On January 02, 2018 a
Request for Production - to Defendant Universal Property and Casualty Insurance CompanyParty: Plaintiff Acosta, Fernando J Plaintiff Acosta, Miriam
was filed
involving a dispute between
Acosta, Fernando J,
Acosta, Miriam,
and
Universal Property And Casualty Insurance Company,
for Contract and Indebtedness
in the District Court of Broward County.
Preview
Case Number: CACE-18-000069 Division: 08
Filing # 65991283 E-Filed 01/02/2018 03:04:02 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
FERNANDO J ACOSTA AND MIRIAM ACOSTA,
Plaintiffs,
Vv.
UNIVERSAL PROPERTY AND CASUALTY
INSURANCE COMPANY,
Defendant. Case No.:
REQUEST FOR PRODUCTION
COMES NOW, Plaintiff(s) by and through the undersigned attorneys and pursuant to the applicable
Florida Rules of Civil Procedure, hereby requests the Defendant to produce the following items for inspection
and/or copying at the offices of the undersigned attorneys:
1. The original and/or a true and correct certified copy of the insurance policy described in the
Complaint including declaration page and all addendums, if any.
2. All correspondence or written communications from Defendant to Plaintiff regarding the subject
loss alleged in the Complaint.
3. Any and all written estimates of repairs created by and/or on behalf of the Defendant regarding
any and all damages to the subject premises allegedly occurring as a result of the subject loss.
4. Copies of all checks issued by Defendant and payable to or on behalf of Plaintiff representing
insurance proceeds for the subject loss alleged in the Complaint.
5. Copies of Plaintiff's recorded statement(s) taken by Defendant or their agents regarding the
subject loss alleged in the Complaint.
6. Copies of Plaintiff's Examination Under Oath Transcript(s) regarding the subject loss alleged in
the Complaint.
7. All delivery receipts, written proof of mailing and all other records evidencing in any manner the
date and/or dates that the entire policy of insurance described in the complaint/Complaint was mailed or
delivered to Plaintiff.
8. Any and all field notes and/or all other documentation of any sort relating to any investigation
undertaken with regard to the Plaintiff's claim prior to Defendant’s reasonably anticipated litigation.
*4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/2/2018 3:03:59 PM.****9. Any and all photographs, video, diagrams, or other documentation depicting the subject loss
and/or relating to the Plaintiff's subject property.
10. The underwriting file relating to the Plaintiff's subject property.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon Defendant
by the Insurance Commissioner of the State of Florida.
MILITZOK & LEVY, P.A.
Attorneys for Plaintiff
The Yankee Clipper Law Center
3230 Stirling Road, Suite 1
Hollywood, Florida 33021
(954) 727-8570 - Telephone
jack@mllawfl.com - E-Mail
michelle@mllawfl.com - Secondary Service
FLService@mllawfl.com - E-Service
By: /s/ Jack Benmeleh
JACK BENMELEH, ESQ.
Florida Bar No.: 62179
Document Filed Date
January 02, 2018
Case Filing Date
January 02, 2018
Category
Contract and Indebtedness
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