IN THE CIRCUIT COURT OF THE 17TH 

JUDICIAL CIRCUIT IN AND FOR 

BROWARD COUNTY, FLORIDA

MAJOR LEAGUE JEWELERS,

 Plaintiff,

v.

JEWELERS MUTUAL INSURANCE 

COMPANY,

Defendant.

/

CASE NO.: 

PROPOSED NOTICE OF TAKING DEPOSITION DUCES TECUM

PLEASE TAKE NOTICE that the undersigned attorneys will take the following 

deposition at the place, date and time indicated below:

NAME DATE TIME PLACE

Corporate Representative 

with knowledge pursuant 

to Fla. R. Civ. P. 

1.310(b)(6)

TBD TBD TBD

In accordance with the Americans with Disabilities Act of 1990, persons needing a special 

accommodation to participate in this proceeding should contact the offices of the 

undersigned at 305-444-5969

Pursuant to Rule 1.310(b)(6) of the Florida Rules of Civil Procedure, you are hereby requested to 

designate one or more officers, directors, managing agents or other persons who consent to 

testify on behalf of the parties being deposed as the persons having the most knowledge 

concerning the area of the subject matter described on Schedule A attached hereto. 

Upon oral examination before a commissioner appointed by the Court, a Notary Public, or any 

other officer authorized to administer oaths by the laws of the State of Florida, who is neither a 

relative nor employee of such attorney or counsel and who is not financially interested in this 

action. The deposition will continue from day to day until completed. The deposition is being 

taken for purposes of discovery and for use as evidence in this case, for use at trial, or for such 

other purposes as are permitted under the Florida Rules of Civil Procedure. 

The deponent is to bring at the above time and place the following documents listed on the 

attached Schedule B.

Filing # 150850124 E-Filed 06/03/2022 04:20:18 PM

Composite A

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 1 of 204
CERTIFICATE OF SERVICE

 I HEREBY CERTIFY that a true and correct copy of the foregoing was served to: 

JEWELERS MUTUAL INSURANCE COMPANY on the 3rd day of June 2022.

Your Insurance Attorney, PLLC.

2601 South Bayshore Drive 18th Floor 

Coconut Grove, FL 33133

Phone No.: 1-888-570-5677

Fax: 1-888-745-5677

Email: YIA20@yourinsuranceattorney.com

Secondary Email: Eservice@yourinsuranceattorney.com

By: ____ /s/ Idelys Martinez_____ 

 Idelys Martinez, Esq.

 Florida Bar No. 1011047

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 2 of 204
SCHEDULE A

1. The allegations set forth in the Complaint.

1. The Insurance Policy entered into between the Insurer and the Insured as referenced in 

the Complaint. 

2. All facts related to the Insurer’s involvement in the Insured’s claim as referenced in the 

Complaint. 

3. All facts related to communications between the Insured and agents of the Insurer as it 

relates to the allegations set forth in the Complaint.

4. The adjustment and claim handling of the instant claim alleged in the Complaint. .

5. The dollar value of the Insured’s damages.

6. All facts and information supporting your defenses to the Plaintiff(s) claim for 

insurance proceeds as alleged in the Complaint. 

7. All facts and information supporting Your Answer and Affirrmative Defenses.

8. All facts and information supporting any defense or exclusion of coverage under the 

Insurance Policy entered into between Plaintiff and Defendant as referenced in the 

Complaint.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 3 of 204
SCHEDULE B

1. Please bring a copy of all documents in your possession for the instant Claim as defined 

in the Complaint that are not protected by a claimed privilege. If you are not producing 

documents pursuant to this Schedule B request because you are claiming a privilege 

please provide a privilege log. If a document is not produced and not referenced on a 

privilege log we will assume it does not exist.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 4 of 204
SERVED WITH COMPLAINT

RE: MAJOR LEAGUE JEWELERS v. JEWELERS MUTUAL INSURANCE 

COMPANY

 

To Whom It May Concern: 

At this time we would like to request that your office provide five or more dates to 

coordinate the deposition of your corporate representative(s), in connection with the abovereferenced matter within one hundred and sixty (160) days. I have attached the proposed areas 

of inquiry for your convenience. Please note this is not an exhaustive list and additional areas of 

inquiry may be necessary depending upon additional discovery and responses to questions asked 

at the deposition. Please forward all dates to YIA20@Yourinsuranceattorney.com

Should you have any questions, please do not hesitate to contact us. In the meantime, I 

look forward to your anticipated prompt cooperation in this matter. Failure to provide dates 

within the prescribed time may necessitate the filing of a Motion to Compel.

Kind Regards, 

YOUR INSURANCE ATTORNEY, PLLC

Idelys Martinez, Esq. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 5 of 204
PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

Plaintiff, MAJOR LEAGUE JEWELERS (the “Insured”), pursuant to Rule 1.350 of the 

Florida Rules of Civil Procedure, hereby requests that Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY (the “Insurance Company”), make available for inspection and 

duplication, in response to each numbered paragraph, all documentsspecified herein which are in its 

possession, custody or control or in the possession, custody or control of its agents, accountants or 

attorneys. Defendant is requested to make such production within the time period prescribed either 

by the Florida Rules of Civil Procedure or by order of the Court, at the offices of Your Insurance 

Attorney, PLLC., 2601 South Bayshore Drive, 18th Floor, Coconut Grove, Florida 33133.

I. DEFINITIONS AND INSTRUCTIONS

1. The terms "you", "your(s)", “yourselves”, “defendant”, and/or “Insurance Company”

means the party or parties to which this request is addressed, and any agents, representatives, 

attorneys or other persons acting or purporting to act, on its behalf.

2. The term “person” means any natural person, individual, proprietorship, partnership,

corporation, association, organization, joint venture, firm, other business enterprise, governmental 

body, group of natural persons, or other entity. 

MAJOR LEAGUE JEWELERS,

 Plaintiff,

v.

JEWELERS MUTUAL INSURANCE 

COMPANY,

Defendant,

/

IN THE CIRCUIT COURT OF THE 17TH 

JUDICIAL CIRCUIT IN AND FOR 

BROWARD COUNTY, FLORIDA

CASE NO.: 

Filing # 150850124 E-Filed 06/03/2022 04:20:18 PM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 6 of 204
Page 2 of 7

3. The “Complaint” means the Complaint filed by the Insured in this action.

4. The term "document" shall mean any written or graphic matter and other means of 

preserving thought or expression and all tangible things from which information can be processed or 

transcribed, including the originals and all non-identical copies, whether different from the original 

by reason of any notation made on such copy or otherwise, including, but not limited to, 

correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, 

meetings or other communications, inter-office and intra-office telephone calls, diaries, 

chronological data, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed matter, 

charts, ledgers, invoices, work-sheets, receipts, returns, computer printouts, prospectuses, financial 

statements, schedules, affidavits, contracts, canceled checks, statements, transcripts, statistics, 

surveys, magazine or newspaper articles, releases (and any and all drafts, alterations or 

modifications, changes and amendments of any of the foregoing), graphic or aural records or 

representations of any kind (including without limitation, photographs, microfiche, microfilm, 

videotape, records and motion pictures) and electronic, mechanical or electric records or 

representations of any kind (including without limitation, tapes, cassettes, discs and records).

5. The term "all documents" means every document or group of documents as above 

defined that are known to you or that can be located or discovered by reasonably diligent efforts.

6. The term “Insurance Company” shall refer to the Defendant in this action, its 

affiliates, subsidiaries, predecessors, successors, agents, attorneys and/or anyone else acting in its 

behalf.

7. The term "communication(s)" means every manner or means of disclosure, transfer or 

exchange of information, whether in person, by telephone, mail, personal delivery or otherwise.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 7 of 204
Page 3 of 7

8. As used herein, the singular shall include the plural, the plural shall include the 

singular, and the masculine, feminine and neuter shall include each of the other genders. 

9. The terms "and", “as well as” and "or" shall be construed disjunctively as well as 

conjunctively as necessary to make the interrogatory inclusive rather than exclusive. The term "all" 

means "any and all." The terms "each" and “every” means "each and every," the term “including” 

means “including without limitation.”

10. The terms "referring to" or "relating to" mean setting forth, pertaining to, 

memorializing, constituting, embodying, discussing, analyzing, reflecting or otherwise concerning.

11. The terms "locate" or "location" means to state the present whereabouts of each 

document and to identify the person(s) having possession, custody or control thereof.

12. The term "to date" shall mean the date on which you respond to this request.

13. When producing the required documents, please keep all documents segregated by 

the file in which the documents are contained and indicate the name of the file in which the 

documents are contained and the name of the documents being produced.

14. When producing the required documents, please produce all other documents that are 

clipped, stapled or otherwise attached to any requested document.

15. In the event such file(s) or document(s) has (have) been removed, either for the 

purpose of this action or for some other purpose, please state the name and address of the person 

who removed the file, the title of the file and each sub-file, if any, maintained within the file, and the 

present location of the file.

16. The words "and" and "or" shall be construed either conjunctively or disjunctively to 

bring within the scope of these requests any documents which might otherwise be construed to be 

outside their scope.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 8 of 204
Page 4 of 7

17. If you claim that the attorney/client or any other privilege or the attorney's work 

product doctrine applies to any document, the production of which is called for by these requests, 

then for each such document, state its date, subject matter, author(s), recipient(s), present custodian 

and all past custodians, and such additional information concerning the claim of privilege or work 

product doctrine as will permit the adjudication of the propriety of the claim. 

18. If you contend that it would be unreasonably burdensome to obtain and provide all of 

the documents called for in response to any one of these requests, then in response to the appropriate 

request:

(a) furnish each such document that is available to you without 

undertaking what you contend to be an unreasonable burden;

(b) state with particularity the grounds on which you contend that 

additional efforts to obtain such documents would be unreasonably 

burdensome; and

(c) describe with particularity the efforts made by you to secure such 

documents, including, without limitation, the identity of all persons 

consulted, and files, records, and documents reviewed, and the 

identity of each person who participated in gathering such documents, 

including the duration of time spent and nature of work done by each 

person.

19. Unless otherwise indicated, all requests include the time period from the date of the

Loss to the date you receive this request.

20. The term “Insured” shall refer to the Plaintiff(s), affiliates, predecessors, successors, 

agents, attorneys and/or anyone else acting in their behalf. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 9 of 204
Page 5 of 7

II. LOST/DESTROYED DOCUMENTS

If any document to be produced was, but is no longer, in your possession, custody or control 

and/or has been destroyed or is otherwise incapable of production or state: (a) the date, place and 

means of the destruction; (b) the name and address of each person deciding upon, participating in 

and having knowledge of the destruction; (c) the reason for the destruction; (d) if not destroyed, the 

reason why the document is incapable of production; and (e) the subject matter of the document.

III. DOCUMENTS REQUESTED

1. A true and correct certified copy of the insurance policy provided by the Insurance 

Company to the Insured, for which this lawsuit is premised, including but not limited to, declaration 

sheet(s), all addendums and attachments.

2. Each and every timesheet, log and all other documents reflecting time spent by the 

Insurance Company at the Property.

3. Each and every document, evidencing the name, address, and the position/relationship 

with the Insurance Company, of every individual who has visited or plans to visit the Property on

behalf of the Insurance Company. 

4. Any and all correspondence or written communications from the Insurance Company 

to the Insured, which in any manner pertain to the Insured’s loss as described in the Complaint. 

5. Any and all correspondence or written communications from the Insured, to the 

Insurance Company which in any manner pertains to the Insured’s loss as described in the 

Complaint.

6. Any and all photographs taken by the Insurance Company of the Property. 

7. All documents containing information regarding a statement by the Insured at any 

time during the Insurance Company’s handling of the Insured’s loss, including adjuster notes, claim 

reports, interoffice memorandum, tape recordings, Examination Under Oath transcripts, and any 

other transcripts or written statements from the Insured.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 10 of 204
Page 6 of 7

8. Any and all bills or estimates for repairs to the Property submitted to the Insurance 

Company by the Insured.

9. Any and all checks paid to, or on behalf of the Insured, representing insurance 

coverage payment(s) for the loss.

10. All reports which in any manner pertain to the Insured’s loss.

11. All Proof of Loss forms pertaining to the subject loss that were sent or received by 

you or your representatives to or from the Insured or the Insured’s representative.

12. Transcripts of all recorded statements taken by you or your representatives in 

connection with the subject loss.

13. All inspection reports or other documents that evidence the cause of the damages at 

issue in the subject claim as determined by you or your representative.

14. All applications for insurance submitted by or on behalf of the Insured to you or your 

representatives in connection with obtaining or renewing the subject Policy.

15. All photographs or videos taken by you or your representative(s) in connection with 

the initial issuance or renewal of the subject Policy.

16. A current curriculum vitae (CV) or resume for each person retained on your behalf 

for the purpose of rendering an opinion as to the cause or extent of the subject damage.

17. All affidavits or sworn statements in your possession pertaining to the subject loss.

18. Transcripts of all examinations under oath (EUO) taken by you or your 

representatives in connection with the subject loss.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 11 of 204
Page 7 of 7

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via U.S. mail 

to: JEWELERS MUTUAL INSURANCE COMPANY c/o The Florida Chief Financial Officer as 

RA, 200 E. Gaines Street, Tallahassee, Florida 32399-4201, on this 3rd day of June 2022.

Your Insurance Attorney, PLLC.

2601 South Bayshore Drive 18th Floor 

Coconut Grove, FL 33133

Phone No.: 1-888-570-5677

Fax: 1-888-745-5677

Email:YIA20@Yourinsuranceattorney.com 

Secondary Email: Eservice@Yourinsuranceattorney.com

 By: /s/ Idelys Martinez______________

Idelys Martinez, Esq.

 Florida Bar No. 1011047

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 12 of 204
MAJOR LEAGUE JEWELERS,

 Plaintiff,

v.

JEWELERS MUTUAL INSURANCE 

COMPANY,

Defendant.

/

IN THE CIRCUIT COURT OF THE 17TH 

JUDICIAL CIRCUIT IN AND FOR 

BROWARD COUNTY, FLORIDA

CASE NO.: 

PLAINTIFF'S FIRST SET OF INTERROGATORIES

Plaintiff, MAJOR LEAGUE JEWELERS (the “Insured”), pursuant to Rule 1.340 of the 

Florida Rules of Civil Procedure, propounds the following First Set of Interrogatories upon 

Defendant, JEWELERS MUTUAL INSURANCE COMPANY (the “Insurance Company”), to be 

answered in writing, under oath, within the time specified.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via U.S. mail 

to: JEWELERS MUTUAL INSURANCE COMPANY c/o The Florida Chief Financial Officer as 

RA, 200 E. Gaines Street, Tallahassee, Florida 32399-4201, on this 3rd day of June 2022.

Respectfully Submitted by,

 

Your Insurance Attorney, PLLC.

2601 South Bayshore Drive 18th Floor 

Coconut Grove, FL 33133

Phone No.: 1-888-570-5677

Fax: 1-888-745-5677

Email:YIA20@Yourinsuranceattorney.com 

Secondary Email: Eservice@Yourinsuranceattorney.com

 By: /s/ Idelys Martinez______________

Idelys Martinez, Esq.

 Florida Bar No. 1011047

Filing # 150850124 E-Filed 06/03/2022 04:20:18 PM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 13 of 204
DEFINITIONS AND INSTRUCTIONS

1. Insert your answers in the space provided following each question. If additional 

space is needed, so indicate in the space provided, prepare your answers on a separate paper, and 

attach the additional paper to your answers.

2. Separately answer each interrogatory, and each subsection of each interrogatory. The 

term "you" and "your" means the party or parties to which this request is addressed, including its 

divisions, departments, subsidiaries, affiliates, predecessors, present or former officers, directors, 

owners, agents, accountants, attorneys, and all other persons acting or purporting to act on its behalf, 

as well as each partnership in which it is a partner.

3. The terms “Insurance Company” or “Defendant” means the defendant in this action to 

which these Interrogatories are addressed, including its agents, attorneys, accountants, and all other 

persons acting or purporting to act on their behalf. The terms “Insurance Company” or “Defendant” 

also includes the party's divisions, departments, subsidiaries, affiliates, predecessors, present or 

former officers, directors, owners, agents, attorneys, and accountants as well as each partnership in 

which it is a partner, and includes any other person, acting or purporting to act on its behalf.

4. The terms "you" and "your" mean the party or parties to which these interrogatories 

are addressed, including its agents, attorneys, accountants, and all other persons acting or purporting 

to act on its behalf. 

5. The “Complaint” means the Complaint filed by the Insured in this action.

6. The term “Claim” means any statement, concept, assertion, idea, allegation, fact, law, 

rule, theory, observation, cause of action, or principle whatsoever, based upon which Plaintiff 

demands that she has suffered damages, or has a right to payment, as the result of any act or 

omission of Defendant. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 14 of 204
7. The terms "person" or "persons" mean any natural person, individual, proprietorship, 

partnership, corporation, association, organization, joint venture, firm, other business enterprise, 

governmental body, and group of natural persons or other entity, and includes any other person 

acting on behalf of a person.

8. The term “contract” means any promise, or set or promises, which creates an 

obligation to do or not do a particular thing where there was meeting of the minds on a given 

proposition and an understanding and intention between the parties. 

9. The term “communication” means any information given, whether oral or written; 

any oral or written statement, conference, consultation, dialogue, colloquy, discussion, conversation, 

agreement, the sharing of knowledge by one with another, bargaining preparatory to making a 

contract or any expression of any kind.

10. The term “document” means and includes any kind of written, typed, recorded or 

graphic matter, however produced or reproduced, of any kind or description, whether sent or 

received, and every record of every type, including originals, non-identical copies and drafts, and 

both sides of any documentation where information appears on both sides, and including but not 

limited to: letters, correspondence, memoranda, meeting transcripts or minutes, public filings or tax 

returns, papers, books, telegrams, bulletins, notices, announcements, instructions, charts, manuals, 

brochures, schedules, cables, telex messages, notes, notations, accountants’ working papers, 

transcriptions, agendas, reports, recordings of telephone or other conversations, of interviews, of 

conferences or of meetings, telephone messages, diaries, indices, books, reports, ledgers, working 

papers, invoices, worksheets, receipts, computer printouts, financial statements, schedules affidavits, 

contracts, canceled checks, statements, transcripts, magazine or newspaper articles, periodicals, 

releases and any and all drafts, alterations and modifications, changes and amendments of any of the 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 15 of 204
foregoing, whether handwritten, printed or electronically prepared, filed or stored, affidavits, 

statements, summaries, opinions, reports, studies, analyses, evaluations, contracts, agreements, 

journals, statistical records, calendars, appointment books, diaries, lists, tabulations, sound 

recordings, computer print-outs, data processing input and output, microfilms, newspapers, 

magazines, books, periodicals or press releases, including information stored on any electromagnetic 

storage device, any written, printed, typed, recorded, or graphic matter, however produced or 

reproduced or stored to which you have or had access. “Document” shall also be deemed to include 

any summary of a document or documents called for hereafter.

11. The term "all documents" means every document or group of documents as above 

defined that are known to you or that can be located or discovered by reasonably diligent efforts.

12. As used herein the singular shall include the plural, the plural shall include the 

singular, and the masculine, feminine, and neuter shall include each of the other genders.

13. The terms "and" as well as "or" shall be construed disjunctively as well as 

conjunctively as necessary to make the interrogatory inclusive rather than exclusive. The term "all" 

means "any and all." The term "each" means "each and every," and the term "every" means "each 

and every."

14. The terms "refer" or "relate to" mean setting forth, pertaining to, memorializing, 

constituting, embodying, discussing, analyzing, reflecting or otherwise concerning.

15. The term "locate" or "location" means to state the present whereabouts of each 

Document and to identify the persons having possession, custody or control thereof.

16. The term "to date" shall mean the date on which you answer these interrogatories.

17. The term “including” means “including but not limited to”.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 16 of 204
18. “Relating to” or “relevant to” means embodying, pertaining to, concerning, involving, 

constituting, comprising, reflecting, discussing, evidencing, referring to, consisting of, or having any 

logical or factual connection whatever with the subject matter in question.

19. The term “Identify,” when used with reference to a natural person, means state:

(a) his full name and address (or, if the present address is not known, his last 

known address).

(b) the full name and address of each of his employers, each corporation of 

which he is an officer or director and each business in which he is a principal.

(c) his present (or, if the present is not known, his last known) position and his 

position or positions at the time of the act to which the interrogatory answer 

relate, and

(d) such other information sufficient to enable Plaintiff to identify the person.

20. “Identify,” when used with reference to any entity other than a natural person, 

means:

(a) state the full name of the entity, the type of entity (e.g., corporation, 

partnership, etc.), the address of its principal place of business, its principal 

business activity, and if it is a corporation, the jurisdiction under the laws of 

which it has been organized and the date of such organization.

21. “Identify,” when used with reference to a document or written communication, means 

state:

(a) its nature (e.g., letter, telegram, floppy disc, computer printout, 

memorandum, chart, report or study), date, author, date and place of 

preparation and the name and address of each addressee, if there is an 

addressee;

(b) the identity of each signer to the document or communication;

(c) the title or heading of the document or communication;

(d) its substance;

(e) its present (or, if the present is not known, the last known) location and 

custodian.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 17 of 204
(f) the identity of each person to whom a copy was sent and each date of its 

receipt and each date of its transmittal or other disposition by (I) respondent 

and (ii) any other person (naming such other person) who, at any time, either 

received, transmitted or otherwise disposed of such document or 

communication and each copy thereof;

(g) the circumstances of each such receipt and each transmittal or other 

disposition, including identification of the person from whom received and 

the person to whom transmitted.

22. “Identify,” when used with reference to an oral transaction or oral communication, 

means state:

(a) its nature (e.g., telephone call, conversation in person, etc.)

(b) the date and place thereof.

(c) the identity and address of each person participating therein, present during 

or witness to any part thereof.

(d) identify each document in which such transaction or communication was 

recorded, described or referred to.

23. “Identify” when used with reference to a lawsuit means state:

(a) the caption of each lawsuit;

(b) the court in which the lawsuit was filed;

(c) the case number;

(d) identify the parties, and

(e) a brief summary of the nature of the claim or charge.

24. “Identify” when used with reference to an administrative claim or charge means 

state:

(a) identify the claimant or charging party;

(b) the administrative office were filed;

(c) the number assigned to identify the claim or charge, and

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 18 of 204
(d) a brief summary of the nature of the claim or charge.

25. “Identify,” when used in any other context that is herein above set forth, means to 

describe the act, word, situation, event, etc. (and/or conduct, course of action of any nature 

whatsoever, including without limitation any failure to act, to engage in any conduct or to pursue any 

course of action), to be identified as fully as possible and identify each document or communication 

or act in which such act, word, situation, event, conduct or course of action, etc., was recorded, refers 

or relates to each answer, forms all or part of the basis for an answer; and/or corroborates and 

answer.

26. You may, in lieu of identifying any Document or written communication, attach a 

true copy of each Document as an exhibit to the answers to these interrogatories. On each occasion 

in which you choose to attach a Document as your answer to an interrogatory, identify the portion of 

the Document that answers the interrogatory.

27. Identify each Document produced pursuant to an interrogatory by the paragraph 

number of the interrogatory in response to which it is produced and by the file from which the 

document was produced.

28. If any of the information furnished in an answer to all or part of an interrogatory is 

not within your personal knowledge, identify each person who has personal knowledge of the 

information furnished in such answer and each person who communicated to you any part of the 

information furnished.

29. If the answer to all or any part of the interrogatory is not presently known or available 

to you, include a statement to that effect, furnish the information now known or otherwise available 

to you, and respond to the entire interrogatory by supplemental answer, in writing, under oath, within 

ten days from the time the entire answer becomes known or available to you, but. in no event less 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 19 of 204
than five days prior to trial.

30. If you contend that it would be unreasonably burdensome to obtain and provide all of 

the information called for in response to any one of these interrogatories or any subpart thereof, then 

in response to the appropriate interrogatory or subpart:

(a) set forth all such information that is available to you without 

undertaking what you contend to be an unreasonable burden;

(b) state with particularity the grounds on which you contend that 

additional efforts to obtain such information would be unreasonably 

burdensome; and

(c) describe with particularity the efforts made by you to secure such 

information, including, without limitation, the identity of all persons 

consulted, and files, records, and documents reviewed, and the 

identity of each person who participated in gathering such 

information, including the duration of time spent and nature of work 

done by each person.

31. Unless your response to an interrogatory is complete when made, these 

interrogatories are continuing insofar as you are required to promptly make further or supplemental 

answers if new information is discovered and/or acquired by you between the date of your initial 

answer and any time thereafter.

32. If you claim in response to any request for production that any requested document is 

"privileged" and not subject to discovery, you shall so state expressly and, in addition, shall provide 

a privilege log, describing the nature of the documents, communications or things not produced or 

disclosed in a manner that, without revealing the information itself privileged or protected, will 

enable other parties to assess the applicability of the privilege or protection.

33. If all of the information furnished in answer to all or part of an interrogatory is not 

within the personal knowledge of the affiant, identify each person to whom all or part of the 

information furnished is a matter of personal knowledge and each person who communicated to the 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 20 of 204
affiant any part of the information furnished.

34. To the extent precise and complete information cannot be furnished, such information 

as is available shall be supplied, together with an estimate of the precise and complete information. 

Where such an estimate is given, the method employed in making the estimate shall be described.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 21 of 204
INTERROGATORIES

1. Please state the name, title, current business address, and phone number of all persons 

answering or assisting with the answering of this set of interrogatories.

2. Please state the date that the Insurance Company first received notice from the 

Insured for a claim of benefits under the Policy for property damages as described in the Complaint 

in this lawsuit.

3. In reference to the Insurance Company’s denial of the Insured’s claim for benefits 

under the Policy, please state:

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 22 of 204
a. The date the decision to deny the claim was made.

b. Identify each person who participated in the decision to deny the Insured’s 

claim.

c. Describe each and every fact upon which you relied in forming the basis for 

your denial of the Insured’s claim.

d. Identify each document sent by the Insurance Company to the Insured 

detailing the reasons why the Insurance Company denied the Insured’s claim.

e. State the location, including, page(s), line(s) and paragraph number(s), and 

the exact language contained in the Policy, which you used to base your decision to deny 

coverage of the Insured’s claim. 

4. Identify each person, by name, address, phone number and position, whom on behalf 

of the Insurance Company, inspected the Insured Property in reference to the claim for benefits 

under the Policy, including his or her field of expertise and the date of each inspection.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 23 of 204
5. Identify each written estimate for repair or replacement, including the amount set 

forth in each estimate, which has been provided to the Insurance Company by the Insured in 

reference to the Insured’s claim for benefits under the Policy.

6. Identify all persons (other than the Insurance Company) believed or known by you, 

your agents or attorneys to have knowledge concerning any of the issues raised by the pleadings, 

specifying the subject matter about which witnesses have knowledge and state whether you have 

obtained any statements (oral, written or recorded) from any of said witnesses, list the dates any such 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 24 of 204
witness statements were taken, by whom any such witness were taken and who has the present 

possession, custody and control of any such statements.

7. Identify all persons who, on the Insurance Company’s behalf, have in any way 

participated in the investigation, evaluation, adjusting or handling of the claim involved hereto. 

Please specify the nature of the participation for each and every such person and give the time period 

during which they participated.

8. For each decision that was made that the claim of the Insured were allegedly not 

covered under the Policy, please state the date you first decided that the Insured was allegedly not 

covered, the date you arrived at the conclusion the Insured was not covered and the names and 

address and phone number and the dates of involvement of each and every person that knows any 

information concerning these matters.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 25 of 204
9. Please describe all requests made by the Insurance Company upon the Insured for 

post-loss compliance (i.e., requests for examination under oath, information, documents, sworn 

proofs of loss, etc.,) in reference to this claim and the dates made.

10. With reference to each of your affirmative defenses raised in the lawsuit, please 

describe each and every fact upon which you rely to substantiate such affirmative defense, including 

identification of all witnesses to each such fact. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 26 of 204
11. Please verify the date the Policy became effective.

12. Please state the amount of money paid by the Insured towards the premium of the 

Policy in place at the time of the Loss.

13. Please state whether or not you performed any inspections of the insured premises 

prior to the Loss. If so, provide the date the inspection was performed, the purpose of the inspection, 

by whom and their contact information.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 27 of 204
14. Please provide the name and contact information for the agent that sold the Policy to 

the Insured. 

15. If you contend that the Insured did not comply with the terms and conditions set forth 

in the Policy please described:

a. the term and/or condition of the Policy not complied with;

b. how the Insured failed to comply with the term and/or condition;

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 28 of 204
c. when a request was made by you demanding compliance with the term and/or 

condition of the Policy;

d. why compliance with the terms and/or condition was necessary for you to 

adjust the Loss and determine coverage.

16. Please verify the name, phone number, address and title of the corporate 

representative(s) with the most knowledge regarding the allegations set forth in the complaint.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 29 of 204
17. Please identify all claims made by the Insured for the Insured premises.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 30 of 204
IN WITNESS WHEREOF, the Insurance Company has executed the foregoing answers to 

interrogatories and states that same are true and correct to the best of the undersigned’s knowledge 

and belief.

_______________________________________

JEWELERS MUTUAL INSURANCE COMPANY

By: ________________________________

Title: _______________________________

STATE OF FLORIDA }

}

COUNTY OF _____________ }

BEFORE ME, the undersigned authority, personally appeared ________________________, 

who is personally known to me or who has produced as identification, being 

first duly sworn according to law, deposes and says that he executed the foregoing Answers to 

Plaintiff's First Set of Interrogatories and that they are true and correct to the best of his/her 

knowledge and belief.

IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of my 

office; in the County and State last aforesaid, this day of ____________ 2022.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 31 of 204
COMPLAINT 

Plaintiff, MAJOR LEAGUE JEWELERS (the “Insured”), hereby sues Defendant, 

JEWELERS MUTUAL INSURANCE COMPANY (the “Insurance Company”), and alleges as 

follows: 

PARTIES, JURISDICTION AND VENUE 

1. This is an action for damages that exceeds Thirty Thousand and 00/100 Dollars 

($30,000.00), exclusive of interest, costs and attorney’s fees and equitable relief by way of a 

Declaratory Judgment action. 

2. The Insured is an individual who at all times material hereto has resided in Broward 

County, Florida. 

3. The Insurance Company is a Florida corporation qualified to do business in Florida 

and has, at all times material hereto, been conducting business in Broward County, Florida. 

4. Venue is proper in Broward County, Florida because the contract, which forms the 

subject matter of this lawsuit, was executed in Broward County, Florida. 

5. All conditions precedent to the filing of this lawsuit have occurred, have been 

waived or have been performed. 

 IN THE CIRCUIT COURT OF THE 17TH 

JUDICIAL CIRCUIT IN AND FOR 

BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

 Plaintiff, 

v. 

JEWELERS MUTUAL INSURANCE 

COMPANY, 

 Defendant, 

 / 

CASE NO.: 

Filing # 150850124 E-Filed 06/03/2022 04:20:18 PM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 32 of 204
GENERAL ALLEGATIONS 

6. At all times material hereto, in consideration of a premium paid by the Insured, 

there was in full force and effect a certain homeowners insurance policy issued by the Insurance 

Company with a policy number of 55-015767 (the “Policy”). A true and correct copy of policy is 

attached hereto as Exhibit “A”. 

7. Accordingly, under the terms of the Policy, the Insurance Company agreed to 

provide insurance coverage to the Insured’s property against certain losses. The damaged property 

is located at 10272 Cayman St, Hollywood, FL 33026 (the “Property”). 

8. On or about September 29th, 2021, while the Policy was in full force and effect, the 

Property sustained a covered loss as a result of Negligent Procurement (the “Loss”). 

9. The Insurance Company assigned claim number 45-014740 to the Loss. 

10. Subsequently, on or about December 23rd, 2021, the Insurance Company informed 

the Insured that it was denying coverage for the Loss on the basis that it was not covered by the 

Policy. However, after diligent inspection of the Loss, it was obvious that the Property sustained 

damage which the Insurance Company agreed to provide coverage for under the terms of the 

Policy. 

11. The Insured has suffered and continues to suffer damages resulting from Insurance 

Company’s breach of the Policy. 

12. The Insured has been obligated to retain the undersigned attorneys for the 

prosecution of this action and is entitled to a reasonable attorney’s fee pursuant to Florida Statute 

Sections 627.428 and/or 626.9373. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 33 of 204
COUNT I 

BREACH OF CONTRACT 

13. The Insured reincorporates paragraphs 1 through 12 as if fully set forth herein. 

14. It is undisputed that the Insured and the Insurance Company entered into a written 

contract, the Policy, wherein the Insured agreed to pay a premium and the Insurance Company 

agreed to insure the Insured’s Property. 

15. The Insured has paid all premiums due and owing as contemplated by the Policy; 

thus, fully performing obligations under the Policy. 

16. The Insured’s Property sustained damage which the Insurance Company agreed to 

provide coverage for under the terms of the Policy. 

17. Furthermore, at all times material hereto, the Insured has satisfied all post-loss 

obligations to the best of ability in accordance with the Policy. 

18. In contrast, the Insurance Company has failed to: (i) acknowledge coverage for the 

Loss; and/or (ii) acknowledge that payment would be forthcoming; and/or (iii) make any payment 

of insurance proceeds to the Insured. As a result of the foregoing, the Insurance Company has 

breached the Policy. 

19. As a direct and proximate result of the Insurance Company’s breach of the Policy, 

the Insured has sustained damages. 

WHEREFORE, the Insured respectfully requests that this Court enter judgment against the 

Insurance Company for damages, plus interest, court costs and reasonable attorney’s fees pursuant 

to Sections 627.428 and/or 626.9373. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 34 of 204
COUNT II 

DECLARATORY JUDGMENT 

20. The Insured reincorporates paragraphs 1 through 12 as if fully set forth herein. 

21. There is a bona fide, actual, present, adverse, and practical need for this Court to 

render a declaration as to whether the Policy issued by Insurer to Insured provides coverage to 

Insured for the Loss. 

22. There is doubt between the Insured and Insurer regarding coverage of the loss 

which affects the rights and/or privileges of the Parties. 

23. This declaration deals with a present controversy as to the application of the law to 

facts regarding the insurance coverage available to Insured for the Loss. 

24. By filing this declaratory judgment action, the Insured is not requesting that the 

Court merely provide legal advice or answer questions propounded from curiosity. 

25. Based upon the foregoing, the Insured is entitled to a declaratory judgment, holding 

that coverage does exist for the Loss; thus removing any doubt that exists between the Parties. 

26. Pursuant to Section 86.081, Florida Statues, the Insured is entitled to costs. 

 WHEREFORE, the Insured respectfully seeks the entry of a declaratory judgment against the 

Insurer holding that the Loss is covered under the Policy, plus costs and attorney fees for bringing 

this action and such other relief as the Court deems just and proper. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 35 of 204
JURY TRIAL DEMAND 

 Plaintiff hereby demands a trial by jury on all issues so triable. 

Dated this 3rd day of June 2022. 

 Respectfully Submitted, 

 Your Insurance Attorney, PLLC. 

2601 South Bayshore Drive 18th Floor 

 Coconut Grove, FL 33133 

 Phone No.: 1-888-570-5677 

 Fax: 1-888-745-5677 

 Email:YIA20@Yourinsuranceattorney.com 

 Secondary Email: Eservice@Yourinsuranceattorney.com 

 By: /s/ Idelys Martinez______________ 

Idelys Martinez, Esq. 

 Florida Bar No. 1011047 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 36 of 204
	
		

	
		

		

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Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 42 of 204
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Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 43 of 204
	
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Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 47 of 204
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Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 48 of 204
Copyright, American Association of Insurance Services, Inc., 2015 

AAIS This endorsement changes

CL 0600 01 15 the policy

Page 1 of 1 -- PLEASE READ THIS CAREFULLY -- 

CERTIFIED TERRORISM LOSS 

1. The following definitions are added. 

a. "Certified act of terrorism" means an act 

that is certified by the Secretary of the 

Treasury, in consultation with the 

Secretary of Homeland Security, and the 

Attorney General of the United States: 

1) to be an act of terrorism; 

2) to be a violent act or an act that is 

dangerous to human life, property, or 

infrastructure; 

3) to have resulted in damage: 

a) within the United States; or 

b) to an air carrier (as defined in 

section 40102 of title 49, United 

States Code); to a United States 

flag vessel (or a vessel based 

principally in the United States, 

on which United States income 

tax is paid and whose insurance 

coverage is subject to regulation 

in the United States), regardless 

of where the loss occurs; or at 

the premises of any United 

States mission; 

4) to have been committed by an 

individual or individuals, as part of an 

effort to coerce the civilian population 

of the United States or to influence 

the policy or affect the conduct of the 

United States Government by 

coercion; and 

5) to have resulted in insured losses in 

excess of five million dollars in the 

aggregate, attributable to all types of 

insurance subject to the Terrorism 

Risk Insurance Act, as amended. 

b. "Certified terrorism loss" means loss that 

results from a "certified act of terrorism". 

2. The "terms" of any terrorism exclusion that is 

part of or that is attached to this Coverage 

Part are amended by the following provision: 

 This exclusion does not apply to "certified 

terrorism loss". 

3. The following provision is added. 

 If the Secretary of the Treasury determines 

that the aggregate amount of "certified 

terrorism loss" has exceeded one hundred 

billion dollars in a calendar year (January 1 

through December 31), and "we" have met 

"our" insurer deductible under the Terrorism 

Risk Insurance Act, as amended, "we" will 

not pay for any portion of "certified terrorism 

loss" that exceeds one hundred billion 

dollars. If the "certified terrorism loss" 

exceeds one hundred billion dollars in a 

calendar year (January 1 through December 

31), losses up to one hundred billion dollars 

are subject to pro rata allocation in 

accordance with procedures established by 

the Secretary of the Treasury under the 

Terrorism Risk Insurance Act, as amended. 

4. The following provisions are added. 

a. Neither the "terms" of this endorsement 

nor the "terms" of any other terrorism 

endorsement attached to this Coverage 

Part provide coverage for any loss that 

would otherwise be excluded by this 

Coverage Part under: 

1) exclusions that address war, military 

action, or nuclear hazard; or 

2) any other exclusion; and 

b. the absence of any other terrorism 

endorsement does not imply coverage 

for any loss that would otherwise be 

excluded by this Coverage Part under: 

1) exclusions that address war, military 

action, or nuclear hazard; or 

2) any other exclusion. 

CL 0600 01 15

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 49 of 204
Copyright, American Association of Insurance Services, Inc., 2006 

AAIS This endorsement changes

CL 1630 06 06 the policy

Page 1 of 3 -- PLEASE READ THIS CAREFULLY -- 

CONDITIONAL TERRORISM EXCLUSION 

NOTICE 

The Terrorism Risk Insurance Program (the Program), as 

established under federal law, is scheduled to terminate while 

your policy is in effect. 

The Terrorism Exclusion found in this endorsement will apply 

only if the federal government does not renew, extend, or 

otherwise replace the Program or if the conditions, definitions, 

or requirements of the Program are changed by the federal 

government and federal law no longer requires that we make 

Terrorism Coverage available to you. 

1. The Terrorism Exclusion set forth by this 

endorsement becomes effective on the 

earliest of the following: 

a. the date that the federal Terrorism Risk 

Insurance Program (the Program) 

established by the Terrorism Risk 

Insurance Act has terminated with 

respect to the type of insurance provided 

by the Coverage Part to which this 

endorsement applies; or 

b. the effective date of a renewal, 

extension, or continuation of the 

Program, if federal law no longer requires 

that "we" make terrorism coverage 

available to "you" and the Program has 

been renewed, extended, or replaced 

subject to changes that: 

1) redefine terrorism; or 

2) increase "our" financial exposure 

under the Program; or 

3) impose requirements on insurance 

coverage for terrorism that differ from 

the terms, amounts, or other 

limitations that otherwise govern 

coverage for loss or damage under 

the "terms" of the Coverage Part to 

which this endorsement applies. 

If a condition described above under items 

1.a. and 1.b. occurs prior to the effective 

date of the policy period to which this 

endorsement applies, the Terrorism 

Exclusion set forth by this endorsement 

applies as of the effective date of that policy 

period. 

2. If the Terrorism Exclusion set forth by this 

endorsement becomes effective, this 

Terrorism Exclusion: 

a. supersedes any other endorsements that 

address "certified acts of terrorism", 

"certified terrorism loss", "non-certified 

acts of terrorism", and or "non-certified 

terrorism loss" that also apply to the 

Coverage Part to which this endorsement 

applies, but only with respect to loss or 

damage caused by one or more incidents 

of terrorism that occur on or after the 

effective date of this Terrorism Exclusion; 

and 

b. remains in effect unless "we" notify "you" 

of changes to this Terrorism Exclusion. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 50 of 204
AAIS 

CL 1630 06 06 

Page 2 of 3 

Copyright, American Association of Insurance Services, Inc., 2006 

3. If none of the conditions described above 

under items 1.a. and 1.b. occur, any other 

endorsements that address "certified acts of 

terrorism", "certified terrorism loss", "noncertified acts of terrorism", and or "noncertified terrorism loss" that also apply to the 

Coverage Part to which this endorsement 

applies continue to apply until "we" notify 

"you" of changes to such other 

endorsements. 

4. The word terrorism, when shown in this 

endorsement in quotation marks, has the 

following meaning: 

 "Terrorism" means activities against persons, 

organizations, or property of any nature: 

a. that involve the following or preparation 

for the following: 

1) use or threat of force or violence; or 

2) commission or threat of a dangerous 

act; or 

3) commission or threat of an act that 

interferes with or disrupts an 

electronic, communication, 

information, or mechanical system; 

and 

b. when one or both of the following 

applies: 

1) the effect is to intimidate or coerce a 

government or the civilian population 

or any segment thereof, or to disrupt 

any segment of the economy; or 

2) it appears that the intent is to 

intimidate or coerce a government, 

or to further political, ideological, 

religious, social, or economic 

objectives, or to express (or express 

opposition to) a philosophy or 

ideology. 

5. The following exclusion is added: 

TERRORISM EXCLUSION 

 "We" will not pay for loss or damage caused 

directly or indirectly by "terrorism", including 

action in hindering or defending against an 

actual or expected incident of "terrorism". 

Such loss or damage is excluded regardless 

of any other cause or event that contributes 

concurrently or in any sequence to the loss 

or damage. 

 This exclusion applies only when one or 

more of the following are attributed to an 

incident of "terrorism": 

a. the "terrorism" is carried out by means of 

the dispersal or application of radioactive 

material, or through the use of a nuclear 

weapon or device that involves or 

produces a nuclear reaction, nuclear 

radiation, or radioactive contamination; or 

b. radioactive material is released, and it 

appears that one purpose of the 

"terrorism" was to release such material; 

or 

c. the "terrorism" is carried out by means of 

the dispersal or application of pathogenic 

or poisonous biological or chemical 

materials; or 

d. pathogenic or poisonous biological or 

chemical materials are released, and it 

appears that one purpose of the 

"terrorism" was to release such 

materials; or 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 51 of 204
AAIS 

CL 1630 06 06 

Page 3 of 3 

Copyright, American Association of Insurance Services, Inc., 2006 

e. the total of insured damage to all types of 

property in the United States, its 

territories and possessions, Puerto Rico, 

and Canada exceeds $25,000,000. In 

determining whether the $25,000,000 

threshold is exceeded, "we" will include 

all insured damage sustained by property 

of all persons and entities affected by the 

"terrorism" and business interruption 

losses sustained by owners or occupants 

of the damaged property. For the 

purpose of this provision, insured 

damage means damage that is covered 

by any insurance plus damage that 

would be covered by any insurance but 

for the application of any terrorism 

exclusions. Multiple incidents of 

"terrorism" which occur within a 72-hour 

period and appear to be carried out in 

concert or to have a related purpose or 

common leadership will be deemed to be 

one incident, for the purpose of 

determining whether the threshold is 

exceeded. 

 Item 5.e. above describes the threshold used 

to measure the magnitude of an incident of 

"terrorism" and the circumstances in which 

the threshold will apply, for the purpose of 

determining whether this Terrorism Exclusion 

will apply to that incident. When this 

Terrorism Exclusion applies to an incident of 

"terrorism", there is no coverage under the 

Coverage Part to which this endorsement 

applies. 

6. When the Terrorism Exclusion set forth by 

this endorsement applies due to an incident 

of "terrorism" described above under items 

5.a. or 5.b., that Terrorism Exclusion 

supersedes the Nuclear Hazard Exclusion in 

the Coverage Part to which this endorsement 

applies. 

7. The following provisions are added. 

a. Neither the "terms" of this endorsement 

nor the "terms" of any other terrorism 

endorsement attached to the Coverage 

Part to which this endorsement applies 

provide coverage for any loss or damage 

that would otherwise be excluded by that 

Coverage Part under: 

1) exclusions that address war, military 

action, or nuclear hazard; or 

2) any other exclusion. 

b. The absence of any other terrorism 

endorsement does not imply coverage 

for any loss or damage that would 

otherwise be excluded by the Coverage 

Part to which this endorsement applies 

under: 

1) exclusions that address war, military 

action, or nuclear hazard; or 

2) any other exclusion. 

CL 1630 06 06

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 52 of 204

		
	

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Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 84 of 204
Filing# 150850124 E-Filed 06/03/2022 04:20:18 PM

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

SUMMONS CASE NUMBER

DIVISION

X CIVIL

Q OTHER

PLAINTIFF(S) DEFENDANT(S) CLOCK IN MAJOR LEAGUE JEWELERS JEWELERS MUTUAL

INSURANCE COMPANY

THE STATE OF FLORIDA:

To Each Sheriff of the State:

You ARE COMMANDED to serve this summons and a copy of the Complaint, Plaintiff's First Set of

Interrogatories, Plaintiff's First Request for Production, and Notice of Taking Corporate

Representatives Deposition in this action on defendant:

JEWELERS MUTUAL INSURANCE COMPANY

c/o THE FLORIDA CHIEF FINANCIAL OFFICER as RA

200 E. GAINES STREET

TALLAHASSEE, FLORIDA 32399-4201

Defendant is required to serve written defenses to the Complaint on Plaintiffs Attorney:

Idelys Martinez, Esq., Florida Bar No. 1011047, whose address 2601 S. Bayshore Drive, 18?h Floor, Miami,

Florida 33133 Telephone No.: 1-888-570-5677, Telefax No.: 1-888-745-5677, Email:

Eservice@vourinsuranceattornev.corn, Secondary Email: YIA20@Yourinsuranceattorney.comwithin 20

days after service of this summons on that defendant, exclusive of the day of service, and to file the

original of the defenses with the Clerk of this Court either before service on Plaintiffs attorney or

immediately thereafter. Ifa defendant fails to do so, a default will be entered against that defendant for the

relief demanded in the Complaint.

DATE

CLERK OF COURTS

BY

DEPUTY CLERK

IF YOU ARE A PERSON WITH DISABILITY WHO NEEDS ANY ACCOMODATION IN ORDER TO PARTICIPATE IN THIS

PROCEEDING, YOU ARE ENTITLED, AT NO COST TO YOU, TO THE PROVISION OF CERTAIN ASSISTANCE. PLEASE

CONTACT THE ADA COORDINATOR, ROOM 20140,201 S.E. 63 STREET, FT. LAUDERDALE, FL 33301, (954) 831-7721 AT

LEAST 7 DAYS BEFORE YOUR SCHEDULED COURT APPEARANCE, OR IMMEDIATELY UPON RECEIVING THIS

NOTIFICATION IF THE TIME BEFORE THE SCHEDULE APPEARANCE IS LESS THAN 7 DAYS, IF YOU ARE HEARING OR

VOICE IMPAIRED, CALL 711.

COURTSEAL

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/03/2022 04:20: 16 PM.****

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

DEFENDANT’S NOTICE OF APPEARANCE 

AND DESIGNATION OF E-MAIL ADDRESSES 

COMES NOW WILLIAM R. LEWIS, ESQ., and KATELYN N. LOKUTA, ESQ., 

with the law firm of Butler Weihmuller Katz Craig LLP and hereby files their Notice of 

Appearance to represent the Defendant, JEWELERS MUTUAL INSURANCE 

COMPANY. It is respectfully requested that all future pleadings and discovery be 

served upon the undersigned in connection with this action. 

NOTICE IS ALSO HEREBY GIVEN that the Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY, by and through its undersigned counsel, and pursuant to the 

Supreme Court of Florida No. SC10-2101, Fla. Judicial Admin. R. 2.516(b)(1)(A), 

hereby designate the following primary and secondary e-mail addresses: 

Primary: wlewis@butler.legal 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

Filing # 151790061 E-Filed 06/20/2022 11:25:49 AM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 91 of 204
2 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Attorneys for Defendant, Jewelers Mutual Insurance 

Company

CERTIFICATE OF SERVICE

I certify that the foregoing instrument was served utilizing the Court’s e-filing 

portal and e-service in accordance with Fla.R.Jud.Admin. 2.516 and AOSC13-49 on 

June 20, 2022 to: 

Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Dr., 18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

eservice@yourinsuranceattorney.com 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 92 of 204
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 

Definitions Of Terms 

1. "Plaintiff," “you,” “your,” “Insured” means Plaintiff, MAJOR LEAGUE JEWELERS, 

its affiliates, agents, employees and representatives. 

2. “Defendant” and/or “JEWELERS" means Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY its agents, employees and representatives. 

3. The term "communication" shall mean any transmission of information by any 

means, including, without limitation, by spoken language, electronic transmission 

of data or any other means. The term "communication" shall include, without 

limitation, any copies of written information received by the person or entity 

responding to this request, even if such person or entity is not the primary or direct 

addressee of such written information. 

4. The term "document" or "documents" is used in its broadest sense and includes, 

without limitation, drafts, and documents whether printed, recorded, stored or 

reproduced by any mechanical or electronic process, or written or produced by 

hand, and including computer tapes (including backup tapes) and all other 

computer-related documents, within your possession, custody or control. 

"Documents" shall also include (1) each copy that is not identical to the original or 

to any other copy, and (2) any tangible thing that is called for by or identified in 

response to any request. "Document" as used herein shall be construed broadly to 

include all documents and things within the scope of the Florida Rules of Civil 

Procedure and refers to all writings or other graphic matter, as well as any other 

medium by which information is stored or recorded. It includes originals, drafts, 

copies and reproductions; and it includes, without limiting the generality of the 

foregoing, letters; memoranda; reports and/or summaries of investigations; police 

reports; accident reports; opinions or reports of consultants; diagrams; marginal 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 93 of 204
2 

comments appearing on any documents; accounts; telegrams; studies; lists of 

persons attending meetings or conferences; records or memoranda of telephone 

conversations; written statements; transcripts or recorded statements; recorded 

statements; records of personal conversations or interviews; calculations; 

computations; specifications; drawings; advertisements; circulars; trade letters; 

press releases; prints; recordings; positive or negative films, slides or photographs; 

magnetic, electronic or video tapes; computer tapes, cards or printouts; and all 

other things of like nature; and any and all containers, boxes or other receptacles 

or repositories housing or containing such "documents.” 

5. The term "referring" or "relating" shall mean showing, disclosing, averting to, 

comprising, evidencing, constituting or reviewing. 

6. “Subject Damages” means any loss or damage for which you now contend 

JEWELERS must pay you in this lawsuit. 

7. “Subject Property” means the property that is the subject of your lawsuit. 

8. “Subject Loss” means the loss for which you believe JEWELERS owes you 

insurance proceeds. 

9. The “Subject Policy” means the insurance policy number 55-015767 issued by 

JEWELERS MUTUAL INSURANCE COMPANY to you for the policy period of 

December 28, 2021 to December 28, 2022. 

10. The term "representative" as used herein with regard to a person or entity means 

and includes each and every present and former director, officer, partner, 

employee, agent, independent consultant or expert or other person (including 

attorneys) acting or purporting to act on behalf of the person or entity. 

11. The singular includes the plural and vice versa; the words "and" and "or" shall be 

both conjunctive; the word "all" means "any and all"; the word "any" means "any 

and all"; the word "including" means "including, without limitation." 

12. All other words have their plain and ordinary meaning. 

Instructions 

1. This set of interrogatories shall be deemed to be continuing so as to require further 

and supplemental responses as specified in Florida Rules of Civil Procedure. 

2. Where identification of a document is requested, please set forth the identity of its 

author or originator, date of such authorship or origination, identity of each person 

to whom the original or copy was addressed or delivered, identity of each person 

known or reasonably believed to have present possession, custody, or control 

thereof, and a brief description of the subject matter thereof. 

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3 

3. If any documents covered by this Interrogatory are withheld by reason of a claim of 

privilege, work product immunity or other ground of non-production, a list is to be 

furnished identifying each such documents for which the privilege is claimed 

specifically by its nature (e.g., letter, memorandum, etc.) together with the following 

information with respect to any such document withheld: author; recipient; sender; 

indicated or blind copies; date; subject matter; basis on which the privilege is 

claimed; number of pages; and the paragraph of this Interrogatory to which such 

document relates. 

4. If you assert that any document to be identified in connection with answering these 

interrogatories has been destroyed or lost, set forth in writing the contents of the 

document, the date the document was destroyed or lost and the name of the 

person who authorized or directed the destruction of the document or was last in 

possession of the document. If you cannot respond to any of the interrogatories in 

full, answer to the extent possible, and specify in writing the reasons for your 

inability to provide a complete answer to the interrogatory. 

5. All objections or answers to interrogatories which fail or refuse fully to respond to 

any interrogatory on the ground of any claim of privilege of any kind whatever shall 

(a) state the nature of the claim of privilege; (b) state all facts relied upon in support 

of the claim of the privilege or related thereto; (c) identify all documents related to 

the claim of privilege; (d) identify all persons having knowledge of any facts related 

to the claim of privilege; and (3) identify all events, transactions or occurrences 

related to the claim of privilege. 

6. Where identification of a person is requested, please set forth the person's name, 

last-known home and business address and telephone number, and relation to the 

party answering these interrogatories, if any. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 95 of 204
4 

INTERROGATORIES

1. State comprehensively and in detail all damages that you are seeking to recover 

in this lawsuit. Be sure that your answer (a) sets forth the grand total amount 

claimed, in dollars and cents; (b) contains a line item description for each item of 

damage claimed, including the precise dollar amount claimed for each line item; 

(c) contains a detailed description of how you determined the amount of each 

damage claimed; (d) shows all your calculations in determining these dollar 

figures; 

RESPONSE: 

2. State with specificity the total monetary amount Plaintiff is alleging Jewelers 

owes to Plaintiff as it relates to the lawsuit and how you determined this amount. 

RESPONSE: 

(Remainder of page intentionally left blank.) 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 96 of 204
5 

MAJOR LEAGUE JEWELERS 

By: ______________________________ 

Print Name: _______________________ 

Title: _____________________________ 

ACKNOWLEDGMENT

STATE OF _______________ 

COUNTY OF ______________ 

The foregoing instrument was acknowledged before me by means of ☐ physical 

presence or ☐ online notarization via audio-video communication by 

__________________ on behalf of MAJOR LEAGUE JEWELERS ☐ who is personally 

known to me or ☐ who has produced ________________________ as identification 

and who, after first being duly sworn, deposes and says that he/she has read the 

foregoing Answers to the Interrogatories which were propounded to him/her by the 

Defendant(s) which, to the best of his/her knowledge and belief, are true and correct, 

and who has acknowledged to me that he/she executed the same as his/her free act 

and deed. 

SWORN TO AND SUBSCRIBED before me, this _____ day of 

_______________, 2022. 

___________________________________ 

NOTARY PUBLIC 

State of __________ at Large 

My Commission Expires: 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 97 of 204
*22-000201464*

*22-000201464*

KJ1

cc to:

ANTHONY LOPEZ

2601 SOUTH BAYSHORE DRIVE - SUITE 850

COCONUT GROVE, FL 33133

MAJOR LEAGUE JEWELERS CASE #: CACE-22-008155

COURT: CIRCUIT COURT

COUNTY: BROWARD

PLAINTIFF(S) DFS-SOP #: 22-000201464

VS.

JEWELERS MUTUAL INSURANCE COMPANY

DEFENDANT(S)

_______________________________________/

SUMMONS, COMPLAINT, DISCOVERY

 

NOTICE OF SERVICE OF PROCESS

NOTICE IS HEREBY GIVEN of acceptance of Service of Process by the Chief Financial Officer of the

State of Florida. Said process was received in my office by ELECTRONIC DELIVERY on Tuesday,

June 14, 2022 and a copy was forwarded by ELECTRONIC DELIVERY on Thursday, June 16, 2022 to

the designated agent for the named entity as shown below.

 JEWELERS MUTUAL INSURANCE COMPANY

 MARK K WILLSON

 24 JEWELERS PARK DR

 NEENAH, WI 54956

*Our office will only serve the initial process(Summons and Complaint) or Subpoena and is not responsible

for transmittal of any subsequent filings, pleadings, or documents unless otherwise ordered by the Court

pursuant to Florida Rules of Civil Procedure, Rule #1.080

 

 Jimmy Patronis

 Chief Financial Officer

Office of the General Counsel - Service of Process Section

200 East Gaines Street - P.O. Box 6200 - Tallahassee, FL 32314-6200 - (850)413-4200

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 98 of 204
IN THE CIRCUIT COURT OF THE 

17TH JUDICIAL CIRCUIT IN AND 

FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

________________________________________/ 

DEFENDANT’S MOTION TO DISMISS 

COUNT II OF PLAINTIFFS’ COMPLAINT 

Defendant, JEWELERS MUTUAL INSURANCE COMPANY (“JEWELERS 

MUTUAL”), by and through its undersigned counsel, moves this Court to dismiss Count II of 

the Complaint (“Complaint”) filed by Plaintiff, MAJOR LEAGUE JEWELERS (“PLAINTIFF”), 

and in support thereof states as follows: 

I. FACTUAL BACKGROUND 

1. JEWELERS MUTUAL issued an insurance policy to Plaintiff, identified by 

policy number 55-015767, for the period of December 28, 2020 to December 28, 2021, which 

provided coverage for PLAINTIFF’s jewelry sold from its physical retail space located at 

10272 Cayman St., Hollywood, FL 33026, subject to the terms, conditions, limitations, and 

exclusions contained therein. See Complaint, ¶ 6. 

2. PLAINTIFF alleges its property sustained a covered loss as a result of 

Negligent Procurement on or about September 29, 2021 (“Claim”). See Complaint, ¶ 8. 

3. PLAINTIFF disagrees with JEWELERS MUTUAL’s coverage position in 

connection with the Claim. See Complaint, ¶ 10.

4. PLAINTIFF’S Complaint includes two (2) causes of action. Count II is a cause 

of action in connection with the Claim for declaratory relief. Count I is a cause of action in 

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2 

connection with the Claim for breach of contract.

5. Count II is duplicative of Count I and PLAINTIFF has failed to articulate a 

separate bona fide, actual, present need for any declaration of rights.

6. Therefore, this Court should dismiss Count II of the Complaint.

II. LEGAL ARGUMENT 

Count II should be dismissed because it fails to state a cause of action for declaratory 

relief. In order to demonstrate a right to proceed with an action seeking declaratory relief, 

“the party seeking a declaration must show that he is in doubt as to the existence or 

nonexistence of some right, status, immunity, power, or privilege and that he is entitled to 

have such doubt removed.” “X” Corp. v. “Y” Person, 622 So.2d 1098, 1101 (Fla. 2d DCA 

1993) (citing Flagship Real Estate Corp. v. Flagship Banks, Inc., 374 So. 2d 1020 (Fla. 2d 

DCA 1979)). Moreover, “[b]efore any proceedings for declaratory relief should be entertained 

it should be clearly made to appear that there is a bona fide, actual, present need for the 

declaration.” Wells v. Wells, 24 So.3d 579, 583 (Fla. 4th DCA 2009) (quoting May v. Holley, 

59 So.2d 636, 639 (Fla. 1952)). 

In Count II of the Complaint, PLAINTIFF purports to seek declaratory relief. 

Specifically, PLAINTIFF seeks a declaration by this Court as to whether PLAINTIFF is entitled 

to coverage under the Policy for the reported loss. However, the Complaint also asserts a 

breach of contract count for this loss. The breach of contract and declaratory relief counts are 

premised on the same factual disputes and seek a determination of coverage available for 

the reported loss. In such a circumstance, “Plaintiff will be able to secure full, adequate and 

complete relief through the breach of contract claim,” and the claims for declaratory judgment 

should be dismissed. Fernando Grinberg Trust Success Int. Properties, LLC v. Scottsdale 

Ins. Co., No. 10-20448-Civ, 2010 WL 2510662, at *1 (S.D. Fla. June 21, 2010). As explained 

in Fernando Grinberg Trust Success Int. Properties: 

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3 

A court may declare the rights and other legal relations of any interested party 

in the case of an actual controversy within its jurisdiction. 28 U.S.C. § 2201. 

Florida Statute Section 86.021 provides for the declaration of rights or status 

where a party to an agreement is in doubt as to his or her rights. City of 

Hollywood v. Fla. Power & Light, Co., 624 So.2d 285 (Fla. Dist. Ct. App. 1993). 

The only relevant inquiry in a motion to dismiss a declaratory judgment action 

is whether or not the plaintiff is entitled to a declaration of rights. Toban v. Am. 

Sec. Ins. Co., No. 06-61912-Civ, 2007 WL 1796250, at *2 (S.D. Fla. June 20, 

2007); see also Gov’t Emp. Ins. v. Anta, 379 So.2d 1038, 1039 (Fla. Dist. Ct. 

App. 1980). “[A] trial court should not entertain an action for declaratory 

judgment on issues which are properly raised in other counts of pleadings and 

already before the court, through which the plaintiff will be able to secure full, 

adequate and complete relief.” McIntosh v. Harbour Club Villas, 468 So.2d 

1075, 1080-81 (Fla. Dist. Ct. App. 1985) (Nesbitt, J. specially concurring); see 

also Taylor v. Cooper, 60 So.2d 534, 535-36 (Fla. 1952). 

Id.

“The Declaratory Judgment Act ‘permits actual controversies to be settled before they 

ripen into violations of law or a breach of contractual duty.’” Eisenberg v. Standard Ins. Co., 

No. 09-80199-CIV, 2009 WL 3667086, at *2 (S.D. Fla. Oct. 26, 2009) (quoting 10B C. Wright 

& A. Miller, Federal Practice & Procedure, Civil 3d § 2751 (2004)). Asking the Court to declare 

whether the policy provides coverage to the PLAINTIFF for the Loss, however, is not a proper 

use of the declaratory judgment act. Where, as here, the PLAINTIFF believes that the 

insurance policy does, in fact, provide coverage, the PLAINTIFF is actually seeking a judicial 

declaration that JEWELERS MUTUAL has breached the Policy. As explained in Eisenberg: 

A petition seeking declaratory judgment that alleges breach of duties and 

obligations under the terms of a contract and asks the court to declare those 

terms breached is nothing more than a petition claiming breach of contract. It 

thus provides an adequate remedy at law, and a decision on the merits of the 

breach of contract claim would render the [plaintiff’s] request for declaratory 

judgment moot or redundant. 

Id. at *2-3 (quoting Amerisure Mut. Ins. Co. v. Maschmeyer Landscapers, Inc., 2007 WL 

2811080 (E.D. Mo. 2007)). Simply put, there is no need for such a judicial declaration 

because PLAINTIFF has not identified a legitimate confusion, ambiguity or the need for 

judicial interpretation of the Policy itself. 

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A judicial declaration is unnecessary and duplicative of the breach of contract claim in 

the Complaint. It has been held that “[a] court must dismiss a claim for declaratory judgment 

if it is duplicative of a claim for breach of contract and, in effect, seeks adjudication on the 

merits of the breach of contract claim.” Miami Yacht Charters, LLC v. National Union Fire Ins. 

Co. of Pittsburgh, PA, No. 11-21163-CIV, 2012 WL 1416428, at *2 (S.D. Fla. Apr. 24, 2012) 

(citations omitted). In Berkower v. USAA Casualty Insurance Company, 2016 WL 4574919 

(S.D. Fla. Sept. 1, 2016), the Southern District affirmed its holding in Fernando Grinberg 

Trust, 2010 WL 2510662, *1 (S.D. Fla) and addressed the impact of Higgins v. State Farm 

Fire & Cas. Co., 894 So.2d 5, 15 (Fla. 2004), which held that declaratory judgments “may 

proceed based on an unambiguous insurance policy.” The Berkower Court noted that despite 

the holding in Higgins, a court must dismiss a declaratory judgment action when the breach 

of contract claim involves the same factual dispute as the declaratory judgment claim and the 

plaintiff will be able to secure full and adequate relief in the breach of contract claim. Berkower 

v. USAA Casualty Insurance Company, 2016 WL 4574919, *3 [Emphasis added]; see also

Regency of Palm Beach, Inc. v. QBE Ins. Corp., 2009 WL 2729954 (S.D. Fla. Aug. 25, 2009) 

(dismissing portions of declaratory judgment count because damages will be resolved in the 

breach of contract count); Cummins vs. Lexington Insurance Company, 2018 WL 4039310 

(S.D. Fla. 2018); Perez, No. 19-22761-CIV, 2019 WL 5457746, at *5; Perez, No. 19-cv22346-GAYLES, 2020 WL 607145, at *3. Here, as in Berkower, PLAINTIFF has asserted a 

count for breach of contract and a count for declaratory relief. Both counts incorporate by 

reference all general allegations of the Complaint, and both counts also seek recovery of 

attorneys’ fees and costs. PLAINTIFF is asking the Court to determine coverage under the 

Policy and will be able to secure full and adequate relief in Count I for breach of contract 

which is premised on the identical factual dispute. 

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5 

In sum, PLAINTIFF’S claim for declaratory relief is, in reality, an improperly plead 

action for breach of contract. PLAINTIFF has failed to articulate a separate bona fide, actual, 

present need for any declaration of rights. As such, Count II of PLAINTIFF’s Complaint 

should be dismissed as a matter of law. 

WHEREFORE, Defendant, JEWELER’S MUTUAL INSURANCE COMPANY, 

respectfully requests that this Court enter an Order dismissing Count II of the Complaint filed 

by Plaintiff, MAJOR LEAGUE JEWELERS, for the reasons stated herein and grant 

JEWELERS MUTUAL such other and further relief as this Court deems just and proper. 

BUTLER WEIHMULLER KATZ CRAIG LLP 

s/ Katelyn N. Lokuta 

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Attorneys for Defendant, Jewelers Mutual Insurance 

Company 

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6 

CERTIFICATE OF SERVICE

I certify that a copy hereof has been furnished to: 

Idelys Martinez, Esq. 

Florida Bar No.: 1011047 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Dr., 18th Floor 

Coconut Grove, FL 33133 

Phone: (888)570-5677 

YIA20@yourinsuranceattorney.com 

Eservice@yourinsuranceattorney.com 

Attorneys For: Plaintiff 

By e-Portal on June 30, 2022 

 s/ Katelyn N. Lokuta____________________ 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 104 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

ANSWER, AFFIRMATIVE DEFENSES AND DEMAND FOR JURY TRIAL 

COMES NOW, the Defendant, JEWELERS MUTUAL INSURANCE COMPANY 

(“Jewelers Mutual”), by and through its undersigned counsel, and responds to the 

Complaint filed herein as follows: 

PARTIES, JURISDICTION AND VENUE

1. Admitted that Plaintiff has alleged that their action is one for damages that 

exceed Thirty Thousand Dollars ($30,000.00), exclusive of attorney’s fees and costs; 

otherwise, denied. 

2. Defendant is without sufficient information to admit the allegations of this 

paragraph. Therefore, denied. 

3. Denied that Jewelers Mutual is a Florida corporation. Admitted for purposes 

of jurisdiction and venue, that Jewelers Mutual is authorized to do business in Florida and 

has, at all times material hereto, been conducting business in Broward County, Florida; 

otherwise denied. 

4. Admitted for purposes of jurisdiction and venue, otherwise, denied. 

5. Denied. 

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2 

GENERAL ALLEGATIONS 

6. Admitted that Jewelers Mutual issued an insurance policy to Plaintiff, 

identified by policy number 55-015767, for the period of December 28, 2021 to December 

28, 2022, which provided coverage for Plaintiff’s jewelry sold from its physical retail space 

located at 10272 Cayman St., Hollywood, FL 33026, subject to the terms, conditions, 

limitations, and exclusions contained therein (“Policy”); otherwise, denied. 

7. Admitted that Jewelers Mutual issued an insurance policy to Plaintiff, 

identified by policy number 55-015767, for the period of December 28, 2021 to December 

28, 2022, which provided coverage for Plaintiff’s jewelry sold from its physical retail space 

located at 10272 Cayman St., Hollywood, FL 33026, subject to the terms, conditions, 

limitations, and exclusions contained therein; otherwise, denied. 

8. Admitted that Jewelers Mutual issued an insurance policy to Plaintiff, 

identified by policy number 55-015767, for the period of December 28, 2021 to December 

28, 2022, which provided coverage for Plaintiff’s jewelry sold from its physical retail space 

located at 10272 Cayman St., Hollywood, FL 33026, subject to the terms, conditions, 

limitations, and exclusions contained therein; Admitted that Plaintiff reported a 

supplemental claim for loss, arising from transit of certain jewelry on or about September 

29, 2021; otherwise denied. 

9. Admitted that Jeweler’s Mutual assigned claim number 45-014740 to 

investigate the supplemental loss reported by Plaintiff, arising from transit of certain 

jewelry on or about September 29, 2021. 

10. Admitted that on or about December 23, 2021, Jeweler’s Mutual informed 

the Plaintiff that it was denying coverage for claim number 45-014740, as the loss was 

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3 

not covered by the jewelers insurance policy identified by policy number 55-015767, 

issued to the Plaintiff, for the period of December 28, 2020 to December 28, 2021; 

otherwise denied. 

11. Denied. 

12. Jewelers Mutual is without knowledge as to what to compelled Plaintiff to 

retain counsel, therefore denied. 

COUNT I- BREACH OF CONTRACT

13. Defendant readopts and realleges its responses to paragraphs 1 through 

12 as if fully set forth herein. 

14. Admitted that Jewelers Mutual issued an insurance policy to Plaintiff, 

identified by policy number 55-015767, for the period of December 28, 2020 to December 

28, 2021, which provided coverage for Plaintiff’s jewelry sold from its physical retail space 

located at 10272 Cayman St., Hollywood, FL 33026, for a premium paid, subject to the 

terms, conditions, limitations, and exclusions contained therein; otherwise denied. 

15. Admitted that the Plaintiff has paid all premiums due and owing as 

contemplated by “the Policy”; otherwise denied. 

16. Denied. 

17. Denied. 

18. Admitted that the loss was not covered by the insurance policy identified by 

policy number 55-015767, issued to the Plaintiff, for the period of December 28, 2020 to 

December 28, 2021; otherwise denied. 

19. Denied. 

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COUNT II- DECLARATORY JUDGMENT 

20.-26. See Motion to Dismiss Count II filed contemporaneously with this 

answer. 

AFFIRMATIVE DEFENSES 

FIRST AFFIRMATIVE DEFENSE 

Plaintiff failed to provide the department with the Notice required by section 

627.70152, Florida Statutes, et seq. Section 627.70152(3)(a), Florida Statutes, states: 

(3) NOTICE. – 

(a) As a condition precedent to filing a suit under a property insurance 

policy, a claimant must provide the department with written notice of 

intent to initiate litigation on a form provided by the department. Such 

notice must be given at least 10 business days before filing suit under 

the policy, but may not be given before the insurer has made a 

determination of coverage under s. 627.70131. Notice to the insurer 

must be provided by the department to the e-mail address 

designated by the insurer under s. 624.422. The notice must state 

with specificity all of the following information: 

1. That the notice is provided pursuant to this section. 

2. The alleged acts or omissions of the insurer giving rise to the 

suit, which may include a denial of coverage. 

3. If provided by an attorney or other representative, that a copy 

of the notice was provided to the claimant. 

4. If the notice is provided following a denial of coverage, an 

estimate of damages, if known. 

5. If the notice is provided following acts or omissions by the 

insurer other than denial of coverage, both of the following: 

a. The presuit settlement demand, which must itemize the 

damages, attorney fees, and costs. 

b. The disputed amount. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 108 of

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Documentation to support the information provided in this paragraph 

may be provided along with the notice to the insurer. 

(b) A claimant must serve a notice of intent to initiate litigation within the 

time limits provided in s. 95.11. However, the notice is not required if 

the suit is a counterclaim. Service of a notice tolls the time limits 

provided in s. 95.11 for 10 business days if such time limits will expire 

before the end of the 10-day notice period. 

* * * 

This statute requires Plaintiff to provide the department with written notice of intent 

to initiate litigation on a form provided by the department to Jewelers Mutual. Notice must 

be given at least 10 business days before filing suit under the Policy. 

Plaintiff filed the Complaint on June 3, 2022. But Plaintiff failed to provide a Notice 

required by the statute before filing the Complaint. A Notice that complies with all 

requirements of the statute is a condition precedent to Plaintiff’s filing suit. Plaintiff failed 

to comply with all requirements of the statute, and did not file a Notice. Because Plaintiff 

failed to file the required Notice, the Complaint fails to satisfy the minimum pleading 

requirements as established by section 627.70152(3), Florida Statutes. As such, Plaintiff 

has not perfected her right to sue Jewelers Mutual. 

Plaintiff cannot demonstrate entitlement to attorney’s fees under the statute. 

Plaintiff did not provide a pre-suit demand, so there is no reasonable basis for a 

calculation of attorney’s fees based on section 627.70152(8)(a), Florida Statutes. 

SECOND AFFIRMATIVE DEFENSE 

The relief sought by Plaintiff in this lawsuit and the underlying claim, in all or part, 

is excepted, excluded, and/or limited under the following Policy provision: 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 109 of

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PERILS NOT COVERED, EXCLUSIONS AND LIMITATIONS

“We” do not pay for loss if one or more of the following exclusions apply to the loss, 

regardless of other causes or events that contribute to or aggravate the loss, whether 

such causes or events act to produce the loss before, at the same time as, or after the 

excluded causes or events. 

* * * 

4. Criminal, Fraudulent or Dishonest Act – 

a. “We” do not cover loss caused by or resulting from criminal, 

fraudulent or dishonest acts committed by: 

* * * 

3) Others to whom “you” or anyone delivers or entrusts the 

property covered for any reason, including but not limited 

to giving possession of property to someone by reason 

a fraudulent scheme, trick, device or false pretense by 

the person receiving the property except for temporary 

safekeeping during travel; 

Based upon information and belief, the items shipped by Plaintiff were delivered to 

the customer who purchased the jewelry, however the customer claims to have not 

received the package. Losses resulting from criminal or fraudulent acts, including 

delivering or entrusting property to someone by reason of false pretense, are not covered 

under the Policy.

THIRD AFFIRMATIVE DEFENSE 

The relief sought by Plaintiff in this lawsuit and the underlying claim, in all 

or part, is excepted, excluded, and/or limited under the following Policy provision: 

PERILS NOT COVERED, EXCLUSIONS AND LIMITATIONS

“We” do not pay for loss if one or more of the following exclusions apply to the loss, 

regardless of other causes or events that contribute to or aggravate the loss, whether 

such causes or events act to produce the loss before, at the same time as, or after the 

excluded causes or events. 

* * * 

6. Disappearance – “We” do not cover unexplained loss, shortage 

discovered on taking inventory, or shortage from a package received 

in good condition with unbroken seals. 

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Based upon information and belief, the items shipped by Plaintiff were delivered to 

the customer who purchased the jewelry, however the customer claims to have not 

received the package. Unexplained losses are not covered by the Policy. 

FOURTH AFFIRMATIVE DEFENSE 

The relief sought by Plaintiff in this lawsuit and the underlying claim, in all 

or part, is excepted, excluded, and/or limited under the following Policy provision: 

PROPERTY NOT COVERED AND EXCLUSIONS 

“We” do not cover property: 

* * * 

6. While being shipped, unless there is a limit of insurance on the Declarations 

Page and it is: 

a. Shipped by the U.S. Postal Service as Registered Mail or Priority Express; 

b. Shipped by armored car service; or 

c. Shipped under receipt by a private, paid delivery service or other common 

or contract carrier (not including any service provided by the U.S. Postal 

Service). 

Jewelers Block Renewal Declaration JB DS 01 01 03 

2. Off All Described Premises 

 Limit of Insurance Deductible 

a. In transit by:

1) Registered Mail through the U.S. Postal Service in 

excess of any coverage purchased from the U.S. Postal $100,000 ZERO 

Service 

2) Priority Mail Express through the U.S. Postal Service in 

excess of any coverage purchased from the U.S. Postal $25,000 $2,500 

Service. The Priority Mail Express deductible (up to 

$2,500) will be waived for shipments arranged through 

JM Shipping Solution or another online logistics site 

approved by us. 

3) Armored car service ZERO ZERO 

4) Specified private, paid delivery service, or other contract ZERO ZERO 

or common carrier 

5) Unspecified private, paid delivery service, or other ZERO ZERO 

contract common carrier (not including any service 

provided by the U.S. Postal Services 

According to the Declarations Page, only items shipped Registered Mail or Priority 

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Mail Express, through the United Stated Postal Service are covered by the Policy. Upon 

information and belief the insured jewelry was shipped via FedEx and not through the 

United States Postal Service. Thus, the shipped jewelry would not be covered by the 

policy. 

STATEMENT 

Jewelers Mutual denies all allegation not specifically admitted herein and hereby 

reserves the right to amend this Answer to assert additional defenses or any other 

applicable terms, conditions, limitations, and/or exclusions of the Policy that may become 

apparent during discovery. 

WHEREFORE, the Defendant, JEWELERS MUTUAL INSURANCE COMPANY, 

respectfully requests judgment in its favor, costs of this action and such other relief as 

this Court deems appropriate under the circumstances. Defendant demands a jury trial 

on all issues so triable as a matter of right. 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Counsel for Defendant, Jewelers Mutual Insurance 

Company

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 112 of

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CERTIFICATE OF SERVICE

I certify that a copy hereof has been furnished to: 

Idelys Martinez, Esq. 

Florida Bar No.: 1011047 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Dr., 18th Floor 

Coconut Grove, FL 33133 

Phone: (888)570-5677 

YIA20@yourinsuranceattorney.com 

Eservice@yourinsuranceattorney.com 

Attorneys For: Plaintiff 

by e-Portal on June 30, 2022. 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 113 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

DEFENDANT’S NOTICE OF SERVING ANSWERS TO 

PLAINTIFF’S FIRST SET OF INTERROGATORIES

TO: Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 South Bayshore Drive 

18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

Secondary: eservice@yourinsuranceattorney.com 

Counsel for Major League Jewelers 

COMES NOW, the Defendant, JEWELERS MUTUAL INSURANCE COMPANY, 

by and through its undersigned counsel, and files this Notice of Serving its Answers to 

Plaintiff, MAJOR LEAGUE JEWELERS’ Interrogatories. 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

Filing # 154352358 E-Filed 07/29/2022 03:29:06 PM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 114 of

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400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Counsel for Defendant, Jewelers Mutual Insurance 

Company

CERTIFICATE OF SERVICE 

I certify that the foregoing Notice has been furnished by e-Portal and that the 

foregoing Notice and Answers have been furnished to the above-named addressee via 

e-mail on July 29, 2022. 

 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 115 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

NOTICE OF PRODUCTION FROM NON-PARTIES 

TO: Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 South Bayshore Drive 

18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

Secondary: eservice@yourinsuranceattorney.com 

Counsel for Major League Jewelers 

YOU ARE HEREBY NOTIFIED that after ten (10) days from the date of service 

of this Notice if service is by delivery or e-mail and after fifteen (15) days if service is by 

mail, and if no objection is received from any party, the undersigned will issue the 

attached Subpoenas Duces Tecum Without Deposition directed to: 

JPM Bros. 

36 W. 47th St., Suite 1002 

New York, NY 10036 

KC Jewelry 

550 S. Hill St., Suite 640 

Los Angeles, CA 90013 

who are not parties to this action to produce the items listed at the date, time, and place 

specified in the Subpoenas Duces Tecum Without Deposition. In accordance with 

Filing # 153760098 E-Filed 07/21/2022 09:18:06 AM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 116 of

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2 

Rule 1.351(b), Fla. R. Civ. P., any objection to production pursuant to said Rule must be 

served within ten (10) days of the date of service of this Notice. 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Counsel for Defendant, Jewelers Mutual Insurance 

Company

CERTIFICATE OF SERVICE

I certify that a copy hereof has been furnished to the above-named addressee by 

e-Portal on July 21, 2022. 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 117 of

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MOTION FOR EXTENSION OF TIME TO FILE

RESPONSE TO DISCOVERY REQUESTS

COMES NOW, Plaintiff, MAJOR LEAGUE JEWELERS, moves this Court for an order 

extending the time in which Plaintiff’s response to the Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY, discovery requests are due. In support of this motion, the Plaintiff 

states as follows: 

1. On or about June 21st, 2022, Plaintiff was served with Defendant’s First Set of 

Interrogatories to Plaintiff and Defendant’s Request for Production of Documents.

2. Plaintiff seeks additional time in which to adequately respond to Defendant’s 

discovery requests by 30 days.

3. Plaintiff is not seeking to extend any other deadlines.

4. An extension of time for the requested deadline will be sufficient to adequately file 

a response to Defendant’s discovery requests.

5. Furthermore, an extension of the deadline will not prejudice either party.

WHEREFORE, MAJOR LEAGUE JEWELERS, respectfully requests that this Court enter 

an Order granting this Motion to Extend the time in which Plaintiff's response to the Defendant’s 

IN THE CIRCUIT COURT OF THE 17

TH

JUDICIAL CIRCUIT, IN AND FOR

BROWARD COUNTY, FLORIDA

MAJOR LEAGUE JEWELERS,

Plaintiff,

v.

JEWELERS MUTUAL INSURANCE 

COMPANY,

Defendant. /

CASE NO.: CACE-22-008155

Filing # 153927529 E-Filed 07/24/2022 11:28:05 AM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 118 of

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discovery requests are due, and for any further relief this Court deems just and proper.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via E-Mail to 

all parties on this 24tth of July, 2022.

 Your Insurance Attorney, PLLC.

Counsel for the Insured

2601 South Bayshore Drive 18th Floor 

Coconut Grove, FL 33133

Phone No.: 1-888-570-5677

Fax: 1-888-745-5677

Email: YIA5@Yourinsuranceattorney.com

Secondary Email: Eservice@Yourinsuranceattorney.com

 By: /s/ David Garcia______________

David Garcia, Esq.

Florida Bar No. 87055

Idelys Martinez, Esq.

 Florida Bar No. 1011047

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

SUBPOENA DUCES TECUM WITHOUT DEPOSITION

THE STATE OF FLORIDA: 

TO: RECORDS CUSTODIAN 

JPM Bros. 

36 W. 47th St., Suite 1002 

New York, NY 10036 

YOU ARE HEREBY COMMANDED to appear at Veritext Legal Solutions, 7 

Times Square, 16th Floor, New York, NY 10036, on August 23, 2022 at 10:00am, and 

to have with you at that time and place all documents on attached Exhibit “A:” 

These items will be inspected and may be copied at that time. You will not be 

required to surrender the original items. You may comply with this Subpoena by 

providing legible copies of the items to be produced to the attorney whose name 

appears on this Subpoena on or before the scheduled date of production. You may 

condition the preparation of the copies upon the payment in advance of the reasonable 

cost of preparation. You may mail or deliver the copies to the attorney whose 

name appears on this Subpoena and thereby eliminate your appearance at the 

time and place specified above. You have the right to object to the production 

pursuant to this Subpoena at any time before production by giving written notice to the 

attorney whose name appears on this Subpoena. THIS WILL NOT BE A 

DEPOSITION. NO TESTIMONY WILL BE TAKEN.

If you fail to: 

(1) appear as specified; or 

(2) furnish the records instead of appearing as provided above; or 

(3) object to this Subpoena, 

you may be in contempt of Court. You are subpoenaed by the following attorney, and 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 120 of

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unless excused from this Subpoena by this attorney or the Court, you shall respond to 

this Subpoena as directed. 

DATED on August 1, 2022. 

Katelyn Lokuta, Esq. 

For the Court 

William R. Lewis, Esq. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

Katelyn N. Lokuta, Esq. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

BUTLER WEIHMULLER KATZ CRAIG LLP

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Counsel for Defendant, Jewelers Mutual Insurance 

Company 

*** IF DUPLICATION OF THE REQUESTED RECORDS WILL COST IN EXCESS OF 

$50.00, WE REQUEST THAT YOU CONTACT OUR OFFICE PRIOR TO 

DUPLICATING/ SENDING THE RECORDS. 

ALL INVOICES MUST BE ITEMIZED. *** 

Note: You will be in compliance with this subpoena if you elect to mail or email legible 

copies of the documents requested above, to the address indicated below, on or before 

August 23, 2022: 

Tammy Garcia, 

Paralegal 

Butler Weihmuller Katz Craig LLP 

400 North Ashley Drive, Suite 2300 

Tampa, FL 33602 

tgarcia@butler.legal 

(813) 594-5689 

Fax: (813) 281-0900 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 121 of

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DEFINITIONS 

1. The term "communication" shall mean any transmission of information by any 

means, including, without limitation, by spoken language, electronic transmission 

of data or any other means. The term "communication" shall include, without 

limitation, any copies of written information received by the person or entity 

responding to this request, even if such person or entity is not the primary or 

direct addressee of such written information. 

2. The term "document" or "documents" is used in its broadest sense and includes, 

without limitation, drafts, documents whether printed, recorded, stored or 

reproduced by any mechanical or electronic process, or written or produced by 

hand, and including computer tapes (including backup tapes) and all other 

computer-related documents, within your possession, custody or control. 

"Documents" shall also include (1) each copy that is not identical to the original 

or to any other copy, and (2) any tangible thing that is called for by or identified in 

response to any request. "Document" as used herein shall be construed broadly 

to include all documents and things within the scope of the Florida Rules of Civil 

Procedure and refers to all writings or other graphic matter, as well as any other 

medium by which information is stored or recorded. It includes originals, drafts, 

copies and reproductions; and it includes, without limiting the generality of the 

foregoing, letters; memoranda; reports and/or summaries of investigations; police 

reports; accident reports; opinions or reports of consultants; diagrams; marginal 

comments appearing on any documents; accounts; telegrams; studies; lists of 

persons attending meetings or conferences; records or memoranda of telephone 

conversations; written statements; transcripts or recorded statements; recorded 

statements; records of personal conversations or interviews; calculations; 

computations; specifications; drawings; advertisements; circulars; trade letters; 

press releases; prints; recordings; positive or negative films, slides or 

photographs; magnetic, electronic or video tapes; computer tapes, cards or 

printouts; and all other things of like nature; and all containers, boxes or other 

receptacles or repositories housing or containing such "documents." 

3. "Plaintiff", means Plaintiff, MAJOR LEAGUE JEWELERS, their affiliates, agents, 

employees and representatives. 

4. "Defendant" and/or “JEWELERS” means Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY and its respective agents, employees and 

representatives. 

5. “Subject Property” means the jewelry alleged as being lost during transit on or 

about September 28, 2021 that is the subject of Plaintiff’s Complaint. 

6. “Subject Claim” and/or “Subject Loss”, shall refer to Plaintiff’s claim with 

JEWELERS and assigned claim number 45-014740 with an alleged date of loss 

on or about September 28, 2021. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 122 of

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7. "Person" means a natural person, firm, association, partnership, corporation or 

other firm of legal or business entity, public or private. 

8. The term "referring" or "relating" shall mean showing, disclosing, averting to, 

comprising, evidencing, constituting or reviewing. 

9. The term "representative" as used herein with regard to a person or entity means 

and includes each and every present and former director, officer, partner, 

employee, agent, independent consultant or expert or other person (including 

attorneys) acting or purporting to act on behalf of the person or entity. 

10. The singular includes the plural and vice versa; the words "and" and "or" shall be 

both conjunctive; the word "including" means "including, without limitation." 

11. All other words have their plain and ordinary meaning. 

INSTRUCTIONS

1. You are instructed either to produce documents as they are kept in the ordinary 

course of business or to produce documents organized and labeled to 

correspond with the categories on Exhibit A. In addition, documents are to be 

produced in full and unexpurgated form. 

2. This request shall be deemed continuing so as to require further and 

supplemental production in the event that the party requested to produce, or any 

of his or her attorneys, agents or representatives, obtains or discovers additional 

information or documents between the time of the initial production and the time 

of hearing or trial. 

3. If any document covered by Exhibit A is withheld by reason of a claim of 

privilege, work product immunity or other ground of non-production, a list is to be 

furnished at the time that documents are produced identifying each such 

document not produced specifically by its nature (e.g., letter, memorandum, etc.) 

together with the following information with respect to any such document 

withheld: Author(s); recipient(s); sender(s); indicated or blind copies; date; 

subject matter; basis for non-production; number of pages; and the paragraph(s) 

of Exhibit A to which such document relates. 

4. If a portion of an otherwise responsive document contains information that is 

subject to a claim of privilege, only those portions of the document subject to the 

claim of privilege shall be deleted or redacted from the document and the rest of 

the document shall be produced. 

5. In the event that any document called for by Exhibit A has been destroyed, lost, 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 123 of

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discarded or otherwise disposed of, each such document is to be identified as 

completely as possible, including, without limitation, the following information: 

Author(s); recipient(s); sender(s); subject matter; date prepared or received; date 

of disposal; person(s) currently in possession of the document; and person 

disposing of the document. 

6. All objections to any category of documents to be produced pursuant to this 

request or to any definition or instruction it contains shall be in writing and 

delivered to Plaintiff’s counsel at or before the time of production. 

(Remainder of page left blank intentionally) 

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EXHIBIT A 

Documents to be Produced 

1. All documents related to invoice number 91997 with an invoice date of 

September 29, 2021 (“Invoice”). This includes but is not limited to proofs of 

payment, shipping invoices, tracking information, and correspondence related to 

the purchase. 

2. All documents related to where the watch listed on the Invoice, CRT Santos 

Men’s Watch, Full Diams (“Watch”). This includes documents identifying who the 

recipient of the shipment was, the address it was shipped to, the carrier it was 

shipped with, the tracking information, and documents related to delivery. 

3. All documents related to any insurance on the Watch shipped, including but not 

limited to insurance purchased through the carrier. 

4. All documents related to any claims made by you or on your behalf relating to the 

shipment being lost in transit. 

5. All documents or other items of a tangible nature that calculate or evaluate the 

cost and/or value of the Watch. 

Note: Any and all electronic files maintained in the regular course of business that are 

responsive to the above requests are required to be produced to Defendant in their 

electronic, pristine, native format. Any USB, flash drive or external drive forwarded to 

Defendant producing the requested electronic files will be returned to the nonparty if 

requested once the electronic files are in the Defendant’s possession. 

Note: You MUST return the following Affidavit, notarized and completed in full. 

Otherwise, you will not be in compliance with this request. 

 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 125 of

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9 

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

AFFIDAVIT OF RECORDS CUSTODIAN CERTIFICATE OF AUTHENTICITY 

IT IS HEREBY CERTIFIED that (please fill out either A or B only): 

A) the attached records with regard to: 

JPM Bros. 

36 W. 47th St., Suite 1002 

New York, NY 10036 

are authentic copies of all of the documents and tangible items in the possession, or 

under the control of JPM Bros. that are responsive to requests contained in the Notice 

propounded by Defendant, and that said documents and tangible items consist of 

______ pages and/or the following: 

______________________________________________________________________ 

 ______________________________________ . 

It is certified that the making of the said documents and tangible items is a regular 

practice of JPM Bros.

It is certified that the said documents and tangible items are kept in the course of a 

regularly conducted business activity of JPM Bros.

- OR - 

B) I certify that I have performed a diligent search of all documents and tangible 

items in the possession, or under the control, of JPM Bros. and have determined 

that that none are responsive to requests contained in the Notice propounded by 

Defendant. 

I certify that I searched all records dating back ___ years, and that the documents and 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 126 of

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10 

tangible items in the possession, or under the control, of JPM Bros. are maintained in 

the following manner: 

_____________________________________________________________________ 

_____________________________________________________________________, 

and that none were found relating to the Plaintiff(s)/Claimant(s)/Property(ies) involved in 

this litigation. 

Though none were found, I certify that the making of the type of documents and tangible 

items which are requested, is a regular practice of JPM Bros. 

Though none were found, I certify that the type of documents and tangible items 

responsive to the requests contained in the Notice propounded by Defendant, are kept 

in the course of a regularly conducted business activity of JPM Bros.

 

Dated this ______ day of ___________________, 2022. 

By: ______________________________ 

Records Custodian 

STATE OF: ___________________ 

COUNTY OF: _________________ 

THE FOREGOING INSTRUMENT was acknowledged before me this day of 

____________________, 2022 by means of  physical presence or  online 

notarization by ___________________________, who  is personally known to me or 

 who has produced ____________________ as identification. 

______________________________ 

NOTARY PUBLIC 

My Commission Expires: 

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

SUBPOENA DUCES TECUM WITHOUT DEPOSITION

THE STATE OF FLORIDA: 

TO: RECORDS CUSTODIAN 

KC Jewelry 

550 S. Hill St., Suite 640 

Los Angeles, CA 90013 

YOU ARE HEREBY COMMANDED to appear at Veritext Legal Solutions, 707 

Wilshire Boulevard, Suite 3500, Los Angeles, CA 90017, on August 23, 2022 at 

10:00am, and to have with you at that time and place all documents on attached Exhibit 

“A:” 

These items will be inspected and may be copied at that time. You will not be 

required to surrender the original items. You may comply with this Subpoena by 

providing legible copies of the items to be produced to the attorney whose name 

appears on this Subpoena on or before the scheduled date of production. You may 

condition the preparation of the copies upon the payment in advance of the reasonable 

cost of preparation. You may mail or deliver the copies to the attorney whose 

name appears on this Subpoena and thereby eliminate your appearance at the 

time and place specified above. You have the right to object to the production 

pursuant to this Subpoena at any time before production by giving written notice to the 

attorney whose name appears on this Subpoena. THIS WILL NOT BE A 

DEPOSITION. NO TESTIMONY WILL BE TAKEN.

If you fail to: 

(1) appear as specified; or 

(2) furnish the records instead of appearing as provided above; or 

(3) object to this Subpoena, 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 128 of

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you may be in contempt of Court. You are subpoenaed by the following attorney, and 

unless excused from this Subpoena by this attorney or the Court, you shall respond to 

this Subpoena as directed. 

DATED on August 1, 2022. 

Katelyn Lokuta, Esq. 

For the Court 

William R. Lewis, Esq. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

Katelyn N. Lokuta, Esq. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

BUTLER WEIHMULLER KATZ CRAIG LLP

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Counsel for Defendant, Jewelers Mutual Insurance 

Company 

*** IF DUPLICATION OF THE REQUESTED RECORDS WILL COST IN EXCESS OF 

$50.00, WE REQUEST THAT YOU CONTACT OUR OFFICE PRIOR TO 

DUPLICATING/ SENDING THE RECORDS. 

ALL INVOICES MUST BE ITEMIZED. *** 

Note: You will be in compliance with this subpoena if you elect to mail or email legible 

copies of the documents requested above, to the address indicated below, on or before 

August 23, 2022: 

Tammy Garcia, 

Paralegal 

Butler Weihmuller Katz Craig LLP 

400 North Ashley Drive, Suite 2300 

Tampa, FL 33602 

tgarcia@butler.legal 

(813) 594-5689 

Fax: (813) 281-0900 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 129 of

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DEFINITIONS 

1. The term "communication" shall mean any transmission of information by any 

means, including, without limitation, by spoken language, electronic transmission 

of data or any other means. The term "communication" shall include, without 

limitation, any copies of written information received by the person or entity 

responding to this request, even if such person or entity is not the primary or 

direct addressee of such written information. 

2. The term "document" or "documents" is used in its broadest sense and includes, 

without limitation, drafts, documents whether printed, recorded, stored or 

reproduced by any mechanical or electronic process, or written or produced by 

hand, and including computer tapes (including backup tapes) and all other 

computer-related documents, within your possession, custody or control. 

"Documents" shall also include (1) each copy that is not identical to the original 

or to any other copy, and (2) any tangible thing that is called for by or identified in 

response to any request. "Document" as used herein shall be construed broadly 

to include all documents and things within the scope of the Florida Rules of Civil 

Procedure and refers to all writings or other graphic matter, as well as any other 

medium by which information is stored or recorded. It includes originals, drafts, 

copies and reproductions; and it includes, without limiting the generality of the 

foregoing, letters; memoranda; reports and/or summaries of investigations; police 

reports; accident reports; opinions or reports of consultants; diagrams; marginal 

comments appearing on any documents; accounts; telegrams; studies; lists of 

persons attending meetings or conferences; records or memoranda of telephone 

conversations; written statements; transcripts or recorded statements; recorded 

statements; records of personal conversations or interviews; calculations; 

computations; specifications; drawings; advertisements; circulars; trade letters; 

press releases; prints; recordings; positive or negative films, slides or 

photographs; magnetic, electronic or video tapes; computer tapes, cards or 

printouts; and all other things of like nature; and all containers, boxes or other 

receptacles or repositories housing or containing such "documents." 

3. "Plaintiff", means Plaintiff, MAJOR LEAGUE JEWELERS, their affiliates, agents, 

employees and representatives. 

4. "Defendant" and/or “JEWELERS” means Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY and its respective agents, employees and 

representatives. 

5. “Subject Property” means the jewelry alleged as being lost during transit on or 

about September 28, 2021 that is the subject of Plaintiff’s Complaint. 

6. “Subject Claim” and/or “Subject Loss”, shall refer to Plaintiff’s claim with 

JEWELERS and assigned claim number 45-014740 with an alleged date of loss 

on or about September 28, 2021. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 130 of

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7. "Person" means a natural person, firm, association, partnership, corporation or 

other firm of legal or business entity, public or private. 

8. The term "referring" or "relating" shall mean showing, disclosing, averting to, 

comprising, evidencing, constituting or reviewing. 

9. The term "representative" as used herein with regard to a person or entity means 

and includes each and every present and former director, officer, partner, 

employee, agent, independent consultant or expert or other person (including 

attorneys) acting or purporting to act on behalf of the person or entity. 

10. The singular includes the plural and vice versa; the words "and" and "or" shall be 

both conjunctive; the word "including" means "including, without limitation." 

11. All other words have their plain and ordinary meaning. 

INSTRUCTIONS

1. You are instructed either to produce documents as they are kept in the ordinary 

course of business or to produce documents organized and labeled to 

correspond with the categories on Exhibit A. In addition, documents are to be 

produced in full and unexpurgated form. 

2. This request shall be deemed continuing so as to require further and 

supplemental production in the event that the party requested to produce, or any 

of his or her attorneys, agents or representatives, obtains or discovers additional 

information or documents between the time of the initial production and the time 

of hearing or trial. 

3. If any document covered by Exhibit A is withheld by reason of a claim of 

privilege, work product immunity or other ground of non-production, a list is to be 

furnished at the time that documents are produced identifying each such 

document not produced specifically by its nature (e.g., letter, memorandum, etc.) 

together with the following information with respect to any such document 

withheld: Author(s); recipient(s); sender(s); indicated or blind copies; date; 

subject matter; basis for non-production; number of pages; and the paragraph(s) 

of Exhibit A to which such document relates. 

4. If a portion of an otherwise responsive document contains information that is 

subject to a claim of privilege, only those portions of the document subject to the 

claim of privilege shall be deleted or redacted from the document and the rest of 

the document shall be produced. 

5. In the event that any document called for by Exhibit A has been destroyed, lost, 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 131 of

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discarded or otherwise disposed of, each such document is to be identified as 

completely as possible, including, without limitation, the following information: 

Author(s); recipient(s); sender(s); subject matter; date prepared or received; date 

of disposal; person(s) currently in possession of the document; and person 

disposing of the document. 

6. All objections to any category of documents to be produced pursuant to this 

request or to any definition or instruction it contains shall be in writing and 

delivered to Plaintiff’s counsel at or before the time of production. 

(Remainder of page left blank intentionally) 

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EXHIBIT A 

Documents to be Produced 

1. All documents related to invoice number 1062340 with an invoice date of 

September 10, 2021 (“Invoice”). This includes but is not limited to proofs of 

payment, shipping invoices, tracking information, and correspondence related to 

the purchase. 

2. All documents related to where the chain listed on the Invoice as item no. 

NK013220 (“Chain”). This includes documents identifying who the recipient of 

the shipment was, the address it was shipped to, the carrier it was shipped with, 

the tracking information, and documents related to delivery. 

3. All documents related to any insurance on the Chain shipped, including but not 

limited to insurance purchased through the carrier. 

4. All documents related to any claims made by you or on your behalf relating to the 

shipment being lost in transit. 

5. All documents or other items of a tangible nature that calculate or evaluate the 

cost and/or value of the Chain. 

Note: Any and all electronic files maintained in the regular course of business that are 

responsive to the above requests are required to be produced to Defendant in their 

electronic, pristine, native format. Any USB, flash drive or external drive forwarded to 

Defendant producing the requested electronic files will be returned to the nonparty if 

requested once the electronic files are in the Defendant’s possession. 

Note: You MUST return the following Affidavit, notarized and completed in full. 

Otherwise, you will not be in compliance with this request. 

 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 133 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

AFFIDAVIT OF RECORDS CUSTODIAN CERTIFICATE OF AUTHENTICITY 

IT IS HEREBY CERTIFIED that (please fill out either A or B only): 

C) the attached records with regard to: 

KC Jewelry 

550 S. Hill St., Suite 640 

Los Angeles, CA 90013 

are authentic copies of all of the documents and tangible items in the possession, or 

under the control of KC Jewelry that are responsive to requests contained in the Notice 

propounded by Defendant, and that said documents and tangible items consist of 

______ pages and/or the following: 

______________________________________________________________________ 

 ______________________________________ . 

It is certified that the making of the said documents and tangible items is a regular 

practice of KC Jewelry.

It is certified that the said documents and tangible items are kept in the course of a 

regularly conducted business activity of KC Jewelry.

- OR - 

D) I certify that I have performed a diligent search of all documents and tangible 

items in the possession, or under the control, of KC Jewelry and have 

determined that that none are responsive to requests contained in the Notice 

propounded by Defendant. 

I certify that I searched all records dating back ___ years, and that the documents and 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 134 of

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tangible items in the possession, or under the control, of KC Jewelry are maintained in 

the following manner: 

_____________________________________________________________________ 

_____________________________________________________________________, 

and that none were found relating to the Plaintiff(s)/Claimant(s)/Property(ies) involved in 

this litigation. 

Though none were found, I certify that the making of the type of documents and tangible 

items which are requested, is a regular practice of KC Jewelry. 

Though none were found, I certify that the type of documents and tangible items 

responsive to the requests contained in the Notice propounded by Defendant, are kept 

in the course of a regularly conducted business activity of KC Jewelry.

 

Dated this ______ day of ___________________, 2022. 

By: ______________________________ 

Records Custodian 

STATE OF: ___________________ 

COUNTY OF: _________________ 

THE FOREGOING INSTRUMENT was acknowledged before me this day of 

____________________, 2022 by means of  physical presence or  online 

notarization by ___________________________, who  is personally known to me or 

 who has produced ____________________ as identification. 

______________________________ 

NOTARY PUBLIC 

My Commission Expires: 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 135 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

DEFENDANT’S NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF

TO: Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Drive, 18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

eservice@yourinsuranceattorney.com 

COMES NOW, the Defendant, JEWELERS MUTUAL INSURANCE COMPANY, 

by and through its undersigned counsel, and in accordance with the applicable Rules of 

Civil Procedure, requests that the Plaintiff, MAJOR LEAGUE JEWELERS, answer the 

attached Interrogatories, within thirty (30) days after service hereof. 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Filing # 151857424 E-Filed 06/21/2022 10:12:51 AM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 136 of

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2 

Facsimile: (813) 281-0900 

Attorneys for Defendant, Jewelers Mutual Insurance 

Company

CERTIFICATE OF SERVICE

I certify that the foregoing Notice has been furnished by e-Portal and that the 

foregoing Notice and Interrogatories have been furnished to the above-named 

addressee by e-mail on June 21, 2022. 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 137 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

DEFENDANT’S RESPONSE TO PLAINTIFF’S REQUEST FOR PRODUCTION

COMES NOW, the Defendant, JEWELERS MUTUAL INSURANCE COMPANY 

(“Jewelers”), by and through its undersigned counsel, and responds to Plaintiff, MAJOR 

LEAGUE JEWELERS’ Request for Production, as follows: 

1. A true and correct certified copy of the insurance policy provided by the Insurance 

Company to the Insured, for which this lawsuit is premised, including but not limited 

to, declaration sheet(s), all addendums and attachments. 

RESPONSE: A certified copy of the policy Jewelers issued to Major League 

Jewelers will be produced. 

2. Each and every timesheet, log and all other documents reflecting time spent by 

the Insurance Company at the Property. 

RESPONSE: Jewelers objects to this request as it is vague, ambiguous and 

overly broad. Jewelers also objects to the extent that the request seeks 

documents protected from disclosure by the attorney-client privilege, work 

product doctrine or because they are documents contained in the claim file 

which are not discoverable in a first party breach of contract action. See 

Nationwide Ins. Co. of Florida v. Demmo, 57 So.3d 982 (Fla. 2d DCA 2011); 

Gavin’s Ace Hardware, Inc. v. Federated Mutual Insurance Company, 2011 

WL 5104476 (M.D.Fla. 2011). Subject to and without waiving the foregoing, 

none in Jewelers’ possession relating to the subject claim. 

3. Each and every document, evidencing the name, address, and the 

position/relationship with the Insurance Company, of every individual who has visited 

or plans to visit the Property on behalf of the Insurance Company. 

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RESPONSE: Jewelers objects to this request as it is vague, ambiguous and 

overly broad. Jewelers also objects to the extent that the request seeks 

documents protected from disclosure by the attorney-client privilege, work 

product doctrine or because they are documents contained in the claim file 

which are not discoverable in a first party breach of contract action. See 

Nationwide Ins. Co. of Florida v. Demmo, 57 So.3d 982 (Fla. 2d DCA 2011); 

Gavin’s Ace Hardware, Inc. v. Federated Mutual Insurance Company, 2011 

WL 5104476 (M.D.Fla. 2011). Subject to and without waiving the foregoing, 

none in Jewelers’ possession relating to the subject claim. 

4. Any and all correspondence or written communications from the Insurance Company 

to the Insured, which in any manner pertain to the Insured’s loss as described in the 

Complaint. 

RESPONSE: Documents responsive to this request attached hereto. 

5. Any and all correspondence or written communications from the Insured, to the 

Insurance Company which in any manner pertains to the Insured’s loss as 

described in the Complaint. 

RESPONSE: Documents responsive to this request attached hereto. 

6. Any and all photographs taken by the Insurance Company of the Property. 

RESPONSE: None. 

7. All documents containing information regarding a statement by the Insured at any 

time during the Insurance Company’s handling of the Insured’s loss, including 

adjuster notes, claim reports, interoffice memorandum, tape recordings, 

Examination Under Oath transcripts, and any other transcripts or written 

statements from the Insured. 

RESPONSE: Jewelers objects to this request as it is vague, ambiguous and 

overly broad. Jewelers also objects to the extent that the request seeks 

documents protected from disclosure by the attorney-client privilege, work 

product doctrine or because they are documents contained in the claim file 

which are not discoverable in a first party breach of contract action. See 

Nationwide Ins. Co. of Florida v. Demmo, 57 So.3d 982 (Fla. 2d DCA 2011); 

Gavin’s Ace Hardware, Inc. v. Federated Mutual Insurance Company, 2011 

WL 5104476 (M.D.Fla. 2011). Subject to and without waiving the foregoing, 

none in Jewelers’ possession relating to the subject claim. 

8. Any and all bills or estimates for repairs to the Property submitted to the Insurance 

Company by the Insured. 

RESPONSE: None. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 139 of

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9. Any and all checks paid to, or on behalf of the Insured, representing insurance 

coverage payment(s) for the loss. 

RESPONSE: None. 

10. All reports which in any manner pertain to the Insured’s loss. 

RESPONSE: None. 

11. All Proof of Loss forms pertaining to the subject loss that were sent or received by 

you or your representatives to or from the Insured or the Insured’s representative. 

RESPONSE: None. 

12. Transcripts of all recorded statements taken by you or your representatives in 

connection with the subject loss. 

RESPONSE: None. 

13. All inspection reports or other documents that evidence the cause of the damages 

at issue in the subject claim as determined by you or your representative. 

RESPONSE: Documents responsive to this request attached hereto. 

14. All applications for insurance submitted by or on behalf of the Insured to you or 

your representatives in connection with obtaining or renewing the subject Policy. 

RESPONSE: Objection. Jewelers objects to this request because it seeks 

information and materials that are neither relevant to the subject matter of 

the suit nor calculated to lead to the discovery of relevant matters, and which 

constitute work product and/or are protected by attorney-client privilege. 

The request calls also for Jewelers to produce documents from its claim file, 

underwriting file and/or documents that relate to its internal claims handling 

procedures, which is improper in a breach of contract action based on a firstparty property insurance claim. See, e.g., State Farm Florida Ins. Co. vs. 

Desai, 106 So. 3d 5 (Fla. 3d DCA 2013); Gen. Star Indem. Co. v. Atlantic 

Hospitality of Florida, LLC, 93 So. 3d 501 (Fla. 3d DCA 2012); State Farm 

Florida Ins. Co. v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012); State Farm 

Florida Ins. Co. v. Ramirez, 86 So. 3d 1198 (Fla. 3d DCA 2012); Nationwide 

Ins. Co. of Florida v. Demmo, 57 So. 3d 982 (Fla. 2d DCA 2011); State Farm 

Fire & Cas. Co. v. Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm 

Florida Ins. Co. v. Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See also, 

State Farm Mut. Auto. Ins. Co. v. O’Hearn, 975 So. 2d 633 (Fla. 2d DCA 2008); 

U.S. Fire Ins. Co. v. Clearwater Oaks Bank, 421 So. 2d 783 (Fla. 2d DCA 1982); 

W. Am. Ins. Co. v. Neva Prods., Inc., 490 So. 2d 117 (Fla. 2d DCA 1986); Geico 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 140 of

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4 

Gen. Ins. Co. v. Hoy, 927 So. 2d 122 (Fla. 2d DCA 2006); State Farm Mut. Ins. 

Co. v. Cook, 744 So. 2d 567 (Fla. 2d DCA 1999); Am. Bankers Ins. Co. of 

Florida v. Wheeler, 711 So. 2d 1347 (Fla. 5th DCA 1998); Michigan Millers Mut. 

Ins. Co. v. Bourke, 581 So. 2d 1368 (Fla. 2d DCA 1991); State Farm Fire & Cas. 

Co. v. Martin, 673 So. 2d 518 (Fla. 5th DCA 1996); and, Gen. Star Indem. Co. 

v. Anheuser-Busch Co., Inc., 741 So. 2d 1259 (Fla. 5th DCA 1999). 

15. All photographs or videos taken by you or your representative(s) in connection with 

the initial issuance or renewal of the subject Policy. 

RESPONSE: Objection. Jewelers objects to this request because it seeks 

documents protected by the work product doctrine. The request calls also 

for Jewelers to produce documents from its claim file, underwriting file 

and/or documents that relate to its internal claims handling procedures, 

which is improper in a breach of contract action based on a first-party 

property insurance claim. See, e.g., State Farm Florida Ins. Co. vs. Desai, 

106 So. 3d 5 (Fla. 3d DCA 2013); Gen. Star Indem. Co. v. Atlantic Hospitality 

of Florida, LLC, 93 So. 3d 501 (Fla. 3d DCA 2012); State Farm Florida Ins. Co. 

v. Aloni, 101 So. 3d 412 (Fla. 4th DCA 2012); State Farm Florida Ins. Co. v. 

Ramirez, 86 So. 3d 1198 (Fla. 3d DCA 2012); Nationwide Ins. Co. of Florida v. 

Demmo, 57 So. 3d 982 (Fla. 2d DCA 2011); State Farm Fire & Cas. Co. v. 

Valido, 662 So. 2d 1012 (Fla. 3d DCA 1995); State Farm Florida Ins. Co. v. 

Gallmon, 835 So. 2d 389 (Fla. 2d DCA 2003). See also, State Farm Mut. Auto. 

Ins. Co. v. O’Hearn, 975 So. 2d 633 (Fla. 2d DCA 2008); U.S. Fire Ins. Co. v. 

Clearwater Oaks Bank, 421 So. 2d 783 (Fla. 2d DCA 1982); W. Am. Ins. Co. v. 

Neva Prods., Inc., 490 So. 2d 117 (Fla. 2d DCA 1986); Geico Gen. Ins. Co. v. 

Hoy, 927 So. 2d 122 (Fla. 2d DCA 2006); State Farm Mut. Ins. Co. v. Cook, 744 

So. 2d 567 (Fla. 2d DCA 1999); Am. Bankers Ins. Co. of Florida v. Wheeler, 

711 So. 2d 1347 (Fla. 5th DCA 1998); Michigan Millers Mut. Ins. Co. v. Bourke, 

581 So. 2d 1368 (Fla. 2d DCA 1991); State Farm Fire & Cas. Co. v. Martin, 673 

So. 2d 518 (Fla. 5th DCA 1996); and, Gen. Star Indem. Co. v. Anheuser-Busch 

Co., Inc., 741 So. 2d 1259 (Fla. 5th DCA 1999). Subject to and without waiving 

the foregoing, none in Jewelers’ possession. 

16. A current curriculum vitae (CV) or resume for each person retained on your behalf 

for the purpose of rendering an opinion as to the cause or extent of the subject 

damage. 

RESPONSE: None at this time. Discovery is ongoing. Jewelers reserves the 

right to amend and/or supplement its response, if necessary. 

17. All affidavits or sworn statements in your possession pertaining to the subject loss. 

RESPONSE: None. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 141 of

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18. Transcripts of all examinations under oath (EUO) taken by you or your 

representatives in connection with the subject loss 

RESPONSE: None. 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Counsel for Defendant, Jewelers Mutual Insurance 

Company

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 142 of

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CERTIFICATE OF SERVICE

I certify that a copy hereof has been furnished to: 

Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 South Bayshore Drive 

18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

Secondary: eservice@yourinsuranceattorney.com 

Counsel for Major League Jewelers 

By e-Portal on July 29, 2022. 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 143 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE 

COMPANY, 

Defendant. 

________________________________/ 

DEFENDANT’S MOTION TO COMPEL DISCOVERY RESPONSES 

COMES NOW the Defendant JEWELERS MUTUAL INSURANCE COMPANY 

(“JEWELERS”), by and through its undersigned counsel, pursuant to Rules 1.350 and 

1.380, Florida Rules of Civil Procedure, and hereby file this Motion to Compel Discovery 

Responses and for Attorney’s Fees and Costs, and in support thereof, would state as 

follows: 

1. On June 21st, 2022 JEWELERS propounded Defendant’s First Set of 

Interrogatories on Plaintiff. See attached Composite Exhibit “1.”

2. Plaintiff’s responses were due July 21, 2022. 

3. Plaintiff did not respond to discovery by July 21, 2022. 

4. On July 22, 2022 counsel for JEWELERS sent correspondence via email and 

USPS to counsel for Plaintiff in a good faith attempt to obtain discovery responses and 

within requested that all responses be provided by August 4, 2022. See attached Exhibit 

“2.”

5. Plaintiff did not respond to Jewelers good faith attempt to obtain overdue 

discovery. 

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6. On July 24, 2022, Plaintiff filed a Motion for Extension of Time to File Response to 

Discovery Requests, requesting a thirty (30) day extension to provide discovery 

responses. See attached Exhibit “3.”

7. The thirty (30) day extension as requested by Plaintiff came, and went. 

8. On August 25, 2022, JEWELERS sent correspondence via email and USPS to 

counsel for Plaintiff in a second good faith attempt to obtain overdue discovery responses 

and within again requested that all responses be provided by September 1, 2022. See 

attached Exhibit “4.”

9. On August 31, 2022, the parties conducted a telephonic meet and confer in good 

faith regarding Plaintiff’s overdue discovery responses. Plaintiff had not provided 

responses to JEWELERS discovery and counsel requested an additional extension to do 

so. 

10. On August 31, 2022, JEWELERS requested via email that counsel for Plaintiff 

prepare an agreed order for an extension to September 9th, 2022. See attached Exhibit 

“5.”

11. Plaintiff failed to provide JEWELERS with an agreed order for an extension and 

has yet to comply with discovery obligations. 

12. Plaintiff’s failure to provide responses and/or file any appropriate objections to 

Defendant’s First Set of Interrogatories outlined in this Motion to Compel has hindered 

JEWELERS’ right to discovery of relevant information and significantly prejudiced 

JEWELERS. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 145 of

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13. Pursuant to Rule 1.380, Fla. R. Civ. P., JEWELERS requests this Court enter an 

order requiring Plaintiff to respond to Defendant’s First Set of Interrogatories within seven 

(7) days of the order being entered. 

14. Additionally, an accordance with Rule 1.380(4), Fla. R. Civ. P., JEWELERS also 

requests this Court award JEWELERS’ attorney fees and costs for having to bring this 

Motion to Compel. 

WHEREFORE, the Defendant, JEWELERS MUTUAL INSURANCE COMPANY, 

respectfully requests this Court grant this Motion to Compel, award attorney’s fees and 

costs, and award any and all other relief this Honorable Court deems just and proper. 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

tgarcia@butler.legal 

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Counsel for Defendant, Jewelers Mutual Insurance 

Company

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 146 of

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CERTIFICATE OF SERVICE

I certify that a copy hereof has been furnished via e-Portal on September 13, 

2022 to: 

Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Dr., 18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

eservice@yourinsuranceattorney.com 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 147 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

DEFENDANT’S NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF

TO: Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Drive, 18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

eservice@yourinsuranceattorney.com 

COMES NOW, the Defendant, JEWELERS MUTUAL INSURANCE COMPANY, 

by and through its undersigned counsel, and in accordance with the applicable Rules of 

Civil Procedure, requests that the Plaintiff, MAJOR LEAGUE JEWELERS, answer the 

attached Interrogatories, within thirty (30) days after service hereof. 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Filing # 151857424 E-Filed 06/21/2022 10:12:51 AM

Composite 1

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 148 of

204
2 

Facsimile: (813) 281-0900 

Attorneys for Defendant, Jewelers Mutual Insurance 

Company

CERTIFICATE OF SERVICE

I certify that the foregoing Notice has been furnished by e-Portal and that the 

foregoing Notice and Interrogatories have been furnished to the above-named 

addressee by e-mail on June 21, 2022. 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 149 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 

Definitions Of Terms 

1. "Plaintiff," “you,” “your,” “Insured” means Plaintiff, MAJOR LEAGUE JEWELERS, 

its affiliates, agents, employees and representatives. 

2. “Defendant” and/or “JEWELERS" means Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY its agents, employees and representatives. 

3. The term "communication" shall mean any transmission of information by any 

means, including, without limitation, by spoken language, electronic transmission 

of data or any other means. The term "communication" shall include, without 

limitation, any copies of written information received by the person or entity 

responding to this request, even if such person or entity is not the primary or direct 

addressee of such written information. 

4. The term "document" or "documents" is used in its broadest sense and includes, 

without limitation, drafts, and documents whether printed, recorded, stored or 

reproduced by any mechanical or electronic process, or written or produced by 

hand, and including computer tapes (including backup tapes) and all other 

computer-related documents, within your possession, custody or control. 

"Documents" shall also include (1) each copy that is not identical to the original or 

to any other copy, and (2) any tangible thing that is called for by or identified in 

response to any request. "Document" as used herein shall be construed broadly to 

include all documents and things within the scope of the Florida Rules of Civil 

Procedure and refers to all writings or other graphic matter, as well as any other 

medium by which information is stored or recorded. It includes originals, drafts, 

copies and reproductions; and it includes, without limiting the generality of the 

foregoing, letters; memoranda; reports and/or summaries of investigations; police 

reports; accident reports; opinions or reports of consultants; diagrams; marginal 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 150 of

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2 

comments appearing on any documents; accounts; telegrams; studies; lists of 

persons attending meetings or conferences; records or memoranda of telephone 

conversations; written statements; transcripts or recorded statements; recorded 

statements; records of personal conversations or interviews; calculations; 

computations; specifications; drawings; advertisements; circulars; trade letters; 

press releases; prints; recordings; positive or negative films, slides or photographs; 

magnetic, electronic or video tapes; computer tapes, cards or printouts; and all 

other things of like nature; and any and all containers, boxes or other receptacles 

or repositories housing or containing such "documents.” 

5. The term "referring" or "relating" shall mean showing, disclosing, averting to, 

comprising, evidencing, constituting or reviewing. 

6. “Subject Damages” means any loss or damage for which you now contend 

JEWELERS must pay you in this lawsuit. 

7. “Subject Property” means the property that is the subject of your lawsuit. 

8. “Subject Loss” means the loss for which you believe JEWELERS owes you 

insurance proceeds. 

9. The “Subject Policy” means the insurance policy number 55-015767 issued by 

JEWELERS MUTUAL INSURANCE COMPANY to you for the policy period of 

December 28, 2021 to December 28, 2022. 

10. The term "representative" as used herein with regard to a person or entity means 

and includes each and every present and former director, officer, partner, 

employee, agent, independent consultant or expert or other person (including 

attorneys) acting or purporting to act on behalf of the person or entity. 

11. The singular includes the plural and vice versa; the words "and" and "or" shall be 

both conjunctive; the word "all" means "any and all"; the word "any" means "any 

and all"; the word "including" means "including, without limitation." 

12. All other words have their plain and ordinary meaning. 

Instructions 

1. This set of interrogatories shall be deemed to be continuing so as to require further 

and supplemental responses as specified in Florida Rules of Civil Procedure. 

2. Where identification of a document is requested, please set forth the identity of its 

author or originator, date of such authorship or origination, identity of each person 

to whom the original or copy was addressed or delivered, identity of each person 

known or reasonably believed to have present possession, custody, or control 

thereof, and a brief description of the subject matter thereof. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 151 of

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3 

3. If any documents covered by this Interrogatory are withheld by reason of a claim of 

privilege, work product immunity or other ground of non-production, a list is to be 

furnished identifying each such documents for which the privilege is claimed 

specifically by its nature (e.g., letter, memorandum, etc.) together with the following 

information with respect to any such document withheld: author; recipient; sender; 

indicated or blind copies; date; subject matter; basis on which the privilege is 

claimed; number of pages; and the paragraph of this Interrogatory to which such 

document relates. 

4. If you assert that any document to be identified in connection with answering these 

interrogatories has been destroyed or lost, set forth in writing the contents of the 

document, the date the document was destroyed or lost and the name of the 

person who authorized or directed the destruction of the document or was last in 

possession of the document. If you cannot respond to any of the interrogatories in 

full, answer to the extent possible, and specify in writing the reasons for your 

inability to provide a complete answer to the interrogatory. 

5. All objections or answers to interrogatories which fail or refuse fully to respond to 

any interrogatory on the ground of any claim of privilege of any kind whatever shall 

(a) state the nature of the claim of privilege; (b) state all facts relied upon in support 

of the claim of the privilege or related thereto; (c) identify all documents related to 

the claim of privilege; (d) identify all persons having knowledge of any facts related 

to the claim of privilege; and (3) identify all events, transactions or occurrences 

related to the claim of privilege. 

6. Where identification of a person is requested, please set forth the person's name, 

last-known home and business address and telephone number, and relation to the 

party answering these interrogatories, if any. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 152 of

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4 

INTERROGATORIES

1. State comprehensively and in detail all damages that you are seeking to recover 

in this lawsuit. Be sure that your answer (a) sets forth the grand total amount 

claimed, in dollars and cents; (b) contains a line item description for each item of 

damage claimed, including the precise dollar amount claimed for each line item; 

(c) contains a detailed description of how you determined the amount of each 

damage claimed; (d) shows all your calculations in determining these dollar 

figures; 

RESPONSE: 

2. State with specificity the total monetary amount Plaintiff is alleging Jewelers 

owes to Plaintiff as it relates to the lawsuit and how you determined this amount. 

RESPONSE: 

(Remainder of page intentionally left blank.) 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 153 of

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5 

MAJOR LEAGUE JEWELERS 

By: ______________________________ 

Print Name: _______________________ 

Title: _____________________________ 

ACKNOWLEDGMENT

STATE OF _______________ 

COUNTY OF ______________ 

The foregoing instrument was acknowledged before me by means of ☐ physical 

presence or ☐ online notarization via audio-video communication by 

__________________ on behalf of MAJOR LEAGUE JEWELERS ☐ who is personally 

known to me or ☐ who has produced ________________________ as identification 

and who, after first being duly sworn, deposes and says that he/she has read the 

foregoing Answers to the Interrogatories which were propounded to him/her by the 

Defendant(s) which, to the best of his/her knowledge and belief, are true and correct, 

and who has acknowledged to me that he/she executed the same as his/her free act 

and deed. 

SWORN TO AND SUBSCRIBED before me, this _____ day of 

_______________, 2022. 

___________________________________ 

NOTARY PUBLIC 

State of __________ at Large 

My Commission Expires: 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 154 of

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July 22, 2022 

VIA EMAIL: 

Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Drive, 18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

eservice@yourinsuranceattorney.com 

Re: Major League Jewelers vs. Jewelers Mutual Insurance Company

Case No.: CACE-22-008155 

Our File Number: 2027-2111098 

Dear Ms. Martinez, 

I write in a good faith attempt to obtain full, complete, and proper responses to the 

written discovery requests propounded by Jewelers Mutual Insurance Company (“Jewelers 

Mutual”) without Court intervention, in strict compliance with Florida Rules of Civil Procedure 

1.380(a)(4), as well as other authority. 

Plaintiff sued Jewelers Mutual. The accusations leveled are false and without support. 

Thus, on June 21, 2022, Jewelers Mutual propounded written discovery to defend itself, as is 

its absolute right. Specifically, Jewelers Mutual served its First Set of Interrogatories and First 

Request for Production to Plaintiff. 

Plaintiff’s responses to these discovery requests were due on July 21, 2022. No 

request for an extension to respond was requested by Plaintiff and Plaintiff neither objected 

nor moved for a protective order. Consequently, Plaintiff waived most objections by operation 

of law. 

Please supply full, complete, and proper responses to Jewelers Mutual’s discovery 

requests by 5:00pm on Thursday, August 4, 2022. If you do not, Jewelers Mutual will be 

forced to seek judicial assistance. We hope it does not come to that. 

Regards, 

BUTLER WEIHMULLER KATZ CRAIG LLP 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 155 of

204
Idelys Martinez, Esq. 

July 22, 2022 

Page 2 

William R. Lewis 

wlewis@butler.legal 

Katelyn Lokuta, Esq. 

klokuta@butler.legal 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 156 of

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MOTION FOR EXTENSION OF TIME TO FILE

RESPONSE TO DISCOVERY REQUESTS

COMES NOW, Plaintiff, MAJOR LEAGUE JEWELERS, moves this Court for an order 

extending the time in which Plaintiff’s response to the Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY, discovery requests are due. In support of this motion, the Plaintiff 

states as follows: 

1. On or about June 21st, 2022, Plaintiff was served with Defendant’s First Set of 

Interrogatories to Plaintiff and Defendant’s Request for Production of Documents.

2. Plaintiff seeks additional time in which to adequately respond to Defendant’s 

discovery requests by 30 days.

3. Plaintiff is not seeking to extend any other deadlines.

4. An extension of time for the requested deadline will be sufficient to adequately file 

a response to Defendant’s discovery requests.

5. Furthermore, an extension of the deadline will not prejudice either party.

WHEREFORE, MAJOR LEAGUE JEWELERS, respectfully requests that this Court enter 

an Order granting this Motion to Extend the time in which Plaintiff's response to the Defendant’s 

IN THE CIRCUIT COURT OF THE 17

TH

JUDICIAL CIRCUIT, IN AND FOR

BROWARD COUNTY, FLORIDA

MAJOR LEAGUE JEWELERS,

Plaintiff,

v.

JEWELERS MUTUAL INSURANCE 

COMPANY,

Defendant. /

CASE NO.: CACE-22-008155

Filing # 153927529 E-Filed 07/24/2022 11:28:05 AM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 157 of

204
discovery requests are due, and for any further relief this Court deems just and proper.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via E-Mail to 

all parties on this 24tth of July, 2022.

 Your Insurance Attorney, PLLC.

Counsel for the Insured

2601 South Bayshore Drive 18th Floor 

Coconut Grove, FL 33133

Phone No.: 1-888-570-5677

Fax: 1-888-745-5677

Email: YIA5@Yourinsuranceattorney.com

Secondary Email: Eservice@Yourinsuranceattorney.com

 By: /s/ David Garcia______________

David Garcia, Esq.

Florida Bar No. 87055

Idelys Martinez, Esq.

 Florida Bar No. 1011047

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 158 of

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August 25, 2022 

VIA EMAIL AND CERTIFIED MAIL 9489009000276428901741: 

Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Drive, 18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

eservice@yourinsuranceattorney.com 

Re: Major League Jewelers vs. Jewelers Mutual Insurance Company

Case No.: CACE-22-008155 

Our File Number: 2027-2111098 

Dear Ms. Martinez, 

I write in a good faith attempt to obtain full, complete, and proper responses to the 

written discovery requests propounded by Jewelers Mutual Insurance Company (“Jewelers 

Mutual”) without Court intervention, in strict compliance with Florida Rules of Civil Procedure 

1.380(a)(4), as well as other authority. 

Plaintiff sued Jewelers Mutual. The accusations leveled are false and without support. 

Thus, on June 21, 2022, Jewelers Mutual propounded written discovery to defend itself, as is 

its absolute right. Specifically, Jewelers Mutual served its First Set of Interrogatories and First 

Request for Production to Plaintiff. 

Plaintiff’s responses to these discovery requests were due on July 21, 2022. On July 

22, 2022, we wrote to you in a good faith attempt to obtain overdue discovery. Plaintiff did not 

respond to our letter, but instead filed a Motion for Extension on July 24, 2022 requesting a 

30 day extension. Plaintiff did not reach out to Counsel for AXIS to obtain an agreed upon 

extension or set the motion for hearing. 

Nonetheless, the 30 day extension to respond as requested by Plaintiff came, and 

went. Plaintiff did not respond, object or move for a protective order. Consequently, Plaintiff 

waived most objections by operation of law. 

If full, complete, and proper responses to Jewelers Mutual’s discovery requests are 

not produced within seven (7) days of the date of this letter, a motion to compel will be filed 

and set for a hearing. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 159 of

204
Idelys Martinez, Esq. 

August 25, 2022 

Page 2 

Regards, 

BUTLER WEIHMULLER KATZ CRAIG LLP 

William R. Lewis 

wlewis@butler.legal 

Katelyn Lokuta, Esq. 

klokuta@butler.legal 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 160 of

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Archived: Tuesday, September 13, 2022 12:01:57 PM

From: Katelyn Lokuta

Mail received time: Wed, 31 Aug 2022 12:14:48

Sent: Wed, 31 Aug 2022 16:14:47

To: 'im@yourinsuranceattorney.com'

Cc: 'vjorge@yourinsuranceattorney.com' Julia Dearborn 'YIA20@Yourinsuranceattorney.com'

Subject: FW: 5141-004 Major League Jewelers v. Jewelers MutualCase Number:CACE-22-008155:

Importance: Normal

Sensitivity: None

Good Afternoon,

I glad we could connect this morning to discuss the discovery issues and Plaintiff’s claims. In light of your need for an

additional time to respond to our discovery requests, please send us a proposed agreed order on your motion for

extension to respond to discovery until September 9

th

(next Friday).

Thank you!

Katelyn Lokuta | Attorney at Law

BUTLER WEIHMULLER KATZ CRAIGLLP

400 N. Ashley Drive, Suite 2300 | Tampa, FL 33602

Direct 813.594.5622 | Office 813.281.1900

www.butler.legal | email | vCard | location

From: Katelyn Lokuta

Sent: Tuesday, August 30, 2022 4:34 PM

To: 'Victoria Jorge' <vjorge@yourinsuranceattorney.com>

Cc: Idelys Martinez <im@yourinsuranceattorney.com>; YIA20 <YIA20@yourinsuranceattorney.com>; Julia Dearborn

<jdearborn@butler.legal>

Subject: RE: 5141-004 Major League Jewelers v. Jewelers Mutual Case Number: CACE-22-008155:

Good Afternoon,

Does Idelys intend on re-scheduling the teleconference, which was supposed to take place at 4pm this afternoon?

Katelyn Lokuta | Attorney at Law

BUTLER WEIHMULLER KATZ CRAIGLLP

400 N. Ashley Drive, Suite 2300 | Tampa, FL 33602

Direct 813.594.5622 | Office 813.281.1900

www.butler.legal | email | vCard | location

From: Julia Dearborn <jdearborn@butler.legal>

Sent: Monday, August 29, 2022 3:24 PM

To: 'Victoria Jorge' <vjorge@yourinsuranceattorney.com>; Tammy Garcia <tgarcia@butler.legal>; Katelyn Lokuta

<klokuta@butler.legal>

Cc: Idelys Martinez <im@yourinsuranceattorney.com>; YIA20 <YIA20@yourinsuranceattorney.com>

Subject: RE: 5141-004 Major League Jewelers v. Jewelers Mutual Case Number: CACE-22-008155:

Good afternoon,

4pm tomorrow works. Please have Idelys call Katelyn at 813.594.5622.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 161 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

DEFENDANT’S NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF

TO: Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Drive, 18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

eservice@yourinsuranceattorney.com 

COMES NOW, the Defendant, JEWELERS MUTUAL INSURANCE COMPANY, 

by and through its undersigned counsel, and in accordance with the applicable Rules of 

Civil Procedure, requests that the Plaintiff, MAJOR LEAGUE JEWELERS, answer the 

attached Interrogatories, within thirty (30) days after service hereof. 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Filing # 151857424 E-Filed 06/21/2022 10:12:51 AM

Composite 1

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 162 of

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2 

Facsimile: (813) 281-0900 

Attorneys for Defendant, Jewelers Mutual Insurance 

Company

CERTIFICATE OF SERVICE

I certify that the foregoing Notice has been furnished by e-Portal and that the 

foregoing Notice and Interrogatories have been furnished to the above-named 

addressee by e-mail on June 21, 2022. 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 163 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF 

Definitions Of Terms 

1. "Plaintiff," “you,” “your,” “Insured” means Plaintiff, MAJOR LEAGUE JEWELERS, 

its affiliates, agents, employees and representatives. 

2. “Defendant” and/or “JEWELERS" means Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY its agents, employees and representatives. 

3. The term "communication" shall mean any transmission of information by any 

means, including, without limitation, by spoken language, electronic transmission 

of data or any other means. The term "communication" shall include, without 

limitation, any copies of written information received by the person or entity 

responding to this request, even if such person or entity is not the primary or direct 

addressee of such written information. 

4. The term "document" or "documents" is used in its broadest sense and includes, 

without limitation, drafts, and documents whether printed, recorded, stored or 

reproduced by any mechanical or electronic process, or written or produced by 

hand, and including computer tapes (including backup tapes) and all other 

computer-related documents, within your possession, custody or control. 

"Documents" shall also include (1) each copy that is not identical to the original or 

to any other copy, and (2) any tangible thing that is called for by or identified in 

response to any request. "Document" as used herein shall be construed broadly to 

include all documents and things within the scope of the Florida Rules of Civil 

Procedure and refers to all writings or other graphic matter, as well as any other 

medium by which information is stored or recorded. It includes originals, drafts, 

copies and reproductions; and it includes, without limiting the generality of the 

foregoing, letters; memoranda; reports and/or summaries of investigations; police 

reports; accident reports; opinions or reports of consultants; diagrams; marginal 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 164 of

204
2 

comments appearing on any documents; accounts; telegrams; studies; lists of 

persons attending meetings or conferences; records or memoranda of telephone 

conversations; written statements; transcripts or recorded statements; recorded 

statements; records of personal conversations or interviews; calculations; 

computations; specifications; drawings; advertisements; circulars; trade letters; 

press releases; prints; recordings; positive or negative films, slides or photographs; 

magnetic, electronic or video tapes; computer tapes, cards or printouts; and all 

other things of like nature; and any and all containers, boxes or other receptacles 

or repositories housing or containing such "documents.” 

5. The term "referring" or "relating" shall mean showing, disclosing, averting to, 

comprising, evidencing, constituting or reviewing. 

6. “Subject Damages” means any loss or damage for which you now contend 

JEWELERS must pay you in this lawsuit. 

7. “Subject Property” means the property that is the subject of your lawsuit. 

8. “Subject Loss” means the loss for which you believe JEWELERS owes you 

insurance proceeds. 

9. The “Subject Policy” means the insurance policy number 55-015767 issued by 

JEWELERS MUTUAL INSURANCE COMPANY to you for the policy period of 

December 28, 2021 to December 28, 2022. 

10. The term "representative" as used herein with regard to a person or entity means 

and includes each and every present and former director, officer, partner, 

employee, agent, independent consultant or expert or other person (including 

attorneys) acting or purporting to act on behalf of the person or entity. 

11. The singular includes the plural and vice versa; the words "and" and "or" shall be 

both conjunctive; the word "all" means "any and all"; the word "any" means "any 

and all"; the word "including" means "including, without limitation." 

12. All other words have their plain and ordinary meaning. 

Instructions 

1. This set of interrogatories shall be deemed to be continuing so as to require further 

and supplemental responses as specified in Florida Rules of Civil Procedure. 

2. Where identification of a document is requested, please set forth the identity of its 

author or originator, date of such authorship or origination, identity of each person 

to whom the original or copy was addressed or delivered, identity of each person 

known or reasonably believed to have present possession, custody, or control 

thereof, and a brief description of the subject matter thereof. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 165 of

204
3 

3. If any documents covered by this Interrogatory are withheld by reason of a claim of 

privilege, work product immunity or other ground of non-production, a list is to be 

furnished identifying each such documents for which the privilege is claimed 

specifically by its nature (e.g., letter, memorandum, etc.) together with the following 

information with respect to any such document withheld: author; recipient; sender; 

indicated or blind copies; date; subject matter; basis on which the privilege is 

claimed; number of pages; and the paragraph of this Interrogatory to which such 

document relates. 

4. If you assert that any document to be identified in connection with answering these 

interrogatories has been destroyed or lost, set forth in writing the contents of the 

document, the date the document was destroyed or lost and the name of the 

person who authorized or directed the destruction of the document or was last in 

possession of the document. If you cannot respond to any of the interrogatories in 

full, answer to the extent possible, and specify in writing the reasons for your 

inability to provide a complete answer to the interrogatory. 

5. All objections or answers to interrogatories which fail or refuse fully to respond to 

any interrogatory on the ground of any claim of privilege of any kind whatever shall 

(a) state the nature of the claim of privilege; (b) state all facts relied upon in support 

of the claim of the privilege or related thereto; (c) identify all documents related to 

the claim of privilege; (d) identify all persons having knowledge of any facts related 

to the claim of privilege; and (3) identify all events, transactions or occurrences 

related to the claim of privilege. 

6. Where identification of a person is requested, please set forth the person's name, 

last-known home and business address and telephone number, and relation to the 

party answering these interrogatories, if any. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 166 of

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4 

INTERROGATORIES

1. State comprehensively and in detail all damages that you are seeking to recover 

in this lawsuit. Be sure that your answer (a) sets forth the grand total amount 

claimed, in dollars and cents; (b) contains a line item description for each item of 

damage claimed, including the precise dollar amount claimed for each line item; 

(c) contains a detailed description of how you determined the amount of each 

damage claimed; (d) shows all your calculations in determining these dollar 

figures; 

RESPONSE: 

2. State with specificity the total monetary amount Plaintiff is alleging Jewelers 

owes to Plaintiff as it relates to the lawsuit and how you determined this amount. 

RESPONSE: 

(Remainder of page intentionally left blank.) 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 167 of

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5 

MAJOR LEAGUE JEWELERS 

By: ______________________________ 

Print Name: _______________________ 

Title: _____________________________ 

ACKNOWLEDGMENT

STATE OF _______________ 

COUNTY OF ______________ 

The foregoing instrument was acknowledged before me by means of ☐ physical 

presence or ☐ online notarization via audio-video communication by 

__________________ on behalf of MAJOR LEAGUE JEWELERS ☐ who is personally 

known to me or ☐ who has produced ________________________ as identification 

and who, after first being duly sworn, deposes and says that he/she has read the 

foregoing Answers to the Interrogatories which were propounded to him/her by the 

Defendant(s) which, to the best of his/her knowledge and belief, are true and correct, 

and who has acknowledged to me that he/she executed the same as his/her free act 

and deed. 

SWORN TO AND SUBSCRIBED before me, this _____ day of 

_______________, 2022. 

___________________________________ 

NOTARY PUBLIC 

State of __________ at Large 

My Commission Expires: 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 168 of

204
July 22, 2022 

VIA EMAIL: 

Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Drive, 18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

eservice@yourinsuranceattorney.com 

Re: Major League Jewelers vs. Jewelers Mutual Insurance Company

Case No.: CACE-22-008155 

Our File Number: 2027-2111098 

Dear Ms. Martinez, 

I write in a good faith attempt to obtain full, complete, and proper responses to the 

written discovery requests propounded by Jewelers Mutual Insurance Company (“Jewelers 

Mutual”) without Court intervention, in strict compliance with Florida Rules of Civil Procedure 

1.380(a)(4), as well as other authority. 

Plaintiff sued Jewelers Mutual. The accusations leveled are false and without support. 

Thus, on June 21, 2022, Jewelers Mutual propounded written discovery to defend itself, as is 

its absolute right. Specifically, Jewelers Mutual served its First Set of Interrogatories and First 

Request for Production to Plaintiff. 

Plaintiff’s responses to these discovery requests were due on July 21, 2022. No 

request for an extension to respond was requested by Plaintiff and Plaintiff neither objected 

nor moved for a protective order. Consequently, Plaintiff waived most objections by operation 

of law. 

Please supply full, complete, and proper responses to Jewelers Mutual’s discovery 

requests by 5:00pm on Thursday, August 4, 2022. If you do not, Jewelers Mutual will be 

forced to seek judicial assistance. We hope it does not come to that. 

Regards, 

BUTLER WEIHMULLER KATZ CRAIG LLP 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 169 of

204
Idelys Martinez, Esq. 

July 22, 2022 

Page 2 

William R. Lewis 

wlewis@butler.legal 

Katelyn Lokuta, Esq. 

klokuta@butler.legal 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 170 of

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MOTION FOR EXTENSION OF TIME TO FILE

RESPONSE TO DISCOVERY REQUESTS

COMES NOW, Plaintiff, MAJOR LEAGUE JEWELERS, moves this Court for an order 

extending the time in which Plaintiff’s response to the Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY, discovery requests are due. In support of this motion, the Plaintiff 

states as follows: 

1. On or about June 21st, 2022, Plaintiff was served with Defendant’s First Set of 

Interrogatories to Plaintiff and Defendant’s Request for Production of Documents.

2. Plaintiff seeks additional time in which to adequately respond to Defendant’s 

discovery requests by 30 days.

3. Plaintiff is not seeking to extend any other deadlines.

4. An extension of time for the requested deadline will be sufficient to adequately file 

a response to Defendant’s discovery requests.

5. Furthermore, an extension of the deadline will not prejudice either party.

WHEREFORE, MAJOR LEAGUE JEWELERS, respectfully requests that this Court enter 

an Order granting this Motion to Extend the time in which Plaintiff's response to the Defendant’s 

IN THE CIRCUIT COURT OF THE 17

TH

JUDICIAL CIRCUIT, IN AND FOR

BROWARD COUNTY, FLORIDA

MAJOR LEAGUE JEWELERS,

Plaintiff,

v.

JEWELERS MUTUAL INSURANCE 

COMPANY,

Defendant. /

CASE NO.: CACE-22-008155

Filing # 153927529 E-Filed 07/24/2022 11:28:05 AM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 171 of

204
discovery requests are due, and for any further relief this Court deems just and proper.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via E-Mail to 

all parties on this 24tth of July, 2022.

 Your Insurance Attorney, PLLC.

Counsel for the Insured

2601 South Bayshore Drive 18th Floor 

Coconut Grove, FL 33133

Phone No.: 1-888-570-5677

Fax: 1-888-745-5677

Email: YIA5@Yourinsuranceattorney.com

Secondary Email: Eservice@Yourinsuranceattorney.com

 By: /s/ David Garcia______________

David Garcia, Esq.

Florida Bar No. 87055

Idelys Martinez, Esq.

 Florida Bar No. 1011047

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 172 of

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August 25, 2022 

VIA EMAIL AND CERTIFIED MAIL 9489009000276428901741: 

Idelys Martinez, Esq. 

Your Insurance Attorney, PLLC 

2601 S. Bayshore Drive, 18th Floor 

Coconut Grove, FL 33133 

YIA20@yourinsuranceattorney.com 

eservice@yourinsuranceattorney.com 

Re: Major League Jewelers vs. Jewelers Mutual Insurance Company

Case No.: CACE-22-008155 

Our File Number: 2027-2111098 

Dear Ms. Martinez, 

I write in a good faith attempt to obtain full, complete, and proper responses to the 

written discovery requests propounded by Jewelers Mutual Insurance Company (“Jewelers 

Mutual”) without Court intervention, in strict compliance with Florida Rules of Civil Procedure 

1.380(a)(4), as well as other authority. 

Plaintiff sued Jewelers Mutual. The accusations leveled are false and without support. 

Thus, on June 21, 2022, Jewelers Mutual propounded written discovery to defend itself, as is 

its absolute right. Specifically, Jewelers Mutual served its First Set of Interrogatories and First 

Request for Production to Plaintiff. 

Plaintiff’s responses to these discovery requests were due on July 21, 2022. On July 

22, 2022, we wrote to you in a good faith attempt to obtain overdue discovery. Plaintiff did not 

respond to our letter, but instead filed a Motion for Extension on July 24, 2022 requesting a 

30 day extension. Plaintiff did not reach out to Counsel for AXIS to obtain an agreed upon 

extension or set the motion for hearing. 

Nonetheless, the 30 day extension to respond as requested by Plaintiff came, and 

went. Plaintiff did not respond, object or move for a protective order. Consequently, Plaintiff 

waived most objections by operation of law. 

If full, complete, and proper responses to Jewelers Mutual’s discovery requests are 

not produced within seven (7) days of the date of this letter, a motion to compel will be filed 

and set for a hearing. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 173 of

204
Idelys Martinez, Esq. 

August 25, 2022 

Page 2 

Regards, 

BUTLER WEIHMULLER KATZ CRAIG LLP 

William R. Lewis 

wlewis@butler.legal 

Katelyn Lokuta, Esq. 

klokuta@butler.legal 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 174 of

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Archived: Tuesday, September 13, 2022 12:01:57 PM

From: Katelyn Lokuta

Mail received time: Wed, 31 Aug 2022 12:14:48

Sent: Wed, 31 Aug 2022 16:14:47

To: 'im@yourinsuranceattorney.com'

Cc: 'vjorge@yourinsuranceattorney.com' Julia Dearborn 'YIA20@Yourinsuranceattorney.com'

Subject: FW: 5141-004 Major League Jewelers v. Jewelers MutualCase Number:CACE-22-008155:

Importance: Normal

Sensitivity: None

Good Afternoon,

I glad we could connect this morning to discuss the discovery issues and Plaintiff’s claims. In light of your need for an

additional time to respond to our discovery requests, please send us a proposed agreed order on your motion for

extension to respond to discovery until September 9

th

(next Friday).

Thank you!

Katelyn Lokuta | Attorney at Law

BUTLER WEIHMULLER KATZ CRAIGLLP

400 N. Ashley Drive, Suite 2300 | Tampa, FL 33602

Direct 813.594.5622 | Office 813.281.1900

www.butler.legal | email | vCard | location

From: Katelyn Lokuta

Sent: Tuesday, August 30, 2022 4:34 PM

To: 'Victoria Jorge' <vjorge@yourinsuranceattorney.com>

Cc: Idelys Martinez <im@yourinsuranceattorney.com>; YIA20 <YIA20@yourinsuranceattorney.com>; Julia Dearborn

<jdearborn@butler.legal>

Subject: RE: 5141-004 Major League Jewelers v. Jewelers Mutual Case Number: CACE-22-008155:

Good Afternoon,

Does Idelys intend on re-scheduling the teleconference, which was supposed to take place at 4pm this afternoon?

Katelyn Lokuta | Attorney at Law

BUTLER WEIHMULLER KATZ CRAIGLLP

400 N. Ashley Drive, Suite 2300 | Tampa, FL 33602

Direct 813.594.5622 | Office 813.281.1900

www.butler.legal | email | vCard | location

From: Julia Dearborn <jdearborn@butler.legal>

Sent: Monday, August 29, 2022 3:24 PM

To: 'Victoria Jorge' <vjorge@yourinsuranceattorney.com>; Tammy Garcia <tgarcia@butler.legal>; Katelyn Lokuta

<klokuta@butler.legal>

Cc: Idelys Martinez <im@yourinsuranceattorney.com>; YIA20 <YIA20@yourinsuranceattorney.com>

Subject: RE: 5141-004 Major League Jewelers v. Jewelers Mutual Case Number: CACE-22-008155:

Good afternoon,

4pm tomorrow works. Please have Idelys call Katelyn at 813.594.5622.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 175 of

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IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT 

IN AND FOR BROWARD COUNTY, FLORIDA 

MAJOR LEAGUE JEWELERS, 

Plaintiff, 

CASE NO.: CACE-22-008155 

v. 

JEWELERS MUTUAL INSURANCE COMPANY, 

Defendant. 

_______________________________________/ 

NOTICE OF HEARING 

PLEASE TAKE NOTICE that a hearing will be held before the Honorable Sandra 

Perlman, one of the Judges of the above-styled Court, via Video Teleconference on the 

8th Day of November, 2022, at 8:45 a.m., or as soon thereafter as same may be heard, 

on: 

Defendant's Motion to Compel Overdue Discovery Responses 

TIME RESERVED: 5-10 minutes. 

The undersigned attorney will be / will not be securing the services 

of a court reporter. 

PLEASE BE GOVERNED ACCORDINGLY. 

BUTLER WEIHMULLER KATZ CRAIG LLP

WILLIAM R. LEWIS, ESQ. 

Florida Bar No.: 0879827 

wlewis@butler.legal 

KATELYN N. LOKUTA, ESQ. 

Florida Bar No: 106198 

klokuta@butler.legal 

Secondary: jdearborn@butler.legal 

Filing # 157971875 E-Filed 09/22/2022 03:40:43 PM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 176 of

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400 N. Ashley Drive, Suite 2300 

Tampa, Florida 33602 

Telephone: (813) 281-1900 

Facsimile: (813) 281-0900 

Attorneys for Defendant, Jewelers Mutual Insurance 

Company

CERTIFICATE OF SERVICE

I certify that a copy hereof has been furnished to: 

Idelys Martinez, Esq. 

David F. Garcia, Esq. 

Your Insurance Attorney, PLLC 

2601 South Bayshore Drive 

18th Floor 

Coconut Grove, FL 33133-5454 

YIA20@yourinsuranceattorney.com 

Secondary: eservice@yourinsuranceattorney.com 

Counsel for Plaintiff 

 

 by e-Portal on September 22, 2022. 

 

________________________________________ 

KATELYN N. LOKUTA, ESQ. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 177 of

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PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

Plaintiff, MAJOR LEAGUE JEWELERS (the “Insured”), pursuant to Rule 1.350 of the 

Florida Rules of Civil Procedure, hereby requests that Defendant, JEWELERS MUTUAL 

INSURANCE COMPANY (the “Insurance Company”), make available for inspection and 

duplication, in response to each numbered paragraph, all documentsspecified herein which are in its 

possession, custody or control or in the possession, custody or control of its agents, accountants or 

attorneys. Defendant is requested to make such production within the time period prescribed either 

by the Florida Rules of Civil Procedure or by order of the Court, at the offices of Your Insurance 

Attorney, PLLC., 2601 South Bayshore Drive, 18th Floor, Coconut Grove, Florida 33133.

I. DEFINITIONS AND INSTRUCTIONS

1. The terms "you", "your(s)", “yourselves”, “defendant”, and/or “Insurance Company”

means the party or parties to which this request is addressed, and any agents, representatives, 

attorneys or other persons acting or purporting to act, on its behalf.

2. The term “person” means any natural person, individual, proprietorship, partnership,

corporation, association, organization, joint venture, firm, other business enterprise, governmental 

body, group of natural persons, or other entity. 

MAJOR LEAGUE JEWELERS,

 Plaintiff,

v.

JEWELERS MUTUAL INSURANCE 

COMPANY,

Defendant,

/

IN THE CIRCUIT COURT OF THE 17TH 

JUDICIAL CIRCUIT IN AND FOR 

BROWARD COUNTY, FLORIDA

CASE NO.: 

Filing # 150850124 E-Filed 06/03/2022 04:20:18 PM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 178 of

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Page 2 of 7

3. The “Complaint” means the Complaint filed by the Insured in this action.

4. The term "document" shall mean any written or graphic matter and other means of 

preserving thought or expression and all tangible things from which information can be processed or 

transcribed, including the originals and all non-identical copies, whether different from the original 

by reason of any notation made on such copy or otherwise, including, but not limited to, 

correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, 

meetings or other communications, inter-office and intra-office telephone calls, diaries, 

chronological data, minutes, books, reports, studies, summaries, pamphlets, bulletins, printed matter, 

charts, ledgers, invoices, work-sheets, receipts, returns, computer printouts, prospectuses, financial 

statements, schedules, affidavits, contracts, canceled checks, statements, transcripts, statistics, 

surveys, magazine or newspaper articles, releases (and any and all drafts, alterations or 

modifications, changes and amendments of any of the foregoing), graphic or aural records or 

representations of any kind (including without limitation, photographs, microfiche, microfilm, 

videotape, records and motion pictures) and electronic, mechanical or electric records or 

representations of any kind (including without limitation, tapes, cassettes, discs and records).

5. The term "all documents" means every document or group of documents as above 

defined that are known to you or that can be located or discovered by reasonably diligent efforts.

6. The term “Insurance Company” shall refer to the Defendant in this action, its 

affiliates, subsidiaries, predecessors, successors, agents, attorneys and/or anyone else acting in its 

behalf.

7. The term "communication(s)" means every manner or means of disclosure, transfer or 

exchange of information, whether in person, by telephone, mail, personal delivery or otherwise.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 179 of

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Page 3 of 7

8. As used herein, the singular shall include the plural, the plural shall include the 

singular, and the masculine, feminine and neuter shall include each of the other genders. 

9. The terms "and", “as well as” and "or" shall be construed disjunctively as well as 

conjunctively as necessary to make the interrogatory inclusive rather than exclusive. The term "all" 

means "any and all." The terms "each" and “every” means "each and every," the term “including” 

means “including without limitation.”

10. The terms "referring to" or "relating to" mean setting forth, pertaining to, 

memorializing, constituting, embodying, discussing, analyzing, reflecting or otherwise concerning.

11. The terms "locate" or "location" means to state the present whereabouts of each 

document and to identify the person(s) having possession, custody or control thereof.

12. The term "to date" shall mean the date on which you respond to this request.

13. When producing the required documents, please keep all documents segregated by 

the file in which the documents are contained and indicate the name of the file in which the 

documents are contained and the name of the documents being produced.

14. When producing the required documents, please produce all other documents that are 

clipped, stapled or otherwise attached to any requested document.

15. In the event such file(s) or document(s) has (have) been removed, either for the 

purpose of this action or for some other purpose, please state the name and address of the person 

who removed the file, the title of the file and each sub-file, if any, maintained within the file, and the 

present location of the file.

16. The words "and" and "or" shall be construed either conjunctively or disjunctively to 

bring within the scope of these requests any documents which might otherwise be construed to be 

outside their scope.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 180 of

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Page 4 of 7

17. If you claim that the attorney/client or any other privilege or the attorney's work 

product doctrine applies to any document, the production of which is called for by these requests, 

then for each such document, state its date, subject matter, author(s), recipient(s), present custodian 

and all past custodians, and such additional information concerning the claim of privilege or work 

product doctrine as will permit the adjudication of the propriety of the claim. 

18. If you contend that it would be unreasonably burdensome to obtain and provide all of 

the documents called for in response to any one of these requests, then in response to the appropriate 

request:

(a) furnish each such document that is available to you without 

undertaking what you contend to be an unreasonable burden;

(b) state with particularity the grounds on which you contend that 

additional efforts to obtain such documents would be unreasonably 

burdensome; and

(c) describe with particularity the efforts made by you to secure such 

documents, including, without limitation, the identity of all persons 

consulted, and files, records, and documents reviewed, and the 

identity of each person who participated in gathering such documents, 

including the duration of time spent and nature of work done by each 

person.

19. Unless otherwise indicated, all requests include the time period from the date of the

Loss to the date you receive this request.

20. The term “Insured” shall refer to the Plaintiff(s), affiliates, predecessors, successors, 

agents, attorneys and/or anyone else acting in their behalf. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 181 of

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Page 5 of 7

II. LOST/DESTROYED DOCUMENTS

If any document to be produced was, but is no longer, in your possession, custody or control 

and/or has been destroyed or is otherwise incapable of production or state: (a) the date, place and 

means of the destruction; (b) the name and address of each person deciding upon, participating in 

and having knowledge of the destruction; (c) the reason for the destruction; (d) if not destroyed, the 

reason why the document is incapable of production; and (e) the subject matter of the document.

III. DOCUMENTS REQUESTED

1. A true and correct certified copy of the insurance policy provided by the Insurance 

Company to the Insured, for which this lawsuit is premised, including but not limited to, declaration 

sheet(s), all addendums and attachments.

2. Each and every timesheet, log and all other documents reflecting time spent by the 

Insurance Company at the Property.

3. Each and every document, evidencing the name, address, and the position/relationship 

with the Insurance Company, of every individual who has visited or plans to visit the Property on

behalf of the Insurance Company. 

4. Any and all correspondence or written communications from the Insurance Company 

to the Insured, which in any manner pertain to the Insured’s loss as described in the Complaint. 

5. Any and all correspondence or written communications from the Insured, to the 

Insurance Company which in any manner pertains to the Insured’s loss as described in the 

Complaint.

6. Any and all photographs taken by the Insurance Company of the Property. 

7. All documents containing information regarding a statement by the Insured at any 

time during the Insurance Company’s handling of the Insured’s loss, including adjuster notes, claim 

reports, interoffice memorandum, tape recordings, Examination Under Oath transcripts, and any 

other transcripts or written statements from the Insured.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 182 of

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Page 6 of 7

8. Any and all bills or estimates for repairs to the Property submitted to the Insurance 

Company by the Insured.

9. Any and all checks paid to, or on behalf of the Insured, representing insurance 

coverage payment(s) for the loss.

10. All reports which in any manner pertain to the Insured’s loss.

11. All Proof of Loss forms pertaining to the subject loss that were sent or received by 

you or your representatives to or from the Insured or the Insured’s representative.

12. Transcripts of all recorded statements taken by you or your representatives in 

connection with the subject loss.

13. All inspection reports or other documents that evidence the cause of the damages at 

issue in the subject claim as determined by you or your representative.

14. All applications for insurance submitted by or on behalf of the Insured to you or your 

representatives in connection with obtaining or renewing the subject Policy.

15. All photographs or videos taken by you or your representative(s) in connection with 

the initial issuance or renewal of the subject Policy.

16. A current curriculum vitae (CV) or resume for each person retained on your behalf 

for the purpose of rendering an opinion as to the cause or extent of the subject damage.

17. All affidavits or sworn statements in your possession pertaining to the subject loss.

18. Transcripts of all examinations under oath (EUO) taken by you or your 

representatives in connection with the subject loss.

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 183 of

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Page 7 of 7

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via U.S. mail 

to: JEWELERS MUTUAL INSURANCE COMPANY c/o The Florida Chief Financial Officer as 

RA, 200 E. Gaines Street, Tallahassee, Florida 32399-4201, on this 3rd day of June 2022.

Your Insurance Attorney, PLLC.

2601 South Bayshore Drive 18th Floor 

Coconut Grove, FL 33133

Phone No.: 1-888-570-5677

Fax: 1-888-745-5677

Email:YIA20@Yourinsuranceattorney.com 

Secondary Email: Eservice@Yourinsuranceattorney.com

 By: /s/ Idelys Martinez______________

Idelys Martinez, Esq.

 Florida Bar No. 1011047

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 184 of

204
MAJOR LEAGUE JEWELERS,

 Plaintiff,

v.

JEWELERS MUTUAL INSURANCE 

COMPANY,

Defendant.

/

IN THE CIRCUIT COURT OF THE 17TH 

JUDICIAL CIRCUIT IN AND FOR 

BROWARD COUNTY, FLORIDA

CASE NO.: 

PLAINTIFF'S FIRST SET OF INTERROGATORIES

Plaintiff, MAJOR LEAGUE JEWELERS (the “Insured”), pursuant to Rule 1.340 of the 

Florida Rules of Civil Procedure, propounds the following First Set of Interrogatories upon 

Defendant, JEWELERS MUTUAL INSURANCE COMPANY (the “Insurance Company”), to be 

answered in writing, under oath, within the time specified.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via U.S. mail 

to: JEWELERS MUTUAL INSURANCE COMPANY c/o The Florida Chief Financial Officer as 

RA, 200 E. Gaines Street, Tallahassee, Florida 32399-4201, on this 3rd day of June 2022.

Respectfully Submitted by,

 

Your Insurance Attorney, PLLC.

2601 South Bayshore Drive 18th Floor 

Coconut Grove, FL 33133

Phone No.: 1-888-570-5677

Fax: 1-888-745-5677

Email:YIA20@Yourinsuranceattorney.com 

Secondary Email: Eservice@Yourinsuranceattorney.com

 By: /s/ Idelys Martinez______________

Idelys Martinez, Esq.

 Florida Bar No. 1011047

Filing # 150850124 E-Filed 06/03/2022 04:20:18 PM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 185 of

204
DEFINITIONS AND INSTRUCTIONS

1. Insert your answers in the space provided following each question. If additional 

space is needed, so indicate in the space provided, prepare your answers on a separate paper, and 

attach the additional paper to your answers.

2. Separately answer each interrogatory, and each subsection of each interrogatory. The 

term "you" and "your" means the party or parties to which this request is addressed, including its 

divisions, departments, subsidiaries, affiliates, predecessors, present or former officers, directors, 

owners, agents, accountants, attorneys, and all other persons acting or purporting to act on its behalf, 

as well as each partnership in which it is a partner.

3. The terms “Insurance Company” or “Defendant” means the defendant in this action to 

which these Interrogatories are addressed, including its agents, attorneys, accountants, and all other 

persons acting or purporting to act on their behalf. The terms “Insurance Company” or “Defendant” 

also includes the party's divisions, departments, subsidiaries, affiliates, predecessors, present or 

former officers, directors, owners, agents, attorneys, and accountants as well as each partnership in 

which it is a partner, and includes any other person, acting or purporting to act on its behalf.

4. The terms "you" and "your" mean the party or parties to which these interrogatories 

are addressed, including its agents, attorneys, accountants, and all other persons acting or purporting 

to act on its behalf. 

5. The “Complaint” means the Complaint filed by the Insured in this action.

6. The term “Claim” means any statement, concept, assertion, idea, allegation, fact, law, 

rule, theory, observation, cause of action, or principle whatsoever, based upon which Plaintiff 

demands that she has suffered damages, or has a right to payment, as the result of any act or 

omission of Defendant. 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 186 of

204
7. The terms "person" or "persons" mean any natural person, individual, proprietorship, 

partnership, corporation, association, organization, joint venture, firm, other business enterprise, 

governmental body, and group of natural persons or other entity, and includes any other person 

acting on behalf of a person.

8. The term “contract” means any promise, or set or promises, which creates an 

obligation to do or not do a particular thing where there was meeting of the minds on a given 

proposition and an understanding and intention between the parties. 

9. The term “communication” means any information given, whether oral or written; 

any oral or written statement, conference, consultation, dialogue, colloquy, discussion, conversation, 

agreement, the sharing of knowledge by one with another, bargaining preparatory to making a 

contract or any expression of any kind.

10. The term “document” means and includes any kind of written, typed, recorded or 

graphic matter, however produced or reproduced, of any kind or description, whether sent or 

received, and every record of every type, including originals, non-identical copies and drafts, and 

both sides of any documentation where information appears on both sides, and including but not 

limited to: letters, correspondence, memoranda, meeting transcripts or minutes, public filings or tax 

returns, papers, books, telegrams, bulletins, notices, announcements, instructions, charts, manuals, 

brochures, schedules, cables, telex messages, notes, notations, accountants’ working papers, 

transcriptions, agendas, reports, recordings of telephone or other conversations, of interviews, of 

conferences or of meetings, telephone messages, diaries, indices, books, reports, ledgers, working 

papers, invoices, worksheets, receipts, computer printouts, financial statements, schedules affidavits, 

contracts, canceled checks, statements, transcripts, magazine or newspaper articles, periodicals, 

releases and any and all drafts, alterations and modifications, changes and amendments of any of the 

Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 187 of

204
foregoing, whether handwritten, printed or electronically prepared, filed or stored, affidavits, 

statements, summaries, opinions, reports, studies, analyses, evaluations, contracts, agreements, 

journals, statistical records, calendars, appointment books, diaries, lists, tabulations, sound 

recordings, computer print-outs, data processing input and output, microfilms, newspapers, 

magazines, books, periodicals or press releases, including information stored on any electromagnetic 

storage device, any written, printed, typed, recorded, or graphic matter, however produced or 

reproduced or stored to which you have or had access. “Document” shall also be deemed to include 

any summary of a document or documents called for hereafter.

11. The term "all documents" means every document or group of documents as above 

defined that are known to you or that can be located or discovered by reasonably diligent efforts.

12. As used herein the singular shall include the plural, the plural shall include the 

singular, and the masculine, feminine, and neuter shall include each of the other genders.

13. The terms "and" as well as "or" shall be construed disjunctively as well as 

conjunctively as necessary to make the interrogatory inclusive rather than exclusive. The term "all" 

means "any and all." The term "each" means "each and every," and the term "every" means "each 

and every."

14. The terms "refer" or "relate to" mean setting forth, pertaining to, memorializing, 

constituting, embodying, discussing, analyzing, reflecting or otherwise concerning.

15. The term "locate" or "location" means to state the present whereabouts of each 

Document and to identify the persons having possession, custody or control thereof.

16. The term "to date" shall mean the date on which you answer these interrogatories.

17. The term “including” means “including but not limited to”.

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18. “Relating to” or “relevant to” means embodying, pertaining to, concerning, involving, 

constituting, comprising, reflecting, discussing, evidencing, referring to, consisting of, or having any 

logical or factual connection whatever with the subject matter in question.

19. The term “Identify,” when used with reference to a natural person, means state:

(a) his full name and address (or, if the present address is not known, his last 

known address).

(b) the full name and address of each of his employers, each corporation of 

which he is an officer or director and each business in which he is a principal.

(c) his present (or, if the present is not known, his last known) position and his 

position or positions at the time of the act to which the interrogatory answer 

relate, and

(d) such other information sufficient to enable Plaintiff to identify the person.

20. “Identify,” when used with reference to any entity other than a natural person, 

means:

(a) state the full name of the entity, the type of entity (e.g., corporation, 

partnership, etc.), the address of its principal place of business, its principal 

business activity, and if it is a corporation, the jurisdiction under the laws of 

which it has been organized and the date of such organization.

21. “Identify,” when used with reference to a document or written communication, means 

state:

(a) its nature (e.g., letter, telegram, floppy disc, computer printout, 

memorandum, chart, report or study), date, author, date and place of 

preparation and the name and address of each addressee, if there is an 

addressee;

(b) the identity of each signer to the document or communication;

(c) the title or heading of the document or communication;

(d) its substance;

(e) its present (or, if the present is not known, the last known) location and 

custodian.

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(f) the identity of each person to whom a copy was sent and each date of its 

receipt and each date of its transmittal or other disposition by (I) respondent 

and (ii) any other person (naming such other person) who, at any time, either 

received, transmitted or otherwise disposed of such document or 

communication and each copy thereof;

(g) the circumstances of each such receipt and each transmittal or other 

disposition, including identification of the person from whom received and 

the person to whom transmitted.

22. “Identify,” when used with reference to an oral transaction or oral communication, 

means state:

(a) its nature (e.g., telephone call, conversation in person, etc.)

(b) the date and place thereof.

(c) the identity and address of each person participating therein, present during 

or witness to any part thereof.

(d) identify each document in which such transaction or communication was 

recorded, described or referred to.

23. “Identify” when used with reference to a lawsuit means state:

(a) the caption of each lawsuit;

(b) the court in which the lawsuit was filed;

(c) the case number;

(d) identify the parties, and

(e) a brief summary of the nature of the claim or charge.

24. “Identify” when used with reference to an administrative claim or charge means 

state:

(a) identify the claimant or charging party;

(b) the administrative office were filed;

(c) the number assigned to identify the claim or charge, and

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(d) a brief summary of the nature of the claim or charge.

25. “Identify,” when used in any other context that is herein above set forth, means to 

describe the act, word, situation, event, etc. (and/or conduct, course of action of any nature 

whatsoever, including without limitation any failure to act, to engage in any conduct or to pursue any 

course of action), to be identified as fully as possible and identify each document or communication 

or act in which such act, word, situation, event, conduct or course of action, etc., was recorded, refers 

or relates to each answer, forms all or part of the basis for an answer; and/or corroborates and 

answer.

26. You may, in lieu of identifying any Document or written communication, attach a 

true copy of each Document as an exhibit to the answers to these interrogatories. On each occasion 

in which you choose to attach a Document as your answer to an interrogatory, identify the portion of 

the Document that answers the interrogatory.

27. Identify each Document produced pursuant to an interrogatory by the paragraph 

number of the interrogatory in response to which it is produced and by the file from which the 

document was produced.

28. If any of the information furnished in an answer to all or part of an interrogatory is 

not within your personal knowledge, identify each person who has personal knowledge of the 

information furnished in such answer and each person who communicated to you any part of the 

information furnished.

29. If the answer to all or any part of the interrogatory is not presently known or available 

to you, include a statement to that effect, furnish the information now known or otherwise available 

to you, and respond to the entire interrogatory by supplemental answer, in writing, under oath, within 

ten days from the time the entire answer becomes known or available to you, but. in no event less 

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than five days prior to trial.

30. If you contend that it would be unreasonably burdensome to obtain and provide all of 

the information called for in response to any one of these interrogatories or any subpart thereof, then 

in response to the appropriate interrogatory or subpart:

(a) set forth all such information that is available to you without 

undertaking what you contend to be an unreasonable burden;

(b) state with particularity the grounds on which you contend that 

additional efforts to obtain such information would be unreasonably 

burdensome; and

(c) describe with particularity the efforts made by you to secure such 

information, including, without limitation, the identity of all persons 

consulted, and files, records, and documents reviewed, and the 

identity of each person who participated in gathering such 

information, including the duration of time spent and nature of work 

done by each person.

31. Unless your response to an interrogatory is complete when made, these 

interrogatories are continuing insofar as you are required to promptly make further or supplemental 

answers if new information is discovered and/or acquired by you between the date of your initial 

answer and any time thereafter.

32. If you claim in response to any request for production that any requested document is 

"privileged" and not subject to discovery, you shall so state expressly and, in addition, shall provide 

a privilege log, describing the nature of the documents, communications or things not produced or 

disclosed in a manner that, without revealing the information itself privileged or protected, will 

enable other parties to assess the applicability of the privilege or protection.

33. If all of the information furnished in answer to all or part of an interrogatory is not 

within the personal knowledge of the affiant, identify each person to whom all or part of the 

information furnished is a matter of personal knowledge and each person who communicated to the 

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affiant any part of the information furnished.

34. To the extent precise and complete information cannot be furnished, such information 

as is available shall be supplied, together with an estimate of the precise and complete information. 

Where such an estimate is given, the method employed in making the estimate shall be described.

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INTERROGATORIES

1. Please state the name, title, current business address, and phone number of all persons 

answering or assisting with the answering of this set of interrogatories.

2. Please state the date that the Insurance Company first received notice from the 

Insured for a claim of benefits under the Policy for property damages as described in the Complaint 

in this lawsuit.

3. In reference to the Insurance Company’s denial of the Insured’s claim for benefits 

under the Policy, please state:

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a. The date the decision to deny the claim was made.

b. Identify each person who participated in the decision to deny the Insured’s 

claim.

c. Describe each and every fact upon which you relied in forming the basis for 

your denial of the Insured’s claim.

d. Identify each document sent by the Insurance Company to the Insured 

detailing the reasons why the Insurance Company denied the Insured’s claim.

e. State the location, including, page(s), line(s) and paragraph number(s), and 

the exact language contained in the Policy, which you used to base your decision to deny 

coverage of the Insured’s claim. 

4. Identify each person, by name, address, phone number and position, whom on behalf 

of the Insurance Company, inspected the Insured Property in reference to the claim for benefits 

under the Policy, including his or her field of expertise and the date of each inspection.

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5. Identify each written estimate for repair or replacement, including the amount set 

forth in each estimate, which has been provided to the Insurance Company by the Insured in 

reference to the Insured’s claim for benefits under the Policy.

6. Identify all persons (other than the Insurance Company) believed or known by you, 

your agents or attorneys to have knowledge concerning any of the issues raised by the pleadings, 

specifying the subject matter about which witnesses have knowledge and state whether you have 

obtained any statements (oral, written or recorded) from any of said witnesses, list the dates any such 

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witness statements were taken, by whom any such witness were taken and who has the present 

possession, custody and control of any such statements.

7. Identify all persons who, on the Insurance Company’s behalf, have in any way 

participated in the investigation, evaluation, adjusting or handling of the claim involved hereto. 

Please specify the nature of the participation for each and every such person and give the time period 

during which they participated.

8. For each decision that was made that the claim of the Insured were allegedly not 

covered under the Policy, please state the date you first decided that the Insured was allegedly not 

covered, the date you arrived at the conclusion the Insured was not covered and the names and 

address and phone number and the dates of involvement of each and every person that knows any 

information concerning these matters.

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9. Please describe all requests made by the Insurance Company upon the Insured for 

post-loss compliance (i.e., requests for examination under oath, information, documents, sworn 

proofs of loss, etc.,) in reference to this claim and the dates made.

10. With reference to each of your affirmative defenses raised in the lawsuit, please 

describe each and every fact upon which you rely to substantiate such affirmative defense, including 

identification of all witnesses to each such fact. 

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11. Please verify the date the Policy became effective.

12. Please state the amount of money paid by the Insured towards the premium of the 

Policy in place at the time of the Loss.

13. Please state whether or not you performed any inspections of the insured premises 

prior to the Loss. If so, provide the date the inspection was performed, the purpose of the inspection, 

by whom and their contact information.

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14. Please provide the name and contact information for the agent that sold the Policy to 

the Insured. 

15. If you contend that the Insured did not comply with the terms and conditions set forth 

in the Policy please described:

a. the term and/or condition of the Policy not complied with;

b. how the Insured failed to comply with the term and/or condition;

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c. when a request was made by you demanding compliance with the term and/or 

condition of the Policy;

d. why compliance with the terms and/or condition was necessary for you to 

adjust the Loss and determine coverage.

16. Please verify the name, phone number, address and title of the corporate 

representative(s) with the most knowledge regarding the allegations set forth in the complaint.

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17. Please identify all claims made by the Insured for the Insured premises.

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IN WITNESS WHEREOF, the Insurance Company has executed the foregoing answers to 

interrogatories and states that same are true and correct to the best of the undersigned’s knowledge 

and belief.

_______________________________________

JEWELERS MUTUAL INSURANCE COMPANY

By: ________________________________

Title: _______________________________

STATE OF FLORIDA }

}

COUNTY OF _____________ }

BEFORE ME, the undersigned authority, personally appeared ________________________, 

who is personally known to me or who has produced as identification, being 

first duly sworn according to law, deposes and says that he executed the foregoing Answers to 

Plaintiff's First Set of Interrogatories and that they are true and correct to the best of his/her 

knowledge and belief.

IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of my 

office; in the County and State last aforesaid, this day of ____________ 2022.

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IN THE COUNTY COURT FOR THE 17TH 

JUDICIAL CIRCUIT IN AND FOR 

BROWARD COUNTY, FLORIDA 

CASE NO.: CACE-22-008155

MAJOR LEAGUE JEWELERS,

Plaintiffs,

v.

JEWELERS MUTUAL INSURANCE 

COMPANY,

Defendant.

____________________________________/

PLAINTIFF’S UNVERIFIED RESPONSES TO DEFENDANT’S

FIRST SET OF INTERROGATORIES

COMES NOW, Plaintiff’s, MAJOR LEAGUE JEWELERS, hereby gives notice of the 

service of his responses to Defendant JEWELERS MUTUAL INSURANCE COMPANY, First 

Set of Interrogatories.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via 

Electronic Mail to: counsel of record for the Defendant, on this 7

th day of November 2022.

Your Insurance Attorney, PLLC. 

2601 South Bayshore Drive 18th Floor 

Coconut Grove, FL 33133

Phone No.: 1-888-570-5677

Fax: 1-888-745-5677

Email:YIA20@Yourinsuranceattorney.com

Secondary Email: vjorge@Yourinsuranceattorney.com

By: /s/ David Garcia 

David Garcia, Esq. 

Florida Bar No. 87055 

Idelys Martinez, Esq. 

Florida Bar No. 1011047

Filing # 160783340 E-Filed 11/07/2022 03:06:43 PM Case 0:22-cv-62137-RNS Document 1-1 Entered on FLSD Docket 11/16/2022 Page 204 of

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