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Filing # 128836483 E-Filed 06/16/2021 08:48:41 AM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.:
CHRISTOPHER S. LEPORTE & SARA
J. LEPORTE,
Plaintiff(s),
VS.
TOWER HILL PREFERREDINSURANCE
COMPANY,
Defendant.
PLAINTIFF'S FIRST REOUEST FOR PRODUCTIONTO DEFENDANT
COMES NOW the Plaintiff(s),by and throughundersignedcounsel, pursuant to Rule
1.350 of the Florida Rules of Civil Procedure, hereby requests Defendant, to furnish copies of the
following documentsto the offices of the undersignedattorney within the time prescribedby law.
DEFINITIONS
1) The term "communication"shall mean any transmissionofinformation by any means,
including,without limitation,by spoken language,electronic transmissionof data or any
other means. The term "communication"shall include,without limitation,any copies of
written informationreceived by the person or entity respondingto this request, even if such
person or entity is not the primary or direct addressee of such written information.
2) The term "document" or "documents"is used in its broadest sense and includes,without
limitation,drafts, documentswhether printed, recorded, stored or reproducedby any
mechanical or electronic process, or written or produced by hand, and including computer
tapes (including backup tapes) and all other computer-relateddocuments,within your
possession, custody or control. "Documents" shall also include (1) each copy that is not
identical to the original or to any other copy, and (2) any tangible thing that is called for by or
identified in response to any request. "Document" as used herein shall be construed broadly
to include all documents and things within the scope of the Florida Rules of Civil Procedure
and refers to all writings or other graphic matter, as well as any other mediumby which
informationis stored or recorded. It includes originals,drafts, copies and reproductions; and
Shield Law Group ofFlorida, LLC * 15751 SheridanStreet 300, Davie, FL 33331 * Telephone #: 786-496-2223
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/16/2021 08:48:37 AM.****
it includes, without limiting the generalityofthe forgoing, letters; memoranda; reports and/or
summaries of investigations; police reports; accident reports; opinions or reports of
consultants;diagrams; marginalcomments appearing on any documents; accounts;
telegrams; studies; lists ofpersons attending meetings or conferences; records ofmemoranda
oftelephoneconversations; specifications; drawings; advertisements; circulars;trade letters;
press releases; prints; recordings; positive or negative films, slides or photographs; magnetic,
electronic or video tapes; computertapes, cards or printouts, and all other things of like
nature; and any and all containers, boxes or other receptacles or repositories housing or
containingsuch "documents."
3) "Person"means a natural person, firm, association, partnership,corporation,or other firm of
legal or business entity, public or private.
4) The term "referring"or "relating"shall mean showing, disclosing, averting to, comprising,
evidencing, constitutingor reviewing.
5) The term "representative" as used herein with regard to a person or entity means and includes
each and every present and former director,officer, partner, employee, agent, independent
consultant or expert or other person (including attorneys)acting or purportingto act on behalf
of the person or entity.
6) "Subject damages" means any property loss or damage for which the plaintiffcontends that
the defendant must pay under the terms and conditions of the subject insurancecontract with
the parties.
7) The singular includes the plural and vice versa; the words "and" and "or" shall be both
conjunctive; the word "all" means "any and all"; the word "any" means "any and all"; the
word "including"means "including, without limitation."
DOCUMENT REQUEST:
1) All documents whichyou believe supportthe Plaintiff's claims.
2) All reports and current curriculum vitae from any expert(s) retained for any reason regarding
Plaintiffs claim.
3) All correspondenceregardingthe claim not containedwithin the claims file, includingbut not
limited to email or other written documentsof any kind or correspondencewith Plaintiff,
Plaintiffs counsel, experts, independent adjusters, appraisers, inspector, and any other third
party, or to anyone in the companyfor which the Adjuster works or provides services.
4) All correspondenceregardingthe claim contained within the claims file, includingbut not
limited to; email or other written documentsof any kind or correspondencewith Plaintiff,
Plaintiffs counsel, experts, independent adjusters, appraisers, inspectors, and any other third
party, or to anyone in the companyfor which the Adjuster works or provides services
Shield Law Group ofFlorida, LLC * 15751 SheridanStreet 300, Davie, FL 33331 * Telephone #: 786-496-2223
5) All writings, memoranda, notes, or other materials reflecting examinationof Plaintiff?s
dwelling by Defendant or its agents, includingbefore and after the subject date of loss as set
forth in the Complaint.
6) All photographsor video depiction of Plaintiffsproperty in the possession of the Defendant
or any agent of Defendant, both before and after the date of loss as set forth in the Complaint.
7) All proofs of loss receivedby Defendant from Plaintiffs or any representativeofPlaintiff.
8) All estimates receivedby Defendant from any source for repairs to Plaintiffsresidence.
9) All documents sent to any governmental agenciesrelatedto this claim, and/orthe reason it
has not been fully settled or paid.
10) All time sheets or start/stop time indicationsfor site visits at Plaintiff's property.
11) Any documents reflecting any scientific or other authority (e.g., treatises, books, studies,
software programs, etc.) relied upon by the Defendant in adjusting the claim or determining
any amount Defendant would or would not pay.
12) Any documents that would more fully explain why the Defendant has not paid this claim in
the amount requestedby the Plaintiff.
13) Any lists of experts regularlyutilized by the Adjuster with the accompanying information
showingthe specific expertise sufficientto properly evaluate the claim, or that is directedby
Defendant to Adjuster for any kind of consideration in the selectionof experts.
14) Copies ofall documents evidencing paymentsmade to Plaintiffs relating to this claim,
includingthose that simply reference such payments or refusal to pay or any other kind of
payment or refusal to pay.
15) A copy of any and all inspection reports of Plaintiff's property.
16) All statements of witnessesrelating to the facts or issues involved in this lawsuit.
17). All reports, studies,memorandums, correspondence, documents, or any other evidence
regardingthe results of any tests performed by anyone by or on behalfof the Defendant for
any of the allegations by the Defendant.
Shield Law Group ofFlorida, LLC * 15751 SheridanStreet 300, Davie, FL 33331 * Telephone #: 786-496-2223
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy has been providedthrough service of process with the
Complaint and Summons.
RespectfullySubmitted,
Shield Law Group of Florida, LLC
15751 Sheridan Street #300
Davie, FL 33331
Telephone: 786-496-2223
By: /s/ Jamie Alvarez, Esq. 0526762
JAMIE ALVAREZ, ESQ.
FLA BAR NO.: 0526762
For Service of documents only:
Shield Law Group ofFlorida, LLC * 15751 SheridanStreet 300, Davie, FL 33331 * Telephone #: 786-496-2223
Preview
Filing # 128836483 E-Filed 06/16/2021 08:48:41 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: CHRISTOPHER S. LEPORTE & SARA J. LEPORTE, Plaintiff(s), VS. TOWER HILL PREFERREDINSURANCE COMPANY, Defendant. PLAINTIFF'S FIRST REOUEST FOR PRODUCTIONTO DEFENDANT COMES NOW the Plaintiff(s),by and throughundersignedcounsel, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby requests Defendant, to furnish copies of the following documentsto the offices of the undersignedattorney within the time prescribedby law. DEFINITIONS 1) The term "communication"shall mean any transmissionofinformation by any means, including,without limitation,by spoken language,electronic transmissionof data or any other means. The term "communication"shall include,without limitation,any copies of written informationreceived by the person or entity respondingto this request, even if such person or entity is not the primary or direct addressee of such written information. 2) The term "document" or "documents"is used in its broadest sense and includes,without limitation,drafts, documentswhether printed, recorded, stored or reproducedby any mechanical or electronic process, or written or produced by hand, and including computer tapes (including backup tapes) and all other computer-relateddocuments,within your possession, custody or control. "Documents" shall also include (1) each copy that is not identical to the original or to any other copy, and (2) any tangible thing that is called for by or identified in response to any request. "Document" as used herein shall be construed broadly to include all documents and things within the scope of the Florida Rules of Civil Procedure and refers to all writings or other graphic matter, as well as any other mediumby which informationis stored or recorded. It includes originals,drafts, copies and reproductions; and Shield Law Group ofFlorida, LLC * 15751 SheridanStreet 300, Davie, FL 33331 * Telephone #: 786-496-2223 *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/16/2021 08:48:37 AM.**** it includes, without limiting the generalityofthe forgoing, letters; memoranda; reports and/or summaries of investigations; police reports; accident reports; opinions or reports of consultants;diagrams; marginalcomments appearing on any documents; accounts; telegrams; studies; lists ofpersons attending meetings or conferences; records ofmemoranda oftelephoneconversations; specifications; drawings; advertisements; circulars;trade letters; press releases; prints; recordings; positive or negative films, slides or photographs; magnetic, electronic or video tapes; computertapes, cards or printouts, and all other things of like nature; and any and all containers, boxes or other receptacles or repositories housing or containingsuch "documents." 3) "Person"means a natural person, firm, association, partnership,corporation,or other firm of legal or business entity, public or private. 4) The term "referring"or "relating"shall mean showing, disclosing, averting to, comprising, evidencing, constitutingor reviewing. 5) The term "representative" as used herein with regard to a person or entity means and includes each and every present and former director,officer, partner, employee, agent, independent consultant or expert or other person (including attorneys)acting or purportingto act on behalf of the person or entity. 6) "Subject damages" means any property loss or damage for which the plaintiffcontends that the defendant must pay under the terms and conditions of the subject insurancecontract with the parties. 7) The singular includes the plural and vice versa; the words "and" and "or" shall be both conjunctive; the word "all" means "any and all"; the word "any" means "any and all"; the word "including"means "including, without limitation." DOCUMENT REQUEST: 1) All documents whichyou believe supportthe Plaintiff's claims. 2) All reports and current curriculum vitae from any expert(s) retained for any reason regarding Plaintiffs claim. 3) All correspondenceregardingthe claim not containedwithin the claims file, includingbut not limited to email or other written documentsof any kind or correspondencewith Plaintiff, Plaintiffs counsel, experts, independent adjusters, appraisers, inspector, and any other third party, or to anyone in the companyfor which the Adjuster works or provides services. 4) All correspondenceregardingthe claim contained within the claims file, includingbut not limited to; email or other written documentsof any kind or correspondencewith Plaintiff, Plaintiffs counsel, experts, independent adjusters, appraisers, inspectors, and any other third party, or to anyone in the companyfor which the Adjuster works or provides services Shield Law Group ofFlorida, LLC * 15751 SheridanStreet 300, Davie, FL 33331 * Telephone #: 786-496-2223 5) All writings, memoranda, notes, or other materials reflecting examinationof Plaintiff?s dwelling by Defendant or its agents, includingbefore and after the subject date of loss as set forth in the Complaint. 6) All photographsor video depiction of Plaintiffsproperty in the possession of the Defendant or any agent of Defendant, both before and after the date of loss as set forth in the Complaint. 7) All proofs of loss receivedby Defendant from Plaintiffs or any representativeofPlaintiff. 8) All estimates receivedby Defendant from any source for repairs to Plaintiffsresidence. 9) All documents sent to any governmental agenciesrelatedto this claim, and/orthe reason it has not been fully settled or paid. 10) All time sheets or start/stop time indicationsfor site visits at Plaintiff's property. 11) Any documents reflecting any scientific or other authority (e.g., treatises, books, studies, software programs, etc.) relied upon by the Defendant in adjusting the claim or determining any amount Defendant would or would not pay. 12) Any documents that would more fully explain why the Defendant has not paid this claim in the amount requestedby the Plaintiff. 13) Any lists of experts regularlyutilized by the Adjuster with the accompanying information showingthe specific expertise sufficientto properly evaluate the claim, or that is directedby Defendant to Adjuster for any kind of consideration in the selectionof experts. 14) Copies ofall documents evidencing paymentsmade to Plaintiffs relating to this claim, includingthose that simply reference such payments or refusal to pay or any other kind of payment or refusal to pay. 15) A copy of any and all inspection reports of Plaintiff's property. 16) All statements of witnessesrelating to the facts or issues involved in this lawsuit. 17). All reports, studies,memorandums, correspondence, documents, or any other evidence regardingthe results of any tests performed by anyone by or on behalfof the Defendant for any of the allegations by the Defendant. Shield Law Group ofFlorida, LLC * 15751 SheridanStreet 300, Davie, FL 33331 * Telephone #: 786-496-2223 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy has been providedthrough service of process with the Complaint and Summons. RespectfullySubmitted, Shield Law Group of Florida, LLC 15751 Sheridan Street #300 Davie, FL 33331 Telephone: 786-496-2223 By: /s/ Jamie Alvarez, Esq. 0526762 JAMIE ALVAREZ, ESQ. FLA BAR NO.: 0526762 For Service of documents only: Shield Law Group ofFlorida, LLC * 15751 SheridanStreet 300, Davie, FL 33331 * Telephone #: 786-496-2223