Insurance Carrier to Insured Interrogatories – Florida Car accident

1. State your name, residence and business addresses, date of birth, social security number and the policy or policy numbers of insurance which you claim which arose out of a West Palm Beach Florida Accident are at issue in this matter.
2. Provide a detailed factual description of the underlying circumstances that you contend.
a. Provide defense and coverage under the policies at issue.
b. Provide any indication of negligent handling, contractual breaches, bad faith or other wrongful conduct on the part of the defendant carrier.
c. Provide the date when you first received notice of claim which arose out of a West Palm Beach Florida Accident or lawsuit brought against you that you contend provides defense and/or coverage obligations by the defendant carrier.
d. Provide the date when you first gave notice to the defendant carrier of the claim which arose out of a West Palm Beach Florida Accident or lawsuit identified in the preceding interrogatory.
3. Describe in detail each and every communication you have had with the defendant carrier or any of its agents or employees with respect to the claim which arose out of a West Palm Beach Florida Accident or lawsuit identified in Interrogatory 2.
4. Identify by category and amount each element and item of damage you claim which arose out of a West Palm Beach Florida Accident to have sustained as a result of any alleged negligence, breach of duty or bad faith on the part of the carrier.
5. Identify all documents by nature (e.g., letter, memorandum, e-mail, etc.) including the date, author, addressees and recipients upon which you relied or referred in answering or attempting to answer of the above interrogatories, and identify the interrogatories to which each such document relates.
6. Identify the person who currently has possession of each document identified in your previous answer.
7. Identify each person who participated in the preparation of any of your answers to these interrogatories, or who provided information or assistance in connection with the preparation of any answer, or whom you consulted or from whom you sought information or assistance in connection with the preparation of any answer, and identify the interrogatories to which each person applies.
8. Provide the name, address, area of expertise and qualifications of each expert retained by you who is expected to testify at trial, and with respect to each, provide:
a. the subject matter on which he is expected to testify
b. the substance of every opinion to which he is expected to testify
c. the facts upon which he bases each opinion
d. a list of all documents, treatises and articles consulted by each expert in reaching his opinion
e. the basis and amount of each expert's compensation
f. the relationship, if any, of each expert to the insurance industry

DEFENDANT, CARRIER
By its attorneys,

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