Filing # 50523986 E-Filed 12/27/2016 04:14:55 PM
`
`14568
`
`IN THE COUNTY COURT OF THE 1 STH
`JUDICIAL CIRCUIT, IN AND FOR
`PALM BEACH COUNTY, FLORIDA
`
`AIMEE BERNSTEIN
`
`CASENO.: 2014CA013711
`
`Plaintiff,
`
`vs.
`
`HOMEOWNERS CHOICE PROPERTY &
`CASUALTY INSURANCE COMPANY,
`
`Defendant.
`_____________________________ I
`
`NOT A CERTIFIED COPY
`
`DEFENDANT’S EXHIBIT LIST
`
`COMES NOW, Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY
`
`INSURANCE COMPANY, by and through undersigned counsel, pursuant to the Order Setting
`
`Jury Trial and Directing Pretrial and Mediations Procedures dated November 28, 2016, hereby
`
`files its Exhibit List and further states:
`
`1.
`
`Certified policy of insurance number HCPC-HO3-422083-1 issued to Aimee
`
`Bernstein by Homeowners Choice Property & Casualty Insurance Company, Inc. effective April
`
`29, 2014 through April 29, 2015.
`
`2.
`
`Letter from Homeowners Choice Property & Casualty Insurance Company, Inc.
`
`to Aimee Bernstein dated August 27, 2014.
`
`3.
`
`Letter from Homeowners Choice Property & Casualty Insurance Company, Inc.
`
`to Aimee Bernstein dated November 7, 2014.
`
`4.
`
`Twenty First Century Engineering report.
`
`FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/27/2016 04:14:55 PM
`
`
`
`14568
`
`IN THE COUNTY COURT OF THE 1 STH
`JUDICIAL CIRCUIT, IN AND FOR
`PALM BEACH COUNTY, FLORIDA
`
`AIMEE BERNSTEIN
`
`CASENO.: 2014CA013711
`
`Plaintiff,
`
`vs.
`
`HOMEOWNERS CHOICE PROPERTY &
`CASUALTY INSURANCE COMPANY,
`
`Defendant.
`_____________________________ I
`
`NOT A CERTIFIED COPY
`
`DEFENDANT’S EXHIBIT LIST
`
`COMES NOW, Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY
`
`INSURANCE COMPANY, by and through undersigned counsel, pursuant to the Order Setting
`
`Jury Trial and Directing Pretrial and Mediations Procedures dated November 28, 2016, hereby
`
`files its Exhibit List and further states:
`
`1.
`
`Certified policy of insurance number HCPC-HO3-422083-1 issued to Aimee
`
`Bernstein by Homeowners Choice Property & Casualty Insurance Company, Inc. effective April
`
`29, 2014 through April 29, 2015.
`
`2.
`
`Letter from Homeowners Choice Property & Casualty Insurance Company, Inc.
`
`to Aimee Bernstein dated August 27, 2014.
`
`3.
`
`Letter from Homeowners Choice Property & Casualty Insurance Company, Inc.
`
`to Aimee Bernstein dated November 7, 2014.
`
`4.
`
`Twenty First Century Engineering report.
`
`FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/27/2016 04:14:55 PM
`
`
`
`5.
`
`6.
`
`7.
`
`Photographs taken by Lee Vorcheimer on August 18, 2014.
`
`Photographs taken by Lee Vorcheimer on October 6, 2014.
`
`Photographs taken during the inspection conducted by Twenty First Century
`
`Engineering Corp, on October 12, 2015.
`
`NOT A CERTIFIED COPY
`
`8.
`
`Two (2) sets of photographs taken by Engleson & Associates, Inc. taken on an
`
`unknown date.
`
`9.
`
`Property diagram prepared by John M. Carroll of Twenty First Century
`
`Engineering Corp.
`
`10.
`
`Plumbing videos taken on or around August 1, 2014 by Lindstrom Air
`
`Conditioning & Plumbing.
`
`11.
`
`Documents produced by Engleson & Associates, Inc. pursuant to the non-party
`
`subpoena served upon it:
`
`a.
`
`b.
`
`c.
`
`d.
`
`Homeowners Choice Property & Casualty Insurance Company, Inc. Quote for
`Aimee Bernstein dated April 23, 2014.
`
`Letter from Homeowners Choice Property & Casualty Insurance Company, Inc.
`to Aimee Bernstein dated August 9, 2014.
`
`Email from Plaintiff to Homeowners Choice Property & Casualty Insurance
`Company, Inc. dated August 18, 2014.
`
`Letter from Homeowners Choice Property & Casualty Insurance Company, Inc.
`to Aimee Bernstein dated August 27, 2014.
`
`e. '
`
`f.
`
`Letter from Homeowners Choice Property & Casualty Insurance Company, Inc.
`to Aimee Bernstein dated August 27,2014, with handwritten notes/annotations.
`
`Email from Plaintiff to Tom Engleson on September 23, 2014.
`
`
`
`g.
`
`h.
`
`Email from Plaintiff to Tom Engleson of Engleson & Associates, Inc. dated
`September 23,2014.
`
`Fax/letter from Engleson & Associates, Inc. to Homeowners Choice Property &
`Casualty Insurance Company, Inc. dated September 26, 2014 with fax
`confirmation page.
`
`i.
`
`j.
`
`k.
`
`l.
`
`Email from Raymond Faldetta to Tom Engleson on September 29,2014.
`
`Total Care Insurance Repair, Inc. report dated September 29, 2014.
`
`Email from Ray Faldetta of Total Care Insurance Repair to Tom Engleson of
`Engleson & Associates, Inc. dated September 29, 2014.
`
`Email from Tom Engleson of Engleson & Associates, Inc. dated September 29,
`2014.
`
`,m. Email from Tom Engleson to Homeowners Choice Property & Casualty Insurance
`Company, Inc. dated September 30, 2014.
`
`NOT A CERTIFIED COPY
`
`n.
`
`o.
`
`p.
`
`q.
`
`r.
`
`s.
`
`t.
`
`Email-from Tom Engleson to Aimee Bernstein on September 30, 2014.
`
`Email from Aimee Bernstein to Tom Engleson on September 30, 2014.
`
`Email from Tom Engleson of Engleson & Associates, Inc. to Homeowners
`Choice Property & Casualty Insurance Company, Inc. dated September 30,2014.
`
`Email exchange between Tom Engleson of Engleson & Associates, Inc. and
`Plaintiff dated September 30, 2014.
`
`Text messages between Trenchless Pipe Lining to Tom Engleson of Engleson &
`Associates, Inc. on October 21, 2014.
`
`Email from Tom Engleson to Ron Kall of ALC Building Consulting on October
`25,2014.
`
`Email from Tom Engleson of Engleson & Associates, Inc. to Ron Kall dated
`October 25, 2014.
`
`u.
`
`Email from Tom Engleson to Plaintiff on October 26, 2014.
`
`v.
`
`w.
`
`Email from Plaintiff to Tom Engleson on October 26,2014.
`
`Email exchange between Tom Engleson of Engleson & Associates, Inc. and
`Plaintiff dated October 26,2014.
`
`
`
`x.
`
`y.
`
`z.
`
`Emails exchanged between Tom Engleson and Plaintiff on November 3, 2014 and
`November 4, 2014.
`
`Letter from Homeowners Choice Property & Casualty Insurance Company, Inc.
`to Plaintiff dated November 7, 2014.
`
`Handwritten notes.
`
`12.
`
`Documents produced by Total Care Insurance Repair, Inc. pursuant to the non-
`
`party subpoena served upon it:
`
`NOT A CERTIFIED COPY
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`Lindstrom Air Conditioning & Plumbing proposal to Aimee Bernstein dated
`August 8,2014.
`
`Email from Raymond Faldetta to Tom Engleson dated September 29,2014.
`
`Total Care Insurance Repair, Inc. report dated September 29,2014.
`
`Email from Raymond Faldetta to Groelle & Salmon, P.A. dated January 20,2015.
`
`Handwritten notes.
`
`13.
`
`Documents produced by Lindstrom Air Conditioning & Plumbing proposal to
`
`Aimee Bernstein dated August 8, 2014:
`
`a.
`
`b.
`
`c.
`
`d.
`
`Lindstrom Air Conditioning & Plumbing work order/invoice #P34220 in the
`amount of $350.00 to Aimee Bernstein dated July 24,2014.
`
`Plumbing video taken by Lindstrom Air Conditioning & Plumbing at the subject
`insured property.
`
`Lindstrom Air Conditioning & Plumbing work order #P34916 to Aimee Bernstein
`dated August 1,2014.
`
`Lindstrom Air Conditioning & Plumbing work order &P22144 to Aimee Bernstein
`dated August 5, 2014.
`
`e.
`
`Lindstrom Air Conditioning & Plumbing proposal to Aimee Bemsten dated
`AugustS, 2014.
`
`14.
`
`Documents produced by Roto-Rooter Plumbing & Drain Service pursuant to the non
`
`party subpoena served upon it:
`
`
`
`a.
`
`b.
`
`c.
`
`Roto-Rooter Services Company Terms and Conditions.
`
`Roto-Rooter Plumbing & Drain Service invoice #17778897 to Aimee Bernstein
`dated May 25, 2014 in the amount of $362.48.
`
`Roto-Rooter Plumbing & Drain Service invoice #17778897 to Aimee Bernstein
`dated May 25, 2014 in the amount of $362.48, with handwritten annotations.
`
`d.
`
`Roto-Rooter Plumbing & Drain Service Ticket Inquiry #17848220 dated July 22,
`2014.
`
`15.
`
`Audio taped recorded statement of Aimee Bernstein taken by Lee Vorcheimer on
`
`August 18, 2014.
`
`16.
`
`17.
`
`Exhibits to the deposition of Aimee Bernstein taken May 6, 2015.
`
`Exhibits to the deposition of Sherry Oldham, Corporate Representative of
`
`Homeowners Choice Property & Casualty Insurance Company, Inc. taken August 20,2015.
`
`18.
`
`Exhibits to the deposition of Lee Vorcheimer taken November 2,2015.
`
`19. All records produced by Plaintiff in response to Request to Produce.
`
`NOT A CERTIFIED COPY
`
`20.
`
`21.
`
`22.
`
`23.
`
`24.
`
`25.
`
`26.
`
`27.
`
`All exhibits listed on Plaintiffs exhibit list, with objections thereto reserved.
`
`All exhibits to depositions of the parties in this action.
`
`All exhibits to depositions of any witnesses in this action.
`
`All of Plaintiff s responses to Interrogatories.
`
`All records produced pursuant to non-party subpoenas.
`
`Plaintiffs response to any and all Request for Admissions in this case.
`
`All necessary impeachment and rebuttal exhibits.
`
`All photographs taken pursuant to this lawsuit.
`
`
`
`28.
`
`All depositions of the parties and witnesses in this action.
`
`Defendant reserves its right to amend its Exhibit List throughout this proceeding.
`
`CERTIFICATE OF SERVICE
`WE HEREBY CERTIFY that on this jj/fef December, 2016 we electronically filed the
`
`foregoing document with the Clerk of the Court using the Florida Courts E-Filing Portal. We
`
`also certify that the foregoing document is being served this day on Ryan Sherman, Esq.
`
`EserviceSLPA@gmail.com respectively by the Florida Courts E-Filing Portal, or in some other
`
`authorized manner for those counsel or parties who are not authorized to receive electronic
`
`NOT A CERTIFIED COPY
`
`Notices of Electronic Filing.
`
`GROELLE & SALMON, P.A.
`Attorneys for Defendant
`11301 Okeechobee Blvd., Second Floor
`West Palm Beach, FL 33411
`(561) 963-5500
`(561) 963-2265 Facsimile
`
`ROBERT C. GROELLE, ESQUIRE
`Fla. Bar No.: 829323
`PATRICK J. CARLETON, ESQUIRE
`Fla. Bar No.: 94867
`
`
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