Preview
Filing # 91958398 E-Filed 07/01/2019 05:02:51 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICAL CIRCUIT, IN AND FOR
ORANGE COUNTY, FLORIDA
MARIA LAFLEUR, CASE NO.: 2017-CA-004500-O
Plaintiff,
v.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
_____________________________________/
UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY’S MOTION TO
COMPEL ENTRY UPON LAND FOR INSPECTION
Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY
(“Universal”), by and through the undersigned counsel, hereby files its Motion to Compel Entry
Upon Land for Inspection pursuant to Fla. R. Civ. P. 1.350(a) and states as follows:
1. This is a first-party breach of contract claim arising from wind damage which
allegedly occurred on or about July 5, 2015.
2. On September 21, 2018, this Court entered a Uniform Order Setting Case for Jury
Trial; Pre-Trial Conference and Requiring Pretrial Matters to be Completed, setting this matter on
the jury trial docket commencing on October 7, 2019.
3. On June 27, 2019, Defendant requested an inspection of the subject property. In its
correspondence, Universal identified the name of the inspector, Brian DuChene, with Terracon
and proposed dates and times for the site inspection to take place.
4. On July 1, 2019, Joshua Blacksten, counsel for Plaintiff advised that a request
needed to be submitted in writing. Mr. Blacksten further advised that his office would object,
stating “the inspection is unnecessary as your client inspected pre-suit and the sufficiency of its
Maria LaFleur v. UPCIC
CASE NO. 2017-CA-004500-O
Page 2 of 4
coverage position (which is the ultimate question of fact/law to be determined) is based on that
inspection.” A copy of the correspondence to/from Plaintiff’s counsel is attached hereto as Exhibit
“A.”
5. Aside from Plaintiff’s counsel opinion, Plaintiff has failed to provide any
explanation as to why or what Plaintiff’s attorney opposes.
6. Despite the “objection,” by Plaintiff’s counsel’s lack of response, the Florida Rules
of Civil Procedure states as follows:
RULE 1.350. PRODUCTION OF DOCUMENTS AND THINGS
AND ENTRY UPON LAND FOR INSPECTION AND OTHER
PURPOSES
(a) Request; Scope. Any party may request any other party (1)
to produce and permit the party making the request, or someone
acting in the requesting party’s behalf, to inspect and copy any
designated documents, including electronically stored information,
writings, drawings, graphs, charts, photographs, phono-records, and
other data compilations from which information can be obtained,
translated, if necessary, by the party to whom the request is directed
through detection devices into reasonably usable form, that
constitute or contain matters within the scope of rule 1.280(b) and
that are in the possession, custody, or control of the party to whom
the request is directed; (2) to inspect and copy, test, or sample any
tangible things that constitute or contain matters within the scope of
rule 1.280(b) and that are in the possession, custody, or control of
the party to whom the request is directed; or (3) to permit entry upon
designated land or other property in the possession or control of the
party upon whom the request is served for the purpose of inspection
and measuring, surveying, photographing, testing, or sampling the
property or any designated object or operation on it within the scope
of rule 1.280(b).
7. Further, Rule 1.280, states:
RULE 1.280. GENERAL PROVISIONS GOVERNING
DISCOVERY
(a) Discovery Methods. Parties may obtain discovery by one or
more of the following methods: depositions upon oral examination
or written questions; written interrogatories; production of
Maria LaFleur v. UPCIC
CASE NO. 2017-CA-004500-O
Page 3 of 4
documents or things or permission to enter upon land or other
property for inspection and other purposes; physical and mental
examinations; and requests for admission. Unless the court orders
otherwise and under subdivision (c) of this rule, the frequency of use
of these methods is not limited, except as provided in rules 1.200,
1.340, and 1.370.
8. To-date, Plaintiff’s counsel has refused to allow entry and/or propose any dates of
availability, despite Universal’s request.
9. Plaintiff’s counsel has failed to provide an explanation and/or clarification as to the
reason for any alleged opposition.
10. Pursuant to the trial order, the discovery cut-off is September 3, 2019.
11. Based on Plaintiff’s intentional delay in coordinating an agreed upon date to
conduct the site inspection (as requested by Defendant) and given the time constraints with trial
approaching, the undersigned has been forced to file the instant Motion.
12. Without being able to conduct the investigation of the subject premises, Universal
will be prejudiced in its defense of this matter.
13. Pursuant to Fla. R. Civ. P. 1.350(a), Universal requests that the Court allow it an
opportunity to conduct a site inspection of the subject residence in an effort to facilitate the subject
lawsuit.
14. If granted, Universal will coordinate a date and time convenient to all parties and
in accordance with any Order issued by the Court.
15. This Motion is not being filed for purposes of delay and inspection of the subject
residence will not prejudice either party.
16. The undersigned Counsel for the Defendant certifies that he has, in good faith,
conferred or attempted to confer with counsel for the Plaintiff in an effort to resolve this dispute
without court action but has been unable to do so.
Maria LaFleur v. UPCIC
CASE NO. 2017-CA-004500-O
Page 4 of 4
WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests
this Court to enter an Order allowing 1) Universal the ability to enter the residence of the Plaintiff
to perform a site inspection of the alleged damages in this matter, 2) to pay reasonable attorney’s
fees and costs to the Defendant for bringing this Motion; and 3) to grant any and all other relief
this Court deems just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing has been furnished by electronic
filing to: Kenneth R. Duboff, Esq., (courtdocument@dubofflawfirm.com) on this 1st day of July,
2019.
Attorneys for Defendant
Universal Property & Casualty Ins. Co.
1855 West State Road 434, Suite 282
Longwood, Florida 32750
Telephone: 833-658-8594
Facsimile: 954-958-1262
By: /s/ Jason R. Urbanowicz, Esq.
Jason R. Urbanowicz, Esq.
Florida Bar No. 391026
For Service of Court Documents only:
Primary: upciceservice05@universalproperty.com
Secondary: lb1101@universalproperty.com
Tertiary: ju1010@universalproperty.com
Ashley Waisanen
From: Ashley Waisanen
Sent: Monday, July 1, 2019 4:24 PM
To: Joshua Blacksten, Esq.
Cc: libia@dubofflawfirm.com; Andrea Stratford
Subject: RE: LaFleur v. UPCIC - Request for Site Inspection
Thank you for the clarification, we will proceed with a motion to compel.
From: Joshua Blacksten, Esq.
Sent: Monday, July 1, 2019 4:18 PM
To: Ashley Waisanen
Cc: libia@dubofflawfirm.com; Andrea Stratford
Subject: RE: LaFleur v. UPCIC ‐ Request for Site Inspection
The request shall set forth the items to be inspected, either by individual item or category, and
describe each item and category with reasonable particularity. The request shall specify a
reasonable time, place, and manner of making the inspection or performing the related acts.
And, once you do that, please be advised that we shall object as the inspection is unnecessary as
your client inspected pre-suit and the sufficiency of its coverage position (which is the ultimate
question of fact/law to be determined) is based on that inspection.
From: Ashley Waisanen
Sent: Monday, July 1, 2019 2:56 PM
To: Joshua Blacksten, Esq.
Cc: libia@dubofflawfirm.com; Andrea Stratford
Subject: RE: LaFleur v. UPCIC ‐ Request for Site Inspection
Good afternoon,
I just want to clarify that you are referring to rule 1.350 where requests may be made without leave of court? As you know,
this matter is set for trial.
Are you indicating that you are requiring a court order in order to conduct a site inspection?
Please confirm so that we may proceed accordingly.
Thank you.
1.350 Production of Documents and Things and Entry Upon Land for Inspection
(a) Request; Scope. Any party may request any other party (1) to produce and permit the party making the request, or someone
acting in the requesting party’s behalf, to inspect and copy any designated documents, including electronically stored
information, writings, drawings, graphs, charts, photographs, phono‐records, and other data compilations from which
information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices
into reasonably usable form, that constitute or contain matters within the scope of rule 1.280(b) and that are in the possession,
custody, or control of the party to whom the request is directed; (2) to inspect and copy, test, or sample any tangible things
1
Exhibit "A"
that constitute or contain matters within the scope of rule 1.280(b) and that are in the possession, custody, or control of the
party to whom the request is directed; or (3) to permit entry upon designated land or other property in the possession or
control of the party upon whom the request is served for the purpose of inspection and measuring, surveying, photographing,
testing, or sampling the property or any designated object or operation on it within the scope of rule 1.280(b).
(b) Procedure.Without leave of court the request may be served on the plaintiff after commencement of the action and on any
other party with or after service of the process and initial pleading on that party. The request shall set forth the items to be
inspected, either by individual item or category, and describe each item and category with reasonable particularity. The request
shall specify a reasonable time, place, and manner of making the inspection or performing the related acts. The party to whom
the request is directed shall serve a written response within 30 days after service of the request, except that a defendant may
serve a response within 45 days after service of the process and initial pleading on that defendant. The court may allow a
shorter or longer time. For each item or category the response shall state that inspection and related activities will be permitted
as requested unless the request is objected to, in which event the reasons for the objection shall be stated. If an objection is
made to part of an item or category, the part shall be specified. When producing documents, the producing party shall either
produce them as they are kept in the usual course of business or shall identify them to correspond with the categories in the
request. A request for electronically stored information may specify the form or forms in which electronically stored
information is to be produced. If the responding party objects to a requested form, or if no form is specified in the request, the
responding party must state the form or forms it intends to use. If a request for electronically stored information does not
specify the form of production, the producing party must produce the information in a form or forms in which it is ordinarily
maintained or in a reasonably usable form or forms. The party submitting the request may move for an order under rule 1.380
concerning any objection, failure to respond to the request, or any part of it, or failure to permit inspection as requested.
(c) Persons Not Parties. This rule does not preclude an independent action against a person not a party for production of
documents and things and permission to enter upon land.
(d) Filing of Documents. Unless required by the court, a party shall not file any of the documents or things produced with the
response. Documents or things may be filed in compliance with Florida Rule of Judicial Administration 2.425 and rule 1.280(g)
when they should be considered by the court in determining a matter pending before the court.
Ashley Waisanen
Paralegal
Alder Adjusting Corporation
(W): (954) 958-1200 ext:6701
www.universalproperty.com
Join us and GO GREEN! Go paperless with Universal.
Confidentiality Notice: This e-mail message, including
any attachments, is for the sole use of the intended recipient(s) and may
contain confidential and privileged information. Any unauthorized review, use,
disclosure or distribution is prohibited. If you are not the intended recipient
and received this in error, please contact the sender by reply e-mail. You are
hereby notified that the copying, use or distribution of any information or
materials transmitted in or with this message is strictly prohibited.
From: Joshua Blacksten, Esq.
Sent: Monday, July 1, 2019 2:28 PM
To: Ashley Waisanen
Cc: libia@dubofflawfirm.com
Subject: RE: LaFleur v. UPCIC ‐ Request for Site Inspection
2
If you would like to inspect, please seek leave as provided by the rules.
From: Kenneth Duboff
Sent: Monday, July 1, 2019 10:46 AM
To: 'DLF'
Subject: FW: LaFleur v. UPCIC ‐ Request for Site Inspection
Importance: High
Please review this
Kenneth R. Duboff, Esq.
680 NE 127th Street
North Miami, Florida 33161
Office: 305-899-0085
www.dubofflawfirm.com
KDuboff@dubofflawfirm.com
From: Ashley Waisanen
Sent: Thursday, June 27, 2019 11:09 AM
To: courtdocument@dubofflawfirm.com; kduboff@dubofflawfirm.com; Libia Nava
Cc: Andrea Stratford ; UPCIC eService 05
Subject: LaFleur v. UPCIC ‐ Request for Site Inspection
Importance: High
Good morning,
Please allow this to serve as our formal written request to coordinate a site inspection of the subject property. Brian
DuChene, with Terracon will perform the inspection and is available on the following dates:
July 9, 10, 11, 12 at 9 AM (or later if needed).
Please advise as to whether any of these dates/times work for your office so that we may confirm with our engineer.
Thank you.
Ashley Waisanen
Paralegal
Alder Adjusting Corporation
(W): (954) 958-1200 ext:6701
www.universalproperty.com
3
Join us and GO GREEN! Go paperless with Universal.
Confidentiality Notice: This e-mail message, including
any attachments, is for the sole use of the intended recipient(s) and may
contain confidential and privileged information. Any unauthorized review, use,
disclosure or distribution is prohibited. If you are not the intended recipient
and received this in error, please contact the sender by reply e-mail. You are
hereby notified that the copying, use or distribution of any information or
materials transmitted in or with this message is strictly prohibited.
4
Preview
Filing # 91958398 E-Filed 07/01/2019 05:02:51 PM IN THE CIRCUIT COURT OF THE NINTH JUDICAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA MARIA LAFLEUR, CASE NO.: 2017-CA-004500-O Plaintiff, v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. _____________________________________/ UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY’S MOTION TO COMPEL ENTRY UPON LAND FOR INSPECTION Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY (“Universal”), by and through the undersigned counsel, hereby files its Motion to Compel Entry Upon Land for Inspection pursuant to Fla. R. Civ. P. 1.350(a) and states as follows: 1. This is a first-party breach of contract claim arising from wind damage which allegedly occurred on or about July 5, 2015. 2. On September 21, 2018, this Court entered a Uniform Order Setting Case for Jury Trial; Pre-Trial Conference and Requiring Pretrial Matters to be Completed, setting this matter on the jury trial docket commencing on October 7, 2019. 3. On June 27, 2019, Defendant requested an inspection of the subject property. In its correspondence, Universal identified the name of the inspector, Brian DuChene, with Terracon and proposed dates and times for the site inspection to take place. 4. On July 1, 2019, Joshua Blacksten, counsel for Plaintiff advised that a request needed to be submitted in writing. Mr. Blacksten further advised that his office would object, stating “the inspection is unnecessary as your client inspected pre-suit and the sufficiency of its Maria LaFleur v. UPCIC CASE NO. 2017-CA-004500-O Page 2 of 4 coverage position (which is the ultimate question of fact/law to be determined) is based on that inspection.” A copy of the correspondence to/from Plaintiff’s counsel is attached hereto as Exhibit “A.” 5. Aside from Plaintiff’s counsel opinion, Plaintiff has failed to provide any explanation as to why or what Plaintiff’s attorney opposes. 6. Despite the “objection,” by Plaintiff’s counsel’s lack of response, the Florida Rules of Civil Procedure states as follows: RULE 1.350. PRODUCTION OF DOCUMENTS AND THINGS AND ENTRY UPON LAND FOR INSPECTION AND OTHER PURPOSES (a) Request; Scope. Any party may request any other party (1) to produce and permit the party making the request, or someone acting in the requesting party’s behalf, to inspect and copy any designated documents, including electronically stored information, writings, drawings, graphs, charts, photographs, phono-records, and other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form, that constitute or contain matters within the scope of rule 1.280(b) and that are in the possession, custody, or control of the party to whom the request is directed; (2) to inspect and copy, test, or sample any tangible things that constitute or contain matters within the scope of rule 1.280(b) and that are in the possession, custody, or control of the party to whom the request is directed; or (3) to permit entry upon designated land or other property in the possession or control of the party upon whom the request is served for the purpose of inspection and measuring, surveying, photographing, testing, or sampling the property or any designated object or operation on it within the scope of rule 1.280(b). 7. Further, Rule 1.280, states: RULE 1.280. GENERAL PROVISIONS GOVERNING DISCOVERY (a) Discovery Methods. Parties may obtain discovery by one or more of the following methods: depositions upon oral examination or written questions; written interrogatories; production of Maria LaFleur v. UPCIC CASE NO. 2017-CA-004500-O Page 3 of 4 documents or things or permission to enter upon land or other property for inspection and other purposes; physical and mental examinations; and requests for admission. Unless the court orders otherwise and under subdivision (c) of this rule, the frequency of use of these methods is not limited, except as provided in rules 1.200, 1.340, and 1.370. 8. To-date, Plaintiff’s counsel has refused to allow entry and/or propose any dates of availability, despite Universal’s request. 9. Plaintiff’s counsel has failed to provide an explanation and/or clarification as to the reason for any alleged opposition. 10. Pursuant to the trial order, the discovery cut-off is September 3, 2019. 11. Based on Plaintiff’s intentional delay in coordinating an agreed upon date to conduct the site inspection (as requested by Defendant) and given the time constraints with trial approaching, the undersigned has been forced to file the instant Motion. 12. Without being able to conduct the investigation of the subject premises, Universal will be prejudiced in its defense of this matter. 13. Pursuant to Fla. R. Civ. P. 1.350(a), Universal requests that the Court allow it an opportunity to conduct a site inspection of the subject residence in an effort to facilitate the subject lawsuit. 14. If granted, Universal will coordinate a date and time convenient to all parties and in accordance with any Order issued by the Court. 15. This Motion is not being filed for purposes of delay and inspection of the subject residence will not prejudice either party. 16. The undersigned Counsel for the Defendant certifies that he has, in good faith, conferred or attempted to confer with counsel for the Plaintiff in an effort to resolve this dispute without court action but has been unable to do so. Maria LaFleur v. UPCIC CASE NO. 2017-CA-004500-O Page 4 of 4 WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests this Court to enter an Order allowing 1) Universal the ability to enter the residence of the Plaintiff to perform a site inspection of the alleged damages in this matter, 2) to pay reasonable attorney’s fees and costs to the Defendant for bringing this Motion; and 3) to grant any and all other relief this Court deems just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing has been furnished by electronic filing to: Kenneth R. Duboff, Esq., (courtdocument@dubofflawfirm.com) on this 1st day of July, 2019. Attorneys for Defendant Universal Property & Casualty Ins. Co. 1855 West State Road 434, Suite 282 Longwood, Florida 32750 Telephone: 833-658-8594 Facsimile: 954-958-1262 By: /s/ Jason R. Urbanowicz, Esq. Jason R. Urbanowicz, Esq. Florida Bar No. 391026 For Service of Court Documents only: Primary: upciceservice05@universalproperty.com Secondary: lb1101@universalproperty.com Tertiary: ju1010@universalproperty.com Ashley Waisanen From: Ashley Waisanen Sent: Monday, July 1, 2019 4:24 PM To: Joshua Blacksten, Esq. Cc: libia@dubofflawfirm.com; Andrea Stratford Subject: RE: LaFleur v. UPCIC - Request for Site Inspection Thank you for the clarification, we will proceed with a motion to compel. From: Joshua Blacksten, Esq. Sent: Monday, July 1, 2019 4:18 PM To: Ashley Waisanen Cc: libia@dubofflawfirm.com; Andrea Stratford Subject: RE: LaFleur v. UPCIC ‐ Request for Site Inspection The request shall set forth the items to be inspected, either by individual item or category, and describe each item and category with reasonable particularity. The request shall specify a reasonable time, place, and manner of making the inspection or performing the related acts. And, once you do that, please be advised that we shall object as the inspection is unnecessary as your client inspected pre-suit and the sufficiency of its coverage position (which is the ultimate question of fact/law to be determined) is based on that inspection. From: Ashley Waisanen Sent: Monday, July 1, 2019 2:56 PM To: Joshua Blacksten, Esq. Cc: libia@dubofflawfirm.com; Andrea Stratford Subject: RE: LaFleur v. UPCIC ‐ Request for Site Inspection Good afternoon, I just want to clarify that you are referring to rule 1.350 where requests may be made without leave of court? As you know, this matter is set for trial. Are you indicating that you are requiring a court order in order to conduct a site inspection? Please confirm so that we may proceed accordingly. Thank you. 1.350 Production of Documents and Things and Entry Upon Land for Inspection (a) Request; Scope. Any party may request any other party (1) to produce and permit the party making the request, or someone acting in the requesting party’s behalf, to inspect and copy any designated documents, including electronically stored information, writings, drawings, graphs, charts, photographs, phono‐records, and other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form, that constitute or contain matters within the scope of rule 1.280(b) and that are in the possession, custody, or control of the party to whom the request is directed; (2) to inspect and copy, test, or sample any tangible things 1 Exhibit "A" that constitute or contain matters within the scope of rule 1.280(b) and that are in the possession, custody, or control of the party to whom the request is directed; or (3) to permit entry upon designated land or other property in the possession or control of the party upon whom the request is served for the purpose of inspection and measuring, surveying, photographing, testing, or sampling the property or any designated object or operation on it within the scope of rule 1.280(b). (b) Procedure.Without leave of court the request may be served on the plaintiff after commencement of the action and on any other party with or after service of the process and initial pleading on that party. The request shall set forth the items to be inspected, either by individual item or category, and describe each item and category with reasonable particularity. The request shall specify a reasonable time, place, and manner of making the inspection or performing the related acts. The party to whom the request is directed shall serve a written response within 30 days after service of the request, except that a defendant may serve a response within 45 days after service of the process and initial pleading on that defendant. The court may allow a shorter or longer time. For each item or category the response shall state that inspection and related activities will be permitted as requested unless the request is objected to, in which event the reasons for the objection shall be stated. If an objection is made to part of an item or category, the part shall be specified. When producing documents, the producing party shall either produce them as they are kept in the usual course of business or shall identify them to correspond with the categories in the request. A request for electronically stored information may specify the form or forms in which electronically stored information is to be produced. If the responding party objects to a requested form, or if no form is specified in the request, the responding party must state the form or forms it intends to use. If a request for electronically stored information does not specify the form of production, the producing party must produce the information in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms. The party submitting the request may move for an order under rule 1.380 concerning any objection, failure to respond to the request, or any part of it, or failure to permit inspection as requested. (c) Persons Not Parties. This rule does not preclude an independent action against a person not a party for production of documents and things and permission to enter upon land. (d) Filing of Documents. Unless required by the court, a party shall not file any of the documents or things produced with the response. Documents or things may be filed in compliance with Florida Rule of Judicial Administration 2.425 and rule 1.280(g) when they should be considered by the court in determining a matter pending before the court. Ashley Waisanen Paralegal Alder Adjusting Corporation (W): (954) 958-1200 ext:6701 www.universalproperty.com Join us and GO GREEN! Go paperless with Universal. Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient and received this in error, please contact the sender by reply e-mail. You are hereby notified that the copying, use or distribution of any information or materials transmitted in or with this message is strictly prohibited. From: Joshua Blacksten, Esq. Sent: Monday, July 1, 2019 2:28 PM To: Ashley Waisanen Cc: libia@dubofflawfirm.com Subject: RE: LaFleur v. UPCIC ‐ Request for Site Inspection 2 If you would like to inspect, please seek leave as provided by the rules. From: Kenneth Duboff Sent: Monday, July 1, 2019 10:46 AM To: 'DLF' Subject: FW: LaFleur v. UPCIC ‐ Request for Site Inspection Importance: High Please review this Kenneth R. Duboff, Esq. 680 NE 127th Street North Miami, Florida 33161 Office: 305-899-0085 www.dubofflawfirm.com KDuboff@dubofflawfirm.com From: Ashley Waisanen Sent: Thursday, June 27, 2019 11:09 AM To: courtdocument@dubofflawfirm.com; kduboff@dubofflawfirm.com; Libia Nava Cc: Andrea Stratford ; UPCIC eService 05 Subject: LaFleur v. UPCIC ‐ Request for Site Inspection Importance: High Good morning, Please allow this to serve as our formal written request to coordinate a site inspection of the subject property. Brian DuChene, with Terracon will perform the inspection and is available on the following dates: July 9, 10, 11, 12 at 9 AM (or later if needed). Please advise as to whether any of these dates/times work for your office so that we may confirm with our engineer. Thank you. Ashley Waisanen Paralegal Alder Adjusting Corporation (W): (954) 958-1200 ext:6701 www.universalproperty.com 3 Join us and GO GREEN! Go paperless with Universal. Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient and received this in error, please contact the sender by reply e-mail. You are hereby notified that the copying, use or distribution of any information or materials transmitted in or with this message is strictly prohibited. 4