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Filing # 134825007 E-Filed 09/17/2021 03:24:50 PM
IN THE CIRCUIT COURT OF THE 171TH
JUDICIAL
CIRCUIT
IN
AND
FOR
BROWARD COUNTY, FLORIDA
NATACHA BEAUFILS,
Plaintiff,
CASE No: CACE-21-007700
V
CITIZEMS PROPERTY INSURANCE
CORPORATION,
Defendant.
I
PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION
Plaintiff, NATACHA BEAUFILS, (the "Plaintiff'), by and through her undersigned
counsel, in accordance with the Florida Rules of Civil Procedure, hereby files this Response to
Defendant's Request for Production, and in response thereto, states as follows:
RESPONSES TO REQUEST FOR PRODUCTION
1. All documents evidencing, referring or relating in any way to the facts, acts, omissions, events,
or matters alleged in Plaintiff's complaint.
RESPONSE: Please refer to all documents attached hereto.
2. All documentsupon which you intend to rely to establishyour claim for damages.
RESPONSE: Please refer to all documents attached hereto.
3. Copies of each and every exhibit which you expect to introduce at trial or which relates to or
illustratesyour testimony at trial.
RESPONSE: None in Plaintiff's possession, custody, or control at this time.
4. Any and all correspondence, letters, or other writings sent by you or any of your agents or
representatives to Defendant or any of its agents or representatives in relationto the claim that is
the subject ofthis case.
RESPONSE: Please refer to all correspondenceattached hereto.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/17/2021 03:24:49 PM.****
5. Any and all written communicationbetween the Plaintiff and any third party concerning the
processing, acceptance, or denial by Defendant, of any portion of the claim that is the subject of
this case.
RESPONSE: Please refer to all communications attached hereto.
6. Any and all materials, papers, documents,photographs or tangiblethings ofany typereliedupon
by the Plaintiff, other than the insurance policy, as a basis for making the claim that is the subject
of this case.
RESPONSE: Please refer to all documents attached hereto.
7. Any and all pictures and videos of all portions of your property that you allege were damage,
taken before 1 1/07/2020 showing the property that you allege was damaged and that is the subject
of this case.
RESPONSE: None in Plaintiff's possession, custody, or control.
8. Any and all pictures and videos taken on or about 1 1/07/2020 showing the property that you
allege was damaged and that is the subject ofthis case.
RESPONSE: Please refer to all photographs attached hereto.
9. Any and all pictures and videos taken after 1 1/07/2020 showing the property that you allege
was damaged and that is the subject ofthis case.
RESPONSE: Please refer to all photographs attached hereto.
10. Any and all photographs taken by anyone, including but not limited to you and your public
adjuster, as a result of, in connection with, or in any way related to the that is the subject of this
case.
RESPONSE: Please refer to all photographs attached hereto.
11. Any and all audio, video, or audio/video recordings taken by anyone, including but not limited
to you and your public adjuster, as a result of, in connection with, or in any way related to the
claim that is the subject ofthis case.
RESPONSE: None in Plaintiff's possession, custody, or control.
12. Damage investigation summariesrelating to, or regarding the claim that is the subject of this
case.
RESPONSE: Please refer to all estimates attached hereto.
13. Copies of any and all estimates to repair or replace the alleged damage to real property and
personal propertythat you allege is covered under each of the insurance policy that is the subject
of Plaintiff's Complaint in relationto the claim that is the subject ofthis case.
RESPONSE: Please refer to all estimates attached hereto.
14. Copies ofany and all estimatesfor additional living expenseand debris removal thatyou allege
is covered under the insurance policies that are the subject of Plaintiff's Complaint
RESPONSE: None in Plaintiff's possession, custody, or control at this time.
15. Copies of any and all documents that show payments made by the Plaintiff(s) to any third
party, in relation to the claim that is the subjectofthis case.
RESPONSE: None in Plaintiff's possession, custody, or control.
16. Any and all statements, affidavits or declarationin Plaintiff's possession, custody, or control
regarding the claim that is the subject ofthis case.
RESPONSE: None in Plaintiff's possession, custody, or control.
17. Any materials, documents or tangible things you contend were provided to the Defendant by
the Plaintiff or its agents following the notice of loss in the claim that is the subject ofthis case.
RESPONSE: Please refer to all documents attached hereto.
18. All appraisals of loss or value of loss prepared by, for, or on behalfof the Plaintiff regarding
the subject losses of the Plaintiffin relationto the claim that is the subject ofthis case.
RESPONSE: None in Plaintiff's possession, custody, or control.
19. All estimates or proposals for repair, replacement,renovation, improvement, or construction
on the property during the five (5) years preceding the filing of this lawsuit.
RESPONSE: Please refer to all estimates attached hereto.
20. All contracts for repair, replacement,renovation,improvement,or constructionon the property
during the five (5) years preceding the filing of this lawsuit.
RESPONSE: None in Plaintiff's possession, custody, or control.
21. All invoices for repair, replacement,renovation, improvement, or constructionon the property
during the five (5) years preceding the filing of this lawsuit.
RESPONSE: None in Plaintiff's possession, custody, or control.
22. All permits for repair, replacement,renovation, improvement, or construction on the property
during the five (5) years preceding the filing of this lawsuit.
RESPONSE: None in Plaintiff's possession, custody, or control.
23. Copies of any diagrams, models, drawings, sketches, blueprints or any other reproductionof
the property that were made during the five (5) years preceding the filing of this lawsuit.
RESPONSE: None in Plaintiff's possession, custody, or control.
24. All estimates or proposals received by the Plaintiff(s) on or after 1 1/07/2020 for repair,
replacement, renovation, improvement, or constructionto the property.
RESPONSE: Please refer to all estimates attached hereto.
25. All contracts relating to repair, replacement,renovation, improvement, or constructionon the
property after 1 1/07/2020.
RESPONSE: None in Plaintiff's possession, custody, or control.
26. All invoices received by the Plaintiff(s) on or after 1 1/07/2020 for repair, replacement,
renovation,improvement, or constructionon the property.
RESPONSE: None in Plaintiff's possession, custody, or control.
27. All permits applied for on or after 1 1/07/2020 for repair, replacement, renovation,
improvement, or constructionon the property.
RESPONSE: None in Plaintiff's possession, custody, or control.
28. Copies of any diagrams, models, drawings, sketches, blueprints or any other reproductionof
the property that was made on or after 1 1/07/2020.
RESPONSE: Please refer to all estimates attached hereto.
29. Copies of any and all Proofs of Loss forms with supporting documents, regardlessof whether
the forms were sent to the Defendant or not.
RESPONSE: Please refer to all Proof of Loss documents attached hereto.
30. All investigative reports concerning the Plaintiff's claim and all written communications
between the Plaintiffand any third party concerning said report or reports.
RESPONSE: Please refer to all documents attached hereto.
31. A copy of each check for payments made by the Plaintiff in relation to the claims that is the
subject ofthis case.
RESPONSE: None in Plaintiff's possession, custody, or control.
32. Any document showing or explaining what items the Plaintiff has made payment for, the
amount of payment and how the payment amount was determined.
RESPONSE: None in Plaintiff's possession, custody, or control.
33. A copy ofthe inspection report that the Plaintiff obtained before closing on the Property.
RESPONSE: Please refer to all reports attached hereto.
34. Any and all documentsthat the Plaintiff, or Plaintiff's agent(s), submitted to the Defendant to
report the loss.
RESPONSE: Please refer to all documents attached hereto.
35. Any and all documents evincing the identity, qualifications, and/or opinions of any expert
retained by you or your counsel to provide testimony in this action.
RESPONSE: Plaintiff has yet to retain an expert witness. As such, none in Plaintiff's
possession, custody, or control at this time.
36. Any and all documents constituting,evincing,or relatingto the opinions of any expert retained
by you or your counsel to provide testimony in this action, including, but not limited to, expert
reports.
RESPONSE: Plaintiff has yet to retain an expert witness. As such, none in Plaintiff's
possession, custody, or control at this time.
37. All expert reports, including but not limited to diagrams, photographs,notes, memoranda, field
notes, samples, contracts, video tapes, correspondence, calculations, rough drafts, partial drafts,
and laboratoryreports related in any way to the facts ofthis claim or litigation.
RESPONSE: Plaintiff has yet to retain an expert witness. As such, none in Plaintiff's
possession, custody, or control at this time.
38. Copy of all documentssubmittedby the Plaintiff(s), or its agents, during the last ten (10) years
in relation to other insurance claim(s) regarding this property.
RESPONSE: None.
39. Copy of all photographs taken by the Plaintiff(s), or its agents, during the last ten (10) years in
relation to other insurance claim(s) regarding this property.
RESPONSE: None.
40. Copy of all estimates obtainedby the Plaintiff(s) during the last ten (10) years in relation to
other insurance claim(s) regarding this property.
RESPONSE: None.
41. Copy of all paymentsreceived by the Plaintiff(s), or its agents, from any insurance carrier in
relation to other insurance claim(s) regarding this property.
RESPONSE: None.
42. Any and all document showing or explaining what items the Plaintiff(s)received payment for,
the amount of payment and how the payment amount was determined.
RESPONSE: None.
43. Any and all documentsshowing or explaining how the Plaintiff(s)used the money received in
relationto all property insurance claim(s) submitted during the past ten (10) years.
RESPONSE: None.
44. Any report, document, or analysis of the value and/or structural integrity of the property
prepared in the last 10 years.
RESPONSE: Please refer to all reports attached hereto.
45. Copies of the last two statements for every mortgage currently encumbering the subject
property.
RESPONSE: None in Plaintiff's possession, custody, or control at this time.
46. Any and all documentswhich you intend to use at trial for any purpose.
RESPONSE: Please refer to all documents attached hereto.
47. All documents identified or relied upon in your answers to interrogatories propounded by
Citizens Property Insurance Corporation and served contemporaneouslywith this request.
RESPONSE: Please refer to all documents attached hereto.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy ofthe foregoing has been sent via email
to:
mroche@mmlawpa.comon this 17I,th day of September,
2021.
VARGAS GONZALEZ
HEVIA BALDWIN, LLP
815 Ponce de Leon Blvd, 3rd Floor
Miami, Florida 33134
Tel: 305.631.2528
Fax: 305.631.2741
E-mail:
Service e-mail: Servicel
By:
/s/ Eduardo Ochoa, Esq.
Eduardo Ochoa, Esq.
Fla. Bar No.: 1025044
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Filing # 134825007 E-Filed 09/17/2021 03:24:50 PM IN THE CIRCUIT COURT OF THE 171TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA NATACHA BEAUFILS, Plaintiff, CASE No: CACE-21-007700 V CITIZEMS PROPERTY INSURANCE CORPORATION, Defendant. I PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION Plaintiff, NATACHA BEAUFILS, (the "Plaintiff'), by and through her undersigned counsel, in accordance with the Florida Rules of Civil Procedure, hereby files this Response to Defendant's Request for Production, and in response thereto, states as follows: RESPONSES TO REQUEST FOR PRODUCTION 1. All documents evidencing, referring or relating in any way to the facts, acts, omissions, events, or matters alleged in Plaintiff's complaint. RESPONSE: Please refer to all documents attached hereto. 2. All documentsupon which you intend to rely to establishyour claim for damages. RESPONSE: Please refer to all documents attached hereto. 3. Copies of each and every exhibit which you expect to introduce at trial or which relates to or illustratesyour testimony at trial. RESPONSE: None in Plaintiff's possession, custody, or control at this time. 4. Any and all correspondence, letters, or other writings sent by you or any of your agents or representatives to Defendant or any of its agents or representatives in relationto the claim that is the subject ofthis case. RESPONSE: Please refer to all correspondenceattached hereto. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/17/2021 03:24:49 PM.**** 5. Any and all written communicationbetween the Plaintiff and any third party concerning the processing, acceptance, or denial by Defendant, of any portion of the claim that is the subject of this case. RESPONSE: Please refer to all communications attached hereto. 6. Any and all materials, papers, documents,photographs or tangiblethings ofany typereliedupon by the Plaintiff, other than the insurance policy, as a basis for making the claim that is the subject of this case. RESPONSE: Please refer to all documents attached hereto. 7. Any and all pictures and videos of all portions of your property that you allege were damage, taken before 1 1/07/2020 showing the property that you allege was damaged and that is the subject of this case. RESPONSE: None in Plaintiff's possession, custody, or control. 8. Any and all pictures and videos taken on or about 1 1/07/2020 showing the property that you allege was damaged and that is the subject ofthis case. RESPONSE: Please refer to all photographs attached hereto. 9. Any and all pictures and videos taken after 1 1/07/2020 showing the property that you allege was damaged and that is the subject ofthis case. RESPONSE: Please refer to all photographs attached hereto. 10. Any and all photographs taken by anyone, including but not limited to you and your public adjuster, as a result of, in connection with, or in any way related to the that is the subject of this case. RESPONSE: Please refer to all photographs attached hereto. 11. Any and all audio, video, or audio/video recordings taken by anyone, including but not limited to you and your public adjuster, as a result of, in connection with, or in any way related to the claim that is the subject ofthis case. RESPONSE: None in Plaintiff's possession, custody, or control. 12. Damage investigation summariesrelating to, or regarding the claim that is the subject of this case. RESPONSE: Please refer to all estimates attached hereto. 13. Copies of any and all estimates to repair or replace the alleged damage to real property and personal propertythat you allege is covered under each of the insurance policy that is the subject of Plaintiff's Complaint in relationto the claim that is the subject ofthis case. RESPONSE: Please refer to all estimates attached hereto. 14. Copies ofany and all estimatesfor additional living expenseand debris removal thatyou allege is covered under the insurance policies that are the subject of Plaintiff's Complaint RESPONSE: None in Plaintiff's possession, custody, or control at this time. 15. Copies of any and all documents that show payments made by the Plaintiff(s) to any third party, in relation to the claim that is the subjectofthis case. RESPONSE: None in Plaintiff's possession, custody, or control. 16. Any and all statements, affidavits or declarationin Plaintiff's possession, custody, or control regarding the claim that is the subject ofthis case. RESPONSE: None in Plaintiff's possession, custody, or control. 17. Any materials, documents or tangible things you contend were provided to the Defendant by the Plaintiff or its agents following the notice of loss in the claim that is the subject ofthis case. RESPONSE: Please refer to all documents attached hereto. 18. All appraisals of loss or value of loss prepared by, for, or on behalfof the Plaintiff regarding the subject losses of the Plaintiffin relationto the claim that is the subject ofthis case. RESPONSE: None in Plaintiff's possession, custody, or control. 19. All estimates or proposals for repair, replacement,renovation, improvement, or construction on the property during the five (5) years preceding the filing of this lawsuit. RESPONSE: Please refer to all estimates attached hereto. 20. All contracts for repair, replacement,renovation,improvement,or constructionon the property during the five (5) years preceding the filing of this lawsuit. RESPONSE: None in Plaintiff's possession, custody, or control. 21. All invoices for repair, replacement,renovation, improvement, or constructionon the property during the five (5) years preceding the filing of this lawsuit. RESPONSE: None in Plaintiff's possession, custody, or control. 22. All permits for repair, replacement,renovation, improvement, or construction on the property during the five (5) years preceding the filing of this lawsuit. RESPONSE: None in Plaintiff's possession, custody, or control. 23. Copies of any diagrams, models, drawings, sketches, blueprints or any other reproductionof the property that were made during the five (5) years preceding the filing of this lawsuit. RESPONSE: None in Plaintiff's possession, custody, or control. 24. All estimates or proposals received by the Plaintiff(s) on or after 1 1/07/2020 for repair, replacement, renovation, improvement, or constructionto the property. RESPONSE: Please refer to all estimates attached hereto. 25. All contracts relating to repair, replacement,renovation, improvement, or constructionon the property after 1 1/07/2020. RESPONSE: None in Plaintiff's possession, custody, or control. 26. All invoices received by the Plaintiff(s) on or after 1 1/07/2020 for repair, replacement, renovation,improvement, or constructionon the property. RESPONSE: None in Plaintiff's possession, custody, or control. 27. All permits applied for on or after 1 1/07/2020 for repair, replacement, renovation, improvement, or constructionon the property. RESPONSE: None in Plaintiff's possession, custody, or control. 28. Copies of any diagrams, models, drawings, sketches, blueprints or any other reproductionof the property that was made on or after 1 1/07/2020. RESPONSE: Please refer to all estimates attached hereto. 29. Copies of any and all Proofs of Loss forms with supporting documents, regardlessof whether the forms were sent to the Defendant or not. RESPONSE: Please refer to all Proof of Loss documents attached hereto. 30. All investigative reports concerning the Plaintiff's claim and all written communications between the Plaintiffand any third party concerning said report or reports. RESPONSE: Please refer to all documents attached hereto. 31. A copy of each check for payments made by the Plaintiff in relation to the claims that is the subject ofthis case. RESPONSE: None in Plaintiff's possession, custody, or control. 32. Any document showing or explaining what items the Plaintiff has made payment for, the amount of payment and how the payment amount was determined. RESPONSE: None in Plaintiff's possession, custody, or control. 33. A copy ofthe inspection report that the Plaintiff obtained before closing on the Property. RESPONSE: Please refer to all reports attached hereto. 34. Any and all documentsthat the Plaintiff, or Plaintiff's agent(s), submitted to the Defendant to report the loss. RESPONSE: Please refer to all documents attached hereto. 35. Any and all documents evincing the identity, qualifications, and/or opinions of any expert retained by you or your counsel to provide testimony in this action. RESPONSE: Plaintiff has yet to retain an expert witness. As such, none in Plaintiff's possession, custody, or control at this time. 36. Any and all documents constituting,evincing,or relatingto the opinions of any expert retained by you or your counsel to provide testimony in this action, including, but not limited to, expert reports. RESPONSE: Plaintiff has yet to retain an expert witness. As such, none in Plaintiff's possession, custody, or control at this time. 37. All expert reports, including but not limited to diagrams, photographs,notes, memoranda, field notes, samples, contracts, video tapes, correspondence, calculations, rough drafts, partial drafts, and laboratoryreports related in any way to the facts ofthis claim or litigation. RESPONSE: Plaintiff has yet to retain an expert witness. As such, none in Plaintiff's possession, custody, or control at this time. 38. Copy of all documentssubmittedby the Plaintiff(s), or its agents, during the last ten (10) years in relation to other insurance claim(s) regarding this property. RESPONSE: None. 39. Copy of all photographs taken by the Plaintiff(s), or its agents, during the last ten (10) years in relation to other insurance claim(s) regarding this property. RESPONSE: None. 40. Copy of all estimates obtainedby the Plaintiff(s) during the last ten (10) years in relation to other insurance claim(s) regarding this property. RESPONSE: None. 41. Copy of all paymentsreceived by the Plaintiff(s), or its agents, from any insurance carrier in relation to other insurance claim(s) regarding this property. RESPONSE: None. 42. Any and all document showing or explaining what items the Plaintiff(s)received payment for, the amount of payment and how the payment amount was determined. RESPONSE: None. 43. Any and all documentsshowing or explaining how the Plaintiff(s)used the money received in relationto all property insurance claim(s) submitted during the past ten (10) years. RESPONSE: None. 44. Any report, document, or analysis of the value and/or structural integrity of the property prepared in the last 10 years. RESPONSE: Please refer to all reports attached hereto. 45. Copies of the last two statements for every mortgage currently encumbering the subject property. RESPONSE: None in Plaintiff's possession, custody, or control at this time. 46. Any and all documentswhich you intend to use at trial for any purpose. RESPONSE: Please refer to all documents attached hereto. 47. All documents identified or relied upon in your answers to interrogatories propounded by Citizens Property Insurance Corporation and served contemporaneouslywith this request. RESPONSE: Please refer to all documents attached hereto. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy ofthe foregoing has been sent via email to: mroche@mmlawpa.comon this 17I,th day of September, 2021. VARGAS GONZALEZ HEVIA BALDWIN, LLP 815 Ponce de Leon Blvd, 3rd Floor Miami, Florida 33134 Tel: 305.631.2528 Fax: 305.631.2741 E-mail: Service e-mail: Servicel By: /s/ Eduardo Ochoa, Esq. Eduardo Ochoa, Esq. Fla. Bar No.: 1025044