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Filing # 100343459 E-Filed 12/16/2019 10:26:48 AM
IN THE CIRCUIT COURT OF THE 14th JUDICIAL CIRCUIT, IN AND FOR
BAY COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: 19004523CA
JAMES MCDOUGAL AND GINGER MCDOUGAL,
Plaintiff,
vs.
CERTAIN UNDERWRITERS AT LLOYDS,
LONDON SUBSCRIBING TO CERTIFICATE
NUMBER ACA080027600-01,
Defendant.
/
PLAINTIFF’S SET OF INTERROGATORIES TO DEFENDANT
Plaintiff, James McDougal and Ginger McDougal, pursuant to Rule 1.340, Fla. R.
Civ. P., serves this First Set of Interrogatories upon Defendant to be answered by Defendant
under oath and in writing, within forty-five (45) days from the date of service hereof.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing was served on Defendant with the
Complaint.
INSURANCE LITIGATION GROUP, P.A.
Attorney for Plaintiff
1500 N.E. 162" Street
Miami, Florida 33162
Telephone: (786) 529-0090
Facsimile: (866) 239-9520
E-Mail: service@ILGPA.COM
By: /s/Kimesha S. Smith
KIMESHA S. SMITH, ESQ.
FL Bar No. 116466
ILG File #: 12365
Claim #: 18315
Case #: * +LAW OFFICES J. PATRICK FLOYD,
CHTD.
Co-Counsel for Plaintiff
408 Long Avenue
Port St. Joe, FL 32456
Phone: (850) 227-7413
Fax: (850) 229-8196
Email: j.patrickfloyd@jpatrickfloyd.com
By: /s/J. Patrick Floyd
J. PATRICK FLOYD, ESQ.
FL Bar No. 257001
ILG File #: 12365
Claim #: 18315
Case #: * +INTERROGATORY DEFINITION AND INSTRUCTIONS
1. The term “Plaintiff” or “Insured” means JAMES MCDOUGAL AND
GINGER MCDOUGAL and his/her/their agents, employees, independent contractors,
attorneys, and all other persons acting or purporting to act on his/her/their behalf.
2. The term “you” or “Defendant” means CERTAIN UNDERWRITERS AT
LLOYDS, LONDON SUBSCRIBING TO CERTIFICATE NUMBER ACA080027600-
01, and its agents, employees, independent contractors, subsidiaries, divisions, parent
company, holding company, directors, officers, attorneys, and all other persons acting or
purporting to act on its behalf.
3. The term “Policy” means the policy, number ACA080027600-01, which
Defendant issued to Insured for the property located at 209 7th Street, Mexico Beach, FL
32456, US that was in effect on the date of loss alleged in Plaintiff's Complaint filed in
this action.
4. The term “Insured Building” or “Insured Property” means the insured
structure and/or its contents located at the address alleged in Plaintiff’s Complaint filed in
this action.
5. The term “Loss” means the event at issue in which the Insured suffered
property damage, on the date of loss alleged in Plaintiff's Complaint.
6. The term “Claim” means the Plaintiff's request, made pursuant to Plaintiff's
insurance Policy, that Defendant pay Plaintiff the amount of damages that Plaintiff
sustained as a result of the Loss.
7. The term “coverage/denial letter” means any letter(s) sent by Defendant to
the Insured regarding his/her Claim.
8. The term “person” means any natural person, individual, proprietorship,
partnership, corporation, association, organization, joint venture, firm, other business
enterprise, governmental body, group of natural persons or other entity.
9. The term “document” or “documents” means any written, typed, or graphic
matter or other means of preserving thought or expression and all tangible things from
which information can be processed or transcribed, including the originals and all non-
identical copies, whether different from the original by reason of any notation made on
such copy or otherwise, including, but not limited to, correspondence, emails, memoranda,
ILG File #: 12365
Claim #: 18315
Case #: * +notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other
communications, interoffice and intraoffice telephone calls, diaries, claim diaries,
electronic claim notes, chronological data, minutes, books, reports, studies, summaries,
pamphlets, printed matter, charts, ledgers, invoices, worksheets, receipts, returns, computer
printouts, prospectuses, financial statements, schedules, affidavits, contracts, canceled
checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases
(and all drafts, alterations and modifications, changes and amendments of any of the
foregoing), graphic or natural records or representations of any kind (including without
limitation photographs, photographic negative, microfiche, microfilm, videotape,
recordings, motion pictures, phonograph recordings, transcripts or log of such recording,
projection), electronic, computer, mechanical, or electric records or representations of any
kind (including without limitation tapes, cassettes, discs and records), and binders, cover
notes, certificates, analysis, study memoranda, note lists, diaries, logs, questionnaires, bills,
purchase orders, shipping orders, memorandum of contract, agreements, licenses, permits,
orders, financial data, acknowledgements, computer or data procession cards, computer or
data processing discs, and all other data compilations from which information can be
obtained or translated, reports and/or summaries of investigations, drafts and revisions of
drafts of any documents and original preliminary notes or sketches, no matter how
produced or maintained, in your actual or constructive possession, custody or control,
whether prepared, published or released by you or by any other person. If data is stored on
computer or electronic media (inter-company email, for example), produce hard copies of
each such document.” “Documents” includes all attachments and enclosures.
10. The term “all documents” means every document or group of documents,
as above defined, that are known to you or that can be located or discovered by reasonably
diligent efforts.
11. As used herein, the singular shall include the plural, the plural shall include
the singular, and masculine feminine and neuter shall include each of the other genders.
12. The connectives “and” and “or” shall be construed either disjunctive or
conjunctively as necessary to bring within the scope of these requests all responses that
might otherwise be construed to be outside their scope.
13. The terms “coverage letter(s)” means the correspondence from You to the
Insured throughout the claim at issue regarding Your position as to coverage for the Loss.
14. The terms “relating to” or “in any way related to” means in whole or in part
constituting, containing, concerning, discussing, commending upon, describing, analyzing,
identifying, stating, pertaining to, referring to, or forming the basis of.
ILG File #: 12365
Claim #: 18315
Case #: * +15. “Identify” and “identity” mean:
a. With respect to a natural person, to state the person’s name, title at the
time in question, employer and business address at the time in question,
and the current or last known employer, business address, and home
address;
b. With respect to an organization or entity, to state the full legal name of
the entity and full name by which the organization or entity is commonly
known or does business;
c. With respect to a document, to state the name(s) and title(s) of the
author(s) and/or signatory(ies), addressee(s), and recipient(s) of any
copies; the subject matter or title; the date of the document; the division,
department, or unit of your organization with which the author(s) and/or
addressee(s) are or were affiliated; and its present location and
custodian; and
d. With respect to an oral communication to state the names and titles of
all persons involved in the communication, and the date and
approximate time of the communication.
16. This request shall be continuing in nature so as to require the filing of
supplemental interrogatory answers to the extent required by Florida law.
INTERROGATORIES
1. State the name and address of the person(s) answering these interrogatories,
and, if applicable, the person’s official position or relationship with the party to whom the
interrogatories are directed.
2. Describe any and all policies of insurance which you contend cover or may
cover the allegations set forth in Plaintiff's complaint, detailing as to such policies the name
of the insurer, the number of the policy, the available limits of liability, and the name and
address of the custodian of the policy.
3. State the date that Defendant first received any notice from Plaintiff and/or
the Insured concerning a claim for benefits under the Policy as a result of the Loss.
4. Identify all persons, believed or known by you, your agents, or attorneys to
have any knowledge concerning any of the issues raised in the pleadings, specifying the
subject matter about which the witness may have knowledge.
5. State whether you have obtained any statements (oral, written and/or
recorded) from any witness, the dates any such witness statements were taken, by whom.
ILG File #: 12365
Claim #: 18315
Case #: * +any such witness statements were taken, and who has present possession, custody and
control of any such statements.
6. Does the Coverage/Denial letter specifically cite to each and every policy
provision and all facts upon which you are relying in connection with your decision to
deny, or otherwise not make full payment to Plaintiff for Plaintiff's Claim? If your answer
is anything other than an unqualified affirmative, identify all other Policy provisions and
facts upon which you are relying for your denial or partial payment of Plaintiff's Claim.
7. Do you contend that all or any portion of the Loss is not covered by the
Policy(ies) issued by you? Unless your answer is an unqualified negative, please set forth
the specific amounts that you contend are not covered, and for each such amount, all facts,
including exclusions or other provisions of the Policy(ies), supporting your contention that
no coverage exists.
8. State each and every Policy provision and all facts related to each upon
which you are relying in connection with your decision to deny, or otherwise not make full
payment to Plaintiff, on Plaintiff's Claim.
9. With reference to each of your affirmative defenses raised in this lawsuit,
please describe all facts upon which you rely to substantiate such affirmative defense,
including identification of all witnesses to each such fact.
10. With reference to each of your affirmative defenses raised in this lawsuit,
please describe all documents and electronically stored information upon which you rely
to substantiate such affirmative defense.
11. Identify all persons involved on your behalf in determining whether to
afford coverage for Plaintiff's Claim. For each person identified, identify the person’s
employer and explain the role of each person identified in determining whether to pay
Plaintiff's Claim.
12. Identify each document sent from Defendant to the Insured in reference to
the Loss involved herein, including the date sent and the name of the individual who sent
said communication.
13. Identify each person, who on behalf of Defendant, inspected the Insured
Property, including their field of expertise and date of each inspection.
14. With regard to any third parties (including all adjusters including your direct
employees, independent contractors, and all other persons or entities) who provided
services, analysis, adjusting, or otherwise rendered opinions to you in adjusting or handling
your determination of whether to pay Plaintiff's Claim, please identify: (a) the date and
nature of the services provided by each third party; (b) all documents you provided to such
third party; and (c) all documents such third party provided to you.
ILG File #: 12365
Claim #: 18315
Case #: * +15. Did the Defendant request the Insured to perform any post loss duties for
the Claim, including to submit to an Examination Under Oath, to submit a sworn proof of
loss, to permit inspection, etc.
16. If your answer to the preceding interrogatory was yes, please state for each
request, the exact request made, the date of the request, whether the request was written or
oral, and what did the Insured do in response to said request.
17. Please state with specificity any conditions subsequent to the Plaintiff's
Claim that you contend have not been fulfilled by the Plaintiff, if any exist.
18. Have you heard or do you know about any statement or remark made by or
on behalf of any party to this lawsuit, other than yourself, concerning any issue in this
lawsuit? If so, state and name and address of each person who made the statement or
statements, the name and address of each person who heard it, and the date, time, place and
substance of each statement.
19, State the name and address of every person known to you, your agents, or
your attorneys who has knowledge about, or possession, custody or control of, any
estimate, model, plat, map, drawing, motion picture, videotape, or photograph pertaining
to any fact or issue involved in this lawsuit; and describe as to each, what item such person
has, the name and address of the person who took or prepared it, and the date it was taken
or prepared.
20. List all amounts that Defendant has paid to the Insured, and/or for the
Insured’s benefit, regarding the Loss. State the date each payment was made and what
each payment was for.
21. If an inspection of the Insured Property was performed within the past ten
(10) years on the Insured Property, state the nature of the inspection, the name and address
of any person who performed the inspection, the date of the inspection, and whether any
written reports or communications were prepared in connection with the inspection, and
whether any photographs or video was taken.
22. Identify all insurance claims made by the Insured over the past ten (10)
years. For each claim, identify the date of the claim, the amount of the claim, the insurance
carrier, the policy number, the basis of the claim, and how the claim was resolved (e.g.,
payment, denial, still pending).
23. Do you contend any person or entity other than you - is or may be, liable in
whole or in part for the claims asserted against Defendant in this lawsuit? If so, state the
full name and address of each such person or entity, the legal basis for your contention, the
facts or evidence upon which your contention is based, and whether or not you have
notified each such person or entity of your contention
ILG File #: 12365
Claim #: 18315
Case #: * +24. — If you claim that you were unable to pay Plaintiff's Claim because you had
insufficient information or the notice of Claim did not have sufficient support, state: when
you first realized that you had insufficient information, each and every effort made by you
to obtain the needed information, when you informed the Plaintiff of the need for further
information, and when you gave up trying to obtain the needed information.
25. If an appraisal of the Insured Property or its contents was performed, state
the items that have been appraised, the amount that each such item was appraised for, the
name and address of any person who performed or contributed to said appraisal, and the
date of said appraisal.
ILG File #: 12365
Claim #: 18315
Case #: * +I have read the foregoing Answers to Interrogatories and do swear that they are true and
correct to the best of my knowledge and belief.
xX
(Defendant)
STATE OF )
COUNTY OF )
SUBSCRIBED and sworn to (or affirmed) before me this day of ;
20 , by , who is[ ] personally known or [ ] produced as identification
a , and who [ ] did [did not] take an oath.
Dated this day of »201_
NOTARY PUBLIC,
State of
Commission Expires:
ILG File #: 12365
Claim #: 18315
Case #: ** “
Preview
Filing # 100343459 E-Filed 12/16/2019 10:26:48 AM IN THE CIRCUIT COURT OF THE 14th JUDICIAL CIRCUIT, IN AND FOR BAY COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 19004523CA JAMES MCDOUGAL AND GINGER MCDOUGAL, Plaintiff, vs. CERTAIN UNDERWRITERS AT LLOYDS, LONDON SUBSCRIBING TO CERTIFICATE NUMBER ACA080027600-01, Defendant. / PLAINTIFF’S SET OF INTERROGATORIES TO DEFENDANT Plaintiff, James McDougal and Ginger McDougal, pursuant to Rule 1.340, Fla. R. Civ. P., serves this First Set of Interrogatories upon Defendant to be answered by Defendant under oath and in writing, within forty-five (45) days from the date of service hereof. CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing was served on Defendant with the Complaint. INSURANCE LITIGATION GROUP, P.A. Attorney for Plaintiff 1500 N.E. 162" Street Miami, Florida 33162 Telephone: (786) 529-0090 Facsimile: (866) 239-9520 E-Mail: service@ILGPA.COM By: /s/Kimesha S. Smith KIMESHA S. SMITH, ESQ. FL Bar No. 116466 ILG File #: 12365 Claim #: 18315 Case #: * +LAW OFFICES J. PATRICK FLOYD, CHTD. Co-Counsel for Plaintiff 408 Long Avenue Port St. Joe, FL 32456 Phone: (850) 227-7413 Fax: (850) 229-8196 Email: j.patrickfloyd@jpatrickfloyd.com By: /s/J. Patrick Floyd J. PATRICK FLOYD, ESQ. FL Bar No. 257001 ILG File #: 12365 Claim #: 18315 Case #: * +INTERROGATORY DEFINITION AND INSTRUCTIONS 1. The term “Plaintiff” or “Insured” means JAMES MCDOUGAL AND GINGER MCDOUGAL and his/her/their agents, employees, independent contractors, attorneys, and all other persons acting or purporting to act on his/her/their behalf. 2. The term “you” or “Defendant” means CERTAIN UNDERWRITERS AT LLOYDS, LONDON SUBSCRIBING TO CERTIFICATE NUMBER ACA080027600- 01, and its agents, employees, independent contractors, subsidiaries, divisions, parent company, holding company, directors, officers, attorneys, and all other persons acting or purporting to act on its behalf. 3. The term “Policy” means the policy, number ACA080027600-01, which Defendant issued to Insured for the property located at 209 7th Street, Mexico Beach, FL 32456, US that was in effect on the date of loss alleged in Plaintiff's Complaint filed in this action. 4. The term “Insured Building” or “Insured Property” means the insured structure and/or its contents located at the address alleged in Plaintiff’s Complaint filed in this action. 5. The term “Loss” means the event at issue in which the Insured suffered property damage, on the date of loss alleged in Plaintiff's Complaint. 6. The term “Claim” means the Plaintiff's request, made pursuant to Plaintiff's insurance Policy, that Defendant pay Plaintiff the amount of damages that Plaintiff sustained as a result of the Loss. 7. The term “coverage/denial letter” means any letter(s) sent by Defendant to the Insured regarding his/her Claim. 8. The term “person” means any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, group of natural persons or other entity. 9. The term “document” or “documents” means any written, typed, or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed, including the originals and all non- identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, emails, memoranda, ILG File #: 12365 Claim #: 18315 Case #: * +notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other communications, interoffice and intraoffice telephone calls, diaries, claim diaries, electronic claim notes, chronological data, minutes, books, reports, studies, summaries, pamphlets, printed matter, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, canceled checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases (and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphic or natural records or representations of any kind (including without limitation photographs, photographic negative, microfiche, microfilm, videotape, recordings, motion pictures, phonograph recordings, transcripts or log of such recording, projection), electronic, computer, mechanical, or electric records or representations of any kind (including without limitation tapes, cassettes, discs and records), and binders, cover notes, certificates, analysis, study memoranda, note lists, diaries, logs, questionnaires, bills, purchase orders, shipping orders, memorandum of contract, agreements, licenses, permits, orders, financial data, acknowledgements, computer or data procession cards, computer or data processing discs, and all other data compilations from which information can be obtained or translated, reports and/or summaries of investigations, drafts and revisions of drafts of any documents and original preliminary notes or sketches, no matter how produced or maintained, in your actual or constructive possession, custody or control, whether prepared, published or released by you or by any other person. If data is stored on computer or electronic media (inter-company email, for example), produce hard copies of each such document.” “Documents” includes all attachments and enclosures. 10. The term “all documents” means every document or group of documents, as above defined, that are known to you or that can be located or discovered by reasonably diligent efforts. 11. As used herein, the singular shall include the plural, the plural shall include the singular, and masculine feminine and neuter shall include each of the other genders. 12. The connectives “and” and “or” shall be construed either disjunctive or conjunctively as necessary to bring within the scope of these requests all responses that might otherwise be construed to be outside their scope. 13. The terms “coverage letter(s)” means the correspondence from You to the Insured throughout the claim at issue regarding Your position as to coverage for the Loss. 14. The terms “relating to” or “in any way related to” means in whole or in part constituting, containing, concerning, discussing, commending upon, describing, analyzing, identifying, stating, pertaining to, referring to, or forming the basis of. ILG File #: 12365 Claim #: 18315 Case #: * +15. “Identify” and “identity” mean: a. With respect to a natural person, to state the person’s name, title at the time in question, employer and business address at the time in question, and the current or last known employer, business address, and home address; b. With respect to an organization or entity, to state the full legal name of the entity and full name by which the organization or entity is commonly known or does business; c. With respect to a document, to state the name(s) and title(s) of the author(s) and/or signatory(ies), addressee(s), and recipient(s) of any copies; the subject matter or title; the date of the document; the division, department, or unit of your organization with which the author(s) and/or addressee(s) are or were affiliated; and its present location and custodian; and d. With respect to an oral communication to state the names and titles of all persons involved in the communication, and the date and approximate time of the communication. 16. This request shall be continuing in nature so as to require the filing of supplemental interrogatory answers to the extent required by Florida law. INTERROGATORIES 1. State the name and address of the person(s) answering these interrogatories, and, if applicable, the person’s official position or relationship with the party to whom the interrogatories are directed. 2. Describe any and all policies of insurance which you contend cover or may cover the allegations set forth in Plaintiff's complaint, detailing as to such policies the name of the insurer, the number of the policy, the available limits of liability, and the name and address of the custodian of the policy. 3. State the date that Defendant first received any notice from Plaintiff and/or the Insured concerning a claim for benefits under the Policy as a result of the Loss. 4. Identify all persons, believed or known by you, your agents, or attorneys to have any knowledge concerning any of the issues raised in the pleadings, specifying the subject matter about which the witness may have knowledge. 5. State whether you have obtained any statements (oral, written and/or recorded) from any witness, the dates any such witness statements were taken, by whom. ILG File #: 12365 Claim #: 18315 Case #: * +any such witness statements were taken, and who has present possession, custody and control of any such statements. 6. Does the Coverage/Denial letter specifically cite to each and every policy provision and all facts upon which you are relying in connection with your decision to deny, or otherwise not make full payment to Plaintiff for Plaintiff's Claim? If your answer is anything other than an unqualified affirmative, identify all other Policy provisions and facts upon which you are relying for your denial or partial payment of Plaintiff's Claim. 7. Do you contend that all or any portion of the Loss is not covered by the Policy(ies) issued by you? Unless your answer is an unqualified negative, please set forth the specific amounts that you contend are not covered, and for each such amount, all facts, including exclusions or other provisions of the Policy(ies), supporting your contention that no coverage exists. 8. State each and every Policy provision and all facts related to each upon which you are relying in connection with your decision to deny, or otherwise not make full payment to Plaintiff, on Plaintiff's Claim. 9. With reference to each of your affirmative defenses raised in this lawsuit, please describe all facts upon which you rely to substantiate such affirmative defense, including identification of all witnesses to each such fact. 10. With reference to each of your affirmative defenses raised in this lawsuit, please describe all documents and electronically stored information upon which you rely to substantiate such affirmative defense. 11. Identify all persons involved on your behalf in determining whether to afford coverage for Plaintiff's Claim. For each person identified, identify the person’s employer and explain the role of each person identified in determining whether to pay Plaintiff's Claim. 12. Identify each document sent from Defendant to the Insured in reference to the Loss involved herein, including the date sent and the name of the individual who sent said communication. 13. Identify each person, who on behalf of Defendant, inspected the Insured Property, including their field of expertise and date of each inspection. 14. With regard to any third parties (including all adjusters including your direct employees, independent contractors, and all other persons or entities) who provided services, analysis, adjusting, or otherwise rendered opinions to you in adjusting or handling your determination of whether to pay Plaintiff's Claim, please identify: (a) the date and nature of the services provided by each third party; (b) all documents you provided to such third party; and (c) all documents such third party provided to you. ILG File #: 12365 Claim #: 18315 Case #: * +15. Did the Defendant request the Insured to perform any post loss duties for the Claim, including to submit to an Examination Under Oath, to submit a sworn proof of loss, to permit inspection, etc. 16. If your answer to the preceding interrogatory was yes, please state for each request, the exact request made, the date of the request, whether the request was written or oral, and what did the Insured do in response to said request. 17. Please state with specificity any conditions subsequent to the Plaintiff's Claim that you contend have not been fulfilled by the Plaintiff, if any exist. 18. Have you heard or do you know about any statement or remark made by or on behalf of any party to this lawsuit, other than yourself, concerning any issue in this lawsuit? If so, state and name and address of each person who made the statement or statements, the name and address of each person who heard it, and the date, time, place and substance of each statement. 19, State the name and address of every person known to you, your agents, or your attorneys who has knowledge about, or possession, custody or control of, any estimate, model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this lawsuit; and describe as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. 20. List all amounts that Defendant has paid to the Insured, and/or for the Insured’s benefit, regarding the Loss. State the date each payment was made and what each payment was for. 21. If an inspection of the Insured Property was performed within the past ten (10) years on the Insured Property, state the nature of the inspection, the name and address of any person who performed the inspection, the date of the inspection, and whether any written reports or communications were prepared in connection with the inspection, and whether any photographs or video was taken. 22. Identify all insurance claims made by the Insured over the past ten (10) years. For each claim, identify the date of the claim, the amount of the claim, the insurance carrier, the policy number, the basis of the claim, and how the claim was resolved (e.g., payment, denial, still pending). 23. Do you contend any person or entity other than you - is or may be, liable in whole or in part for the claims asserted against Defendant in this lawsuit? If so, state the full name and address of each such person or entity, the legal basis for your contention, the facts or evidence upon which your contention is based, and whether or not you have notified each such person or entity of your contention ILG File #: 12365 Claim #: 18315 Case #: * +24. — If you claim that you were unable to pay Plaintiff's Claim because you had insufficient information or the notice of Claim did not have sufficient support, state: when you first realized that you had insufficient information, each and every effort made by you to obtain the needed information, when you informed the Plaintiff of the need for further information, and when you gave up trying to obtain the needed information. 25. If an appraisal of the Insured Property or its contents was performed, state the items that have been appraised, the amount that each such item was appraised for, the name and address of any person who performed or contributed to said appraisal, and the date of said appraisal. ILG File #: 12365 Claim #: 18315 Case #: * +I have read the foregoing Answers to Interrogatories and do swear that they are true and correct to the best of my knowledge and belief. xX (Defendant) STATE OF ) COUNTY OF ) SUBSCRIBED and sworn to (or affirmed) before me this day of ; 20 , by , who is[ ] personally known or [ ] produced as identification a , and who [ ] did [did not] take an oath. Dated this day of »201_ NOTARY PUBLIC, State of Commission Expires: ILG File #: 12365 Claim #: 18315 Case #: ** “