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Filing # 141862200 E-Filed 01/12/2022 02:42:50 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT, IN AND FOR
MIAMI DADE COUNTY, FLORIDA
CASE NO.: 2021-022397-CA-01
PHU TROUNG,
Plaintiff,
v.
CITIZENS PROPERTY INSURANCE
CORPORATION, A FLORIDA
GOVERNMENTAL ENTITY,
Defendant.
___________________________________/
DEFENDANT’S FIRST REQUEST TO PRODUCE TO PLAINTIFF
Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, A FLORIDA
GOVERNMENTAL ENTITY, hereby files this First Request to Produce to Plaintiff, PHU
TROUNG, to produce the following documents for inspection and/or photocopying within thirty
(30) days of receipt of this request at the offices specified below. At the trial of this cause, you
will also be called upon to produce all of the documents requested, plus additional documents
received by you subsequent to your compliance with the above Request to Produce.
1. All documents, photographs, videos or other pictorial representations evidencing
roof damage and interior damage sustained by the Plaintiff from the loss which occurred at 7553
W. 4th Court, Hialeah, FL 33014 (“Loss Location”), that was assigned Defendant’s claim number
001-00-257631 (“Loss”). Please provide a digital copy of the photographs in jpg format.
2. All documents relating to the retention of any individual, company, professional or
service to assist in addressing the damages from the Loss including but not limited to, any
agreement, contract and assignment of benefit with any contractor, remediation service,
emergency repair service, water extraction company, hygienist, roofer and public adjuster.
3. All documents evidencing repairs for damages from the Loss including but not
limited to, estimates for repairs, proposals, bids, quotes, contracts, subcontracts, blueprints,
invoices, reports plans and permits.
4. All documents evidencing expenditures and/or payments by or on behalf of Plaintiff
for repair of the alleged damage sustained at the subject insured property in connection with the
Loss, including but not limited to, paid receipts, canceled checks, cashier checks, credit card
receipts or payments, bank statements and bank withdrawals.
5. Any and all estimates written and/or rendered to Plaintiff by any person, company
or entity to repair any portion of the damage sustained at the insured property as a result of the
Loss.
6. Any and all reports, incident reports, statements or investigative materials obtained
regarding the cause of the Loss.
7. Any and all reports, lab analysis, raw lab data, inspection or testing results from
any industrial hygienist, restoration contractor, mold and mildew specialist regarding any mold
and mildew conditions at the Loss Location.
8. Any and all correspondence to Plaintiff and/or Plaintiff’s representatives from
Defendant and/or its representatives regarding the Loss.
9. Any and all correspondence from Defendant/or Defendant’s representatives to
Plaintiff and/or Plaintiff’s representatives regarding the Loss.
10. All contracts, estimates, invoices, proposals, bids, quotes, statements, receipts,
canceled checks, proof of payment and other documents relating to repairs, remodeling, restoration
or maintenance performed at the insured property or to the structure in the last seven (7) years.
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11. All photographs, videos or other pictorial representations of the areas of the subject
insured property claimed damaged available to Plaintiff, depicting the property condition before
the Loss occurred. Please provide a digital copy of the photographs in jpg format.
12. All policies of insurance under which any claim has been made related to the
alleged damage in the Loss and all correspondence, applications, memoranda, or other documents
relating to the policies of insurance or any claim under the policies of insurance.
13. All documents evidencing expenditures by or on behalf of Plaintiff for repair of the
alleged damage sustained at the Loss Location in connection with any prior losses, including but
not limited to, estimates for repairs, proposals, bids, quotes, contracts, subcontracts, blueprints,
canceled checks for repairs, receipts, invoices, and/or other evidence of payments for such repairs,
reconstruction, modification or restoration of the insured dwelling.
14. All photographs, videos, or other pictorial representations of the areas of the subject
insured property claimed damaged as a result of any prior losses which occurred at the insured
property, available to Plaintiff, depicting the property condition before, during, and after the prior
losses occurred. Please provide a digital copy of the photographs in jpg format.
15. Any and all copies of home inspection reports and/or evaluations performed at any
time since the Plaintiff purchased or acquired an ownership interest in the insured property.
16. Any and all records relating to the inspection, installation, repair, replacement
and/or maintenance of any part of the roof at the insured property, at any time since you purchased
the insured property.
17. Any and all records relating to the renovation, remodeling, inspection, repair,
painting, sealing, and/or maintenance of the interior of the insured property at any time since you
purchased the insured property.
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18. Any and all documents reflecting the name and address of the current mortgagee
on the insured premises. Should any mortgage have been satisfied please provide proof of the
satisfaction.
19. A copy of Plaintiff’s current Mortgage Statement reflecting principal balance.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
to Daniel D. Castro, Esq. using the Florida Courts E-Filing Portal, to
th
dcastro@morganlawgroup.net; and mlg.eservice@morganlawgroup.net; this 12 day of January,
2022.
GROELLE & SALMON, P.A.
Attorneys for Defendant
11301 Okeechobee Blvd., Second Floor
West Palm Beach, FL 33411
(561) 963-5500 / Facsimile: (561) 963-2265
Primary Email: gswcourtdocs@gspalaw.com
Email: cmitchell@gspalaw.com
/s/ Cynthia K. Mitchell
By: ___________________________________
CYNTHIA K. MITCHELL, ESQUIRE
Fla. Bar No.: 571563
40591
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Preview
Filing # 141862200 E-Filed 01/12/2022 02:42:50 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT, IN AND FOR MIAMI DADE COUNTY, FLORIDA CASE NO.: 2021-022397-CA-01 PHU TROUNG, Plaintiff, v. CITIZENS PROPERTY INSURANCE CORPORATION, A FLORIDA GOVERNMENTAL ENTITY, Defendant. ___________________________________/ DEFENDANT’S FIRST REQUEST TO PRODUCE TO PLAINTIFF Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, A FLORIDA GOVERNMENTAL ENTITY, hereby files this First Request to Produce to Plaintiff, PHU TROUNG, to produce the following documents for inspection and/or photocopying within thirty (30) days of receipt of this request at the offices specified below. At the trial of this cause, you will also be called upon to produce all of the documents requested, plus additional documents received by you subsequent to your compliance with the above Request to Produce. 1. All documents, photographs, videos or other pictorial representations evidencing roof damage and interior damage sustained by the Plaintiff from the loss which occurred at 7553 W. 4th Court, Hialeah, FL 33014 (“Loss Location”), that was assigned Defendant’s claim number 001-00-257631 (“Loss”). Please provide a digital copy of the photographs in jpg format. 2. All documents relating to the retention of any individual, company, professional or service to assist in addressing the damages from the Loss including but not limited to, any agreement, contract and assignment of benefit with any contractor, remediation service, emergency repair service, water extraction company, hygienist, roofer and public adjuster. 3. All documents evidencing repairs for damages from the Loss including but not limited to, estimates for repairs, proposals, bids, quotes, contracts, subcontracts, blueprints, invoices, reports plans and permits. 4. All documents evidencing expenditures and/or payments by or on behalf of Plaintiff for repair of the alleged damage sustained at the subject insured property in connection with the Loss, including but not limited to, paid receipts, canceled checks, cashier checks, credit card receipts or payments, bank statements and bank withdrawals. 5. Any and all estimates written and/or rendered to Plaintiff by any person, company or entity to repair any portion of the damage sustained at the insured property as a result of the Loss. 6. Any and all reports, incident reports, statements or investigative materials obtained regarding the cause of the Loss. 7. Any and all reports, lab analysis, raw lab data, inspection or testing results from any industrial hygienist, restoration contractor, mold and mildew specialist regarding any mold and mildew conditions at the Loss Location. 8. Any and all correspondence to Plaintiff and/or Plaintiff’s representatives from Defendant and/or its representatives regarding the Loss. 9. Any and all correspondence from Defendant/or Defendant’s representatives to Plaintiff and/or Plaintiff’s representatives regarding the Loss. 10. All contracts, estimates, invoices, proposals, bids, quotes, statements, receipts, canceled checks, proof of payment and other documents relating to repairs, remodeling, restoration or maintenance performed at the insured property or to the structure in the last seven (7) years. 2 11. All photographs, videos or other pictorial representations of the areas of the subject insured property claimed damaged available to Plaintiff, depicting the property condition before the Loss occurred. Please provide a digital copy of the photographs in jpg format. 12. All policies of insurance under which any claim has been made related to the alleged damage in the Loss and all correspondence, applications, memoranda, or other documents relating to the policies of insurance or any claim under the policies of insurance. 13. All documents evidencing expenditures by or on behalf of Plaintiff for repair of the alleged damage sustained at the Loss Location in connection with any prior losses, including but not limited to, estimates for repairs, proposals, bids, quotes, contracts, subcontracts, blueprints, canceled checks for repairs, receipts, invoices, and/or other evidence of payments for such repairs, reconstruction, modification or restoration of the insured dwelling. 14. All photographs, videos, or other pictorial representations of the areas of the subject insured property claimed damaged as a result of any prior losses which occurred at the insured property, available to Plaintiff, depicting the property condition before, during, and after the prior losses occurred. Please provide a digital copy of the photographs in jpg format. 15. Any and all copies of home inspection reports and/or evaluations performed at any time since the Plaintiff purchased or acquired an ownership interest in the insured property. 16. Any and all records relating to the inspection, installation, repair, replacement and/or maintenance of any part of the roof at the insured property, at any time since you purchased the insured property. 17. Any and all records relating to the renovation, remodeling, inspection, repair, painting, sealing, and/or maintenance of the interior of the insured property at any time since you purchased the insured property. 3 18. Any and all documents reflecting the name and address of the current mortgagee on the insured premises. Should any mortgage have been satisfied please provide proof of the satisfaction. 19. A copy of Plaintiff’s current Mortgage Statement reflecting principal balance. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to Daniel D. Castro, Esq. using the Florida Courts E-Filing Portal, to th dcastro@morganlawgroup.net; and mlg.eservice@morganlawgroup.net; this 12 day of January, 2022. GROELLE & SALMON, P.A. Attorneys for Defendant 11301 Okeechobee Blvd., Second Floor West Palm Beach, FL 33411 (561) 963-5500 / Facsimile: (561) 963-2265 Primary Email: gswcourtdocs@gspalaw.com Email: cmitchell@gspalaw.com /s/ Cynthia K. Mitchell By: ___________________________________ CYNTHIA K. MITCHELL, ESQUIRE Fla. Bar No.: 571563 40591 4