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Filing # 108270665 E-Filed 06/02/2020 02:31:34 PM
21938103
IN THE CIRCUIT COURT OF THE 14TH JUDICIAL
CIRCUIT IN AND FOR BAY COUNTY, FLORIDA
CASE NO. 19004524CA
UNION RESTORATION, INC., a/a/o RAQUEL
ESTRADA,
Plaintiff,
v.
EDISON INSURANCE COMPANY,
Defendant.
/
DEFENDANT, EDISON INSURANCE COMPANY’S, FIRST REQUEST FOR
PRODUCTION TO PLAINTIFFS, UNION RESTORATION, INC., A/A/(O RAQUEL
ESTRADA
Defendant, EDISON INSURANCE COMPANY, by and through undersigned
counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby
requests that Plaintiffs, UNION RESTORATION, INC. a/afo RAQUEL ESTRADA,
produce for inspection and copying at the offices of Conroy Simberg, 125 West Romana
Street, Suite 320, Pensacola, FL 32502, within thirty (30) days of the date of service of
these requests the documents referenced below.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a copy hereof has been furnished by service through the
eportal to Larry Moskowitz, Esq., Larry Moskowitz, P.A., 400 Southeast 9th Street, Fort
Lauderdale, FL 33316, Attorney for Plaintiff on this 2"¢ day of June, 2020.CASE NO. 19004524CA
CONROY SIMBERG
Attorney for Defendant, Edison Insurance Company
125 West Romana Street, Suite 320
Pensacola, FL 32502
Telephone: (850) 436-6605
Facsimile: (850) 436-2102
Primary Email: eservicepns@conroysimberg.com
Secondary Email: cvarner@conroysimberg.com
By: _/s/ Christopher E. Varner.
Christopher E. Varner, Esquire
Florida Bar No. 0140147DEFINITIONS AND INSTRUCTIONS
As used herein, the following terms are defined as indicated:
The terms “you”, “your”, “yours” and “yourself? mean Plaintiffs, UNION
RESTORATION, INC. a/a/o RAQUEL ESTRADA.
The term “document” means all written, graphic and audio or visually recorded
matter of every kind and description, however produced or reproduced,
whether draft or final, original or reproduction, in the actual or constructive
possession, custody or control of Plaintiffs, including but not limited to plans,
drawings, graphs, deeds, title policies, commitments or abstracts, writings,
letters, correspondence, memoranda, notes, films, photographs, audio
recordings, transcripts, contracts, agreements, covenants, permits,
licenses, memoranda of telephone or personal conversations or
communications, microfilm, microfiche, telegrams, books, magazines,
advertisements, periodicals, bulletins, circulars, pamphlets, statements,
notices, reports, rules, regulations, directives, teletype messages, written
communications, minutes or notes of meetings, interoffice communications,
reports, financial statements, ledgers, books of account, proposals,
prospectuses, offers, orders, receipts, working papers, desk calendars,
appointment books, diaries, time sheets, logs, movies, tapes for visual or
audio reproduction, recordings, or materials similar to any of the foregoing,
however denominated by Plaintiffs. The term “document” shall also include
all copies of each document if the copies contain any additional matter or
are not identical copies of the originals.
The term “communication” means any transmission or exchange of information
between two or more persons, orally or in writing, and includes, without
limitation, any conversation or discussion, whether face-to-face or by
means of any telephone, telegraph, telecopier, electronic or other media.
The term “or” means both “or” and “and”.
Unless otherwise indicated, all words and terms used in these requests shall have
the same meaning as in the Complaint filed in this action.
Unless otherwise specified, the period covered by these requests shall be from the
date of October 10, 2012 through the date of filing of your response to these
requests.
The use of the singular herein shall be determined to include the plural and the
masculine the feminine, as appropriate in the context.
If objection is taken to any of the following requests, or if Plaintiffs fail(s) to fully
respond to any request, state the specific grounds therefore and respond tosuch request to the extent to which there is no objection. If privilege is
asserted as to any of the documents requested, fully identify for each such
document:
(a) _ its date;
(b) the type of document (e.g., letter, memo, etc.);
(c) the general subject matter;
Documents are to be produced separately in response to each paragraph of these
requests.
The term “all” means “any” and “all”.DOCUMENTS REQUESTED
Any and all documentation relative to your work for the Assignor(s) involving the
subject loss including, but not limited to, the following:
1. Any and all photographs or other visual depictions of the loss location before
and after remediation/extraction services were provided in this case;
Any and all statements, whether verbal or written, recorded or not, of anyone
concerning the subject loss;
Any and all agreements and/or contracts, and/or assignment of rights and benefits
between you and the Assignor(s);
Any and all agreements and/or contracts, and/or assignment of rights and benefits
between you and a third party in this case (i.e., public adjustment firm);
Your entire employment files for all individuals who were involved with water
extraction/remediation services provided to the Assignor(s) at the subject
loss site to include, but not limited to, current contact information for that
individual(s), employment reviews, hiring sheets, disciplinary notices, and
the like;
Timesheets for all individuals who performed any work whatsoever at the home of
the Assignor(s) located at the subject loss site for the date of loss until your
work was completed;
Copies of all correspondence, memoranda and/or other documentation between
you and the Assignor(s);
Copies of all correspondence, memoranda and/or other documentation between
you and the Defendant concerning the subject loss;
Copies of all estimates, invoices, and any other documentation not sought herein,
relating to Assignor(s), and his/her loss which occurred at the subject loss
sight; and
Any and all measurements taken, tests, diagrams made and/or calculations noted
and employed to determine the services to be provided for the loss of
Assignor(s) which occurred at the subject loss location
Copies of your business licenses for the state, city, county or any other local
municipality licenses involving the subject loss.Copies of any and all certifications of yours for water extraction, mold or
remediation and/or other services your company provided.
Copies of any and all testing protocols employed for water extraction, mold
remediation, and/or any other service your company provides.
Copies of any and all testing protocols specifically used and employed for the loss
claim of Assignor(s) at the subject loss location.
Copies of any and all manuals, written, audio and/or visual materials used in or
meant to be used in the training of your employees who engage in the water extraction,
mold remediation and/or other services your company provides.
Any and all documentation which supports your claim for monetary damages
sought in the Initial Complaint.
The copies of all sign in sheets for employees at the subject loss site.
Copies of all documents, manuals, or materials by you in setting equipment rental
rates for equipment identified in your invoice to Defendant.
Copies of all documents, manuals, or materials used by you in setting service rates
for services identified in your invoice to Defendant.
Preview
Filing # 108270665 E-Filed 06/02/2020 02:31:34 PM 21938103 IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO. 19004524CA UNION RESTORATION, INC., a/a/o RAQUEL ESTRADA, Plaintiff, v. EDISON INSURANCE COMPANY, Defendant. / DEFENDANT, EDISON INSURANCE COMPANY’S, FIRST REQUEST FOR PRODUCTION TO PLAINTIFFS, UNION RESTORATION, INC., A/A/(O RAQUEL ESTRADA Defendant, EDISON INSURANCE COMPANY, by and through undersigned counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby requests that Plaintiffs, UNION RESTORATION, INC. a/afo RAQUEL ESTRADA, produce for inspection and copying at the offices of Conroy Simberg, 125 West Romana Street, Suite 320, Pensacola, FL 32502, within thirty (30) days of the date of service of these requests the documents referenced below. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy hereof has been furnished by service through the eportal to Larry Moskowitz, Esq., Larry Moskowitz, P.A., 400 Southeast 9th Street, Fort Lauderdale, FL 33316, Attorney for Plaintiff on this 2"¢ day of June, 2020.CASE NO. 19004524CA CONROY SIMBERG Attorney for Defendant, Edison Insurance Company 125 West Romana Street, Suite 320 Pensacola, FL 32502 Telephone: (850) 436-6605 Facsimile: (850) 436-2102 Primary Email: eservicepns@conroysimberg.com Secondary Email: cvarner@conroysimberg.com By: _/s/ Christopher E. Varner. Christopher E. Varner, Esquire Florida Bar No. 0140147DEFINITIONS AND INSTRUCTIONS As used herein, the following terms are defined as indicated: The terms “you”, “your”, “yours” and “yourself? mean Plaintiffs, UNION RESTORATION, INC. a/a/o RAQUEL ESTRADA. The term “document” means all written, graphic and audio or visually recorded matter of every kind and description, however produced or reproduced, whether draft or final, original or reproduction, in the actual or constructive possession, custody or control of Plaintiffs, including but not limited to plans, drawings, graphs, deeds, title policies, commitments or abstracts, writings, letters, correspondence, memoranda, notes, films, photographs, audio recordings, transcripts, contracts, agreements, covenants, permits, licenses, memoranda of telephone or personal conversations or communications, microfilm, microfiche, telegrams, books, magazines, advertisements, periodicals, bulletins, circulars, pamphlets, statements, notices, reports, rules, regulations, directives, teletype messages, written communications, minutes or notes of meetings, interoffice communications, reports, financial statements, ledgers, books of account, proposals, prospectuses, offers, orders, receipts, working papers, desk calendars, appointment books, diaries, time sheets, logs, movies, tapes for visual or audio reproduction, recordings, or materials similar to any of the foregoing, however denominated by Plaintiffs. The term “document” shall also include all copies of each document if the copies contain any additional matter or are not identical copies of the originals. The term “communication” means any transmission or exchange of information between two or more persons, orally or in writing, and includes, without limitation, any conversation or discussion, whether face-to-face or by means of any telephone, telegraph, telecopier, electronic or other media. The term “or” means both “or” and “and”. Unless otherwise indicated, all words and terms used in these requests shall have the same meaning as in the Complaint filed in this action. Unless otherwise specified, the period covered by these requests shall be from the date of October 10, 2012 through the date of filing of your response to these requests. The use of the singular herein shall be determined to include the plural and the masculine the feminine, as appropriate in the context. If objection is taken to any of the following requests, or if Plaintiffs fail(s) to fully respond to any request, state the specific grounds therefore and respond tosuch request to the extent to which there is no objection. If privilege is asserted as to any of the documents requested, fully identify for each such document: (a) _ its date; (b) the type of document (e.g., letter, memo, etc.); (c) the general subject matter; Documents are to be produced separately in response to each paragraph of these requests. The term “all” means “any” and “all”.DOCUMENTS REQUESTED Any and all documentation relative to your work for the Assignor(s) involving the subject loss including, but not limited to, the following: 1. Any and all photographs or other visual depictions of the loss location before and after remediation/extraction services were provided in this case; Any and all statements, whether verbal or written, recorded or not, of anyone concerning the subject loss; Any and all agreements and/or contracts, and/or assignment of rights and benefits between you and the Assignor(s); Any and all agreements and/or contracts, and/or assignment of rights and benefits between you and a third party in this case (i.e., public adjustment firm); Your entire employment files for all individuals who were involved with water extraction/remediation services provided to the Assignor(s) at the subject loss site to include, but not limited to, current contact information for that individual(s), employment reviews, hiring sheets, disciplinary notices, and the like; Timesheets for all individuals who performed any work whatsoever at the home of the Assignor(s) located at the subject loss site for the date of loss until your work was completed; Copies of all correspondence, memoranda and/or other documentation between you and the Assignor(s); Copies of all correspondence, memoranda and/or other documentation between you and the Defendant concerning the subject loss; Copies of all estimates, invoices, and any other documentation not sought herein, relating to Assignor(s), and his/her loss which occurred at the subject loss sight; and Any and all measurements taken, tests, diagrams made and/or calculations noted and employed to determine the services to be provided for the loss of Assignor(s) which occurred at the subject loss location Copies of your business licenses for the state, city, county or any other local municipality licenses involving the subject loss.Copies of any and all certifications of yours for water extraction, mold or remediation and/or other services your company provided. Copies of any and all testing protocols employed for water extraction, mold remediation, and/or any other service your company provides. Copies of any and all testing protocols specifically used and employed for the loss claim of Assignor(s) at the subject loss location. Copies of any and all manuals, written, audio and/or visual materials used in or meant to be used in the training of your employees who engage in the water extraction, mold remediation and/or other services your company provides. Any and all documentation which supports your claim for monetary damages sought in the Initial Complaint. The copies of all sign in sheets for employees at the subject loss site. Copies of all documents, manuals, or materials by you in setting equipment rental rates for equipment identified in your invoice to Defendant. Copies of all documents, manuals, or materials used by you in setting service rates for services identified in your invoice to Defendant.