On January 31, 2020 a
Party Discovery
was filed
involving a dispute between
Christensen, Jarae,
Christensen, Michael,
and
United Property & Casualty Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 102552267 E-Filed 01/31/2020 11:20:52 AM
IN THE CIRCUIT COURT IN AND FOR BAY COUNTY, FLORIDA
MICHAEL CHRISTENSEN and JARAE CASE NO, 20000239CA
CHRISTENSEN,
Plaintiff,
vs.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
REQUEST FOR PRODUCTION
“Florida Bar #218261
COMES NOW Plaintiffs, (hereinafter collectively referred to as “Plaintiff”), by and through
the undersigned attorneys, and hereby requests the Defendant to produce the following items for
inspection and/or copying at the office of the undersigned attorneys within the time prescribed by
the applicable rules of civil procedure:
1. A true and correct certified copy of the insurance policy described in the Complaint,
including all declaration sheet(s), addendums and attachments.
2. All photographs taken by Defendant's adjuster during the initial inspection of
the claimed loss.
3. Copies of all photographs taken during Defendant’s investigation conducted during
the normal business of evaluating the claim.
4, All estimates of damage prepared by or on behalf of Defendant after its initial
inspection of the claimed loss.
5. Copies of all damage estimates prepared during Defendant’s investigation conducted
during the normal business of evaluating the claim.
6. All letters, faxes, email communications, and log notes from Defendant's adjusters
or agents which in any manner references any and all damages or causes of loss observed that were
prepared or generated during Defendant’s investigation conducted during the normal business of
evaluating the claim.
DUBOFF7. Defendant’s entire claim file from the date of the initial notice of the loss until the
day before Defendant knew that Defendant was going to deny any further payment or litigate the
claim.
8. Defendant’s entire claim file for the entire time that the claim was being handled by
Defendant not in anticipation of litigation for the loss
9. Any and all correspondence or written communications from Defendant, or its agents
to Plaintiff, or his agents, which in any manner pertain to Plaintiff's alleged loss as described in the
Complaint.
10. Any and all correspondence or written communications from Plaintiff, or his agents
to Defendant, or its agents, which in any manner pertain to Plaintiff's alleged loss as described in
the Complaint.
11. Any and all photographs taken by the Defendant or Defendant’s agents showing the
extent of damage to the insured premises involved herein as were taken prior to the filing of this
lawsuit.
12. Any and all tape recordings of any statements made by Plaintiff or Plaintiff's agents
or employees.
13. Any an all transcripts or written statements from the Plaintiff(s) including, without
limitation, transcripts of examinations under oath.
14. Copies of each and every bill or estimate for repair to the subject property submitted
to Defendant by Plaintiff or Plaintiff's agents or employees.
15. Any and all written estimates or reports reflecting examination or inspection by
Defendant or Defendant’s agents of any of the alleged damage to the insured premises.
16. All documents relating to or supporting Defendant’s denial of any allegation of
Plaintiff's Complaint.
17. All documents relating to or supporting each of Defendant’s affirmative or general
defenses asserted by Defendant.
18. All underwriting files pertaining to the policy of insurance described in the
Complaint/Petition.
19. Any and all documents related to any and all other insurance claims made by
Plaintiff(s) which are not the subject of this action, including estimates, reports, pictures, cancelled
DUBOFFchecks, releases, proofs of loss, recorded statements, transcripts of examinations under oath, and
correspondence by and between the parties related to any and all said other claims.
20. Any and ali brochures, summary statements, pamphlets and advertising materials
prepared by or on behalf of Defendant and disseminated to insurance agencies or policyholders
which in any manner describe the coverages and/or exclusions under the same type of policy
involved in this action.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served
upon Defendant by the Florida Department of Financial Services together with the initial service
of process in this action.
DUBOFF LAW FIRM
ATTORNEYS FOR PLAINTIFF
680 N.E. 127 STREET
NORTH MIAMI, FLORIDA 33161
TELEPHONE (305) 899-0085
Fax No. (305) 899-0091
EMaiL: COURTDOCUMENT@DUBOFFLAWFIRM.COM
By: _/s KENNETH R. DUBOFF
KENNETH R. DUBOFF, ESQ.
FLA. BAR #218261
or so
Document Filed Date
January 31, 2020
Case Filing Date
January 31, 2020
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Filing # 102552267 E-Filed 01/31/2020 11:20:52 AM IN THE CIRCUIT COURT IN AND FOR BAY COUNTY, FLORIDA MICHAEL CHRISTENSEN and JARAE CASE NO, 20000239CA CHRISTENSEN, Plaintiff, vs. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. REQUEST FOR PRODUCTION “Florida Bar #218261 COMES NOW Plaintiffs, (hereinafter collectively referred to as “Plaintiff”), by and through the undersigned attorneys, and hereby requests the Defendant to produce the following items for inspection and/or copying at the office of the undersigned attorneys within the time prescribed by the applicable rules of civil procedure: 1. A true and correct certified copy of the insurance policy described in the Complaint, including all declaration sheet(s), addendums and attachments. 2. All photographs taken by Defendant's adjuster during the initial inspection of the claimed loss. 3. Copies of all photographs taken during Defendant’s investigation conducted during the normal business of evaluating the claim. 4, All estimates of damage prepared by or on behalf of Defendant after its initial inspection of the claimed loss. 5. Copies of all damage estimates prepared during Defendant’s investigation conducted during the normal business of evaluating the claim. 6. All letters, faxes, email communications, and log notes from Defendant's adjusters or agents which in any manner references any and all damages or causes of loss observed that were prepared or generated during Defendant’s investigation conducted during the normal business of evaluating the claim. DUBOFF7. Defendant’s entire claim file from the date of the initial notice of the loss until the day before Defendant knew that Defendant was going to deny any further payment or litigate the claim. 8. Defendant’s entire claim file for the entire time that the claim was being handled by Defendant not in anticipation of litigation for the loss 9. Any and all correspondence or written communications from Defendant, or its agents to Plaintiff, or his agents, which in any manner pertain to Plaintiff's alleged loss as described in the Complaint. 10. Any and all correspondence or written communications from Plaintiff, or his agents to Defendant, or its agents, which in any manner pertain to Plaintiff's alleged loss as described in the Complaint. 11. Any and all photographs taken by the Defendant or Defendant’s agents showing the extent of damage to the insured premises involved herein as were taken prior to the filing of this lawsuit. 12. Any and all tape recordings of any statements made by Plaintiff or Plaintiff's agents or employees. 13. Any an all transcripts or written statements from the Plaintiff(s) including, without limitation, transcripts of examinations under oath. 14. Copies of each and every bill or estimate for repair to the subject property submitted to Defendant by Plaintiff or Plaintiff's agents or employees. 15. Any and all written estimates or reports reflecting examination or inspection by Defendant or Defendant’s agents of any of the alleged damage to the insured premises. 16. All documents relating to or supporting Defendant’s denial of any allegation of Plaintiff's Complaint. 17. All documents relating to or supporting each of Defendant’s affirmative or general defenses asserted by Defendant. 18. All underwriting files pertaining to the policy of insurance described in the Complaint/Petition. 19. Any and all documents related to any and all other insurance claims made by Plaintiff(s) which are not the subject of this action, including estimates, reports, pictures, cancelled DUBOFFchecks, releases, proofs of loss, recorded statements, transcripts of examinations under oath, and correspondence by and between the parties related to any and all said other claims. 20. Any and ali brochures, summary statements, pamphlets and advertising materials prepared by or on behalf of Defendant and disseminated to insurance agencies or policyholders which in any manner describe the coverages and/or exclusions under the same type of policy involved in this action. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon Defendant by the Florida Department of Financial Services together with the initial service of process in this action. DUBOFF LAW FIRM ATTORNEYS FOR PLAINTIFF 680 N.E. 127 STREET NORTH MIAMI, FLORIDA 33161 TELEPHONE (305) 899-0085 Fax No. (305) 899-0091 EMaiL: COURTDOCUMENT@DUBOFFLAWFIRM.COM By: _/s KENNETH R. DUBOFF KENNETH R. DUBOFF, ESQ. FLA. BAR #218261 or so