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Filing # 136458501 E-Filed 10/13/2021 11:41:32 AM
IN THE CIRCUIT COURT OF THE
5™ JUDICIAL CIRCUIT IN AND FOR
LAKE COUNTY, FLORIDA
THE DIOCESE OF CENTRAL FLORIDA,
CASE NO. 35-2021-CA-001639-AXXX-XX
PLAINTIFF,
V.
CERTAIN UNDERWRITERS AT LLOYD’S, LONDON
SUBSCRIBING To PoLicy No. MSRC-2830-00-
00,
DEFENDANTS. I
DEFENDANTS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENT:
Defendants, CERTAIN UNDERWRITERS AT LLOYD’s, LONDON SUBSCRIBING TO POLICY
No. MSRC-2830-00-00, request that Plaintiff, THE DIOCESE OF CENTRAL FLORIDA, within
the time provided by Fla. R. Civ. P. 1.350, produce the following documents at the
offices of undersigned counsel.
REQUEST FOR PRODUCTION
1 Copies of all documents identified in Plaintiffs responses to Defendants’
First Set of Interrogatories served simultaneously with this request.
2 Copies of all maintenance or repair records regarding the premises
including, but not limited to, work orders, log books, complaints, correspondence,
notices, invoices, estimates, proposals, bids, notes, memoranda, checks, etc., for the
past seven (7) years.
3. Copies of all contracts and written agreements entered into with any public
adjuster, engineer, consultant, architect, estimator, or repair person for work relating to
damages described in the Complaint.
4. Copies of all correspondence between Plaintiff, and its representatives
and agents, and its public adjuster, engineer, consultant, architect, estimator, or repair
person for work relating to the damages described in the Complaint.
5. Copies of all contracts, estimates, proposals, invoices, and reports for
work done on the Property as a result of claimed damage.
6. Photographs, pictures, and video tapes of areas those areas of the subject
property now claimed as damaged taken before the alleged loss.
BERK, MERCHANT |&|Srms
2 Alhambra Plaza, Suite 700 ¢ CORAL GABLES, FLORIDA 33134 # PHONE: 786.338.2900 # FAX: 786.338.2888
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 10/13/2021 11:48:36 AM
Case No. 2021-CA-001639-AXXX-XX
THE DIOCESE OF CENTRAL FLA. V CERT. Uwrs AT LLoYD’s, LONDON
Page 2 of 3
7. Photographs, pictures, and video tapes of areas those areas of the subject
property now claimed as damaged taken after the alleged loss
8 All documents and correspondence by and between any County Official,
Building Department Official and/or any other regulatory agency or governmental
professional (on the one side) and the Plaintiff and/or Plaintiff's agent (on the other side)
regarding the claimed damages on the subject property, including but not limited to stop
work orders, demolition notices, code violations, code related issues, etc.
9 All records referring or relating to payments made by or on behalf of the
Plaintiff in conjunction with this claim.
10. All records relating to clean-up, debris removal or emergency services in
conjunction with this loss.
11. All expert or consultant reports, if written, and all written documentation in
any form regarding any expert or consultant findings, opinions or conclusions relating to
any aspect of this claim.
12. All permits, inspection reports or correspondence with any building
department relating to this claim.
13. All policies with The Church Insurance Companies and any other entity
related to Church Pension Group that provided property insurance for the premises
described in the Complaint on the date of loss listed in the Complaint.
14. All documents exchanged between Plaintiff and The Church Insurance
Companies and any other entity related to Church Pension Group that provided
property insurance for the premises described in the Complaint on the date of loss listed
in the Complaint.
15. Copies of all insurance policies in effect on the date of loss that provide
property insurance for the premises described in the Complaint.
16. Copies of all Vestry meeting minutes for Holy Trinity Episcopal Church for
the preceding seven (7) years through the present.
17. Copies of all annual reports submitted by or on behalf of Holy Trinity
Episcopal Church to the Diocese of Central Florida for the preceding seven (7) years
through the present.
18. Copies of all applications for loans and grants made by Holy Trinity
Episcopal Church to the Diocese of Central Florida for repairs, improvements, or
maintenance to the buildings located at the address described in the Complaint.
19. All reports, memorandum, letters, or written statements relating to the
BERK, MERCHANT je| Sums
2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 ePHONE: 786.338.2900 @ FAX: 786.338.2888
Case No. 2021-CA-001639-AXXX-XX
THE DIOCESE OF CENTRAL FLA. V CERT. Uwrs AT LLoYD’s, LONDON
Page 3 of 3
condition and maintenance of the buildings and grounds described in the Complaint
prepared by the or on behalf of the Vestry, Junior Warden, or the Diocese of Central
Florida.
20. Copies of all church directories for Holy Trinity Episcopal Church for the
two years preceding the loss described in the Complaint through the present.
Respectfully submitted,
BERK, MERCHANT & Sims, PLC
/s| PATRICK E. BETAR
Patrick E. Betar / FBN: 11073
Laura C. Tapia / FBN: 968676
2 Alhambra Plaza, Suite 700
Coral Gables, Florida 33134
Tel: (786) 338-2900 / Fax: (786) 338-2888
Email: pbetar@berklawfirm.com
kmendez@berklawfirm.com
Itapia@berklawfirm.com
anorwitch@berklawfirm.com
Counsel for Defendants
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was served via
email on this 13" day of October, 2021 to:
Jeremy T. Schilling / FBN: 0098111
Aaron D. Silvers / FBN: 104811
SCHILLING & SILVERS, PLLC
1700 NW 64" Street, Suite 460
Fort Lauderdale, FL 33301
Tel: (954) 712-8877
E-Mail: jschilling@schillingsilvers.com
dadams@schillingsilvers.com
Counsel for Plaintiff
/s| PATRICK E. BETAR
BERK, MERCHANT je| Sums
2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 ePHONE: 786.338.2900 @ FAX: 786.338.2888
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Filing # 136458501 E-Filed 10/13/2021 11:41:32 AM IN THE CIRCUIT COURT OF THE 5™ JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA THE DIOCESE OF CENTRAL FLORIDA, CASE NO. 35-2021-CA-001639-AXXX-XX PLAINTIFF, V. CERTAIN UNDERWRITERS AT LLOYD’S, LONDON SUBSCRIBING To PoLicy No. MSRC-2830-00- 00, DEFENDANTS. I DEFENDANTS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENT: Defendants, CERTAIN UNDERWRITERS AT LLOYD’s, LONDON SUBSCRIBING TO POLICY No. MSRC-2830-00-00, request that Plaintiff, THE DIOCESE OF CENTRAL FLORIDA, within the time provided by Fla. R. Civ. P. 1.350, produce the following documents at the offices of undersigned counsel. REQUEST FOR PRODUCTION 1 Copies of all documents identified in Plaintiffs responses to Defendants’ First Set of Interrogatories served simultaneously with this request. 2 Copies of all maintenance or repair records regarding the premises including, but not limited to, work orders, log books, complaints, correspondence, notices, invoices, estimates, proposals, bids, notes, memoranda, checks, etc., for the past seven (7) years. 3. Copies of all contracts and written agreements entered into with any public adjuster, engineer, consultant, architect, estimator, or repair person for work relating to damages described in the Complaint. 4. Copies of all correspondence between Plaintiff, and its representatives and agents, and its public adjuster, engineer, consultant, architect, estimator, or repair person for work relating to the damages described in the Complaint. 5. Copies of all contracts, estimates, proposals, invoices, and reports for work done on the Property as a result of claimed damage. 6. Photographs, pictures, and video tapes of areas those areas of the subject property now claimed as damaged taken before the alleged loss. BERK, MERCHANT |&|Srms 2 Alhambra Plaza, Suite 700 ¢ CORAL GABLES, FLORIDA 33134 # PHONE: 786.338.2900 # FAX: 786.338.2888 FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 10/13/2021 11:48:36 AM Case No. 2021-CA-001639-AXXX-XX THE DIOCESE OF CENTRAL FLA. V CERT. Uwrs AT LLoYD’s, LONDON Page 2 of 3 7. Photographs, pictures, and video tapes of areas those areas of the subject property now claimed as damaged taken after the alleged loss 8 All documents and correspondence by and between any County Official, Building Department Official and/or any other regulatory agency or governmental professional (on the one side) and the Plaintiff and/or Plaintiff's agent (on the other side) regarding the claimed damages on the subject property, including but not limited to stop work orders, demolition notices, code violations, code related issues, etc. 9 All records referring or relating to payments made by or on behalf of the Plaintiff in conjunction with this claim. 10. All records relating to clean-up, debris removal or emergency services in conjunction with this loss. 11. All expert or consultant reports, if written, and all written documentation in any form regarding any expert or consultant findings, opinions or conclusions relating to any aspect of this claim. 12. All permits, inspection reports or correspondence with any building department relating to this claim. 13. All policies with The Church Insurance Companies and any other entity related to Church Pension Group that provided property insurance for the premises described in the Complaint on the date of loss listed in the Complaint. 14. All documents exchanged between Plaintiff and The Church Insurance Companies and any other entity related to Church Pension Group that provided property insurance for the premises described in the Complaint on the date of loss listed in the Complaint. 15. Copies of all insurance policies in effect on the date of loss that provide property insurance for the premises described in the Complaint. 16. Copies of all Vestry meeting minutes for Holy Trinity Episcopal Church for the preceding seven (7) years through the present. 17. Copies of all annual reports submitted by or on behalf of Holy Trinity Episcopal Church to the Diocese of Central Florida for the preceding seven (7) years through the present. 18. Copies of all applications for loans and grants made by Holy Trinity Episcopal Church to the Diocese of Central Florida for repairs, improvements, or maintenance to the buildings located at the address described in the Complaint. 19. All reports, memorandum, letters, or written statements relating to the BERK, MERCHANT je| Sums 2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 ePHONE: 786.338.2900 @ FAX: 786.338.2888 Case No. 2021-CA-001639-AXXX-XX THE DIOCESE OF CENTRAL FLA. V CERT. Uwrs AT LLoYD’s, LONDON Page 3 of 3 condition and maintenance of the buildings and grounds described in the Complaint prepared by the or on behalf of the Vestry, Junior Warden, or the Diocese of Central Florida. 20. Copies of all church directories for Holy Trinity Episcopal Church for the two years preceding the loss described in the Complaint through the present. Respectfully submitted, BERK, MERCHANT & Sims, PLC /s| PATRICK E. BETAR Patrick E. Betar / FBN: 11073 Laura C. Tapia / FBN: 968676 2 Alhambra Plaza, Suite 700 Coral Gables, Florida 33134 Tel: (786) 338-2900 / Fax: (786) 338-2888 Email: pbetar@berklawfirm.com kmendez@berklawfirm.com Itapia@berklawfirm.com anorwitch@berklawfirm.com Counsel for Defendants CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was served via email on this 13" day of October, 2021 to: Jeremy T. Schilling / FBN: 0098111 Aaron D. Silvers / FBN: 104811 SCHILLING & SILVERS, PLLC 1700 NW 64" Street, Suite 460 Fort Lauderdale, FL 33301 Tel: (954) 712-8877 E-Mail: jschilling@schillingsilvers.com dadams@schillingsilvers.com Counsel for Plaintiff /s| PATRICK E. BETAR BERK, MERCHANT je| Sums 2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 ePHONE: 786.338.2900 @ FAX: 786.338.2888