`
`IN THE COUNTY COURT OF THE NINTH
`JUDICIAL CIRCUIT IN AND FOR ORANGE
`COUNTY, FLORIDA
`
`CASE NO.: 2023-SC-009971-O
`
`PRESTIGE AUTO & TRUCK GLASS, LLC, a/
`a/o BRUCE BYRNE,
`
`Plaintiff,
`
`
`
`v.
`
`ARTISAN AND TRUCKERS CASUALTY
`COMPANY, PROGRESSIVE AMERICAN
`INSURANCE COMPANY, PROGRESSIVE
`CASUALTY INSURANCE COMPANY,
`PROGRESSIVE DIRECT INSURANCE
`COMPANY, PROGRESSIVE EXPRESS
`I N S U R A N C E C O M P A N Y ,
`a n d
`PROGRESSIVE SELECT INSURANCE
`COMPANY,
`
`Defendants.
`
`___________________________________/
`
`PLAINTIFF’S REQUEST FOR DEPOSITIONS
`
`Plaintiff, PRESTIGE AUTO & TRUCK GLASS, LLC, a/a/o BRUCE BYRNE, pursuant
`
`to Florida Rule of Civil Procedure 1.310(b)(6), requests the Defendant issuing the applicable
`
`insurance policy contract provide available deposition dates for the following individuals:
`
`1. The licensed claims adjuster employed by Defendant assigned to investigate, adjust,
`pay, and negotiate the subject windshield repair/replacement claim prior to the filing of this
`lawsuit.
`
`
`
`AND
`
`2. Defendant’s corporate representative(s) with the most knowledge of the following:
`
` (a) Defendant’s relationship with Safelite Solutions, LLC at the time of the subject date
`
` 1
`
`
`
`of loss,
`
`(b) Defendant’s legal position, statements, and actions forming the basis for Defendant’s
`defense of this action on the basis of appraisal,
`
`(c) Safelite’s actions and/or inactions as directed and/or authorized by Defendant relative
`to the invocation of the alleged appraisal provision relating to auto glass claims,
`
`(d) Defendant’s actions and/or inactions related to the notice of loss, investigation,
`adjustment, payment, inspection, appraisal, and negotiation of the subject claim,
`
`(e) Safelite Solutions, LLC’s actions and/or inactions relative to the first notice of loss,
`investigation, adjustment, payment, negotiation, and otherwise handling of the subject claim pre-
`litigation and post-litigation,
`
`(f) The authority granted to Safelite Solutions, LLC by Defendant via contract and/or oral
`and/or written directives when receiving first notice of the loss and/or when investigating,
`adjusting, paying, negotiating, and/or otherwise handling auto glass claims, including the subject
`auto glass claim,
`
`(g) Defendant’s contractual agreement with Safelite Solutions, LLC,
`
` Defendant’s financial and contractual relationship with Auto Glass Inspection
`(h)
`Services, LLC and the extent of the involvement of Auto Glass Inspection Services, LLC in the
`subject claim,
`
`The various pricing formulas and/other methodologies utilized by Defendant,
`(i)
`
`Safelite Solutions, LLC, and/or Auto Glass Inspection Services, LLC and applied to make
`payment of auto glass only claims in the State of Florida during calendar years 2017-2019,
`including but not limited to claims serviced by Plaintiff and/or Safelite owned auto glass repair
`shop and/or other auto glass repair shop.
`
`Any and all payments made to Plaintiff by Defendant and/or other entity for auto
`(j)
`
`glass only repair/replacement services performed on behalf of Allstate insureds in calendar years
`2017-2019.
`
`and
`
`(k) Any and all other allegations, arguments, and issues related to Defendant’s defense of
`the subject action and Plaintiff’s Complaint.
`
` 2
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
`
`electronic transmission to: Christopher J. Martin, Esquire, Law Offices of Dolina Lordeus
`
`Lascaze, 4443 Lyons Road, Suite 206, Coconut Creek, Florida 33073-4388;
`
`ORLANDOLEGAL@ALLSTATE.COM; on this 30th day of June 2023.
`
`
`
`
`
`
`
`
`
` /s/ Kristy L. Barrows
`Kristy L. Barrows, Esquire
`Florida Bar No.: 0035329
`KRISTY L. BARROWS, P.A.
`4767 New Broad Street
`Orlando, Florida 32814
`Phone: (407) 897-0474
`Service Email: service.klbpa@gmail.com
`Attorneys for Plaintiff
`
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