsilvers.com
dadams@schillingsilvers.com