On November 30, 2017 a
Party Discovery
was filed
involving a dispute between
Gloria Ruiz,
Mauricio Villa,
and
American Intergrity Insurance Company Of Florida,
for CA - Other
in the District Court of Orange County.
Preview
Filing # 55909902 B-Filed 05/03/2017 11:41:20 AM y/7-CA— 10S” 3k
IN THE CIRCUIT COURT IN AND FOR POLK COUNTY, FLORIDA
MAURICIO VILLA AND GLORIA
RUIZ,
CASE NO, 2
23
Plaintiff, Ee
vs. ba
mo
AMERICAN INTEGRITY INSURANCE 25
COMPANY OF FLORIDA, moO
: re
Defendant. zs
» COMES NOW 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 civi! procedure:
I.
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.
6.
Copies of all damage estimates prepared during Defendant’s investigation
conducted during the normal business of evaluating the claim,
All letters, faxes, email communications, and log notcs 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.
DUBOTFF
2017CA-001547-0000-00
Received in Polk 05/03/2017 11:43 AM
/
‘NG WAR
301340 ni 037. 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 comnwunications 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
Plaintiffs Complaint.
17. Alldocuments 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.
[aon
2017CA-001547-0000-00 Received in Polk 05/03/2017 11:43 AM19. 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 checks, releases, proofs of loss, recorded statements, transcripts of cxaminations under
oath, and correspondence by and between the parties related to any and all said other claims.
20. Anyand all brochures, summary statements, pamphlets and advertising materials
prepared by or on behalf of Defendunt 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, DuBorr, Esq.
FLA. BAR #218261
DUBOFF
2017CA-001547-0000-00 Received in Polk 05/03/2017 11:43 AM
Document Filed Date
November 30, 2017
Case Filing Date
November 30, 2017
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