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Filing # 127589668 E-Filed 05/26/2021 02:21:30 PM
IN THE CIRCUIT COURT OF THE 14”
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
CASE NO.: 19004412CA
JAMIE AND JENNIFER CARR,
Plaintiffs,
VS.
GULFSTREAM PROPERTY AND
CASUALTY INSURANCE COMPANY,
Defendant.
eee
PLAINTIFFS’ EXHIBIT LIST
COME NOW Plaintiffs, JAMIE AND JENNIFER CARR, by and through their
undersigned attorneys, file their Exhibit List pursuant to the Trial Order, and state as follows:
1. All documents and materials produced during the course of discovery in this action.
2. All pleadings; answers to interrogatories; responses to request for production;
responses to requests for admissions or other motions filed therein.
3. Repair invoices, reports, documentation, correspondence, and estimates related to the
building envelope at the premises.
4. Repair invoices, reports, documentation, correspondence, and estimates related to
exterior damage at the premises.
5. Repair invoices, reports, documentation, correspondence, and estimates related to
interior damage at the premises.
6. Repair invoices, reports, documentation, correspondence, and estimates related to
structural damage at the premises.
7. Repair invoices, reports, documentation, correspondence, and estimates related to
inspections or work performed by DLM Contractors, Inc.
8. Repair invoices, reports, documentation, correspondence, and estimates related to
inspections or work performed by Total Claim Source.
9. Repair invoices, reports, documentation, correspondence, and estimates related to
inspections or work performed by Expert Inspections d/b/a iTest Environmental
Testing & Inspections.
10. Repair invoices, reports, documentation, correspondence, and estimates related to
inspections or work performed by Southeastern Consulting Engineers, Inc.
11. Repair estimates prepared by Gulfstream Property & Casualty Insurance Company,
and their inspectors, employees, agents, or subcontractors.
12. Copies of all checks or evidence of payment from Plaintiffs to vendors in relation to
the subject incident.
13. Copies of all correspondence with Gulfstream Property & Casualty Insurance
Company.
14. Certified copy of the insurance policy issued by Gulfstream Property & Casualty
Insurance Company, which is the subject of this case.
15. All correspondence to and from Jamie Carr.
16. All correspondence to and from Jennifer Carr.
17. All correspondence to and from Total Claim Source.
18. All correspondence to and from Expert Inspections d/b/a iTest Environmental Testing
& Inspections.
19. All correspondence to and from Southeastern Consulting Engineers, Inc.
20. All correspondence to and from Gulfstream Property & Casualty Insurance Company.
21. All correspondence in this matter.
22. All photographs taken of the subject property during the course of the inspections
conducted and throughout the duration of this lawsuit.
23. All photographs taken by Total Claim Source.
24. All photographs taken by Expert Inspections d/b/a iTest Environmental Testing &
Inspections.
25. All photographs taken by Southeastern Consulting Engineers, Inc.
26. All photographs taken by Gulfstream Property & Casualty Insurance Company, or
anyone acting on behalf of Gulfstream Property & Casualty Insurance Company, of
the subject property.
27. All photographs taken by the Plaintiffs, or anyone acting on their behalf of the subject
property.
28. All credit card statements of Plaintiffs showing payments to contractors and vendors
who performed work at the subject property.
29. Gulfstream Property & Casualty Insurance Company’s claim file.
30. Transcripts of any depositions of this action.
31. All documents or materials identified by Defendant in Defendant’s Exhibit List.
32. All documents, photographs, diagrams, reports prepared by Plaintiffs, Defendant
and/or their representatives in the investigation of the claim.
33. All materials, documents, photographs, and other evidence utilized by the experts in
this matter.
34. All home inspection reports.
35. Records of payments made in this matter.
Plaintiffs reserve the right to supplement and/or amend this Exhibit List upon reasonable,
written notice to the Defendant.
[Certificate ofService on thefollowing page.]
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on
this 26th day of May, 2021, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler
Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602,
kmaus@butler legal.
GED LAWYERS, LLP
Attorneys for the Plaintiffs
7171 North Federal Highway
Boca Raton, FL 33487
Telephone: (561) 995-1966
Facsimile: (561) 241-0812
Primary Email: pdlitlaw@gediawyers.com
Secondary Email:bgoetsch@gedlawvers.com
BY: /s/ Scott M. Rosso
SCOTT M. ROSSO, ESQ.
Florida Bar No.: 505757
DAVID R. SHAHEEN, ESQ.
Florida Bar No.: 0117947
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Filing # 127589668 E-Filed 05/26/2021 02:21:30 PM IN THE CIRCUIT COURT OF THE 14” JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO.: 19004412CA JAMIE AND JENNIFER CARR, Plaintiffs, VS. GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. eee PLAINTIFFS’ EXHIBIT LIST COME NOW Plaintiffs, JAMIE AND JENNIFER CARR, by and through their undersigned attorneys, file their Exhibit List pursuant to the Trial Order, and state as follows: 1. All documents and materials produced during the course of discovery in this action. 2. All pleadings; answers to interrogatories; responses to request for production; responses to requests for admissions or other motions filed therein. 3. Repair invoices, reports, documentation, correspondence, and estimates related to the building envelope at the premises. 4. Repair invoices, reports, documentation, correspondence, and estimates related to exterior damage at the premises. 5. Repair invoices, reports, documentation, correspondence, and estimates related to interior damage at the premises. 6. Repair invoices, reports, documentation, correspondence, and estimates related to structural damage at the premises. 7. Repair invoices, reports, documentation, correspondence, and estimates related to inspections or work performed by DLM Contractors, Inc. 8. Repair invoices, reports, documentation, correspondence, and estimates related to inspections or work performed by Total Claim Source. 9. Repair invoices, reports, documentation, correspondence, and estimates related to inspections or work performed by Expert Inspections d/b/a iTest Environmental Testing & Inspections. 10. Repair invoices, reports, documentation, correspondence, and estimates related to inspections or work performed by Southeastern Consulting Engineers, Inc. 11. Repair estimates prepared by Gulfstream Property & Casualty Insurance Company, and their inspectors, employees, agents, or subcontractors. 12. Copies of all checks or evidence of payment from Plaintiffs to vendors in relation to the subject incident. 13. Copies of all correspondence with Gulfstream Property & Casualty Insurance Company. 14. Certified copy of the insurance policy issued by Gulfstream Property & Casualty Insurance Company, which is the subject of this case. 15. All correspondence to and from Jamie Carr. 16. All correspondence to and from Jennifer Carr. 17. All correspondence to and from Total Claim Source. 18. All correspondence to and from Expert Inspections d/b/a iTest Environmental Testing & Inspections. 19. All correspondence to and from Southeastern Consulting Engineers, Inc. 20. All correspondence to and from Gulfstream Property & Casualty Insurance Company. 21. All correspondence in this matter. 22. All photographs taken of the subject property during the course of the inspections conducted and throughout the duration of this lawsuit. 23. All photographs taken by Total Claim Source. 24. All photographs taken by Expert Inspections d/b/a iTest Environmental Testing & Inspections. 25. All photographs taken by Southeastern Consulting Engineers, Inc. 26. All photographs taken by Gulfstream Property & Casualty Insurance Company, or anyone acting on behalf of Gulfstream Property & Casualty Insurance Company, of the subject property. 27. All photographs taken by the Plaintiffs, or anyone acting on their behalf of the subject property. 28. All credit card statements of Plaintiffs showing payments to contractors and vendors who performed work at the subject property. 29. Gulfstream Property & Casualty Insurance Company’s claim file. 30. Transcripts of any depositions of this action. 31. All documents or materials identified by Defendant in Defendant’s Exhibit List. 32. All documents, photographs, diagrams, reports prepared by Plaintiffs, Defendant and/or their representatives in the investigation of the claim. 33. All materials, documents, photographs, and other evidence utilized by the experts in this matter. 34. All home inspection reports. 35. Records of payments made in this matter. Plaintiffs reserve the right to supplement and/or amend this Exhibit List upon reasonable, written notice to the Defendant. [Certificate ofService on thefollowing page.] CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on this 26th day of May, 2021, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602, kmaus@butler legal. GED LAWYERS, LLP Attorneys for the Plaintiffs 7171 North Federal Highway Boca Raton, FL 33487 Telephone: (561) 995-1966 Facsimile: (561) 241-0812 Primary Email: pdlitlaw@gediawyers.com Secondary Email:bgoetsch@gedlawvers.com BY: /s/ Scott M. Rosso SCOTT M. ROSSO, ESQ. Florida Bar No.: 505757 DAVID R. SHAHEEN, ESQ. Florida Bar No.: 0117947