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Filing # 118391276 E-Filed 12/17/2020 01:51:35 PM
IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
CASE NO.:
MERCEDES ESPINO,
FLORIDA BAR NO.: 127612
Plaintiff,
v.
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
_________________________________/
PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT
COMES NOW, the Plaintiff, MERCEDES ESPINO, by and through undersigned
counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby requests the
Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, produce legible copies
of the following documents to the Plaintiff within forty (45) days after service of this
request:
1. A true and correct certified copy of the applicable insurance policy issued by
Defendant to Plaintiff, including any and all endorsements in effect at the time of the
subject loss.
2. Any and all time sheets, logs and/or other documents reflecting the time spent by
Defendant and/or it’s agents at the Plaintiff’s property after notification of the subject
loss.
3. Any and all statements, whether written, oral or recorded, taken of the Plaintiff(s)
and/or their agents, servants, employees, etc., in regards to the subject matter of
Page 1 of 3
this litigation.
4. Any and all statements, whether written, oral or recorded, taken of non-parties in
regards to the subject matter of this litigation.
5. Any and all invoices and bills reflecting payments made by the Plaintiff with regards
to premiums for the subject policy issued by Defendant.
6. Any and all correspondence or other written communication from Defendant to
Plaintiff or Plaintiff’s representatives, relating in any manner to the subject loss.
7. Any and all correspondence or other written communication from Plaintiff or
Plaintiff’s representatives, relating in any manner to the subject loss prior to the
institution of this litigation.
8. Any and all photographs, videos and/or drawings made by Defendant or it’s agents
and/or representatives of the Plaintiff’s property which is the subject matter of this
litigation.
9. A copy of the entire underwriting file for the subject policy of insurance.
10. A copy of the entire claim file, including any table of contents, computer notations,
summaries, for the subject loss, excluding any documents to which a privilege claim
may exist. Please provide a ‘Privilege Log’ detailing any such documents that are
being withheld and the basis for the privilege.
11. Any and all policies, rules, regulations, memorandums, guidelines and/or procedure
manuals regarding Defendant’s process for investigating, evaluating and/or settling
of homeowner claims.
12. Any and all manuals, instructions and/or other materials relied upon by Defendant
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in the training of adjusters and/or appraisers regarding homeowner claims.
13. Any and all estimates prepared by Defendant and/or it’s agents and/or
representatives regarding the subject claim of the Plaintiff.
14. Any and all reports and/or other documents prepared by experts retained in this
matter on behalf of the Defendant.
15. A copy of any and all reports by any general contractor, engineer, roofer, electrician
or other construction personnel hired by Defendant to examine and/or evaluate any
aspect of the Plaintiff’s subject claim.
16. Copies of any and all drafts issued by Defendant to the Plaintiff for payment of any
aspect of the Plaintiff’s subject claim.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served
attached with the Original Summons and Complaint
Thomas J. Morgan, Jr., Esquire
MORGAN LAW GROUP, P.A.
Attorneys for Plaintiffs
55 Merrick Way, Suite 404
Coral Gables, Florida 33134
Phone: 305.569.9900
Fax : 305.443.6828
By: /s/ Thomas J. Morgan
Thomas J. Morgan, Jr.
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Filing # 118391276 E-Filed 12/17/2020 01:51:35 PM IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION CASE NO.: MERCEDES ESPINO, FLORIDA BAR NO.: 127612 Plaintiff, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. _________________________________/ PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT COMES NOW, the Plaintiff, MERCEDES ESPINO, by and through undersigned counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby requests the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, produce legible copies of the following documents to the Plaintiff within forty (45) days after service of this request: 1. A true and correct certified copy of the applicable insurance policy issued by Defendant to Plaintiff, including any and all endorsements in effect at the time of the subject loss. 2. Any and all time sheets, logs and/or other documents reflecting the time spent by Defendant and/or it’s agents at the Plaintiff’s property after notification of the subject loss. 3. Any and all statements, whether written, oral or recorded, taken of the Plaintiff(s) and/or their agents, servants, employees, etc., in regards to the subject matter of Page 1 of 3 this litigation. 4. Any and all statements, whether written, oral or recorded, taken of non-parties in regards to the subject matter of this litigation. 5. Any and all invoices and bills reflecting payments made by the Plaintiff with regards to premiums for the subject policy issued by Defendant. 6. Any and all correspondence or other written communication from Defendant to Plaintiff or Plaintiff’s representatives, relating in any manner to the subject loss. 7. Any and all correspondence or other written communication from Plaintiff or Plaintiff’s representatives, relating in any manner to the subject loss prior to the institution of this litigation. 8. Any and all photographs, videos and/or drawings made by Defendant or it’s agents and/or representatives of the Plaintiff’s property which is the subject matter of this litigation. 9. A copy of the entire underwriting file for the subject policy of insurance. 10. A copy of the entire claim file, including any table of contents, computer notations, summaries, for the subject loss, excluding any documents to which a privilege claim may exist. Please provide a ‘Privilege Log’ detailing any such documents that are being withheld and the basis for the privilege. 11. Any and all policies, rules, regulations, memorandums, guidelines and/or procedure manuals regarding Defendant’s process for investigating, evaluating and/or settling of homeowner claims. 12. Any and all manuals, instructions and/or other materials relied upon by Defendant Page 2 of 3 in the training of adjusters and/or appraisers regarding homeowner claims. 13. Any and all estimates prepared by Defendant and/or it’s agents and/or representatives regarding the subject claim of the Plaintiff. 14. Any and all reports and/or other documents prepared by experts retained in this matter on behalf of the Defendant. 15. A copy of any and all reports by any general contractor, engineer, roofer, electrician or other construction personnel hired by Defendant to examine and/or evaluate any aspect of the Plaintiff’s subject claim. 16. Copies of any and all drafts issued by Defendant to the Plaintiff for payment of any aspect of the Plaintiff’s subject claim. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served attached with the Original Summons and Complaint Thomas J. Morgan, Jr., Esquire MORGAN LAW GROUP, P.A. Attorneys for Plaintiffs 55 Merrick Way, Suite 404 Coral Gables, Florida 33134 Phone: 305.569.9900 Fax : 305.443.6828 By: /s/ Thomas J. Morgan Thomas J. Morgan, Jr. Page 3 of 3