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Filing # 111694584 E-Filed 08/12/2020 03:54:59 PM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
PATSY J. ODOM,
Plaintiff,
v. Case No.: 19-004405 CA.
TOWER HILL SIGNATURE INSURANCE
COMPANY, a Florida insurance corporation,
Defendant.
a
DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY (“Tower Hill”), by
and through the undersigned attorneys and pursuant to Fla. R. Civ. P. 1.350, propounds the
following Request for Production to Plaintiff, PATSY J. ODOM, as follows:
DEFINITIONS:
As used in these Requests, the terms listed below are defined as follows:
1. “You” or “Your” means Plaintiff, PATSY J. ODOM, their agents, representatives,
and, unless privileged, their attorneys.
2. “Identify” or “identification”, when used with respect to an individual, means to
state that individual’s full name, telephone number, and present or last known address.
3. “Document” means any written, recorded, or graphic matter however produced or
reproduced.
4, “Property” means 7601 Kingswood Road, Southport, FL 32409.
5. “Loss” refers to the damage alleged in Plaintiff's Complaint.
6, “Policy” refers to the policy described in Plaintiff's Complaint with a policy
number of PIH0384517.
SCOPE OF PRODUCTION
If any documents are withheld under claim of privilege, furnish a list identifying each
document for which the privilege is claimed, together with the following information:
a brief description of the nature and subject matter;
the date;
the name and title of the author(s);
the name and title of the person(s) to whom the document was addressed;
the name and title of the persons(s) to whom the document was sent;
Page 1 of 4
ARWNE6. the number of pages;
7. the paragraph to which the document is otherwise responsive; and
8. the nature of the claimed privilege.
REQUESTS FOR PRODUCTION
1. All original color and digital photographs or videos in their native format
depicting the damages alleged in your Complaint.
2. All documents, including but not limited to reports, investigations, estimates,
contracts for repair work, proposals or bids, associated with the damages alleged in your
Complaint.
3. Any and all documents reflecting any repairs, maintenance and/or improvements
made to your property since your purchase of the property, including permits, invoices and/or
reports.
4. All correspondence between you and any third parties you consulted to inspect the
damages alleged in your Complaint, including all documents provided to the third parties.
5. All receipts and invoices for repair to the damage alleged in your Complaint.
6. All proof of losses, claim losses, and other documents regarding prior claims
made by you under a policy of homeowner’s insurance, outside of the subject claim.
7. Any and all inspection reports and/or certificates of completion generated after
the completion of any repairs to the alleged Loss, including accompanying photographs.
8. Any and all inspection and/or appraisal reports generated since your purchase of
the Property, including accompanying photographs.
9. All letters, emails and other correspondence between you and Tower Hill, from
the last three years.
Page 2 of 410. Any and all documents relating to your purchase of the Property, including, but
not limited to, the contract for sale and purchase of the Property, seller’s disclosure statement,
loan documents associated with the mortgage on the Property, promissory note, title policy,
Department of Housing and Urban Development form, inspection report and appraisal report.
11. All letters, emails and other correspondence between you and any public
adjusters, related to this claim.
12. All letters, emails, text messages and other correspondence between you and any
insurance agents regarding the damages alleged in your Complaint.
13. Any and all documents reflecting homeowner’s insurance for your Property with
carriers other than Tower Hill, whether the policies are currently in effect or not.
/s/ Nicole M. Fluet
NICOLE M. FLUET, Fla. Bar No. 91077
nfluet@gallowaylawfirm.com
SARAH K. CULLETON, Fla. Bar No. 1015231
sculleton@gallowaylawfirm.com
Galloway, Johnson, Tompkins, Burr & Smith, PLC
400 N. Ashley Drive, Suite 1000
Tampa, Florida 33602
(813) 977-1200
(813) 977-1288 (facsimile)
tampaservice@gallowaylawfirm.com
Counsel for Defendant, Tower Hill Signature
Insurance Company
Page 3 of 4CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 12" day
of August, 2020:
Clark Hamilton, Jr., Esq. Jay Manuel, Esq.
Tyler & Hamilton, P.A. Manuel & Thompson, P.A.
4741 Atlantic Boulevard, Suite A 120 Richard Jackson Boulevard, Suite 200
Jacksonville, FL 32207 Panama City, Florida 325407
Telephone: 904-398-9999 Phone: 850-785-5555
Facsimile: 904-398-0806 Fax: 850-785-0133
courtdocs@floridainsurancelawyers.com jay@manuclthompson.com
tandhpa@bellsouth.net velinda@manuelthompson.com
Counsel for Plaintiff tim@manuelthompson.com
Counsel for Plaintiff
[o] Nicole M. Fluet
NICOLE M. FLUET
SARAH K. CULLETON
Page 4 of 4
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Filing # 111694584 E-Filed 08/12/2020 03:54:59 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA PATSY J. ODOM, Plaintiff, v. Case No.: 19-004405 CA. TOWER HILL SIGNATURE INSURANCE COMPANY, a Florida insurance corporation, Defendant. a DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY (“Tower Hill”), by and through the undersigned attorneys and pursuant to Fla. R. Civ. P. 1.350, propounds the following Request for Production to Plaintiff, PATSY J. ODOM, as follows: DEFINITIONS: As used in these Requests, the terms listed below are defined as follows: 1. “You” or “Your” means Plaintiff, PATSY J. ODOM, their agents, representatives, and, unless privileged, their attorneys. 2. “Identify” or “identification”, when used with respect to an individual, means to state that individual’s full name, telephone number, and present or last known address. 3. “Document” means any written, recorded, or graphic matter however produced or reproduced. 4, “Property” means 7601 Kingswood Road, Southport, FL 32409. 5. “Loss” refers to the damage alleged in Plaintiff's Complaint. 6, “Policy” refers to the policy described in Plaintiff's Complaint with a policy number of PIH0384517. SCOPE OF PRODUCTION If any documents are withheld under claim of privilege, furnish a list identifying each document for which the privilege is claimed, together with the following information: a brief description of the nature and subject matter; the date; the name and title of the author(s); the name and title of the person(s) to whom the document was addressed; the name and title of the persons(s) to whom the document was sent; Page 1 of 4 ARWNE6. the number of pages; 7. the paragraph to which the document is otherwise responsive; and 8. the nature of the claimed privilege. REQUESTS FOR PRODUCTION 1. All original color and digital photographs or videos in their native format depicting the damages alleged in your Complaint. 2. All documents, including but not limited to reports, investigations, estimates, contracts for repair work, proposals or bids, associated with the damages alleged in your Complaint. 3. Any and all documents reflecting any repairs, maintenance and/or improvements made to your property since your purchase of the property, including permits, invoices and/or reports. 4. All correspondence between you and any third parties you consulted to inspect the damages alleged in your Complaint, including all documents provided to the third parties. 5. All receipts and invoices for repair to the damage alleged in your Complaint. 6. All proof of losses, claim losses, and other documents regarding prior claims made by you under a policy of homeowner’s insurance, outside of the subject claim. 7. Any and all inspection reports and/or certificates of completion generated after the completion of any repairs to the alleged Loss, including accompanying photographs. 8. Any and all inspection and/or appraisal reports generated since your purchase of the Property, including accompanying photographs. 9. All letters, emails and other correspondence between you and Tower Hill, from the last three years. Page 2 of 410. Any and all documents relating to your purchase of the Property, including, but not limited to, the contract for sale and purchase of the Property, seller’s disclosure statement, loan documents associated with the mortgage on the Property, promissory note, title policy, Department of Housing and Urban Development form, inspection report and appraisal report. 11. All letters, emails and other correspondence between you and any public adjusters, related to this claim. 12. All letters, emails, text messages and other correspondence between you and any insurance agents regarding the damages alleged in your Complaint. 13. Any and all documents reflecting homeowner’s insurance for your Property with carriers other than Tower Hill, whether the policies are currently in effect or not. /s/ Nicole M. Fluet NICOLE M. FLUET, Fla. Bar No. 91077 nfluet@gallowaylawfirm.com SARAH K. CULLETON, Fla. Bar No. 1015231 sculleton@gallowaylawfirm.com Galloway, Johnson, Tompkins, Burr & Smith, PLC 400 N. Ashley Drive, Suite 1000 Tampa, Florida 33602 (813) 977-1200 (813) 977-1288 (facsimile) tampaservice@gallowaylawfirm.com Counsel for Defendant, Tower Hill Signature Insurance Company Page 3 of 4CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 12" day of August, 2020: Clark Hamilton, Jr., Esq. Jay Manuel, Esq. Tyler & Hamilton, P.A. Manuel & Thompson, P.A. 4741 Atlantic Boulevard, Suite A 120 Richard Jackson Boulevard, Suite 200 Jacksonville, FL 32207 Panama City, Florida 325407 Telephone: 904-398-9999 Phone: 850-785-5555 Facsimile: 904-398-0806 Fax: 850-785-0133 courtdocs@floridainsurancelawyers.com jay@manuclthompson.com tandhpa@bellsouth.net velinda@manuelthompson.com Counsel for Plaintiff tim@manuelthompson.com Counsel for Plaintiff [o] Nicole M. Fluet NICOLE M. FLUET SARAH K. CULLETON Page 4 of 4