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Filing # 122904040 E-Filed 03/11/2021 10:15:35 AM
IN THE CIRCUIT COURT OF THE
FOURTEENTH JUDICIAL CIRCUIT IN
AND FOR WASHINGTON COUNTY,
FLORIDA
Case No.: 19000204CA
TIMOTHY STAEBELL and
SHARON STAEBELL,
Plaintiffs,
Vv.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFFS
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY,
requests that Plaintiffs, TIMOTHY STAEBELL and SHARON STAEBELL, produce the
following documents and items for inspection and copying within thirty (30) days of the date of
service:
DEFINITIONS
The following definitions apply to terms as they are used in this discovery request,
regardless of tense or whether the terms are used in the singular, plural or possessive case:
a. “You” and “your” refers to the party to whom this discovery request is addressed,
including the party’s employees and agents, if any, and all other individuals acting or purporting
to act on the party’s behalf.
b. “Person” and/or “Persons” includes the plural and singular versions of people and
also includes a natural person, corporation, partnership, joint venture, association, government
agency, organization, firm, commission, board, or agency.
c. “Entity” includes all corporations, partnerships, sole proprietorships, individuals
and “person” as that term is defined in these definitions.
Electronically Filed Washington Case # 19000204CAAXMX 03/11/2021 09:15:35 AMd. "Document" means any electronically stored, written, typed, recorded, or graphic
matter, however produced, of any type or description, whether sent or received, including both
sides of originals, known identical copies, and drafts, and including, without limitation, e-mails,
papers, books, letters, correspondence, telegrams, bulletins, notices, announcements, instructions,
charts, manuals, brochures, schedules, cables, telex messages, memoranda, text messages, notes,
notation, accountants’ working papers, transcripts, minutes, agendas, reports, and recordings of
telephone or other conversations, of interviews, of conferences, or of other meetings, affidavits,
statements, summaries, opinions, report studies, analyses, evaluations, contracts, agreements,
journals, statistical records, desk calendars, appointment books, diaries, lists, tabulations, sound
recordings, voicemail recordings, computer printouts, data processing input and output,
microfilms, and other records kept by electronic, photographic or mechanical means, and things
similar to any of the above, however denominated by, and any other documents or electronically
stored information.
e. “Communications” and “Correspondence” means any oral or written statement,
dialogue, colloquialism, discussion, conversation and/or agreement.
f. “Relate to,” “relating to” or “concerning” means to make a statement about, discuss,
describe, reflect, constitute, identify, deal with, refer to, be in connection with or akin to, consist
of, establish, comprise, list, evidence, substantiate or in any way pertain, in whole or in part, to the
subject.
g. "Plaintiffs" means the Plaintiffs named in the caption of this lawsuit.
h. “Personal Property” means any contents or belongings you contend were damaged
or lost as a result of the “Loss.”
i. “Property” means 2624 Greenhead Road, Chipley, FL 32428.
j. “Loss” means the events described by Plaintiffs in the Complaint as covered under
an insurance policy.
k. When producing documents, documents should be identified to correspond with the
particular categories in this request.
1. To “identify” a document means to state: (a) the identity of the person who prepared
the document; (b) the identity of the person who signed the document or in whose name the
document was issued; (c) the identity of each person to whom the document was addressed or
distributed; (d) the nature or substance of the document with sufficient particularity to facilitate
identification of the document. (To the extent you refuse to disclose the nature or substance of the
document, state the nature of the privilege and the circumstances on which you rely in support of
your claim); (e) the document’s date and, if the document bears no date, the date when the
document was prepared; and (f) the physical location and custodian of the document.
m. To “identify” a person with reference to a natural person means to give the person’s
name, the person’s last known address, and, if employed, the name and address of that person’s
employer and job title or position. To identify a person who is not an individual means to state the
name and principal office of that person.INSTRUCTIONS
a. Unless otherwise defined, all words and phrases used herein should be given their
usual meaning and interpreted in their common, ordinary style.
b. This request is continuing so as to require supplemental responses in the event you,
or any person acting on your behalf, obtain additional information between the time of the original
response and conclusion of the trial in this case.
c. With respect to those documents to which you may claim privilege, you are
requested to identify each such document, in writing, on or before the due date of the answers to
these document requests, together with the following information: the nature or description, date,
subject matter and author of the document, as well as the identity of all persons to whom the
document was directed, addressed, or received, and the document request to which the document
corresponds. For each such document you are further required to state the basis for your claim of
privilege, attorneys’ work product, or trial preparation materials.
d. In the event that any requested document or tangible thing is known to have existed
and cannot now be located or has been destroyed or discarded, that document or tangible thing
shall be identified by: (a) the last known custodian; (b) date of destruction or discard; (c) the
manner of destruction or discard; (d) the reason(s) for destruction or discard; (e) as to lost or
misplaced documents or tangible things, the efforts made to locate such documents or tangible
things; (f) a statement describing the document, including a summary of its contents, or the tangible
thing; (g) the identity of the author(s) or creator(s); and (h) persons to whom it was sent or shown.
DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFFS
1. Any and all documents related to any Communication between you or anyone on
your behalf and Defendant, which documents should include but not be limited to letters, electronic
mail, telephone bills showing telephone calls, and online forms and submissions.
2. Any and all documents related to any Communication between you or anyone on
your behalf and any public adjuster concerning the Loss and/or Property, which documents should
include but not be limited to letters, electronic mail, telephone bills showing telephone calls, and
online forms and submissions.
3. Any and all documents related to any Communication between you or anyone on
your behalf and any insurance agent, which documents should include but not be limited to letters,
electronic mail, telephone bills showing telephone calls, and online forms and submissions.
4. Any and all documents related to any Communication between you or anyone on
your behalf and any named insured, which documents should include but not be limited to letters,
electronic mail, telephone bills showing telephone calls, and online forms and submissions.5. Any and all sworn proof of loss forms executed by you or anyone else related to
the Loss.
6. Any and all documents supporting the allegation(s) that you and/or anyone else
complied with your post-loss obligations under the insurance policy, which documents should
include but not be limited to documents showing compliance with the obligations to promptly
report the loss, make reasonable and necessary repairs to protect the property from further damage,
and show the damaged property.
7. Any and all documents that support your position regarding the cause and extent of
the damages to the Property and the necessary cost to repair the Property, and specifically, any
documents substantiating any costs of repair and any damages or estimates for remedial measures
relating to the Property.
8. Any and all detailed invoices showing any services you and/or any person or
company at your direction have performed at the Property.
9. Any and all receipts, invoices and estimates related to any services performed at
the Property by you and/or any person or company at your direction.
10. Any and all written standards, guidelines, or manuals supporting the scope of the
allegedly necessary work.
11. Any and all contracts or agreements between you and any other person or entity
concerning repair of the Property.
12. Any and all documents showing that all persons or entities that have performed
repairs or intends to perform repairs at the Subject Property are licensed to conduct business in
Florida.
13. All and all receipts or related documentation for purchased products utilized in any
Tepairs to the Property.
14. Any and all documents evidencing damage from the Loss to the Property, which
documents may include but not be limited to estimates for repairs, proposals, contracts,
subcontracts, blueprints, invoices, reports, receipts, and correspondence.
15. Any and all documents evidencing expenditures by you or on your behalf for repair
of the Property, which documents may include but not be limited to estimates for repairs,
proposals, contracts, subcontracts, blueprints, canceled checks for repairs, receipts, invoices, other
evidence of payments for such repairs, reconstruction, modification or restoration of the Property.
16. Any and all engineering reports, incident reports, statements, general contractor’s
reports, or other investigation-related documents showing an opinion regarding the cause, origin
and/or extent of the damage arising from the Loss.17. ‘If as part of this litigation you will seek reimbursement/indemnification for
replacement or rebuilding of any structure or appurtenance allegedly damaged in the Loss, produce
any and all documents evidencing the repair and/or replacement of any such property, including
but not limited to estimates, proposals, contracts, subcontracts, cancelled checks, credit card slips,
brochures, appraisals, invoices, receipts, and purchase orders.
18. If as part of this litigation you will seek reimbursement/indemnification for
replacement or repair of any Personal Property allegedly damaged in the Loss, produce any and
all documents evidencing the repair and/or replacement of any such property, including but not
limited to estimates, proposals, contracts, subcontracts, cancelled checks, credit card slips,
brochures, appraisals, invoices, receipts, and purchase orders.
19. Any and all documents and/or records relating to any aspect of the insurance claim
submitted to any insurance company regarding the Loss.
20. Anyand all photographs or other illustrative representations of the Property or areas
of the Property, which photographs or illustrative representations show the Property or any
portions of the Property before the alleged date that the Loss occurred.
21. Anyand all photographs or other illustrative representations of the Property or areas
of the Property, which photographs or illustrative representations show the Property or any
portions of the Property after the alleged date that the Loss occurred.
22. Any and all records pertaining to the rental or lease of the Property in the past five
(5) years, which documents should include but not be limited to any and all lease agreements,
cancelled checks, and contact information for any and all tenants.
23. Any and all documents relating to any lawsuit involving, in any way, the Property,
including but not limited to any mortgage foreclosure actions and/or bankruptcies.
24. Any and all documents relating to any lawsuit involving you, in any way, including
but not limited to any lawsuits that arise from you filing a lawsuit against an insurance company.
25. Any and all correspondence related to the Property between you or anyone and any
mortgagee and/or note holder, which documents should include but not be limited to any
correspondence concerning foreclosure, a risk of foreclosure, mortgage modifications, and/or any
related documents.
26. Any and all lease agreements for the Property.
27. Any and all insurance policies that may provide insurance coverage for the Loss
(whether you submitted a claim to each insurer or not), and any and all correspondence,
applications, memoranda, policies, and any other documents relating to said policies of insurance,
including any and all notices of cancellation or requests for premiums.28. Any and all contracts, subcontracts, blueprints, estimates, invoices, proposals,
statements, receipts, canceled checks, receipts, invoices and other evidence of payments, and any
and all other documents relating to repairs, remodeling, restoration or maintenance performed at
the Property in the last ten (10) years.
29. Any and all documents relating to any prior insurance claims regarding property
damage made by you or any resident of the Property.
30. Any and all inspection reports, photographs, disclosures, and/or related
documentation showing the Property had any damage of any kind at the time of purchase.
31. Any and all inspection reports, photographs, disclosures, and/or related
documentation showing the Property had any damage of any kind prior to the Loss.
32. Any and all documents related to any purchase and/or sale of the Property, which
documents should include but not be limited to construction contracts, any deeds evidencing your
ownership of the Property, and seller’s disclosures.
33. Any and all notes and mortgages related to the Property from the date of purchase
through the present time.
34. Any and all documents showing you or anyone else have made any attempt to
distinguish for Defendant the claimed damage from any prior damage existing at the Property
before the Loss.
35. Any and all documents related to any damage at the Property not being alleged as
a part of the claimed damages in your Complaint.
36. Any and all documents evidencing damage from sources other than the Loss to the
Property, which documents may include but not be limited to estimates for repairs, proposals,
contracts, subcontracts, blueprints, invoices, reports, receipts, and correspondence.
37. A copy of each resume, curriculum vitae, and other document listing the
qualifications of each and every expert and/or consultant hired by you or on behalf of you who
may testify at trial.
38. A copy of any and all medical records related to medical conditions that have
manifested for the first time after the date of loss.
39. A copy of any and all medical records related to medical treatment obtained for
Plaintiff Timothy Staebell's sleep apnea diagnosis.
40. A copy of any and all records pertaining to the antibiotic medication prescribed to
Timothy Staebell by Wendy Corbin, per Mr. Staebell's deposition testimony.CERTIFICATE OF SERVICE
THEREBY CERTIFY that this document was filed using the Florida Courts E-Filing Portal
pursuant to and in compliance with Fla. R. Jud. Admin. 2.516 and a copy hereof has been furnished
via email to: Mohammad Mubarak, Esq, Attorney for Plaintiff, Mubarak & Sherif, PLLC at
mmubarak@baraksherif.com; msherif@mubaraksherif.com; and mlopretto@mubaraksherif.com
on this 11th day of March, 2021.
KELLEY KRONENBERG
/s/ Kimberly J. Fernandes
Kimberly J. Fernandes, Esq.
Fla. Bar No.: 0094536
6267 Old Water Oak Road, Suite 202
Tallahassee, FL 32312
Telephone: (850) 577-1301
Facsimile: (850) 391-5782
Attorneys for Universal Property & Casualty
Insurance Company
Address for service of pleadings only:
kfernandes@kelleykronenberg.com
Imaxwell@kelleykronenberg.com
Preview
Filing # 122904040 E-Filed 03/11/2021 10:15:35 AM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR WASHINGTON COUNTY, FLORIDA Case No.: 19000204CA TIMOTHY STAEBELL and SHARON STAEBELL, Plaintiffs, Vv. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFFS Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, requests that Plaintiffs, TIMOTHY STAEBELL and SHARON STAEBELL, produce the following documents and items for inspection and copying within thirty (30) days of the date of service: DEFINITIONS The following definitions apply to terms as they are used in this discovery request, regardless of tense or whether the terms are used in the singular, plural or possessive case: a. “You” and “your” refers to the party to whom this discovery request is addressed, including the party’s employees and agents, if any, and all other individuals acting or purporting to act on the party’s behalf. b. “Person” and/or “Persons” includes the plural and singular versions of people and also includes a natural person, corporation, partnership, joint venture, association, government agency, organization, firm, commission, board, or agency. c. “Entity” includes all corporations, partnerships, sole proprietorships, individuals and “person” as that term is defined in these definitions. Electronically Filed Washington Case # 19000204CAAXMX 03/11/2021 09:15:35 AMd. "Document" means any electronically stored, written, typed, recorded, or graphic matter, however produced, of any type or description, whether sent or received, including both sides of originals, known identical copies, and drafts, and including, without limitation, e-mails, papers, books, letters, correspondence, telegrams, bulletins, notices, announcements, instructions, charts, manuals, brochures, schedules, cables, telex messages, memoranda, text messages, notes, notation, accountants’ working papers, transcripts, minutes, agendas, reports, and recordings of telephone or other conversations, of interviews, of conferences, or of other meetings, affidavits, statements, summaries, opinions, report studies, analyses, evaluations, contracts, agreements, journals, statistical records, desk calendars, appointment books, diaries, lists, tabulations, sound recordings, voicemail recordings, computer printouts, data processing input and output, microfilms, and other records kept by electronic, photographic or mechanical means, and things similar to any of the above, however denominated by, and any other documents or electronically stored information. e. “Communications” and “Correspondence” means any oral or written statement, dialogue, colloquialism, discussion, conversation and/or agreement. f. “Relate to,” “relating to” or “concerning” means to make a statement about, discuss, describe, reflect, constitute, identify, deal with, refer to, be in connection with or akin to, consist of, establish, comprise, list, evidence, substantiate or in any way pertain, in whole or in part, to the subject. g. "Plaintiffs" means the Plaintiffs named in the caption of this lawsuit. h. “Personal Property” means any contents or belongings you contend were damaged or lost as a result of the “Loss.” i. “Property” means 2624 Greenhead Road, Chipley, FL 32428. j. “Loss” means the events described by Plaintiffs in the Complaint as covered under an insurance policy. k. When producing documents, documents should be identified to correspond with the particular categories in this request. 1. To “identify” a document means to state: (a) the identity of the person who prepared the document; (b) the identity of the person who signed the document or in whose name the document was issued; (c) the identity of each person to whom the document was addressed or distributed; (d) the nature or substance of the document with sufficient particularity to facilitate identification of the document. (To the extent you refuse to disclose the nature or substance of the document, state the nature of the privilege and the circumstances on which you rely in support of your claim); (e) the document’s date and, if the document bears no date, the date when the document was prepared; and (f) the physical location and custodian of the document. m. To “identify” a person with reference to a natural person means to give the person’s name, the person’s last known address, and, if employed, the name and address of that person’s employer and job title or position. To identify a person who is not an individual means to state the name and principal office of that person.INSTRUCTIONS a. Unless otherwise defined, all words and phrases used herein should be given their usual meaning and interpreted in their common, ordinary style. b. This request is continuing so as to require supplemental responses in the event you, or any person acting on your behalf, obtain additional information between the time of the original response and conclusion of the trial in this case. c. With respect to those documents to which you may claim privilege, you are requested to identify each such document, in writing, on or before the due date of the answers to these document requests, together with the following information: the nature or description, date, subject matter and author of the document, as well as the identity of all persons to whom the document was directed, addressed, or received, and the document request to which the document corresponds. For each such document you are further required to state the basis for your claim of privilege, attorneys’ work product, or trial preparation materials. d. In the event that any requested document or tangible thing is known to have existed and cannot now be located or has been destroyed or discarded, that document or tangible thing shall be identified by: (a) the last known custodian; (b) date of destruction or discard; (c) the manner of destruction or discard; (d) the reason(s) for destruction or discard; (e) as to lost or misplaced documents or tangible things, the efforts made to locate such documents or tangible things; (f) a statement describing the document, including a summary of its contents, or the tangible thing; (g) the identity of the author(s) or creator(s); and (h) persons to whom it was sent or shown. DEFENDANT’S REQUEST TO PRODUCE TO PLAINTIFFS 1. Any and all documents related to any Communication between you or anyone on your behalf and Defendant, which documents should include but not be limited to letters, electronic mail, telephone bills showing telephone calls, and online forms and submissions. 2. Any and all documents related to any Communication between you or anyone on your behalf and any public adjuster concerning the Loss and/or Property, which documents should include but not be limited to letters, electronic mail, telephone bills showing telephone calls, and online forms and submissions. 3. Any and all documents related to any Communication between you or anyone on your behalf and any insurance agent, which documents should include but not be limited to letters, electronic mail, telephone bills showing telephone calls, and online forms and submissions. 4. Any and all documents related to any Communication between you or anyone on your behalf and any named insured, which documents should include but not be limited to letters, electronic mail, telephone bills showing telephone calls, and online forms and submissions.5. Any and all sworn proof of loss forms executed by you or anyone else related to the Loss. 6. Any and all documents supporting the allegation(s) that you and/or anyone else complied with your post-loss obligations under the insurance policy, which documents should include but not be limited to documents showing compliance with the obligations to promptly report the loss, make reasonable and necessary repairs to protect the property from further damage, and show the damaged property. 7. Any and all documents that support your position regarding the cause and extent of the damages to the Property and the necessary cost to repair the Property, and specifically, any documents substantiating any costs of repair and any damages or estimates for remedial measures relating to the Property. 8. Any and all detailed invoices showing any services you and/or any person or company at your direction have performed at the Property. 9. Any and all receipts, invoices and estimates related to any services performed at the Property by you and/or any person or company at your direction. 10. Any and all written standards, guidelines, or manuals supporting the scope of the allegedly necessary work. 11. Any and all contracts or agreements between you and any other person or entity concerning repair of the Property. 12. Any and all documents showing that all persons or entities that have performed repairs or intends to perform repairs at the Subject Property are licensed to conduct business in Florida. 13. All and all receipts or related documentation for purchased products utilized in any Tepairs to the Property. 14. Any and all documents evidencing damage from the Loss to the Property, which documents may include but not be limited to estimates for repairs, proposals, contracts, subcontracts, blueprints, invoices, reports, receipts, and correspondence. 15. Any and all documents evidencing expenditures by you or on your behalf for repair of the Property, which documents may include but not be limited to estimates for repairs, proposals, contracts, subcontracts, blueprints, canceled checks for repairs, receipts, invoices, other evidence of payments for such repairs, reconstruction, modification or restoration of the Property. 16. Any and all engineering reports, incident reports, statements, general contractor’s reports, or other investigation-related documents showing an opinion regarding the cause, origin and/or extent of the damage arising from the Loss.17. ‘If as part of this litigation you will seek reimbursement/indemnification for replacement or rebuilding of any structure or appurtenance allegedly damaged in the Loss, produce any and all documents evidencing the repair and/or replacement of any such property, including but not limited to estimates, proposals, contracts, subcontracts, cancelled checks, credit card slips, brochures, appraisals, invoices, receipts, and purchase orders. 18. If as part of this litigation you will seek reimbursement/indemnification for replacement or repair of any Personal Property allegedly damaged in the Loss, produce any and all documents evidencing the repair and/or replacement of any such property, including but not limited to estimates, proposals, contracts, subcontracts, cancelled checks, credit card slips, brochures, appraisals, invoices, receipts, and purchase orders. 19. Any and all documents and/or records relating to any aspect of the insurance claim submitted to any insurance company regarding the Loss. 20. Anyand all photographs or other illustrative representations of the Property or areas of the Property, which photographs or illustrative representations show the Property or any portions of the Property before the alleged date that the Loss occurred. 21. Anyand all photographs or other illustrative representations of the Property or areas of the Property, which photographs or illustrative representations show the Property or any portions of the Property after the alleged date that the Loss occurred. 22. Any and all records pertaining to the rental or lease of the Property in the past five (5) years, which documents should include but not be limited to any and all lease agreements, cancelled checks, and contact information for any and all tenants. 23. Any and all documents relating to any lawsuit involving, in any way, the Property, including but not limited to any mortgage foreclosure actions and/or bankruptcies. 24. Any and all documents relating to any lawsuit involving you, in any way, including but not limited to any lawsuits that arise from you filing a lawsuit against an insurance company. 25. Any and all correspondence related to the Property between you or anyone and any mortgagee and/or note holder, which documents should include but not be limited to any correspondence concerning foreclosure, a risk of foreclosure, mortgage modifications, and/or any related documents. 26. Any and all lease agreements for the Property. 27. Any and all insurance policies that may provide insurance coverage for the Loss (whether you submitted a claim to each insurer or not), and any and all correspondence, applications, memoranda, policies, and any other documents relating to said policies of insurance, including any and all notices of cancellation or requests for premiums.28. Any and all contracts, subcontracts, blueprints, estimates, invoices, proposals, statements, receipts, canceled checks, receipts, invoices and other evidence of payments, and any and all other documents relating to repairs, remodeling, restoration or maintenance performed at the Property in the last ten (10) years. 29. Any and all documents relating to any prior insurance claims regarding property damage made by you or any resident of the Property. 30. Any and all inspection reports, photographs, disclosures, and/or related documentation showing the Property had any damage of any kind at the time of purchase. 31. Any and all inspection reports, photographs, disclosures, and/or related documentation showing the Property had any damage of any kind prior to the Loss. 32. Any and all documents related to any purchase and/or sale of the Property, which documents should include but not be limited to construction contracts, any deeds evidencing your ownership of the Property, and seller’s disclosures. 33. Any and all notes and mortgages related to the Property from the date of purchase through the present time. 34. Any and all documents showing you or anyone else have made any attempt to distinguish for Defendant the claimed damage from any prior damage existing at the Property before the Loss. 35. Any and all documents related to any damage at the Property not being alleged as a part of the claimed damages in your Complaint. 36. Any and all documents evidencing damage from sources other than the Loss to the Property, which documents may include but not be limited to estimates for repairs, proposals, contracts, subcontracts, blueprints, invoices, reports, receipts, and correspondence. 37. A copy of each resume, curriculum vitae, and other document listing the qualifications of each and every expert and/or consultant hired by you or on behalf of you who may testify at trial. 38. A copy of any and all medical records related to medical conditions that have manifested for the first time after the date of loss. 39. A copy of any and all medical records related to medical treatment obtained for Plaintiff Timothy Staebell's sleep apnea diagnosis. 40. A copy of any and all records pertaining to the antibiotic medication prescribed to Timothy Staebell by Wendy Corbin, per Mr. Staebell's deposition testimony.CERTIFICATE OF SERVICE THEREBY CERTIFY that this document was filed using the Florida Courts E-Filing Portal pursuant to and in compliance with Fla. R. Jud. Admin. 2.516 and a copy hereof has been furnished via email to: Mohammad Mubarak, Esq, Attorney for Plaintiff, Mubarak & Sherif, PLLC at mmubarak@baraksherif.com; msherif@mubaraksherif.com; and mlopretto@mubaraksherif.com on this 11th day of March, 2021. KELLEY KRONENBERG /s/ Kimberly J. Fernandes Kimberly J. Fernandes, Esq. Fla. Bar No.: 0094536 6267 Old Water Oak Road, Suite 202 Tallahassee, FL 32312 Telephone: (850) 577-1301 Facsimile: (850) 391-5782 Attorneys for Universal Property & Casualty Insurance Company Address for service of pleadings only: kfernandes@kelleykronenberg.com Imaxwell@kelleykronenberg.com