Party Discovery: LEYVA, LILLIANA vs GREAT LAKES INSURANCE SE

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                                Filing # 198361368 E-Filed 05/15/2024 11:41:53 AM                                                                                        DIN: 5




         LILLIANA LEYVA,                                                         IN THE CIRCUIT COURT OF THE 6th
                   Plaintiff,                                                    JUDICIAL  CIRCUIT  IN  AND FOR
                                                                                 PASCO, COUNTY , FLORIDA.
         Vv.


         GREAT LAKES INSURANCE SE,                                               CASE NO.:
              Defendant.
                                                          /




                         PLAINTIFE’S REQUEST FOR PRODUCTION TO DEFENDANT
                   The   Plaintiff, LILLIANA                   LEYVA,     (the “Plaintiff’), pursuant       to Rule   1.350, Florida

         Rules of Civil Procedure, propound this Request for Production to Defendant, GREAT LAKES

         INSURANCE              SE,     to produce        the items and materials hereinafter set forth on or before               the

         applicable time prescribed by said rule for inspection and/or copying at the office of the

         undersigned attorney, the following items and/or documents:

          1        Any and all insurance policies ever issued by the Defendant to the Plaintiff, including all

         declaration pages, applications, addenda and riders.

         2.        Any and all correspondence between you and Plaintiff or anyone acting on the Plaintiff

         behalf.

         3         Any and all correspondence, forms, reports or other documents between you and any third

         party regarding the Plaintiff or Plaintiffs claim.

         4         Any and all surveillance reports, claims history reports or other investigative reports

         prepared by you or on your behalf with regard to the Plaintiff or Plaintiffs claim.

         5         Any    and         all written    or       recorded   statements   of the   Plaintiff,   his/her   agents,   and/or

         representatives.




Electronically Filed Pasco Case # 2024CA001309CAAXWS 05/15/2024 11:41:53 AM
6        Any and all statements taken by the Defendant or any witness with regards to any fact

relevant to any fact in this case.

7        Any and all police reports relating to the Plaintiff's claim which are the subject of this

litigation.

8        Any and all photographs and/or video of the Plaintiff's property and/or its contents.

9        Any and all proof of loss forms, statements, notices of claim and/or any other document

submitted by the Plaintiff pertaining to his/her claims that are the subject of this litigation.

10.      Any and all appraisals, estimates, or other documents pertaining to the value of Plaintiffs

claim.

11. The underwriting file for the subject property.

12. The entire claim file for the subject loss.

13. The claim notes for the subject loss up to the date that the Defendant anticipated litigation.

                                     CERTIFICATE
                                            OF SERVICE
         Thereby certify that a copy of the foregoing was served upon the Defendant in this action

along with the Complaint.


                                                  By      ourdes Bloomf
                                                                    201,
                                                  Lourdes Bloomfield, Esq.
                                                  Florida Bar No. 125154
                                                  BLOOMFIELD|ROS PLLC
                                                  Counsel for Plaintiff
                                                  3399 NW 72 Ave, Suite 208B
                                                  Miami, FL 33122
                                                  E-mail: roxana@bloomfieldros.con:
                                                  Secondary E-mail: lourdes@bloomfieldros.com
                                                  Office: (786) 204-3330
                                                  Facsimile: (786) 219-5319