[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA NICHOLAS DOUGHERTY, Plaintiff, v. LINDA ANNIBALE, Defendant. ###### COMPLAINT Plaintiff, NICHOLAS DOUGHERTY, hereby files this Complaint against Defendant, ## _/ LINDA ANNIBALE, and states as follows: ###### JURISDICTIONAL ALLEGATIONS This Court has subject matter jurisdiction because the matter in controversy is greater [than][ the][ sum][ of] Fifty [Thousand][ and][ One] Dollars ($50, 001) exclusive of interests and costs. Plaintiff, [NICHOLAS] DOUGHERTY (hereinafter “Plaintiff’ or “Dougherty”), is currently [a][ resident][ of] Allegheny County, residing at 1281 Beagle Drive, Bethel Park, PA 15102. At all times material to the Complaint, he was a resident of Palm Beach County, and resided at 5357 Stonybrook Lane, Boynton Beach, FL 33437 (the “Subject Property”). Defendant, [LINDA] ANNIBALE (hereinafter “Defendant” or “Annibale”), is a resident of Palm Beach County residing at 5357 Stonybrook Lane, Boynton Beach, FL 33437. Venue is proper in Palm Beach County because Defendant resides in Palm Beach County, [and][ the][ action][ occurred][ in][ Palm][ Beach] County. ----- Dougherty [v. ][ Annibale] Complaint ###### Page | [2] GENERAL ALLEGATIONS Plaintiff and Defendant met and began dating in approximately 2002, which quickly progressed [into][ a][ committed] relationship. At that time, Plaintiff and Defendant each owned their own residence but for all intents and purposes, they eventually resided together at Defendant’s residence. Plaintiff and Defendant moved to Florida in 2017 where they planned to retire. While working for NVR Settlement Services as a settlement officer, Defendant transferred to one of their Florida locations. Plaintiff resigned from his position as a bartender at Andora Restaurant after 16 years, [his][ last] day [of] employment being April 4, 2017, but remained in Pittsburgh for the purpose ###### of performing the work required to list both properties for sale. Both Plaintiff s and Defendant’s Pittsburgh properties sold between 2017 and early 2018, [at][ which][ time] Plaintiff joined Defendant in Florida as planned, where he and Defendant resided in Defendant’s aunt’s unoccupied residence until such time as they found and purchased a house. Plaintiff and Defendant met their realtor, Darcy LaFountain, at the Subject Property on November 3, 2017, which property they subsequently purchased. The closing on the Subject Property occurred on December 17, 2017. Plaintiff made two (2) wire transfers to Defendant which went toward the downpayment [of][ the] Subject Property [on] December 19, 2017, in the total amount of $14, 407. 02 (see [“Exhibit][ A”] attached). ----- Dougherty [v. ][ Annibale] Complaint ###### Page | [5] As Plaintiff was employed as a bartender, and his entire income not being considered, [Defendant] recommended using only Defendant’s name on the Deed to the Subject Property, [at][ which][ time] (and subsequent times) Defendant stated that it was simple to do, and that ###### Plaintiffs name would be added after the closing. The realtor, Darcy LaFountain, was fully aware that Plaintiff and Defendant were purchasing [the][ house] together, [as][ were][ both] Plaintiffs[ and] Defendant’s families, as well as the neighbors [who][ became][ friends][ with][ Plaintiff][ and][ Defendant. ] From January through April of 2018, Plaintiff and his brother worked four (4) months completely renovating the Subject Property, the materials for which were purchased by ###### Plaintiff either by cash or his credit cards. The parties moved into the Subject Property in May 2018. Each time Plaintiff asked Defendant why she hadn’t added his name to the Deed as agreed (and [that][ Defendant][ stated][ was] simple [and] inexpensive to do), Defendant would offer some excuse why she hadn’t, but continued to state that she would. Defendant never took the necessary and agreed-upon steps to officially make ###### Plaintiff a joint owner of the Subject Property. In approximately August 2019, Defendant told Plaintiff that she wanted him to move out of the Subject Property. Plaintiff, [after] finally realizing that he had no recourse, reluctantly vacated the Subject Property [on][ October] 1, [2019. ] ----- Dougherty Complaint ###### Page | [4] Plaintiff invested all of his funds on the Subject Property and was left with no money [and][ nowhere][ to][ live][ as][ he][ had][ sold][ his] Pittsburgh duplex [to][ relocate][ in] Florida with Defendant. COUNT 1 [-] UNJUST ENRICHMENT Dougherty re-alleges [and] incorporates by [reference][ the][ statements][ made][ and] contained in paragraphs 1 through 22 above. This is a count for unjust enrichment. Plaintiff has conferred a benefit on Defendant by improving the Subject Property. Defendant has knowledge of the benefit. Defendant accepted the benefit. It would be inequitable for the Defendant to retain the benefit without paying fair value for it. In bringing this action, Plaintiff has become obligated to pay costs for which the Defendant is liable pursuant to §57. 041, Florida Statutes. COUNT II- BREACH OF ORAL CONTRACT Dougherty re-alleges [and] incorporates by [reference][ the][ statements][ made][ and] contained in paragraphs 1 through 29 above. ----- Dougherty Complaint ###### Page | [5] The parties had an oral contract that Plaintiff would perform work on the Subject Property [and][ Defendant][ would] add Plaintiffs name on the title to the Subject Property. Defendant breached the oral contract with Plaintiff Plaintiff sustained damages in excess of $56, 000 (see “Exhibit “B” attached). WHEREFORE, Plaintiff, NICHOLAS DOUGHERTY, demands judgment against Defendant, [LINDA] ANNIBALE, for damages, pre- and post-judgment interest and costs, and award such further relief as the Court deems just and proper. Respectfully submitted, Nicholas Dougherty, Pro Se Plaintiffd: September 28, 2023 ----- PNC Bank Primary [account] number: Page [1][ of][ 3] For the period 12/06/2017 to 01/04/2018 Number of enclosures: 0 NICHOLAS D DOUGHERTY - [For][ 24-hour] banking, and transaction or interest rate information, sign on to 5357 STONYBROOK LANE PNC Bank Online Banking at pnc. com. BOYNTON BEACH FL 33437-1618 S For customer service call 1-888-PNC-BANK Monday [-] Friday: [7][ AM][ -10][ PM][ ET] Saturday [&] Sunday: 8 AM [-] 5 PM E. T Para servicio en esparfol, 1-866-HOLA-PNC Moving? Please contact us at 1-888-PNC-BANK S3 Write to: Customer Service PO Box 609 Pittsburgh [PA][ 15230-9738] ###### Q [Visit][ us][ at][ PNC. com] TDD terminal: 1-800-531-1648 For hearing impaired clients only ###### Standard Checking Account Summary NICHOLAS D DOUGHERTY Account number: Overdraft Protection i Overdraft Coverage - Your account is currently Opted-Out. You or your joint owner may revoke your opt-in or opt-out choice at any time. To learn more about PNC Overdraft Solutions visit us online at pnc. com/overdraftsolutions Call 1-877-508-3605, visit any branch, or Sign on to PNC Online Banking. and select the "Overdraft ' ProtectionSolutions” link settings. under the Account Services section to manage both your Overdraft Coverage and Overdraft Balance Summary f Transaction Summary Checks paid/ Check Card POS Check Card/Bankcard withdrawals signed transactions POS PIN transactions 0 4 2 TOtal ATM PNC Bank Other Bank transactions ATM transactions ATM transactions 2 2 Activity [Detail] Deposits [and][ Other] AdditionsAmount Oescriotion 12/13 12/14 12, 000. 00 Book Trn Credit RED CTED RED 12/19 2. 40Q. Q0 Deposit Reference No. 03537946S 2/26 EXHIBIT ----- For the period 12/06/2017 to 01/04/2018 ###### □ on[For] pnc. com. [ 24-hour] information, sign on to PNC Bank Online Banking NICHOLAS D DOUGHERTY Primary account number: Account number: j Page [2][ of][ 3] Deposits [and] Other Additions - continuedAmount Description 01/03 ualesanKing/uheck CardAmount WithdrawalsDescription and Purchases There was 1 Banking Machine Withdrawal totaling $60. 00 12/11 12/18 There were 2 Check Card/Bank card PIN PCS 12/18 purchases totaling $81. 91 12/18 12/19 There were 4 other Banking Machine/Check 12/19 Card deductions totaling $31. 54 01/03Online and Electronic• Banking• - Deductions There were 17 Online or Electronic Banking Deductions totaling $15, 763. 99 1207 12/08 1208 1213 1218 1218 1218 1219 12, 000. 00 Fed Wire Out 17Cj, i1102KsaQDD2 1219 2, 407. 02 Fed Wire Out T7Cjj51073H91 Diz 1220 1220 1221 1222 1226 1226 1229 01/03 Other Deductions Oate Amount Description There$60. 00 were. 2 Other Deductions totaling i2/19 30. 00 Wire Transfer Fee - Outgoing Wire 12/19 30. 00 Wire Transfer Fee - Outgoing Wire Daily Balance Detail ----- ###### Nicholas D. Dougherty _ Totals Cash and Cash Purchases $ -5^0&00- Checking [Account] $ 24, 957. 42 Discover $ 4, 217. 11 Capital [One] Quicksilver $ 329. 94 State Farm Visa $ 63. 01 Capital [One][ Teamsters] $ 34. 94 Bank of America MC $ 181. 55 Labor $ 21, 390. 00 $ 56. 381. 97 ###### Sb. m 77 ### ----- EXHIBIT ###### b n [H] ----- ###### [to][ Linda][ Annibale] from Nick Dougherty _Zelle 5/18/2018 $100 6/18/2018 $100 6/19/2018 $180 7/16/2018 $253 8/20/2018 $700 9/18/2018 $400 10/1/2018 $40 10/5/2018 $160 10/26/2018 $1, 000 11/19/2018 $400 11/29/2018 $110 12/28/2018 $175 1/4/2019 $110 < ###### 1/9/2019 djo $3, 858 Cash Purchases: Ladders (tohieh I hdi/i Master Bath Vanity $750 < ###### Marble Top >400 <$1, 350 ###### Cash Total _2$ [5, 208] ----- ###### Nicholas D. Dougherty Standard Checking Account (December [2017][ to] June 2019) _ 12/19/2017 Wire transfer (down payment) $ 12, 000. 00 12/19/2017 Wire transfer (down payment) $ 2, 407. 00 12/19/2017 Wire transfer (down payment) $ 30. 00 12/19/2017 Wire transfer (down payment) L 30. 00 $ 14, 467. 00 ###### 1/22/2018 Home Depot $ 1, 002. 00 1/25/2018 Alpha Dumpsters $ 299. 00 1/29/2018 Home Depot $ 100. 00 1/29/2018 Home Depot $ 5. 30 1/29/2018 Home Depot $ 1. 00 1/29/2018 Home Depot $ 141. 74 1/29/2018 Lowe's $ 78. 97 1/29/2018 Lowe's $ 117. 02 1/30/2018 Lowe's $ 69. 79 1/30/2018 Lowes $ 116. 54 $ 1, 931. 36 ###### 2/1/2018 Home Depot $ 575. 52 2/1/2018 Home Depot $ 94. 87 2/1/2018 Home Depot $ 35. 65 2/1/2018 Home Depot $ 4. 25 2/2/2018 Home Depot $ 21. 37 2/5/2018 Lowe's $ 171. 35 2/5/2018 Lowe's $ 70. 67 2/5/2018 Lowe's $ 77. 00 2/13/2018 Home Depot $ 243. 71 2/15/2018 Lowe's $ 232. 71 2/15/2018 Home Depot $ 11. 71 2/20/2018 Home Depot $ 36. 76 2/20/2018 Lowe's $ 12. 81 2/21/2018 Sherwin Williams $ 14. 98 2/22/2018 Sherwin Williams $_ 52. 90 $ 1, 656. 26 ###### 3/28/2018 Lowe's $ 8. 52 3/30/2018 Lowe's $_ 13. 06_ $ 21. 58 ----- - ~] ###### 4/18/2018 _ Synochrony [Bank] $ 158. 00 4/24/2018 Lowe's 1, 000. 00 £ $ 3, 609. 20 ###### 5/25/2018 City [Furniture] (sectional] $ 2, 139. 95 $ 2, 139. 95 ###### 6/18/2018 Home Depot $ 11. 24 $ 11. 24 ###### 8/13/2018 Home Depot $ 111. 51 8/15/2018 Home Depot $ 110. 17 $ 221. 68 ###### 9/6/2018 Lowe's $ 21. 84 9/7/2018 Lowe's $ 34. 31 9/7/2018 Lowe's $ 25. 66 9/12/2018 Home Depot $ 20. 30 9/28/2018 Lowe's $ 67. 08 $ 169. 19 ###### 10/16/2018 Home Depot $ 8. 00 10/16/2018 Lowe's $ 105. 93 10/24/2018 Home Depot $ 17. 53 $ 131. 46 ###### 11/5/2018 Home Depot $ 24. 50 11/8/2018 Home Depot $ 9. 57 $ 34. 07 ###### 12/18/2018 Lowe's $ 43. 82 $ 43. 82 ###### 1/16/2019 4ome Depot $ 4. 25 - 1/16/2019 lome Depot $ 85. 20 1/18/2019 ^we's $ 60. 75 $ 150. 20 ----- ###### 2/5/2019 Lowe's $ 23. 52 $ 23. 52 ###### 4/29/2019 Tuesday Morning $ 320. 99 $ 320. 99 ###### 5/29/2019 Home Depot $_4. 52 $ 4. 51 ###### 6/19/2019 Tuesday Morning $ 21. 39. $ 21. 39 ###### Checking [account][ total] $ 24, 957. 42 ----- ###### Nicholas D. Dougherty Discover Card Statement (February [2019][ to][ October] 2019] 2/9/2019 Lowe's $ 6. 36 2/23/2019 Lowe's 1 48. 04 $ 54. 40 ###### 3/5/2019 Lowe's $ 59. 11 3/9/2019 Lowe's $ 4. 80 3/10/2019 Home Depot $ 12. 14 3/15/2019 Lowe's $ 38. 48 3/18/2019 Drillscutter $ 24. 56 3/22/2019 Home Depot $ 27. 79 3/23/2019 Home Depot $ 10. 64 3/30/2019 Home Depot $ 31. 72 3/30/2019 Home Depot $ 27. 72 3/31/2019 Home Depot 8. 54 $_ $ 245. 50 ###### 4/15/2019 Lowe's $ 53. 78 4/16/2019 Lowe's $ 77. 47 4/16/2019 Lowe's $ 116. 63 4/18/2019 Lowe's $ 8. 54 4/21/2019 Lowe's $ 56. 66 4/22/2019 Home Depot $ 211. 07 $ 524. 15 ###### 5/1/2019 Home Depot $ 59. 46 5/3/2019 Home Depot $ 29. 72 5/11/2019 Home Depot $ 15. 68 5/11/2019 Lowe's $ 214. 44 5/13/2019 Lowe's $ 60. 85 5/14/2019 Lowe's $ 60. 99 5/18/2019 Lowe's $ 104. 35 5/19/2019 Home Depot $ 50. 33 5/22/2019 Lowe's $ 41. 77 5/29/2019 Home Depot 6. 38 $_ $ 643. 97 ----- ###### 6/12/2019 Lowe's $ 72. 98 6/16/2019 Lowe's $ 81. 91 [-] 6/17/2019 Lowe's $ 39. 57 6/26/2019 Lowe's L 32. 58 $ 227. 04 ###### 7/22/2019 Lowe's $ 11. 95 7/29/2019 Lowe's $ 10. 68 7/30/2019 Lowe's $ 64. 18 $ 86. 81 ###### 8/22/2019 Lowe's $ 76. 70 8/22/2019 Lowe's $ 29. 03 8/29/2019 Lowe's S 32. 08 $ 137. 81 ###### 9/13/2019 Lowe's $ 11. 43 9/28/2019 American Airlines 233. 50 $_ $ 244. 93 ###### 10/1/2019 ’enske $ 1, 326. 65 10/1/2019 Motel 6 $ 61. 93 10/1/2019 Super [8] $ 61. 01 10/2/2019 Motel 6 $ 60. 47 10/2/2019 Shell $ 80. 01 10/2/2019 lacetrac $ 69. 50 10/3/2019 jetGo $ 30. 02 10/3/2019 Marathon $ 74. 60 10/3/2019 Pride Mart $ 52. 50 10/4/2019 Extra Space $ 167. 81 10/6/2019 Sunoco $ 68. 00 $ 2, 052. 50 ###### Discover Total 1_4, 217. 11 ----- ###### Nicholas D. Dougherty Capital One Quicksilver MC (January [2018][ to] January 2019) _ 12/30/2017 Home Depot $ 20. 10 1/2/2018 Lowe's 61. 59 $_ $ 81. 69 ###### 1/26/2018 Home Depot [18. 16] $_ $ 18. 16 ###### 10/9/2018 Lowe's $ 45. 96 10/9/2018 Home Depot $ 47. 38 10/9/2018 Home Depot $ 44. 77 $ 138. 11 ###### 1/6/2019 Lowe's $ 54. 06 1/6/2019 Home Depot $ 37. 92 $ 91. 98 Capital [One] Quicksilver [MC] Total $ 329. 94 ###### -- ----- ###### Nicholas D. State Farm Vi (September 2019) 9/23/2019 Lowe's $ 63. 01 $ 63. 01 ###### State Farm Visa Total 63. 01 ----- ###### _Nicholas [D. ] Dougherty Capital One Teamsters MC (April [-] June 2018) 4/7/2018 Lowe's $ 22. 45 $ 22. 45 ###### 6/7/2018 Home Depot $ 12. 49 49 Capital [One][ Teamsters][ MC] Total £ 34. 94 ----- ###### _Nicholas [D. ] Dougherty Bank of America MC (August 2019) ##### _ ###### 8/7/2019 Lowe's $ 11. 75 8/9/2019 Lowe's $ 36. 67 8/10/2019 Lowe's $ 5. 33 8/10/2019 Lowe's $ (3. 71) 8/12/2019 Home Depot $ 19. 89 8/15/2019 Home Depot $ 58. 80 8/19/2019 Lowe's $ 52. 82 $ 181. 55 ###### Bank of America MC Total $_ 181. 55 ----- ###### Nicholas D. Dougherty [-] Labor Tile [-] removal and installation @ $5. 50 sf $8, 800 ###### Paint walls, ceilings, trim, doors, crown and baseboard (1, 700 sf) $5, 100 Crown [-] $600 install_ Bathroom vents [-] install $300 Knockdown $1, 300 Popcorn removal_ $1, 300 French drain $400 Gutters, down spouts $140 Drywall, [bath] $150 Atrium (walls, trim, floor, pergola) $1, 000 Roof [-] repair leak $200 Install outlets, switches $400 ###### nstall baseboards_ $600 Sand livingroom vaulted ceiling_ _$300 Hang [doors] (including [barn] door) $200 nstall toilets (2) $100 3lumb ###### vanities_ $100 nstall livingroom $100 fan_ Remove wallpaper (2 bedrooms walls, 2 bathrooms) $300 ###### $21, 390 #### ____ -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA **MCKENNA S HARMENING, a minor, by and through** **her parent and natural guardian, SAMANTHA** **ROSENTHAL, ** **Plaintiff, ** v. **URBAN AIR WELLINGTON LLC** **and URBAN AIR** CIVIL DIVISION **TRAMPOLINE & ADVENTURE PARK, ** Defendants. ____________________________________________/ **COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL** The Plaintiff, MCKENNA S HARMENING, a minor, by and through her parent and natural **guardian, SAMANTHA ROSENTHAL, by and through the undersigned counsel, hereby sues the, ** **URBAN AIR WELLINGTON LLC** **and URBAN AIR TRAMPOLINE & ADVENTURE PARK, and alleges:** **ALLEGATIONS COMMON TO ALL COUNTS** This is an action for damages which exceeds Fifty Thousand Dollars ($50, 000. 00) exclusive of interests and costs, and is otherwise within the jurisdictional limits of this Court. At all times material hereto, the Plaintiff, MCKENNA S HARMENING, a minor, by **and through her parent and natural guardian, SAMANTHA ROSENTHAL, was and is a resident of** Palm Beach County, Florida and is otherwise sui juris. At all times material hereto, the Defendant, URBAN AIR WELLINGTON LLC, was and is a Florida Corporation organized under the Laws of the State of Florida and doing business in West Palm Beach, Palm Beach County, Florida. ----- At all times material hereto, the Defendant, **URBAN AIR TRAMPOLINE &** **ADVENTURE PARK was and is a Florida Corporation organized under the Laws of the State of** Florida and doing business in Wellington, Palm Beach County, Florida. Venue is proper in this County in that the Defendants do business in Palm Beach County, Florida and/or all of the acts complained of herein occurred in Palm Beach County, Florida. That on or about July 30, 2022, the Plaintiff, MCKENNA S HARMENING, a minor, **by and through her parent and natural guardian, SAMANTHA ROSENTHAL, was a business** invitee of the Defendant, URBAN AIR TRAMPOLINE & ADVENTURE PARK. **COUNT I - NEGLIGENCE CLAIM OF URBAN AIR WELLINGTON LLC** Plaintiff re-alleges and restates the allegations in paragraphs 1 through 6 as if fully set forth herein. That at all times material hereto and specifically on July 30, 2022, Defendant, **URBAN AIR WELLINGTON LLC, owned, managed, controlled, operated, and/or maintained the** premises located at 10560 Forest Hill Blvd, Wellington, Florida, 33414, in Palm Beach County. That on or about July 30, 2022, the Plaintiff, **MCKENNA S HARMENING, ** was patron of the subject premises at **URBAN AIR TRAMPOLINE & ADVENTURE PARK** located at 10560 Forest Hill Blvd, Wellington, Florida, 33414, in Palm Beach County, when improper supervision which led to serious injuries when another patron invaded her trampoline and caused her to fall. That the Defendant owed to its business invitees a duty to provide a reasonably safe environment. ----- That the Defendant, its agents, servants or employees, breached its duty owed to the Plaintiff by negligently maintaining its premises in the following manner: a. By failing to maintain the the premises in a reasonably safe condition, allowing other patrons to invade others trampolines, and to prevent dangerous conditions from occurring; and/or b. By failing to warn of the dangerous condition that existed at the time of the Plaintiff’s incident; and/or c. Failing to place barricades, signs, or other marking devices utilized to alert customers such as the Plaintiff of the dangerous condition that existed at the time of Plaintiff’s incident; and/or d. By failing to correct the hazardous condition of the premises when the Defendant knew or should have known that the general public visits said premises and specifically the Plaintiff herein; and/or e. Was otherwise negligent in the care, maintenance, and upkeep of the premises. That the Defendant knew or in the exercise of reasonable care should have known of the existence of the hazardous and dangerous condition which constituted a dangerous condition to the Plaintiff, and the condition had existed for a sufficient length of time that the Defendant knew or should have known of the condition and could have easily remedied it; and/or That the hazardous and dangerous condition which constituted a dangerous condition to the Plaintiff occurred with such frequency that owner should have known of its existence. ----- The Defendant had actual notice of the dangerous condition. As a direct and proximate result of the aforementioned negligence of the Defendant, the Plaintiff, MCKENNA S HARMENING, suffered significant and severe bodily injury that is permanent within a reasonable degree of medical probability, along with resulting pain and suffering, disability, aggravation of pre-existing injuries, scarring and/or disfigurement, physical impairment, inconvenience, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings and loss of ability to earn money in the future. The losses are either permanent or continuing in nature and the Plaintiff, MCKENNA S HARMENING will suffer the losses in the future. WHEREFORE, the Plaintiff, **MCKENNA S HARMENING, a minor, by and through her** **parent and natural guardian, SAMANTHA ROSENTHAL, hereby demands judgment for damages, ** costs and interest from the Defendant, URBAN AIR WELLINGTON LLC, together with whatever other relief the Court deems just and appropriate. **COUNT II - NEGLIGENCE CLAIM OF URBAN AIR TRAMPOLINE** **& ADVENTURE** **PARK** Plaintiff re-alleges and restates the allegations in paragraphs 1 through 6 as if fully set forth herein. That at all times material hereto and specifically on July 30, 2022, Defendant **URBAN AIR TRAMPOLINE & ADVENTURE PARK, owned, managed, controlled, operated, and/or** maintained the premises located at 10560 Forest Hill Blvd, Wellington, Florida, 33414, in Palm Beach County. That on or about July 30, 2022, the Plaintiff, MCKENNA S HARMENING, was in Defendant, **URBAN AIR TRAMPOLINE & ADVENTURE PARK’s** premises, when improper ----- supervision led to serious injuries when staff allowed other patrons to invade her trampoline, causing her to fall. That the Defendant owed to its business invitees a duty to provide a reasonably safe environment. That the Defendant its agents, servants or employees, breached its duty owed to the Plaintiff by negligently maintaining its premises in the following manner: a. By failing to maintain the premises in a reasonably safe condition, allowing other patrons to invade others trampolines, and to prevent dangerous conditions from occurring; and/or b. By failing to warn of the dangerous condition that existed at the time of the Plaintiff’s incident; and/or c. Failing to place barricades, signs, or other marking devices utilized to alert customers such as the Plaintiff of the dangerous condition that existed at the time of Plaintiff’s incident; and/or d. By failing to correct the hazardous condition of the premises when the Defendant knew or should have known that the general public visits said premises and specifically the Plaintiff herein; and/or e. Was otherwise negligent in the care, maintenance, and upkeep of the premises. That the Defendant knew or in the exercise of reasonable care should have known of the existence of the hazardous and dangerous condition which constituted a dangerous ----- condition to the Plaintiff, and the condition had existed for a sufficient length of time that the Defendant knew or should have known of the condition and could have easily remedied it. As a direct and proximate result of the aforementioned negligence of the Defendant, the Plaintiff, MCKENNA S HARMENING, suffered significant and severe bodily injury that is permanent within a reasonable degree of medical probability, along with resulting pain and suffering, disability, aggravation of pre-existing injuries, scarring and/or disfigurement, physical impairment, inconvenience, loss of capacity for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of earnings and loss of ability to earn money in the future. The losses are either permanent or continuing in nature and the Plaintiff, MCKENNA S HARMENING will suffer the losses in the future. WHEREFORE, the Plaintiff, **MCKENNA S HARMENING, a minor, by and through her** **parent and natural guardian, SAMANTHA ROSENTHAL, hereby demands judgment for damages, ** costs and interest from the Defendant, URBAN AIR TRAMPOLINE & ADVENTURE PARK, together with whatever other relief the Court deems just and appropriate. ----- **DEMAND FOR JURY TRIAL** The Plaintiff, MCKENNA S HARMENING, a minor, by and through her parent and **natural guardian, SAMANTHA ROSENTHAL, hereby demands trial by jury of all issues so triable** as a matter of right. d: March 19[th], 2023 **RUBENSTEIN LAW, P. A. ** Attorneys for 9130 S Dadeland Blvd Miami, Florida 33156 Tel: (305) 661-6000 Fax: (305) 670-7555 Email: phunt@rubensteinlaw. com jdamiani@rubensteinlaw. com eservice@rubensteinlaw. com By: _/s/ Peter Hunt Florida Bar No. : 107350 -----

[Assistant] **IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT** **IN AND FOR PALM BEACH COUNTY, FLORIDA** **MCKENNA S. HARMENING, a minor** **By and through her parent and natural** **Guardian, SAMANTHA ROSENTHAL, ** **Plaintiff, ** **v. ** **URBAN AIR WELLINGTON, LLC AND** **URBAN AIR TRAMPOLINE & ADVENTURE** **PARK, ** **Defendants. ** **__________________________________________/** **DEFENDANTS’ FIRST REQUEST FOR PRODUCTION TO PLAINTIFF** COMES NOW the Defendants, URBAN AIR WELLINGTON, LLC and URBAIN AIR TRAMPOLINE & ADVENTURE PARK (“Defendant”), by and through undersigned counsel, and pursuant to Fla. R. Civ. P. 1. 350, hereby serves its First Request for Production, the responses of which are due within thirty (30) days. **REQUESTS** Individual and/or joint income tax returns, corporate tax returns and any other supporting documentation, including W-2 forms, evidencing income, for the five (5) years preceding the alleged accident/incident to. All documentation, which would reflect Plaintiff's earnings for the present year to(this would include payroll stubs, canceled checks, computer printouts of earnings to, etc. ). Any and all medical, doctor, hospital, drug, nursing, pharmacy, and ambulance bills (including any members of the healing arts and related fields: i. e. , drugs, prosthetics, supports, etc. ) incurred as a result of the injuries which are or may be the subject matter of this lawsuit. All bills and/or invoices relating to any other expenses that you claim you have incurred as a result of this accident/incident, including but not limited to property damage claim estimates, household assistance, and out-of-pocket expenses. Any and all photographs depicting any and all parties and/or witnesses, the injury and the damages sustained by the person(s) involved in the accident/incident herein, the scene and/or site of the accident/incident as described in your Complaint. ----- All reports, evaluations, recommendations and/or analysis submitted by any expert and/or treating physician which relate to or cover the accident/incident which is the subject matter of this lawsuit and/or any injuries, damages or losses alleged caused by the accident/incident. Copies of any and all medical reports and/or records from doctors, physicians (including chiropractors), hospitals, or anyone else of the healing arts that has rendered treatment to you or examined you subsequent to the accident/incident herein which is the subject matter of this lawsuit. (This would include both treating physicians as well as independent medical exams). Copies of any and all writings, recordings, memorandums, notes, depositions and all other materials reflecting statements made by the Defendant. Copies of all applications filled out by you for any type of insurance coverage for which you are submitting an Application to obtain benefits for any of your damages and/or wages for the accident/incident as alleged in your Complaint. Copies of each and every document, chart, paper, graph, employment record, payroll record, time sheets and/or other writings of any type evidencing each and every day, or partial day, you claim to have missed from work as a result of the accident/incident which is the subject matter of this lawsuit. Copies of any and all checks, payout sheets and/or writings that indicate the amount of money, if any, that you have received as reimbursement for lost wages, medical bills (or other bills) from any collateral sources. Copies of all letters of subrogation rights or liens being asserted by any third party/entity as a result of any damages you have sustained as a result of the accident/incident as described in the Complaint. Copies of any and all reports, charts, graphs, or other writings from any vocational specialist, rehabilitative consultants and/or other experts that have assisted you or evaluated you with regard to damages claimed in this lawsuit. Copies of all diagnostic test results, including but not limited to x-rays, CT scans, thermograms, MRI films, EMG, NCS and other electrical studies that were performed on the claimant(s) as a result of the accident which is the subject matter of this lawsuit. All diagnostic films including but not limited to x-rays, CAT scans, CT scans, MRI scans, ultrasounds, thermograms, EMG and NCS studies taken of you as a direct result of the accident/incident described in your Complaint. All diagnostic test results/reports of any and all x-rays, CAT scans, CT scans, MRI scans, ultrasounds, thermograms, EMG and NCS studies that were performed on you during the fifteen (15) year period prior to the accident/incident as described in your Complaint. Copies of the front and back of any and all insurance identification cards and union employment identification cards which would depict the name, address, policy number, claim number and/or identification number of any insurance company and/or employers which will ----- provide you with any benefits to compensate you for any of the damages that you are alleging as a result of the accident/incident which is the subject matter of this lawsuit. Any and all statements, documents, correspondence, charts or other writings of any type taken from Plaintiff’s employers and/or their agents pertaining to employment, wage loss, loss of future earning capacity or the loss of the ability to earn money in the future which would support your allegations in the Complaint. Copies of any and all accident reports, incident reports, police reports or other reports that were generated as a result of the accident/incident that is the subject matter of your Complaint. Traffic accident reports for any and all automobile accidents that you have been involved in within the ten (10) year period before the accident/incident giving rise to this case, and for any and all automobile accidents that you have been involved in since the occurrence of the accident which is the subject matter of this lawsuit. Copies of any Notice of Injury forms that you have filled out for any workman's compensation claim, or workman's compensation notice, that you are required to fill out as a result of any type of on-the-job injury or incident for the past five (5) years to. If you filled one out as a direct result of the accident/incident which is described in your Complaint, produce that one as well. Copies of any and all life, health, or disability insurance policies covering the claimant in this lawsuit that was in full force and effect on theof the accident which is the subject matter of this lawsuit. Copies of any and all statements taken of any witnesses (written or recorded) as a result of the accident/incident which is the subject matter of this lawsuit. Copies of the front and back of all drivers’ licenses in your possession. Copies of any Florida identification cards, front and back. A complete copy of your passport including all stamped pages. Copies of any Releases you may have executed to any party, person, entity for personal injuries you may have sustained or property damage you suffered in the past ten (10) years. Copies of all medical reports and records that were made by any physician or chiropractor regarding any examination that was conducted upon you at the request of any insurance company, worker’s compensation claim, or insurance adjusting company (otherwise known as IME's, independent evaluations, medical evaluations, or physical examinations) which occurred as a consequence of the accident/incident as described in your Complaint. Copies of all medical reports and records that were made by any physician or chiropractor regarding any examination that was conducted upon you at the request of any insurance ----- company or insurance adjusting company (otherwise known as IME's, independent evaluations, medical evaluations, or physical examinations) for the past ten (10) years. Copies of any calendars, diaries, notes or other documentation made by you which memorializes any appointments, your condition, thoughts, damages or any other item of damages you intend to present to the jury at the trial of this case. Please sign and return the enclosed Authorization for Release of Medical Information form. Please sign and return the enclosed Form SSA-7050-F4, Request for Social Security Earnings Information. Please sign and return the enclosed Form 4506, Request for Copy of Tax Return form. Any and all correspondence sent in compliance with Florida Statute 768. 76(6) whereby the provider of any collateral sources were sent by certified registered mail notifying of the Plaintiff’s intent to claim damages from a tortfeasor. Any and all documents received from the provider of collateral sources, pursuant to Florida Statute § 768. 76(7), specifically copies of statements asserting the collateral source provider’s right to payment of collateral source benefits and right of subrogation or reimbursement, notification by the provider of collateral sources that no right of subrogation or reimbursement exists for the collateral sources paid and/or notification by the collateral source provider of its intent to waive right of subrogation or reimbursement. Any and all letters of protection relating to damages/expenses you incurred as a result of the incident alleged in the complaint. Any and all documentation sent to Medicare and/or Medicaid advising Medicare and/or Medicaid that the Plaintiff has made a claim for personal injury and/or has filed suit with regard to the injury(ies) sustained in the subject accident. Any and all documentation received by the Plaintiff or on behalf of the Plaintiff from Medicare and/or Medicaid advising of an intent to assert a lien, the amount of the lien or an intent to waive right of its lien. If the Plaintiff received benefits from a plan administered by ERISA, a copy of the summary plan description, reimbursement agreement executed by the Plaintiff and copy of the policy. Copies of any reports prepared as a result of the Plaintiff submitting to a compulsory medical examination and/or independent medical examination made pursuant to the Florida Rules of Civil Procedure, request by insurance carrier or government entity to include examinations performed at the request of Personal Injury Protection (PIP) carrier, Social Security, workers’ compensation carrier, disability income carrier or any other insurer or provider of government benefits. ----- If the Plaintiff was covered under a group health policy at the time of the accident alleged in the Complaint, a copy of the group health insurance policy and declarations page. If the Plaintiff was covered by a disability income policy at the time of the accident alleged in the Complaint, a copy of the disability income policy and declarations page. If the Plaintiff has ever applied for Social Security Disability benefits, a copy of any application or documents submitted to Social Security upon which the Plaintiff based his claim for disability benefits. If the Plaintiff has ever applied for workers’ compensation benefits, a copy of any application or documents submitted to workers’ compensation upon which the Plaintiff based his/her claim for workers’ compensation. If the Plaintiff has ever applied for unemployment benefits, a copy of any application or documents submitted to unemployment upon which the Plaintiff based his claim for benefits. If the Plaintiff has ever applied for long term disability benefits, a copy of any application or documents submitted upon which the Plaintiff based his claim for benefits. Copies of any and all writings, recordings, memorandums, notes, depositions and all other materials reflecting how the incident alleged in the complaint occurred. All transcripts of any recorded statements and/or EUOs you provided in relating to the incident alleged in the complaint. All documents relating to the allegation that Defendant knew or should of known of the dangerous condition. Copies of any and all social media profiles from 3 years before theof the incident to the present. **CERTIFICATE OF SERVICE** I HEREBY CERTIFY that a true and accurate copy of the above and foregoing has been furnished by E-Mail to E-Filing Portal on 07/31/2023. By: /s/ Carlo D. Marichal Carlo D. Marichal, Esquire Banker Lopez Gassler P. A. Service: service-cmarichal@bankerlopez. com 1200 S. Pine Island Rd. Suite 170 Plantation, FL 33324 Phone: (954) 703-3597 Fax: (954) 533-3051 FBN: 0099034 Attorney for the Defendant -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA NICHOLAS RODKIN AND BRANDI RODKIN, Plaintiff(s), v. TYPTAP INSURANCE COMPANY, Defendant. ### ______________________________________ I **COMPLAINT** COMES NOW, Plaintiff(s), NICHOLAS RODKIN AND BRANDI RODKIN, by and through undersigned counsel, and hereby sues Defendant, TYPTAP INSURANCE COMPANY, and states: **GENERAL** **ALLEGATIONS** This action is for breach of contract. This action exceeds $30, 000. 00, exclusive of attorney’s fees and costs. All allegations are at all times material hereto unless otherwise stated. Plaintiffresides, and Defendant is doing business, in PALM BEACH, Florida. Venue is proper in this court. Defendant insured Plaintiffs property as follows: a. Address: 5640 American Cir Delray Beach, FL, 33484-8565 b. Policy No: 12-1010400-02. Defendant’s claim number is: 12-3002078-20. Plaintiffs home was damaged by a wind event that occurred on 6/19/2020. Plaintiffnotified Defendant of the resulting loss. ----- On February 12, 2021, Defendant sent correspondence indicating they had completed their ### inspection of the insured’s property. The February 12, 2021 correspondence indicated that Defendant is denying coverage for ### Plaintiffs damages. Plaintiffs loss is covered under the policy. Plaintiff retained counsel to protect all rights under the policy. Plaintiff is responsible for all reasonable attorney’s fees and costs. Plaintiff has complied with all conditions precedent to recover under the policy. **COUNT** **I:** **BREACH** **OF** **CONTRACT** Allegations 1 through 15 above are adopted and incorporated herein. The parties had a valid policy-i. e. , contract. Defendant materially breached its duty to pay Plaintiffs loss under the policy. As a result, Plaintiff has suffered loss and resulting damages. **WHEREFORE, ** Plaintiff(s) demand (a) judgment against defendant for all damage and ### resulting loss set forth above, these losses are ongoing and will continue in the future; (b) attorney’s fees and costs pursuant to 627. 428 (attorney’s fees), 57. 041 (costs) and 92. 231 (expert witness fees), Florida Statutes, or otherwise; and (c) trial by jury. d: February 22, 2021. Zs/ _Lindsay_ _Karten_________________ ### Lindsay Karten, Esq. Florida Bar No. 30869 Keller, Melchiorre & Walsh, PLLC 3900 Military Trail, Suite 600 Jupiter, FL 33458 (561) 295-5825 Telephone (561) 766-7054 Facsimile ### lindsay@kmwlegal. com pleadings@kmwlegal. com -----

[Assistant] IN THE CIRCUIT COURT OF THE `15th` JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA NICHOLAS RODKIN and BRANDI RODKIN, CASE NO: 2021-CA-2383 Plaintiffs, v. TYPTAP INSURANCE COMPANY, Defendant, ___________________________________ /_ **DEFENDANT’S, ** **TYPTAP** **INSURANCE** **COMPANY, ** **FIRST** **REQUEST** **FOR** **PRODUCTION** **TO** **PLAINTIFF** COMES NOW, Defendant, TYPTAP INSURANCE COMPANY, by and through the undersigned counsel, and hereby requests that Plaintiffs, NICHOLAS RODKIN and BRANDI RODKIN, produce the following within the time prescribed by the Florida Rules of Civil Procedure: **DEFINITIONS** “Plaintiff’ means: NICHOLAS RODKIN and/or BRANDI RODKIN. “Property” or “residence” refers to the insured property or the insured residence located. Unless otherwise specified herein, all references to “loss” or “damages” refer to the loss Plaintiff reported to Typtap Insurance Company at the property, which is the subject of this lawsuit, and the damages Plaintiff is claiming resulted therefrom, respectively. **REQUEST** **FOR** **PRODUCTION** Photographs depicting any of the damages claimed by you. Photographs depicting the cause of the damages claimed by you. All documents that evidence damage to the property from the subject loss. All correspondence and documents submitted by you and your representatives to Typtap Insurance Company as part of the subject claim. 1 of 5 ----- Any and all assignments signed by Plaintiff for the subject claim. Any and all documents supporting your answers to interrogatories. All leases for the rental of the residence and/or any aspect of it since Plaintiff has owned the residence. All documents pertaining to changes in title or occupancy of the property during the term of the subject policy and/or after theof loss. The accurate record of repair expenses required by your insurance policy. All documents and correspondence exchanged between you and any contractor or service provider concerning the subject claim. All correspondence and documents exchanged between you and your Public Adjuster (or loss consultant) for the subject claim. All correspondence and documents exchanged between you and representatives of #### D’Agostino Roofing. Copies of any appraisal or applications for mortgage financing in the past four (4) years. A copy of your most recent mortgage invoice. Copies of real estate tax payments for the past two years. Any and all documents regarding any and all bankruptcy filed by Plaintiff. Any and all insurance policies covering the property affected by this loss. All non-privileged documents pertaining to the issues raised in your Complaint. All estimates for the repair of the property Plaintiff or anyone on Plaintiffs behalf has prepared since 2010. All documents that evidence expenditures by Plaintiff and/or anyone on Plaintiffs behalf for all repairs, mitigation, reconstruction, modification, renovation, remodeling, construction and/or restoration of the property related to the damage and/or loss - including but not 2 of 5 ----- limited to - receipts, invoices, proposals, contracts, subcontracts, blueprints, and/or canceled checks for repairs. All documents that evidence the repair, replacement, maintenance, modification, renovation, remodeling and/or restoration of the plumbing system in the property - by or on behalf of Plaintiff at any time. All documents that evidence the repair, replacement, maintenance, modification, renovation, remodeling and/or restoration of the roof system in the property - by or on behalf of Plaintiff at any time All contracts, estimates, invoices, proposals, statements, receipts, canceled checks and all other document(s) for all repair(s), replacement(s), reconstruction, modification, renovation, remodeling, construction and/or restoration performed at the property in the last five (5) years from theof this Request for Production not already provided in response to one or more of the preceding paragraphs. All documents and photographs and pictorial representations that evidence the state and/or condition of the property Plaintiff claims were damaged by the loss before the loss occurred ## - including but not limited to cancelled checks, contracts, estimates for repairs, proposals, subcontracts, invoices, reports, brochures, appraisals, receipts, purchase orders, and operator manuals - that have not already been produced in response to one or more of the preceding paragraphs. The written results of all inspections and examinations of the property from all industrial hygienists, restoration contractors, mold and mildew specialists, and all other professionals and experts that have been generated in the past seven (7) years and that have not already been produced in response to one or more of the preceding paragraphs. 3 of 5 ----- All permits issued for the repair, replacement, reconstruction, modification, renovation, remodeling, construction and/or restoration of any part of the residence in the past seven (7) years that have not already been produced in response to one or more of the preceding paragraphs. All permit applications submitted for any construction services performed or to be performed in relation to the subject claim All engineering reports, incident reports, statements and investigative materials obtained regarding the cause of the loss. All documents that evidence wind related damage to the roof of the subject property. Any and all copies of home inspection reports and/or evaluations that were prepared pursuant to Plaintiff’s purchase of the property and/or that were prepared at any time since Plaintiff has owned the property that have not already been produced in response to one or more of the preceding paragraphs. All utility bills for the property for twelve months prior to theof the alleged loss up to the present. All documents that have not already been produced in response to one or more of the preceding paragraphs that show and/or evidence the existence of the damage and that supports Plaintiffs complaint. Any and all documentation of any other insurance claims to any insurance company filed in the last fifteen (15) years. All estimates, proofs of loss and other documents Plaintiff has submitted to any insurance carrier for any insurance claim Plaintiff has had other than the insurance claim that is the subject of this lawsuit within the last seven (7) years. 4 of 5 ----- All documents showing Plaintiff complied with Plaintiffs post-loss contractual duties as stated in the subject insurance contract and made part of Plaintiff s Complaint. All documents regarding all claims filed by Plaintiff with any and all Property Insurance Companies. **CERTIFICATE** **OF** **SERVICE** The undersigned hereby certifies that a copy of the foregoing was served by electronic mail delivery to [pleadings@kmwlegal. com, ](mailto:pleadings@kmwlegal. com) on the 14th day of September, 2021. **TYPTAP** **INSURANCE** **COMPANY** P. O. Box 22967 Tampa, FL 33622 Office: 954-830-7406 Email: [mgonzalez@hcpci. com](mailto:mgonzalez@hcpci. com) By:/s/ Miredys Gonzalez Portieles MIREDYS GONZALEZ PORTIELES, ESQ. Florida Bar No. : 95324 5 of 5 -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA NICHOLAS RODKIN AND BRANDI RODKIN, Plaintiff(s), v. TYPTAP INSURANCE COMPANY, Defendant. ### ______________________________________ I **COMPLAINT** COMES NOW, Plaintiff(s), NICHOLAS RODKIN AND BRANDI RODKIN, by and through undersigned counsel, and hereby sues Defendant, TYPTAP INSURANCE COMPANY, and states: **GENERAL** **ALLEGATIONS** This action is for breach of contract. This action exceeds $30, 000. 00, exclusive of attorney’s fees and costs. All allegations are at all times material hereto unless otherwise stated. Plaintiffresides, and Defendant is doing business, in PALM BEACH, Florida. Venue is proper in this court. Defendant insured Plaintiffs property as follows: a. Address: 5640 American Cir Delray Beach, FL, 33484-8565 b. Policy No: 12-1010400-02. Defendant’s claim number is: 12-3002078-20. Plaintiffs home was damaged by a wind event that occurred on 6/19/2020. Plaintiffnotified Defendant of the resulting loss. ----- On February 12, 2021, Defendant sent correspondence indicating they had completed their ### inspection of the insured’s property. The February 12, 2021 correspondence indicated that Defendant is denying coverage for ### Plaintiffs damages. Plaintiffs loss is covered under the policy. Plaintiff retained counsel to protect all rights under the policy. Plaintiff is responsible for all reasonable attorney’s fees and costs. Plaintiff has complied with all conditions precedent to recover under the policy. **COUNT** **I:** **BREACH** **OF** **CONTRACT** Allegations 1 through 15 above are adopted and incorporated herein. The parties had a valid policy-i. e. , contract. Defendant materially breached its duty to pay Plaintiffs loss under the policy. As a result, Plaintiff has suffered loss and resulting damages. **WHEREFORE, ** Plaintiff(s) demand (a) judgment against defendant for all damage and ### resulting loss set forth above, these losses are ongoing and will continue in the future; (b) attorney’s fees and costs pursuant to 627. 428 (attorney’s fees), 57. 041 (costs) and 92. 231 (expert witness fees), Florida Statutes, or otherwise; and (c) trial by jury. d: February 22, 2021. Zs/ _Lindsay_ _Karten_________________ ### Lindsay Karten, Esq. Florida Bar No. 30869 Keller, Melchiorre & Walsh, PLLC 3900 Military Trail, Suite 600 Jupiter, FL 33458 (561) 295-5825 Telephone (561) 766-7054 Facsimile ### lindsay@kmwlegal. com pleadings@kmwlegal. com -----

[Assistant] IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA NICHOLAS RODKIN AND BRANDI RODKIN, Plaintiff(s), v. TYPTAP INSURANCE COMPANY, Defendant. ### ______________________________________! **NOTICE** **OF** **SERVICE** **OF** **PLAINTIFF’S** **FIRST** **REQUEST** **FOR** **PRODUCTION** **TO** **DEFENDANT** COMES NOW the Plaintiff, NICHOLAS RODKIN AND BRANDI RODKIN, by and through undersigned counsel, and hereby gives notice that Plaintiff’s First Request for Production directed to Defendant, TYPTAP INSURANCE COMPANY, was served on said Defendant with the initial pleading. ## /s/ Lindsay Karten_________ Lindsay Karten, Esq. Florida Bar # 30869 Keller, Melchiorre & Walsh, PLLC 3900 Military Trail, Suite 600 Jupiter, FL 33458 Telephone: (561) 295-5825 Facsimile: (561) 766-7054 [lindsay@kmwlegal. com](mailto:lindsay@kmwlegal. com) [pleadings@kmwlegal. com](mailto:pleadings@kmwlegal. com) ----- ### GENERAL INSTRUCTIONS Re: Rule 1. 350 Request for Production **INFORMED** **ANSWERS:** **PRIMARY** **PURPOSE** **OF** **DISCOVERY:** “The primary purpose of discovery under the rules ofprocedure is to prevent the use of surprise, trickery, ### bluff and legal gymnastics. Revelation through discovery procedures of the strength and weakness of each side before trial encourages settlement of cases and avoids costly litigation. Each side can make an intelligent evaluation of the entire case and may better ### anticipate the ultimate results. ” Grinnell Corp, v. Palms 2100 Ocean Blvd. , 924 So. 2d 887, 893 (Fla. 4DCA 2006). **INFORMED** **ANSWERS:** Before answering this discovery, please review all ### documentation or information so that your answers are accurate, complete and truthful. **DEFINITIONS:** ### a. YOU or YOUR means defendant or anyone acting on its behalf. b. POLICY means the policy pled under the pleadings. C. **PROPERTY** **DAMAGE** is defined under the policy. ### d. DOCUMENT means any document, whether computer generated or otherwise, defined by Rule 1. 350, Fla. R. Civ. P. , including emails. **IF** **YOU** **OBJECT** **ORWITHHELD** **INFORMATION:** Please identify the facts, documents and each person that you rely on in support so that we can evaluate your objection and attempt to avoid motion practice. 1 1 Defendant must disclose “all facts supporting” its objection, denial or defense as well as “any ### records that support those facts and every person who has knowledge of those facts. ” Grinnell Corp, v. Palms 2100 Ocean Blvd. , 924 So. 2d 887, 890 & 894 (Fla. 4th DCA 2006)(“[T]he work ### product concept furnishes no shield against discovery, by interrogatories or by deposition, of the facts that the adverse party's lawyer has learned, or the persons from whom he has learned such facts, or the existence or nonexistence of documents, even though the documents themselves may ### not be subject to discovery. ”). Homeowners Choice Prop. & Cas. Ins. Co. , Inc, v. Avila, 248 So. 3d 180, 184 (Fla. 3rd DCA 2018)(there is no “claims file” privilege in Florida). ----- ### PLAINTIFF’S FIRST REQUEST FOR PRODUCTION **PREFACE:** When producing documents, please identify which documents are responsive to each request to produce and subpart as required under Rule 1. 350(b), ### Fla. R. Civ. P. ("[w]hen producing documents, the producing party. .. shall identify them to correspond with the categories in the request”), whether by bate stamp, insertion of page divider or otherwise. Please produce each inspection report and all resulting photographs and videos in digital format (JPEG) if you inspected plaintiffs residence: a. Before binding or issuing the policy-e. g. , limited to underwriting. b. During any policy period. c. For this claim. Produce each document “upon which you rely for each affirmative defense in your answer. ”2 Note: Please identify which documents or objections are responsive to each ### affirmative defense. As for any communications between the parties: a. All correspondence. b. All emails. c. All summaries of each phone or in person conversation, if any. d. All recorded conversations; if so, please include each audio. e. **SCOPE:** Limited tothis claim. 2 Document is defined under Rule 1. 350. You are required to disclose “the existence or nonexistence of documents, even though the ### documents themselves may not be subject to discovery. ” Grinnell Corp, v. Palms 2100 Ocean Blvd. , 924 So. 2d 887, 890 & 894 (Fla. 4th DCA 2006)(“[T]he work product concept furnishes no shield against discovery, by interrogatories or by deposition, of the facts that the adverse party's ### lawyer has learned, or the persons from whom he has learned such facts, or the existence or nonexistence of documents, even though the documents themselves may not be subject to discovery. ”)(Emphasis Added). There is “no difference between a fact ‘pertaining’ to an incident. .. and a document or fact ‘supporting’ an affirmative defense. .. .” Grinnell Corp. , 924 So. 2d at 893 (Emphasis Added). ----- As for any communications between defendant’s insurance agent and plaintiff: a. All correspondence. b. All emails. c. All summaries of each phone or in person conversation, if any. d. All recorded conversations; if so, please include each audio. e. **SCOPE:** Limited tothis claim. All written and recorded statements from: a. Any plaintiff. b. Any witness. c. Anyone not covered above. d. Each audio for each recorded statement. e. **SCOPE:** Limited to this claim, plaintiffs dwelling, policy or any similar claim. f. **TIME** **PERIOD:** i. During the application process before issuing policy. ii. From inception of policy through present. Certified copy of complete policy for each policy period: a. **EXPLANATION:** We know that coverage, endorsements and exclusions may change from one policy period to the next during any 12 month policy period and hence this request. b. **TIME** **PERIOD:** i. policy first issued to plaintiff. ii. Each renewal. If the policy was not renewed, all documents that identify each reason. If the policy was cancelled, all documents that identify each reason. For each contractor, engineer, roofer, plumber, inspector, trade professional, company or person who inspected, examined or evaluated plaintiffs residence for defendant (“consultant”), we need to know how much money defendant has paid to each consultant for all work performed for defendant during the last 3 years. Allstate Ins. Co. v. Boecher, 733 So. 2d 993, 997 (Fla. l999)(“A jury is entitled to know the extent of the financial connection between the party and the witness, and the cumulative amount a party has paid ### an expert during their relationship. ”). ----- ### For purposes of this request, the term "defendant" shall include any and all related insurance companies. 3 As a result, please produce copies of all IRS Forms 1099 from defendant to each consultant during the last 3 years. Further to plaintiff s interrogatories, we asked you to identify each underwriting guideline, manual or informational materials that were in effect when policy was first issued to ### plaintiff and each renewal that address any of the enumerated policy areas. As a result, please produce each underwriting guideline, manual and informational materials for each policy area (a) filed with the state4 and (b) not filed with the state. Note: Please identify which documents or objections, if any, are responsive to each policy area. Defendant’s complete underwriting file regarding: a. Issuing policy for this risk-i. e. , plaintiffs residence. b. Each renewal. c. **TIME** **PERIOD:** Beforeof loss in this case. Defendant’s complete claim file: a. Limited to this claim. b. Non-privilege documents only, if any. 3 By way of example only, we will use Allstate as an example: Allstate Corporation owns and operates 18 companies around the United States, Canada and India which include Allstate Fire and ### Casualty Insurance Company; Allstate Insurance Company; Allstate Indemnity Company; among others. If one of these companies was the named defendant, it would disclose all money paid by any and all 18 related companies to each consultant. 4 For example, defendant’s underwriting guidelines are public record since it is required to file ### them with the Florida Department of Financial Services, Office of Insurance Regulation, pursuant to Rule 690 170. 013(l)(b), “Underwriting guidelines for. .. homeowners' insurance, for both new and renewal business shall be filed pursuant to this rule. ” (Emphasis Added). The Florida Department of Financial Services then explains a peril and underwriting as follows: “A peril is something that causes or may cause injury, loss, or destruction, such as a fire, tornado, or hurricane. Underwriting guidelines vary between insurers. However, below are a few of the ### most common things an insurer reviews when determining whether to insure a new property or how much to charge. They also use this same underwriting to determine whether or not to offer a renewal policy. The insurer may consider the age of the home, roof, plumbing, electrical wiring or the heat and air. ” See myfloridacfo. com/Division/Consumers/UnderstandingCoverage. ----- All notices of change in policy terms that defendant provided to plaintiff pursuant to §627. 43141, Florida Statutes, that pertain to: a. Each policy provision identified under defendant’s letter to plaintiff denying coverage in this case. b. Each affirmative defense raised by defendant in response to plaintiffs current pleading. (Collectively referred to as “notice of change”). For each notice of change in policy terms identified above that defendant provided to ### plaintiff pursuant to §627. 43141, Florida Statutes, please produce proof that each notice was actually delivered to plaintiff. **TIME** **PERIOD:** Inception of policy throughof loss. -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] **FORM 1. 997. CIVIL COVER SHEET** The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant to section 25. 075, Florida Statutes. (See instructions for completion. ) **I. ** **CASE STYLE** IN THE CIRCUIT/COUNTY COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Nicholas Roselli Plaintiff Case # Judge vs. Olympus Insurance Company Defendant **II. ** **AMOUNT OF CLAIM** Please indicate the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of the claim is requested for data collection and clerical processing purposes only. The amount of the claim shall not be used for any other purpose. ``` ☐ $8, 000 or less ☐ $8, 001 - $30, 000 ☐ $30, 001- $50, 000 ☐ $50, 001- $75, 000 ☒ $75, 001 - $100, 000 ☐ over $100, 000. 00 ``` **III. ** **TYPE OF CASE** (If the case fits more than one type of case, select the most definitive category. ) If the most descriptive label is a subcategory (is indented under a broader category), place an x on both the main category and subcategory lines. ----- **CIRCUIT CIVIL** ``` ☐ Condominium ☐ Contracts and indebtedness ``` `☐` Eminent domain `☐` Auto negligence ``` ☐ Negligence-other ☐ Business governance ☐ Business torts ☐ Environmental/Toxic tort ☐ Third party indemnification ☐ Construction defect ☐ Mass tort ☐ Negligent security ☐ Nursing home negligence ☐ Premises liability-commercial ☐ Premises liability-residential ☐ Products liability ☐ Real Property/Mortgage foreclosure ☐ Commercial foreclosure ☐ Homestead residential foreclosure ☐ Non-homestead residential foreclosure ☐ Other real property actions ☐Professional malpractice ☐ Malpractice-business ☐ Malpractice-medical ☐ Malpractice-other professional ☒ Other ☐ Antitrust/Trade regulation ☐ Business transactions ☐ Constitutional challenge-statute or ordinance ☐ Constitutional challenge-proposed amendment ☐ Corporate trusts ☐ Discrimination-employment or other ☒ Insurance claims ☐ Intellectual property ☐ Libel/Slander ☐ Shareholder derivative action ☐ Securities litigation ☐ Trade secrets ☐ Trust litigation ``` **COUNTY CIVIL** ☐ Small Claims up to $8, 000 ☐ Civil ``` ☐ Real property/Mortgage foreclosure ``` ----- ☐ Replevins ☐ Evictions ☐ Residential Evictions ☐ Non-residential Evictions ☐ Other civil (non-monetary) **COMPLEX BUSINESS COURT** This action is appropriate for assignment to Complex Business Court as delineated and mand by the Administrative Order. Yes ☐ No ☒ **IV. ** **REMEDIES SOUGHT (check all that apply):** ``` ☒ Monetary; ☐ Nonmonetary declaratory or injunctive relief; ☐ Punitive ``` **V. ** **NUMBER OF CAUSES OF ACTION: [ ]** (Specify) 1 **VI. ** **IS THIS CASE A CLASS ACTION LAWSUIT? ** ``` ☐ yes ☒ no ``` **VII. ** **HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED? ** ``` ☒ no ☐ yes If “yes, ” list all related cases by name, case number, and court. ``` **VIII. ** **IS JURY TRIAL DEMANDED IN COMPLAINT? ** ``` ☒ yes ☐ no ``` **IX. ** **DOES THIS CASE INVOLVE ALLEGATIONS OF SEXUAL ABUSE? ** ``` ☐ yes ☒ no ``` I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2. 425. : s/ Erin R. Dix Fla. Bar # 108062 Attorney or party (Bar # if attorney) Erin R. Dix 06/26/2024 (type or print name)-----

[Assistant] **IN THE CIRCUIT COURT OF THE** **FIFTEENTH JUDICIAL CIRCUIT IN AND FOR** **PALM BEACH COUNTY, FLORIDA** **CASE NUMBER:** **NICHOLAS ROSELLI, ** **Plaintiff, ** **v. ** **OLYMPUS INSURANCE COMPANY, ** **Defendant. ** **___________________________________/** **PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT** Plaintiff, Nicholas Roselli, by and through the undersigned counsel, under Florida Rules of Civil Procedure 1. 350 and 1. 280(a), submits to Defendant, Olympus Insurance Company, the following Request to Produce and requests that Defendant furnish copies to Plaintiff at 350 North Lake Destiny Road, Maitland, Florida, 32751, or via E-Mail, within forty-five (45) days of service of the Complaint herein. **DEFINITIONS AND INSTRUCTIONS** For purposes of this Request to Produce, the following terms and definitions are provided: Plaintiff: The term “Plaintiff” as used herein shall mean Nicholas Roselli and their representatives as defined below. Defendant: The term “Defendant” shall mean Olympus Insurance Company, whether by that name or any other, and its representatives as defined below. Representatives: The term "representatives" shall mean any and all present or former partners, agents, employees, servants, officers, directors, attorneys, consultants, sureties, indemnificators, insurers, independent contractors and other persons acting or purporting to act on behalf of the entity referred to. You and Your: The terms "you" and "your" shall refer to Defendant (defined above) and any other person or entity acting or purporting to act on its behalf. ----- Document: The term "document" shall mean any written, printed, typed or other graphic or photographic matter (including without limitation, photographs, charts, graphs, microfiche, microfilm, videotapes, recordings and motion pictures and data stored on a computer disc or computer hard drive) and shall include the originals, identical copies and all non-identical copies, whether different from the original by reason of any notation made on each copy or otherwise and shall include, without limiting the generality of the foregoing, all letters, telegrams, teletypes, correspondence, contracts, agreements, notes, mechanical and electronic sound recordings and transcripts thereof (including, without limitation, tapes, cassettes and discs), computer records, computer printouts, other printed matter produced through computers, calendar and diary entries, memoranda, notes and records of all telephone or personal conversations, meetings and other communication, inter-office and intra-office communications, statements, manuals, summaries and compilations, minutes of meetings, charges, maps, reports, analysis, studies, graphs, prospectus, returns, statistics, pamphlets, books, offers, bulletins, order papers, articles, catalogs, records, tables, books of account, ledgers, vouchers, canceled checks, invoices, bills, receipts, tickets, worksheets and all drafts, alterations, modifications and changes to any of the foregoing, as well as all digitally stored and generated documents and notes. Communication: The term "communication" as used herein shall mean any contact between or among the parties indicated, including but not limited to, all documents (defined above), telephone or personal conversations, meetings, e-mails or electronic contacts, conferences and discussions. Once identified, a communication may be subsequently identified by use of a common description. ----- Identify: The term “identify” when used with reference to a person shall mean to: a. State the full name of the person; b. State the full name of the last known employer of the person; c. State the last known occupation or title of the person with such employer; d. State the last known business telephone number of the person; e. State the last known home address of the person; and f. State the last known home telephone number of the person. Once identified, a person may be subsequently identified by uniform use of a standard name. Identify: The term “identify” when used with reference to a document shall mean to: a. State a complete description of the document; b. Identify the person who prepared the document; c. State theon which the document was prepared; d. State the location at which the document was prepared; and e. Identify the person who presently has care, custody and control of the document. Once identified, a document may be subsequently identified by uniform use of a standard description. Person: The term “person” as used herein shall mean a natural person other than an entity and shall be construed to include groups of natural persons. **INSTRUCTIONS** Should Defendant object to a Request to Produce or not respond pursuant to a claim of privilege, Defendant is required to: a. State the basis of the claim of privilege; b. Identify the subject matter of the information to which a claim of privilege is made; c. Identify all persons or entities who have had access to or claimed to be privileged or were present when the privileged information was discussed, and d. Identify all persons or entities to which the privileged information has been disclosed. ----- **PLAINTIFF’S FIRST REQUEST TO PRODUCE TO DEFENDANT** A true and correct copy of all DEC pages and the full and complete insurance policy(s) referenced in Plaintiff’s Complaint and a sworn statement of a corporate officer of Defendant attesting to the coverage and authenticity of the policy. **RESPONSE:** A copy of any and all other DEC pages and insurance policy(s) that may provide coverage to either Plaintiff for the damages claimed in Plaintiff’s Complaint. **RESPONSE:** A copy of each and every document (defined above) that you reasonably anticipate may be introduced into evidence at the trial of this matter. **RESPONSE:** A copy of any and all documents that you allege may support any affirmative defense which you have raised in this matter. **RESPONSE:** A copy of any and all documents that you allege may support any Motion to Dismiss which you have filed in this matter. **RESPONSE:** ----- Copies of any and all statements, and any transcripts from any person who has knowledge of the facts in this matter including any expert witness or Defendant (defined above) herein. **RESPONSE:** Copies of any and all recorded statement(s) and telephone conversations, as well as any transcripts for the same that have been reduced to writing and/or transcribed, including but not limited to Examinations Under Oath, which were taken of or provided by any insured or their representatives (defined above) that are in your possession or control. **RESPONSE:** Copies of any and all recorded statement(s) and telephone conversations, as well as any transcripts for the same that have been reduced to writing and/or transcribed, which were taken of or provided by any witness that are in your possession or control. **RESPONSE:** Each and every document, report, chart, graph, object, summary, compilation of data or other thing relied upon by any of your experts, in whole or in part, in the formulation of any opinions and conclusion in this case. **RESPONSE:** Copies of any photographs of Plaintiff’s Property located 4015 Sabal Lakes Rd, Delray Beach, Florida, 33445-1218 which are in your possession or control. **RESPONSE:** Copies of any photographs that reflect any damage at Plaintiff’s Property located at 4015 Sabal Lakes Rd, Delray Beach, Florida, 33445-1218 that are in your possession or control. **RESPONSE:** ----- Copies of any photographs of any work performed at Plaintiff’s Property located at 4015 Sabal Lakes Rd, Delray Beach, Florida, 33445-1218 that are in your possession or control. **RESPONSE:** Copies of any and all estimates and damage appraisals and other documents (defined above) referencing damage appraisals regarding Plaintiff’s Property located at 4015 Sabal Lakes Rd, Delray Beach, Florida, 33445-1218 that are in your possession or control. **RESPONSE:** Copies of any and all documents (defined above) upon which you based any denials of coverage for the loss described in Plaintiff’s Complaint. **RESPONSE:** Copies of any and all documents (defined above) upon which you based any denials of all or part of the amount of loss claimed by Plaintiff. **RESPONSE:** If there are any denials of insurance coverage by Defendant, then copies are requested of any and all applications for insurance, insurance forms, data sheets, correspondence, notices, facsimile, e-mails and other documents (defined above) that reference in any way any the insurance policy at issue in this matter. **RESPONSE:** Copies of any and all correspondence, facsimile, notices, e-mails and other documents (defined above) that reference in any way any notices that you provided to Plaintiff regarding cancellation of the insurance policy at issue in this matter. **RESPONSE:** ----- Copies of all PORS, Proof of Mailing and other documents (defined above) that reflect in any way mailings made by you to Plaintiff regarding cancellation of the policy of insurance at issue in this matter. **RESPONSE:** All reports and current curriculum vitae from any expert(s) retained by you for any reason regarding Plaintiff’s claim. **RESPONSE:** Any and all e-mails, letters, facsimile, and other correspondence regarding any claims made by Plaintiff for property insurance benefits as a result of the Wind and/or Hail event of November 16, 2023, including but not limited to, correspondence with experts, correspondence with experts, independent adjusters, appraisers, inspectors, and any other third party. **RESPONSE:** All documents reflecting any payment made to any person (defined above) or entity for any reason as a result of the Wind and/or Hail event described in Plaintiff’s Complaint. **RESPONSE:** All books, treaties or authority used by Defendant’s adjuster in determining what amount to pay or deny regarding the claim at issue. **RESPONSE:** All writings, memoranda, notes or other materials reflecting examination of Plaintiff’s Property by Defendant or its agents. **RESPONSE:** All proofs of loss received by Defendant from Plaintiff. **RESPONSE:** ----- All estimates received by Defendant from any source for repairs to Plaintiff’s Property. **RESPONSE:** Defendant’s latest claims manual or statement of policies and procedures on the processing or handling of property damage claims. **RESPONSE:** Any training manuals, guides and documents that Defendant has provided to its adjusters regarding adjusting Wind and/or Hail damage claims from the past three years to the present. **RESPONSE:** Copies of any peer reviews, estimates, or comparative estimates generated by anyone on Defendant’s behalf regarding the amount of loss at issue. **RESPONSE:** All documents showing the total amount paid during the past three years to any third parties providing services, analyses, or opinions regarding Plaintiff’s claim. **RESPONSE:** A copy of the contract/agreement/document (if any) that Defendant has with anyone, including but not limited to contractors, engineers, adjusters, or experts, who may provide testimony at the trial of this matter. **RESPONSE:** ----- A copy of each resume, curriculum vitae, and other document listing the qualifications of each and every expert and/or consultant hired by you or your representatives (defined above) who may testify at trial. **RESPONSE:** All documents that relate to the drafting, meaning, and interpretation of any language, terms, or provisions, used in the policy at issue. **RESPONSE:** Pursuant to Fla. R. Civ. P. 1. 310(b)(6), please produce three (3) alternatives for deposition to occur no earlier than thirty (30) days but no later than one hundred-twenty (120) days from service for the deposition of the corporate representative(s) with the most knowledge of the claim asserted by the Plaintiff’s Complaint as well as the individual(s) primarily responsible for the decision to deny indemnifying Plaintiff’s amount of loss. A designation of the information upon which such examination will proceed will be provided under separate cover. **RESPONSE:** Copies of any and all notices sent by you or your representatives (defined above) to any insured to participate in a mediation program under Fla. Stat. § 627. 7015 and copies of any and all PORS, Proof of Mailing and other documents (defined above) which reflect in any way mailings made by you to any insured regarding the same. **RESPONSE:** **CERTIFICATE OF SERVICE** **I HEREBY CERTIFY that a true and correct copy of this document will be served on** Defendant along with the Summons and the Complaint in this action. **: June 26, 2024** _/s/Erin Dix_ **COHEN LAW GROUP** Erin Dix, Esq. _FOR THE FIRM_ Florida Bar Number: 108062 350 North Lake Destiny Road Maitland, Florida 32751 Phone: (407) 478-4878 Fax: (407) 478-0204 ----- Primary: edix@itsaboutjustice. law Secondary: lyndon@itsaboutjustice. law -----


[System]
You are a lawyer with 10 years of experience. Based on the complaint, create up to 20 questions for the defendant.

The questions should follow the format and style of this example response to a car accident complaint:
1. All photographs, diagrams, or other printed or written material describing or attempting to describe the scene of the accident alleged in the Complaint, or any person described in the Complaint.
2. Documentation substantiating health insurance coverage available to Plaintiff on the date of the accident sued upon.
3. Any cellular phones or other mobile communication system telephone bills, invoices, statements, itemized accounts, or other data compilation for the equipment owned or used by Plaintiffs for the months relevant to the incident.
4. Any and all films, diagnostic tests, MRIs, X-rays, storage devices, digital images, intra-operative photographs, and/or data compilations from which information can be obtained.
5. If a claim is made for lost wages and/or loss of earning capacity in the future, provide specific documentation like Federal Income Tax Returns and W-2 Forms.

Be specific, detailed and relevant to the complaint's allegations. Avoid generic requests for "all documents" or "all evidence". Each question should request specific items, time periods, or information directly related to the complaint's claims.

[User] **IN** **THE** **COUNTY** **COURT, ** **IN** **AND** **FOR** **PALM** **BEACH** **COUNTY, ** **FLORIDA** **CASE** **NO. ** **BEATRICE** **SMITH** **AND** **JOHN** **A. ** **SMITH, ** **Plaintiffs, ** **vs. ** **UNIVERSAL** **PROPERTY** **AND** **CASUALTY** **INSURANCE** **COMPANY, ** **Defendant. ** ### __________________________________ I ## COMPLAINT **COMES** **NOW** the Plaintiffs, **BEATRICE** **SMITH** **AND** **JOHN** **A. ** **SMITH, ** by and through the undersigned attorney and sues the Defendant, **UNIVERSAL** **PROPERTY** **AND** **CASUALTY** **INSURANCE** **COMPANY, ** a corporation authorized and doing business in the state of Florida, and alleges as follows: This is an action for damages which do not exceed Fifteen Thousand and 00/100 ($15, 000. 00) Dollars, exclusive of attorneys’ fees, costs and interest. On or about September 10, 2017, Plaintiffs’ dwelling, located at 5600 N. Flagler Drive, Apt. 1501, W. Palm Beach, Florida 33407, sustained damage due to Hurricane Irma during the policy period. A policy of homeowners’ insurance with policy number 592-471-139, including the coverages to protect Plaintiffs against the above losses, was issued by Defendant and was in full force and effect as to Plaintiffs when Plaintiffs’ dwelling was damaged. A copy of the policy is in the exclusive control of Defendant, and will be produced during discovery. ----- Plaintiffs notified Defendant of the damages, and Defendant assigned claim number FL17-0148644-E317. Plaintiffs have complied with all conditions precedent to entitle Plaintiffs to recover under the policy. Defendant refused to pay to replace and/or repair the full amount of Plaintiffs’ damages to her dwelling. Defendant’s refusal to pay to replace and/or repair the full amount of damages to Plaintiffs’ dwelling is a breach of contract. Because of Defendant's refusal to pay to replace and/or repair the full ### amount of damages to Plaintiffs’ dwelling, it has become necessary that Plaintiffs retain the services of the undersigned attorney. Plaintiffs are obligated to pay a reasonable fee for the attorneys’ services in bringing this action, plus necessary costs. **WHEREFORE, ** Plaintiffs demand judgment against Defendant for Plaintiffs’ losses with interest on any overdue payments, attorneys’ fees and costs pursuant to _Florida_ _Statutes_ §§ 627. 428, 57. 041, and 92. 231, and demands a trial by jury. **d:** May 25, 2018 ### MORGAN & MORGAN, P. A. _Attorneysfor_ _Plaintiffs_ 703 Waterford Way, Suite 1050 Miami, FL 33126 Phone: (305)929-1907 Fax: (305)929-1925 Email: [ft)ve@forthepeople. com](mailto:ve@forthepeople. com) (Primary) Email: [blargaespada@forthepeople. com](mailto:blargaespada@forthepeople. com) (Secondary) By: /s/ Frederick Pye III, Esq. ### FREDERICK PYE, ESQ. Florida Bar No. : 124221 -----

[Assistant] **IN** **THE** **COUNTY** **COURT, ** **IN** **AND** **FOR** **PALM** **BEACH** **COUNTY, ** **FLORIDA** **CASE** **NO. ** **BEATRICE** **SMITH** **AND** **JOHN** **A. ** **SMITH, ** **Plaintiffs, ** **vs. ** **UNIVERSAL** **PROPERTY** **AND** **CASUALTY** **INSURANCE** **COMPANY, ** **Defendant. ** _______________________________________I_ **REQUEST** **TO** **PRODUCE** Plaintiffs, pursuant to _Florida_ _Rule_ _of_ _Civil_ _Procedure_ 1. 350, requests the Defendant, **UNIVERSAL** **PROPERTY** **AND** **CASUALTY** **INSURANCE** **COMPANY, ** a corporation authorized and doing business in the state of Florida, to furnish copies of the following documents to the offices of the undersigned attorney within forty-five (45) days from theof service hereof: All insurance policies that would inure to the benefit of the Plaintiffs herein, together with any declaration of coverage page and sworn statement of a corporate officer of Defendant attesting to the coverage and authenticity of the policy. All non-privileged portions of the claim file with regard to this claim. For any items withheld, please set forth the nature of the privilege or protection allowing you to withhold the document, theof the document, the drafter, recipient, and a general description of the document. Copies of any and all forms, correspondence, or reports received by you or any of your agents on your behalf concerning the Plaintiffs’ losses from anyone. Any and all statements taken by the Defendant of any witnesses with ----- regard to any fact relevant to any fact in this case, such as were taken prior to the filing ### of suit in this matter. Any and all photographs in the Defendant’s possession related to Plaintiffs’ claim in their native digital format. All audiotapes and transcripts of any statement given by Plaintiffs. Copies of all IRS Forms 1099 from Defendant to any consultants who examined Plaintiffs’ home (whether engineers, contractors or roofers) for past 5 years ### for the evaluation of claims submitted to Defendant by Defendant’s insureds. All reports in your possession that support Defendant’s contention that any ### of Plaintiffs’ charges are not covered or proper. The complete underwriting file with regard to Defendant’s issuance of insurance on the subject risk, and all renewals. **IT** **IS** **HEREBY** requested that the aforesaid production be made within forty-five (45) days from theof service at the office of Morgan & Morgan, P. A. , 703 Waterford Way, Suite 1050, Miami, Florida 33126. Inspection will be made by visual observation, examination and/or copying. ----- **CERTIFICATE** **OF** **SERVICE** **I** **HEREBY** **CERTIFY** that on May 25, 2018, a true and correct copy of the foregoing was served upon the Defendant’s Registered Agent: State of Florida, Chief Financial Officer, 200 E. Gaines St. , Tallahassee, FL 32399. **d:** May 25, 2018 ### MORGAN & MORGAN, P. A. _Attorneysfor_ _Plaintiffs_ 703 Waterford Way, Suite 1050 Miami, FL 33126 Phone: (305)929-1907 Fax: (305)929-1925 Email: [fpye@forthepeople. com](mailto:fpye@forthepeople. com) (Primary) Email: [blargaespada@forthepeople. com](mailto:blargaespada@forthepeople. com) (Secondary) By: /s/ Frederick Pye III, Esq. ### FREDERICK PYE, ESQ. Florida Bar No. : 124221 -----