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Case Number:21-006056-CO Filing # 132454875 E-Filed 08/11/2021 11:42:42 AM IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NUMBER: ANNE MARRA, Plaintiff, ASI PREFERRED INSURANCE CORP. Defendant.     PRODUCE TO DEFENDANT Through the Undersigned Counsel, and under Florida Rules of Civil Procedure 1.350 and 1.280(a), Plaintiff Anne Marra requests that Defendant, ASI Preferred Insurance Corp., furnish copies to Plaintiff at 350 North Lake Destiny Road, Maitland, Florida, 32751, or via E-Mail, within forty-five (45) days of service of the Complaint herein. DEFINITIONS AND INSTRUCTIONS For purposes of this Request for Production, the following terms and definitions are Plaintiff         Anne Marra and their representatives as defined below. Defendant:      ASI Preferred Insurance Corp., whether by that name or any other, and its representatives as defined below. Representatives: The term "representatives" shall mean any and all present or former partners, agents, employees, servants, officers, directors, attorneys, consultants, sureties, indemnificators, insurers, independent contractors and other persons acting or purporting to act on behalf of the entity referred to. You and Your: The terms "you" and "your" shall refer to Defendant (defined above) and any other person or entity acting or purporting to act on its behalf. Document: The term "document" shall mean any written, printed, typed or other graphic or photographic matter (including without limitation, photographs, charts, graphs, microfiche, microfilm, videotapes, recordings and motion pictures and data stored on a computer disc or computer hard drive) and shall include the originals, identical copies and all non-identical copies, whether different from the original by reason of any notation made on each copy or otherwise and shall include, without limiting the generality of the foregoing, all letters, telegrams, teletypes, correspondence, contracts, agreements, notes, mechanical and electronic sound recordings and transcripts thereof (including, without limitation, tapes, cassettes and discs), computer records, computer printouts, other printed matter produced through computers, calendar and diary entries, memoranda, notes and records of all telephone or personal conversations, meetings and other communication, inter-office and intra-office communications, statements, manuals, summaries and compilations, minutes of meetings, charges, maps, reports, analysis, studies, graphs, prospectus, returns, statistics, pamphlets, books, offers, bulletins, order papers, articles, catalogs, records, tables, books of account, ledgers, vouchers, canceled checks, invoices, bills, receipts, tickets, worksheets and all drafts, alterations, modifications and changes to any of the foregoing, as well as all digitally stored and generated documents and notes. Communication: The term "communication" as used herein shall mean any contact between or among the parties indicated, including but not limited to, all documents (defined above), telephone or personal conversations, meetings, e-mails or electronic contacts, conferences and discussions. Once identified, a communication may be subsequently identified by use of a common description. Identify              State the full name of the person; State the full name of the last known employer of the person; State the last known occupation or title of the person with such employer; State the last known business telephone number of the person; State the last known home address of the person; and State the last known home telephone number of the person. Once identified, a person may be subsequently identified by uniform use of a standard name. 8. Identify              State a complete description of the document; Identify the person who prepared the document; State the date on which the document was prepared; State the location at which the document was prepared; and Identify the person who presently has care, custody and control of the document. Once identified, a document may be subsequently identified by uniform use of a standard description. 9. Person              an entity and shall be construed to include groups of natural persons. Instructions Should Defendant object to a Request to Produce or not respond pursuant to a claim of privilege, the Defendant is required to: State the basis of the claim of privilege; Identify the subject matter of the information to which a claim of privilege is made; Identify all persons or entities who have had access to or claimed to be privileged or were present when the privileged information was discussed, and Identify of all persons or entities to which the privileged information has been REMAINDER OF PAGE INTENTIONALLY LEFT BLANK      A true and correct copy of all DEC pages and the full and complete insurance policy(s)              Defendant attesting to the coverage and authenticity of the policy. RESPONSE: A copy of any and all other DEC pages and insurance policy(s) which may provide            RESPONSE: A copy of each and every document (defined above) which you reasonably anticipate may be introduced into evidence at the trial of this matter. RESPONSE: A copy of any and all documents which you allege may support any affirmative defense which you have raised in this matter. RESPONSE: A copy of any and all documents which you allege may support any Motion to Dismiss which you have filed in this matter. RESPONSE: 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. RESPONSE: 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 any insured or their representatives (defined above) which are in your possession or control. RESPONSE: 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 which are in your possession or control. RESPONSE: Each and every document, report, chart, graph, object, summary, compilation of data or other thing relied upon by any of your experts, in whole or in part, in the formulation of any opinions and conclusion in this case. RESPONSE:          668 Bayfront Terrace Sebastian FL 32958 which are in your possession or control. RESPONSE:              668 Bayfront Terrace Sebastian FL 32958 which are in your possession or control. RESPONSE: Copies of any photogra          668 Bayfront Terrace Sebastian FL 32958 which are in your possession or control. RESPONSE: Copies of any and all estimates and damage appraisals and other documents (defined above) referencin        Bayfront Terrace Sebastian FL 32958 which are in your possession or control. RESPONSE: Copies of any and all documents (defined above) upon which you based any denials of coverage for t      RESPONSE: Copies of any and all documents (defined above) upon which you based any denials of all or part of the amount of loss claimed by Plaintiff. RESPONSE: If there are any denials of insurance coverage being made by Defendant, then copies are requested of any and all applications for insurance, insurance forms, data sheets, correspondence, notices, facsimile, e-mails and other documents (defined above) which reference in any way any the insurance policy at issue in this matter. RESPONSE: Copies of any and all correspondence, facsimile, notices, e-mails and other documents (defined above) which reference in any way any notices which you provided to Plaintiff regarding cancellation of the insurance policy at issue in this matter. RESPONSE: Copies of all PORS, Proof of Mailing and other documents (defined above) which reflect in any way mailings made by you to Plaintiff regarding cancellation of the policy of insurance at issue in this matter. RESPONSE: All reports and current curriculum vitae from any expert(s) retained by you for any     RESPONSE: Any and all e-mails, letters, facsimile, and other correspondence regarding any claims made by Plaint          wind event on the date of loss in the Complaint, including but not limited to, correspondence with experts, independent adjusters, appraisers, inspectors, and any other third party. RESPONSE: All documents reflecting any payment made to any person (defined above) or entity for any reason as a result of the wind      RESPONSE:             amount to pay or deny regarding the claim at issue. RESPONSE:            Property by Defendant or its agents. RESPONSE: All proofs of loss received by Defendant from Plaintiff. RESPONSE:              RESPONSE:                   RESPONSE: Any training manuals, guides and documents which Defendant has provided to its adjusters regarding adjusting wind damage claims from the past three years to the present. RESPONSE: Copies of any peer reviews, estimates, or comparative estimates generated by anyone on          RESPONSE: All documents showing the total amount paid during the past three years to any third        s claim. RESPONSE: A copy of the contract/agreement/document (if any) that Defendant has with anyone, including but not limited to contractors, engineers, adjusters, or experts, who may provide testimony at the trial of this matter. RESPONSE: A copy of each resume, curriculum vitae, and other document listing the qualifications of each and every expert and/or consultant hired by your of on behalf of your who may testify at trial. RESPONSE: All documents that relate to the drafting, meaning, and interpretation of any language, terms, or provisions, used in the policy at issue. RESPONSE: Pursuant to Fla. R. Civ. P. 1.310(b)(6), please produce three (3) alternative dates for deposition to occur no earlier than 30 days but no farther than 120 days from service for the deposition of the corporate representative(s) with the most knowledge of the claim                        loss. A designation of the information upon which such examination will proceed will be provided under separate cover. RESPONSE: Copies of any and all notices sent by you or your representatives (defined above) to any insured 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 any insured regarding the same. RESPONSE: CERTIFICATE OF SERVICE I DO HEREBY CERTIFY that a true and correct copy of this document will be served on the Defendant along with the Summons in this action. Date: August 11, 2021 /s/Angela Wood COHEN LAW GROUP Angela Wood, Esq. Florida Bar Number: 108922 FOR THE FIRM 350 North Lake Destiny Road Maitland, Florida 32751 Phone: (407) 478-4878 Fax:(407) 478-0204 Primary: awood@itsaboutjustice.law Secondary: alexus@itsaboutjustice.law