Party Discovery: Neil Espendez Plaintiff vs. Universal Property and Casualty Insurance Company Defendant

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                                Filing #   128870259 E-Filed 06/16/2021 01:11:56 PM




                                                                       IN THE CIRCUIT COURT OF THE
                                                                       17TH JUDICIAL CIRCUIT IN AND
                                                                       FOR        BROWARD                      COUNTY,
                                                                       FLORIDA
              NEIL ESPENDEZ,
                                                                       CASE NO:
                       Plaintiff,

              VS.



              UNIVERSAL PROPERTY & CASUALTY
              INSURANCE COMPANY,


                       Defendant.
                                                             i


                        PLAINTIFF'S REQUEST FOR PRODUCTION TO DEFENDANT


                       The Plaintiff, NEIL ESPENDEZ, pursuant to Rule 1.350, Florida Rules of Civil


              Procedure, propounds this Request for Production                     to   Defendant, UNIVERSAL

              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.       Any    and all insurance   policies   ever   issued   by   the Defendant to the Plaintiff,


              including all   declarationpages,   applications, addenda and riders.

              2.       Any and all correspondence between you and Plaintiff                  or   anyone       acting   on   the


              Plaintiff's behalf.


              3.       Any and all correspondence, forms, reports         or   other documents between you and


              any third   party regarding the Plaintiff or Plaintiff's claim.

              4.       Any and all surveillance reports, claims history reports                   or   other   investigative

              reports prepared by you    or on   you behalfwith     regard to the Plaintiff or Plaintiff's claim.




             ***
                   FILED: BROWARD    COUNTY, FL BRENDA D. FORMAN, CLERK 06/16/2021 01:11:53 PM.****
5.        Any and       all written   or   recorded statements of the     Plaintiff,   his/her agents, and/or


representatives.

6.        Any and all         statements taken by the Defendant or any witness with             regards     to any


fact relevant to any fact in this case.


7.        Any and       all   police reports relating to      the Plaintiff's claims which      are   the   subject

of this   litigation.

8.        Any and all photographs and/or video of the                     Plaintiff's property and/or its


contents.


9.        Any   and all       proof of     loss   forms, statements,   notices of claim and/or any other


document submitted by the Plaintiff                 pertaining to   his/her claims that   are   the   subject of

this   litigation.

10.       Any   and all       appraisals, estimates,     or   other documents pertaining to the value of


Plaintiff's claim.


11.           Defendant's entire           underwriting file including,    but not limited to, all 4         point

inspection reports and any and all wind mitigation reports for Plaintiff's residence.




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                                   CERTIFICATE OF SERVICE


       I   hereby certify   that   a   copy of the   foregoing was       served upon the Defendant in


this action   along with the Complaint.
                                                               --




                                                           <        -JR---tl
                                              By:
                                                      JOHN A. SALCEDO
                                                      Florida Bar No: 14665
                                                      THE MINEO SALCEDO LAW FIRM, P.A.

                                                      Attorneys for Plaintiff
                                                      5600 Davie Road
                                                      Davie, FL 33314
                                                      T:   (954) 463-8100
                                                      F:   (954) 463-8106




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