Party Discovery: SMITH, JAMES R vs. SECURITY FIRST INSURANCE COMPANY

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                                Filing # 101333595 E-Filed 01/08/2020 03:12:29 PM

IN THE CIRCUIT COURT OF THE 14"
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
CASE NUMBER: 2019-004406-CA
JAMES R. SMITH,
Plaintiff,
VS.

SECURITY FIRST INSURANCE COMPANY,

Defendant.
/

PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION TO DEFENDANT
Pursuant to Florida Rules of Civil Procedure 1.280 and 1.350, among others, Plaintiff,
JAMES R. SMITH, request that Defendant, SECURITY FIRST INSURANCE
COMPANY, produce the following for inspection and/or copying within the next 30 days
from the Service of this Request at the offices of KANDELL, KANDELL & PETRIE.
DOCUMENT REQUESTS

1. A certified copy of the subject policy of insurance issued by Defendant to
Plaintiff, JAMES R. SMITH, as well as the application for such policy of
insurance.

2. Any and all correspondence, communication and/or documents forwarded to
Plaintiff or their agents and/or representatives, from Defendant regarding the
claim that is the subject of the instant action.

3. Any and all correspondence, communication and/or documents forwarded to
Defendant from Plaintiff or their agents and/or representatives, regarding the

claim that is the subject of the instant action.10.

11.

Any and all estimates prepared by Defendant, or any representative, employee
and/or agent thereof, for repair or replacement of any damage on the subject
property prior to the filing of this action.

Any and all reports prepared by Defendant, or any representative, employee
and/or agent thereof, regarding the cause and/or scope of damage to the
insured property.

Any and all photographs of the damages and/or the cause of damages taken
during any inspection by Defendant, or any representative, employee and/or
agent thereof.

Any and all reports and/or estimates prepared by any and all third parties or
anyone on behalf of Defendant during the claim evaluation process

Any and all audio recordings, transcriptions of any statement taken, or any
other written correspondence from Plaintiff, their agents and/or
representatives, and/or any third party, including, but not limited to any
roofers, handyman, etc., who inspected the damages and/or investigated the
cause of said damages.

Any documentation Defendant relies on concerning its allegation or
affirmative defense that the claimed damages to the insured property were
preexisting the date of loss.

Copies of any and all recorded statements made by Plaintiff or their agents
regarding the claim that is the subject of the instant action.

Any and all transcripts or written statements from Plaintiff including, but not

limited to, transcripts of examinations under oath.12.

13.

14.

15.

Copies of all documents relating to or supporting each affirmative or general
defense asserted by Defendant regarding the claim that is the subject of the
instant action.

A copy of the entire underwriting file for the insurance policy issued by
Defendant to Plaintiff for the property located at 7401 W. Highway 98, Port St.
Joe, FL 32456.

The application for insurance and all documents submitted to Defendant by
Plaintiff or their agents prior to the issuance of the insurance policy.

Any and all documents related to any and all other insurance claims made by

Plaintiffs, that Defendant intends to use in the instant action.

CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the foregoing was mailed on

this ___ 8th day of ___ January 2020 via eservice to Katherine L. Moran, Esq., at
Katherine. Moran@csklegal.com and Tiffany.Coleman@csklegal.com.

KANDELL, KANDELL & PETRIE
Attorneys for Plaintiff

Suite 601 - Grand Bay Plaza

2665 S. Bayshore Drive

Miami, Florida 33133

Telephone (305)858-2220

     

Fla. Bar No.: 84566