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Filing# 142138484 E-Filed 01/18/2022 11:38:14 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL
CIRCUIT
IN
AND
FOR
BROWARD COUNTY, FLORIDA
MYRTLE DOCTOR AND HOPETON DOCTOR,
CASE NO.: CACE-22-000063
Plaintiffs,
VS.
UNIVERSAL
PROPERTY
&
CASUALTY
INSURANCE COMPANY,
Defendant.
i
REQUEST TO PRODUCE TO PLAINTIFF
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by
and throughundersignedcounsel,pursuant to Rule 1.350,Florida Rules of Civil Procedure,request
Plaintiff(s),
MYRTLE DOCTOR AND HOPETON DOCTOR, to produce for inspection,copying
or photographing,within thirty(30)days,the followingdocuments
1.
Any and all pictures,video and/or any other form of visual recordingin digitalformat of
the items damaged as allegedin Plaintiff's Complaint includingall pictures,videos, and visual
recordingsof the insured property before and after the loss.
2.
Any and all estimates,reports, opinions,correspondence,documentation, records or other
written memorandum from anyone relatingto the property damage allegedlysustained by the
insured property as outlined in Plaintiff's Complaint.
3.
Any and all reports, opinions,correspondence,documentation, records or other written
memorandum from anyone relatingto the causation of Plaintiff's damages alleged in the
Complaint.
4.
All documentation evidencingall communications between you or anyone on your behalf
with any representative
of Defendant, includingbut not limited to, any correspondence,telephone
messages, written memoranda, and notes concerning the loss allegedin the Complaint.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/18/2022 11:38:11 AM.****
5.
Any and all documents relatingto any repairs,
modifications,renovations,or construction
that have been performed on the insured property from the date of purchase to present date,
includingbut not limited to invoices, agreements/contracts,
receipts,photographs, permits,and
certificate of completions.
6.
All estimates and/or repairreceiptsconcerning allegedproperty damage to the insured
property complained of in Plaintiff' s Complaint.
7.
Any and all documents evidencingpermitsobtained relatingto all modifications,repairs
and/or construction that has been performed on the insured property from the date of purchaseto
present date.
8.
Copies of any and all correspondence between Plaintiff(s)
or his/her/their attorneys and
any experts retained to inspect,examine or survey the property to render an opinion as to the cause
of the damage.
9.
Any and all documentation to or from anyone who inspected,reviewed and/or offered an
opinionregardingthe allegeddamage to the insured property.
10. All
documentation indicatingmonies received by Plaintiff from any source, for
reimbursement or payment of property damage to Plaintiff for damages to the insured property
complained of in the Complaint.
11. Copies of any and all bank statements, receipts,credit card statements, electronic payment
confirmations depictingthe purchases of the items of personalproperty Plaintiff(s)
claim as
damaged as a result of the allegeddate of loss at issue.
12. Any documents evidencingall communications between you or anyone on your behalf with
any representativeof Defendant, including but not limited to, any correspondence,telephonic
messages, written memoranda, and notes concerningthe loss.
13. All documents and records relatingto any aspect of any insurance claim submitted to any
insurance company relatingto any loss at the insured property which is subjectof this Complaint.
14. All documents evidencingall communications between you or anyone on your behalfwith
any representativeof Defendant, including but not limited to, any correspondence, telephonic
messages, written memoranda, and notes regardingstates that you took to comply with the policy,
related to the subjectloss allegedin the Complaint.
15. Any and all correspondence, documentation, records, or contracts relatingto the
construction of the insured property and any repairsor modifications performed since the date of
construction.
16. Please provide any and all documents relatingto the Plaintiff's purchase of the insured
property at issue in this lawsuit,includingbut not limited to all information detailing
who the home
was purchased from, the date of purchase,all mortgage companies and mortgage information,
remaining balance of any and all mortgage(s), closing agent, all closing documents, home
inspection,appraisal,and any and all refinance documents.
17. Complete copies of any and all contracts, subcontracts,rental agreements, and any other
agreements between Plaintiff and any other entities or persons relating
to the insured property that
is the subjectof this litigation.
18. Any and all documents evidencing the expenses or costs to Plaintiff for the repairof the
insured property that is the subjectof this litigation.
19. All utility
records for the insured property for one (1)year before the date of loss through
one (1)year after.
20. All documents relatingto the manufacture, purchase,and/or repairof any item you allege
was damaged and for which you seek damages in your Complaint.
21. All documents relating
to any water damage sustained at any time to the property which is
the subjectofthe Complaint.
22. Any and all documents from any Public Adjustingcompany relative to the allegedloss that
is the subjectof this action.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E-
Service
to:
Slava
Borshchukov,
Esq.,
VYACHESLAV BORSHCHUKOV, P.A.,
(service@vb.legal);
on the 18th day of January, 2022.
AttorneyMDefendant
Universal Property& CasualtyCompany
P.O. Box 9388
Fort Lauderdale, Florida 33309
Telephone: (954) 958-3319
Toll-Free: 1-833-658-8594 (JudgesOnly)
Facsimile: (954)958-1262
By-. /sl Sarah Mourer
Sarah Mourer, Esq.
Florida Bar No. 994693
For Service of Court Documents onlv:
Primary:upciceservice02@universalpropertv.com
Secondary jv0504@universalpropertv.com
Tertiary:sm0928@universalpropertv.com
For Scheduling Matters:
jv0504@universalpropertv.com
:Please do not send any inquiriesor scheduling matters to upciceservice@universalpropertv.com
or upciceservice02@universalpropertv.com
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Filing# 142138484 E-Filed 01/18/2022 11:38:14 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA MYRTLE DOCTOR AND HOPETON DOCTOR, CASE NO.: CACE-22-000063 Plaintiffs, VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i REQUEST TO PRODUCE TO PLAINTIFF Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by and throughundersignedcounsel,pursuant to Rule 1.350,Florida Rules of Civil Procedure,request Plaintiff(s), MYRTLE DOCTOR AND HOPETON DOCTOR, to produce for inspection,copying or photographing,within thirty(30)days,the followingdocuments 1. Any and all pictures,video and/or any other form of visual recordingin digitalformat of the items damaged as allegedin Plaintiff's Complaint includingall pictures,videos, and visual recordingsof the insured property before and after the loss. 2. Any and all estimates,reports, opinions,correspondence,documentation, records or other written memorandum from anyone relatingto the property damage allegedlysustained by the insured property as outlined in Plaintiff's Complaint. 3. Any and all reports, opinions,correspondence,documentation, records or other written memorandum from anyone relatingto the causation of Plaintiff's damages alleged in the Complaint. 4. All documentation evidencingall communications between you or anyone on your behalf with any representative of Defendant, includingbut not limited to, any correspondence,telephone messages, written memoranda, and notes concerning the loss allegedin the Complaint. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/18/2022 11:38:11 AM.**** 5. Any and all documents relatingto any repairs, modifications,renovations,or construction that have been performed on the insured property from the date of purchase to present date, includingbut not limited to invoices, agreements/contracts, receipts,photographs, permits,and certificate of completions. 6. All estimates and/or repairreceiptsconcerning allegedproperty damage to the insured property complained of in Plaintiff' s Complaint. 7. Any and all documents evidencingpermitsobtained relatingto all modifications,repairs and/or construction that has been performed on the insured property from the date of purchaseto present date. 8. Copies of any and all correspondence between Plaintiff(s) or his/her/their attorneys and any experts retained to inspect,examine or survey the property to render an opinion as to the cause of the damage. 9. Any and all documentation to or from anyone who inspected,reviewed and/or offered an opinionregardingthe allegeddamage to the insured property. 10. All documentation indicatingmonies received by Plaintiff from any source, for reimbursement or payment of property damage to Plaintiff for damages to the insured property complained of in the Complaint. 11. Copies of any and all bank statements, receipts,credit card statements, electronic payment confirmations depictingthe purchases of the items of personalproperty Plaintiff(s) claim as damaged as a result of the allegeddate of loss at issue. 12. Any documents evidencingall communications between you or anyone on your behalf with any representativeof Defendant, including but not limited to, any correspondence,telephonic messages, written memoranda, and notes concerningthe loss. 13. All documents and records relatingto any aspect of any insurance claim submitted to any insurance company relatingto any loss at the insured property which is subjectof this Complaint. 14. All documents evidencingall communications between you or anyone on your behalfwith any representativeof Defendant, including but not limited to, any correspondence, telephonic messages, written memoranda, and notes regardingstates that you took to comply with the policy, related to the subjectloss allegedin the Complaint. 15. Any and all correspondence, documentation, records, or contracts relatingto the construction of the insured property and any repairsor modifications performed since the date of construction. 16. Please provide any and all documents relatingto the Plaintiff's purchase of the insured property at issue in this lawsuit,includingbut not limited to all information detailing who the home was purchased from, the date of purchase,all mortgage companies and mortgage information, remaining balance of any and all mortgage(s), closing agent, all closing documents, home inspection,appraisal,and any and all refinance documents. 17. Complete copies of any and all contracts, subcontracts,rental agreements, and any other agreements between Plaintiff and any other entities or persons relating to the insured property that is the subjectof this litigation. 18. Any and all documents evidencing the expenses or costs to Plaintiff for the repairof the insured property that is the subjectof this litigation. 19. All utility records for the insured property for one (1)year before the date of loss through one (1)year after. 20. All documents relatingto the manufacture, purchase,and/or repairof any item you allege was damaged and for which you seek damages in your Complaint. 21. All documents relating to any water damage sustained at any time to the property which is the subjectofthe Complaint. 22. Any and all documents from any Public Adjustingcompany relative to the allegedloss that is the subjectof this action. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E- Service to: Slava Borshchukov, Esq., VYACHESLAV BORSHCHUKOV, P.A., (service@vb.legal); on the 18th day of January, 2022. AttorneyMDefendant Universal Property& CasualtyCompany P.O. Box 9388 Fort Lauderdale, Florida 33309 Telephone: (954) 958-3319 Toll-Free: 1-833-658-8594 (JudgesOnly) Facsimile: (954)958-1262 By-. /sl Sarah Mourer Sarah Mourer, Esq. Florida Bar No. 994693 For Service of Court Documents onlv: Primary:upciceservice02@universalpropertv.com Secondary jv0504@universalpropertv.com Tertiary:sm0928@universalpropertv.com For Scheduling Matters: jv0504@universalpropertv.com :Please do not send any inquiriesor scheduling matters to upciceservice@universalpropertv.com or upciceservice02@universalpropertv.com