Preview
Filing # 117781168 E-Filed 12/07/2020 04:18:13 PM
IN THE CIRCUIT COURT OF THE 15™
JUDICIAL CIRCUIT IN AND FOR PALM BEACH
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
ARCA GROUP INTERNATIONAL,
LTD., and ARCA 21, LLC, CASE NO.: 50-2020-CA-010985-XXXX-MB
DIVISION: AN
Plaintiffs,
vs.
HPI PLUMBING, INC.,
Defendant.
/
DEFENDANT’S REQUEST FOR PRODUCTION TO THE PLAINTIFF
COMES NOW, the Defendant, HPI PLUMBING, INC., by and through its undersigned
attorneys, pursuant to Fla. R. Civ. P. 1.350, requests the Plaintiff, ARCA GROUP
INTERNATIONAL, LTD. to produce at the offices of BUCKNER, SHIFRIN, ETTER, DUGAN
& BRADFUTE, P.A., 169 E. Flagler Street, Suite 1200, Miami, Florida, within thirty days hereof,
the following items for the purpose of inspection and/or copying:
1. Any and all photographs of the damage(s) alleged in this lawsuit in Plaintiffs’
possession.
2. The entire file of any public adjuster, loss consultant or consulting expert retained by
the Plaintiff for the loss that is the subject of this lawsuit, including all notes, drafts,
reports, sketches, and all other information compiled and prepared in the public
adjuster’s adjustment of the loss to your property that is the subject of this lawsuit.
3. Any and all estimates prepared by anyone on your behalf for the damage(s) alleged in
this lawsuit.
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 12/07/2020 04:18:13 PM ***10.
ll.
12.
Any and all estimates prepared on behalf of HPI PLUMBING or any third parties that
were provided to you at any time since the subject claim was reported to HPI
PLUMBING or its insurer.
Any contracts or proposals for contract to repair the damages alleged in this lawsuit.
Any receipts, invoices, payment records, or proof of payment for labor or materials to
repair the damages alleged in this lawsuit.
Any receipts, invoices, payment records, or proof of payment for labor or materials to
Tepair any areas that were allegedly damaged in the subject incident in the last five (5)
years.
. Any and all bills, receipts, invoices, cancelled checks or other evidence of either
charges or payments for services rendered to repair the dwelling damages alleged to
have been the result of the subject incident.
Any and all bills, receipts, invoices, cancelled checks or other evidence of either
charges or payments for services rendered to repair any dwelling damages for the last
five (5) years.
Any and all inventories of damaged contents claimed by the Plaintiff to have been the
result of the subject incident.
All bills, repair estimates, invoices, cancelled checks or any other documentation of
charges or payments made for damages to contents that are alleged to have resulted
from the subject incident, if applicable.
Any and all correspondence between the Defendant and the Plaintiffs (or their agents)
regarding the loss involved in this lawsuit, excluding privileged material.13. All documents prepared or obtained regarding all other claims made on the property by
the Plaintiff within the past five (5) years, excluding privileged material.
14. All documents in your possession which either mention or concern interior water
damages for the alleged damages in this claim.
15. All documents that were used by the Plaintiff in determining the cost of repairs and
replacements for both structural parts of the claim as well as any contents or alternative
living arrangements.
16. Any evidence of mold.
17. A copy of the insured’s current mortgage information, including a current statement
reflecting principal balance.
18. All documents regarding prior (to this claim) property damage claims to the subject
premises.
19. All documents regarding subsequent (to this claim) property damage claims to the
subject premises.
20. Please provide documents indicating the owner of the subject premises where the
alleged incident occurred as of the claimed date of loss of July 24, 2020.
21. Please provide a copy of each and every document in your possession that supports
your claim that Defendant HPI Plumbing performed work in the subject condominium
unit, including but not limited to contracts, proposals, invoices, or other written
documents, including correspondence.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via email to:
Aliette D. Rodz, Esq. and Rochelle A. Hall, Esq., Shutts & Bowen, LLP, 200 S. Biscayne
Boulevard, Suite 4100, Miami, FL 33131, Emails: arodz@shutts.com and rhall@shutts.com, on
this 7" day of December, 2020.
BUCKNER, SHIFRIN, ETTER, DUGAN
& BRADFUTE, P.A.
Counsel for Defendant
Alfred I. Dupont Building, Suite 1200
169 E. Flagler Street
Miami, Florida 33131
Telephone: 305-679-9744
Facsimile: 305-679-9745
Primary: Robert@buckner-shifrin.com
Secondary: Jami@buckner-shifrin.com
By: Robert O. Dugan
ROBERT O. DUGAN
Florida Bar No. 454540
Preview
Filing # 117781168 E-Filed 12/07/2020 04:18:13 PM IN THE CIRCUIT COURT OF THE 15™ JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA GENERAL JURISDICTION DIVISION ARCA GROUP INTERNATIONAL, LTD., and ARCA 21, LLC, CASE NO.: 50-2020-CA-010985-XXXX-MB DIVISION: AN Plaintiffs, vs. HPI PLUMBING, INC., Defendant. / DEFENDANT’S REQUEST FOR PRODUCTION TO THE PLAINTIFF COMES NOW, the Defendant, HPI PLUMBING, INC., by and through its undersigned attorneys, pursuant to Fla. R. Civ. P. 1.350, requests the Plaintiff, ARCA GROUP INTERNATIONAL, LTD. to produce at the offices of BUCKNER, SHIFRIN, ETTER, DUGAN & BRADFUTE, P.A., 169 E. Flagler Street, Suite 1200, Miami, Florida, within thirty days hereof, the following items for the purpose of inspection and/or copying: 1. Any and all photographs of the damage(s) alleged in this lawsuit in Plaintiffs’ possession. 2. The entire file of any public adjuster, loss consultant or consulting expert retained by the Plaintiff for the loss that is the subject of this lawsuit, including all notes, drafts, reports, sketches, and all other information compiled and prepared in the public adjuster’s adjustment of the loss to your property that is the subject of this lawsuit. 3. Any and all estimates prepared by anyone on your behalf for the damage(s) alleged in this lawsuit. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 12/07/2020 04:18:13 PM ***10. ll. 12. Any and all estimates prepared on behalf of HPI PLUMBING or any third parties that were provided to you at any time since the subject claim was reported to HPI PLUMBING or its insurer. Any contracts or proposals for contract to repair the damages alleged in this lawsuit. Any receipts, invoices, payment records, or proof of payment for labor or materials to repair the damages alleged in this lawsuit. Any receipts, invoices, payment records, or proof of payment for labor or materials to Tepair any areas that were allegedly damaged in the subject incident in the last five (5) years. . Any and all bills, receipts, invoices, cancelled checks or other evidence of either charges or payments for services rendered to repair the dwelling damages alleged to have been the result of the subject incident. Any and all bills, receipts, invoices, cancelled checks or other evidence of either charges or payments for services rendered to repair any dwelling damages for the last five (5) years. Any and all inventories of damaged contents claimed by the Plaintiff to have been the result of the subject incident. All bills, repair estimates, invoices, cancelled checks or any other documentation of charges or payments made for damages to contents that are alleged to have resulted from the subject incident, if applicable. Any and all correspondence between the Defendant and the Plaintiffs (or their agents) regarding the loss involved in this lawsuit, excluding privileged material.13. All documents prepared or obtained regarding all other claims made on the property by the Plaintiff within the past five (5) years, excluding privileged material. 14. All documents in your possession which either mention or concern interior water damages for the alleged damages in this claim. 15. All documents that were used by the Plaintiff in determining the cost of repairs and replacements for both structural parts of the claim as well as any contents or alternative living arrangements. 16. Any evidence of mold. 17. A copy of the insured’s current mortgage information, including a current statement reflecting principal balance. 18. All documents regarding prior (to this claim) property damage claims to the subject premises. 19. All documents regarding subsequent (to this claim) property damage claims to the subject premises. 20. Please provide documents indicating the owner of the subject premises where the alleged incident occurred as of the claimed date of loss of July 24, 2020. 21. Please provide a copy of each and every document in your possession that supports your claim that Defendant HPI Plumbing performed work in the subject condominium unit, including but not limited to contracts, proposals, invoices, or other written documents, including correspondence.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via email to: Aliette D. Rodz, Esq. and Rochelle A. Hall, Esq., Shutts & Bowen, LLP, 200 S. Biscayne Boulevard, Suite 4100, Miami, FL 33131, Emails: arodz@shutts.com and rhall@shutts.com, on this 7" day of December, 2020. BUCKNER, SHIFRIN, ETTER, DUGAN & BRADFUTE, P.A. Counsel for Defendant Alfred I. Dupont Building, Suite 1200 169 E. Flagler Street Miami, Florida 33131 Telephone: 305-679-9744 Facsimile: 305-679-9745 Primary: Robert@buckner-shifrin.com Secondary: Jami@buckner-shifrin.com By: Robert O. Dugan ROBERT O. DUGAN Florida Bar No. 454540