AUTO GLASS AMERICA LLC Plaintiff vs. GEICO GENERAL INSURANCE COMPANY Defendant, CONO17003311, 03-14-2018_Notice (Fla. Broward Cty. Ct. Mar. 14, 2018) (2024)

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`(4).
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`The application of the underwriting guidelines and the applicable coverage
`
`to the claim made by the above-referenced claimant if a coverage defense has been
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`asserted as a defense in this case;
`
`(5).
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`Asto any coverage defense or defenses raised by the Defendantin the
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`Answer and Affirmative Defenses, whether presently filed or not, and the factual
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`basis for those defenses, including identifying all documents which the Defendantis
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`relying upon to support those defenses;
`
`(6).
`
`The methodology utilized by the Defendant to determine the “prevailing
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`competitive price” as set forth in the policy of insurance;
`
`(7).
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`The data used by the Defendant to determine the "prevailing competitive
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`price”;
`
`(8).
`
`How the Defendant determines whetherit can secure a price from a
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`competent glass repairfacility.
`
`(9).
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`How the Defendant determines the competencyof a glass repair facility.
`
`(10).
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`How the Defendant determines whetherthe glass facility is conveniently
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`located.
`
`(11).
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`The factor or factors utilized by the Defendant to determine the “a
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`competent glass repair facility” as set forth in the policy of insurance.
`
`(12).
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`The factor or factors utilized by the Defendant to determine the “a
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`conveniently located” glass repair facility as set forth in the policy of insurance.
`
`(13).
`
`The specific information Defendant considered in determining whether or
`
`not the Plaintiff's facility was “conveniently located” to the insured.
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`

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`(14).
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`The specific information Defendant considered in determining whether or
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`not the Plaintiff is a “competent” glass repair facility.
`
`(15).
`
`The factor or factors utilized by Defendant to determine whetherto use
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`new, reconditioned, re-manufactured or used parts or equipmentin this claim.
`
`(16).
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`Howthe Defendant notifies its insureds as to the procedure for requesting
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`Defendant to indemnify a glass repair/replacementfacility that will perform the
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`repairs/replacementat the prevailing competitive price.
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`(17).
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`The facilities that would have been identified by Defendantas those that
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`would perform repairs at the prevailing competitive price and were conveniently
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`located.
`
`(18).
`
`(19).
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`The reasoning why Defendant paid the Plaintiff in the amountthat it did.
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`Anyinformation indicating that Defendant could not have secured the
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`price charged bythe Plaintiff in this claim.
`
`(20).
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`If the reimbursem*ntrate has been contested by the Defendant, the
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`methodology implemented by the Defendant in determining the appropriate
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`reimbursem*nt rate to which the Plaintiff is entitled, including the identity ofall
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`persons who were involved in the determination of what reimbursem*ntrate was to
`
`be permitted for the charges of the Plaintiff in this matter.
`
`(21).
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`The range of prevailing competitive prices charged in the area where the
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`windshield was repaired.
`
`(22).
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`All factors considered by the Defendant regarding any denial, withdrawal,
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`indoor reduction of comprehensive benefits to the Plaintiff for windshield repair
`
`and/or replacement services rendered in this claim.
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`

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`(23).
`
`All factors considered by the Defendantin its determination of the
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`appropriate reimbursem*ntrate, including any pricing garnered from any competent
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`glass repair facility in the location of where the insured's windshield wasrepaired.
`
`(24).
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`If the Defendant has raised a material misrepresentation claim as a defense
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`in this case, any aspect of the application of the Defendant's underwriting guidelines
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`to the alleged misrepresentations, including a review of the application process
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`implemented at the time of the inception of the subject insurance policy.
`
`(25).
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`Whether the manner in which this claim was adjusted by representatives
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`of the Defendant were in compliance with Florida Administrative Code § 69B-
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`220.201, particularly the obligation to act in the best interest of the insured atall
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`times and to act with due diligence in adjusting the claim.
`
`(26).
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`The methodology used to determine the “price we can secure” and the
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`“prevailing competitive price” for the payments GEICO madeto:
`
`Auto Glass America, LLC for windshield replacement services for
`(A).
`date of loss 8/30/2016 and policy number 0161643350101038 (attached
`hereto as Exhibit A is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim). ALL EXHIBITS ATTACHED HEREIN
`SHALL BE FILED UNDER SEPARATE COVER.
`
`Auto Glass America, LLC for windshield replacementservices for
`(B).
`date of loss 4/05/2017 and policy number 0512876440101016 (attached
`hereto as Exhibit B is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(C).
`date of loss 7/20/2017 and policy number 0576397930101013 (attached
`hereto as Exhibit C is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(D).
`date of loss 1/06/2017 and policy number 0352857620101037 (attached
`hereto as Exhibit D is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`

`

`Auto Glass America, LLC for windshield replacementservices for
`(E).
`date of loss 8/16/2016 and policy number 0280348220101038 (attached
`hereto as Exhibit E is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(F).
`date of loss 1/27/2017 and policy number 0460526940101030 (attached
`hereto as Exhibit F is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(G).
`date of loss 1/26/2017 and policy number 0287653260101118 (attached
`hereto as Exhibit G is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(H).
`date of loss 11/04/16 and policy number 0549782320101034 (attached hereto
`as Exhibit H is a copy of the invoice, work order, and GEICO check issued as
`full payment on said claim)..
`
`(1). Auto Glass America, LLC for windshield replacementservices for date of
`loss 7/31/2017 and policy number 0432367850101032 (attached hereto as
`Exhibit I is a copy of the invoice, work order, and GEICO check issued as
`full payment on said claim).
`
`(J). Auto Glass America, LLC for windshield replacementservices for date of
`loss 7/16/2017 and policy number 0521194490101020 (attached hereto as
`Exhibit J is a copy of the invoice, work order, and GEICO check issued as
`full payment on said claim).
`
`Auto Glass America, LLC for windshield replacement
`(K).
`services for date of loss 7/27/2017 and policy number 0354054190101310
`(attached hereto as Exhibit K is a copy of the invoice, work order, and
`GEICO checkissued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(L).
`date of loss 11/15/2015 and policy number 0377696600101059 (attached
`hereto as Exhibit L is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(M).
`date of loss 3/01/2017 and policy number 0316811860101012 (attached
`hereto as Exhibit M is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`

`

`Auto Glass America, LLC for windshield replacementservices for
`(N).
`date of loss 1/10/2017 and policy number 0512876440101024 (attached
`hereto as Exhibit N is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(O).
`date of loss 1/24/2017 and policy number 0469323170101026 (attached
`hereto as Exhibit O is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(P).
`date of loss 7/30/2017 and policy number 0116714500101099 (attached
`hereto as Exhibit P is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`(Q).
`Auto Glass America, LLC for windshield replacementservices for
`date of loss 1/06/2017 and policy number 0245627260101030 (attached
`hereto as Exhibit Q is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(R).
`date of loss 7/29/2017 and policy number 0129560690101240 (attached
`hereto as Exhibit R is a copy ofthe invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(S).
`date of loss 12/01/2016 and policy number 0268204940101160 (attached
`hereto as Exhibit S is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(T).
`date of loss 4/22/2017 and policy number 0385760160101055 (attached
`hereto as Exhibit T is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(U).
`date of loss 1/07/2017 and policy number 0450714250101038 (attached
`hereto as Exhibit U is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(V).
`date of loss 5/09/2017 and policy number 0469748080101023 (attached
`hereto as Exhibit V is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(W).
`date of loss 5/8/2017 and policy number 0524426800101044 (attached hereto
`
`

`

`as Exhibit W is a copy ofthe tnvoice, work order, and GEICO checkissued
`as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(X).
`date of loss 1/07/2017 and policy number 0548753370101019 (attached
`hereto as Exhibit X is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(Y).
`date of loss 5/30/2017 and policy number 0588142830101036 (attached
`hereto as Exhibit Y is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(Z).
`date of loss 1/07/2017 and policy number 0547753140101019 (attached
`hereto as Exhibit Z is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(AA).
`date of loss 6/15/2016 and policy number 0532465890101019 (attached
`hereto as Exhibit AA is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(BB).
`date of loss 7/28/2017 and policy number 0589094140101017 (attached
`hereto as Exhibit BB is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(CC).
`date of loss 11/20/2016 and policy number 0435362110101051 (attached
`hereto as Exhibit CC is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(DD).
`date of loss 1/26/2017 and policy number 0333671730101017 (attached
`hereto as Exhibit DD is a copy ofthe invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`The identification of all GEICO personnel who madeorparticipated in the
`(27).
`decision to reimburse or pay Florida windshield replacement claims at 110% to 150%
`of NAGS.
`
`Charges submitted by Florida windshield replacement and repair facilities
`(28).
`to GEICO from 2014 through 2017 for windshield replacementand repair services.
`
`

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`The maximum amountreimbursed by GEICO to any Florida windshield
`(29).
`replacement and repair facility for the same windshield replacement and/or repair
`services at issue in the instant action for the same yearat issue.
`
`* DUCES TECUM: DEPONENTIS TO BRING ALL DOCUMENTSAS
`FOLLOWS:
`
`(1).
`
`Acomplete copy of the Policy, including the Declarations page, all
`endorsem*nts, amendments, riders and attachments.
`
`(2).
`
`All correspondence(byletter, electronic mail or otherwise) between you
`and your insured (or counsel for your insured) relating to the Policy.
`
`(3).
`
`All correspondence(byletter, electronic mail or otherwise) between you
`and your insured (or counsel for your insured) relating to the claim described
`in the Complaint.
`
`All correspondence between Plaintiff and Defendant regarding the claim
`(4.).
`described in the Complaint.
`
`(5).
`
`All log and/or ledgers relating to Defendant’s insured and the date of loss
`in the Complaint, or other documents evidencing the amountof benefits paid
`by Defendant to or for the benefit of the insured’s windshield repair and/or
`replacement.
`
`(6).
`
`Any andall office manuals, claims manuals, policies, procedures and/or
`other documentation addressing Defendant’s processing, payment and
`adjustment of claimslike the one referenced in the Complaint.
`
`(7).|All memoranda, guidelines, policies, procedures and/or instructions to
`Defendant’s adjusters or employees responsible for adjusting, processing and
`paying claimslike the one described in the Complaint.
`
`(8).
`
`All correspondence between Defendantand anythird party billing
`consultants, analysts, providers, auditors, administrators, etc. regarding the
`loss at issue in the instant case.
`
`(9).
`
`Copies of all contracts between Defendant and anythird party billing
`consultants, analysts, providers, auditors, administrators, etc. engaged by
`Defendant for the past three years.
`
`(10). Copies of all documents relating to the development and implementation
`of the term “prevailing competitive price” as used in the property damage
`Limit of Liability provision of the policy in the instant claim.
`
`

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`(11). A listing of all repair and/or replacement facilities you would have
`identified to perform the repairs and/or replacement in this case if the insured
`had madesuch a request in the instant claim.
`
`(12). Any and all agreements Defendant has for administering and handling of
`windshield repair and/or
`replacement claims under
`the comprehensive
`provision of its policy with any third parties.
`
`(13). Any and all documents Defendant intends to rely upon to establish the
`Defendant reimbursed the “prevailing competitive price” for the service
`providedin this case.
`
`(14). Any and all estimates received by Defendant from any source for repairs
`and/or replacement of the insured windshield.
`
`Copiesof all correspondence between Defendantand the insured (including
`(15).
`the insured’s counsel) in connection with the loss described in the Complaint.
`
`(16). Copies of all adjuster notes, diaries or log notes/entries prepared prior to
`Defendant’s receipt of the pre-suit invoice sent by Plaintiff to Defendant.
`
`(17). Copies of any andall records and/or notes generated by Defendantrelating
`to how Defendant determined the amounts paid to Plaintiff for the windshield
`repair and/or replacementservices Plaintiff performed.
`
`(18). Copy of any written or recorded statements (under oath or otherwise) the
`Defendant obtained from the insured pertaining to the subjectloss.
`
`(19). All recordings in audio or visual format of the insured that were taken by
`anyone with respect to the subjectloss.
`
`(20). Copies of all documents you think support any allegation regarding any
`perceivedinsufficiency with the pre-suit invoice sent to Defendant by Plaintiff
`in connection with the instant claim.
`
`(21). Copies of all documents you think support any allegation regarding any
`perceived insufficiency with any documentation submitted to Defendant by
`Plaintiff in connection with the instant claim.
`
`to
`(22). Copies of any and all payment schedules used by the Defendant
`determine amounts paid and/or reduced with regard to invoice received forthis
`matter and claim.
`
`(23). Copies of any and all underlying data contained in any databases used by
`the Defendant to determine amounts paid and/or reduced with regards to the
`invoice received for this matter and claim.
`
`

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`(24). Copies of any and all manuals, programs, or guidelines that contain
`information on reductions of payments for invoices received in this matter and
`claim.
`
`(25). A copy of any andall application, questionnaires, surveys, or other
`documents that Defendantutilizes in selecting its windshield glass repair and
`replacement facility(s)/vendor(s).
`
`(26). A copy of any andall follow up survey(s) that Defendant sendstoits
`insureds after a windshield glass claim is completed.
`
`(27). A-copy of any andall contract and/or agreements with Safelite Plaintiff,
`Safelite Group, Inc., and Safelite Solutions that are in effect, or were in effect
`at the time of the subject claim.
`
`(28). A copy of any andall contracts and/or agreements with any andall
`windshield glass repair and replacement facility(s)/vendor(s), windshield glass
`administrators, windshield glass manufacturers and distributors that are in
`effect or were in effect at the time of the subject claim.
`
`(29). Any and all telephone scripts or other documents used by Defendant or
`provided to SGC Network, Safelite Solutions, Inc. and/or Safelite Group, Inc.
`for use during a phonecall or other communication with the insured or glass
`shop for the handling, servicing, and administering (e.g., payments) of glass
`claims.
`
`(30). Any and all market studies performed by SGC Network, Safelite
`Solutions, Inc. and/or Safelite Group, Inc., and any ofits agents/entities
`to determine the reasonable, fair, prevailing competitive price, and/or
`reimbursem*nt amounts for automobile glass,
`labor, kit/adhesive,
`molding and other items for automobile glass claims in the State of
`Florida in the past three (3) years.
`
`Anyand all market studies performed by Defendant and any ofits
`(31).
`agents/ entities to determine the reasonable,fair, prevailing competitive
`price, and/or reimbursem*nt amounts for automobile glass,
`labor,
`kit/adhesive, molding and other items for Plaintiff claims in the State of
`Florida in the past three (3) years.
`
`(32). Any and all documents utilized by Defendant indicating how an
`automobile glass replacement/repair shop is chosen to have a claim
`selected to undergo an appraisal and/or inspection process in the State
`of Florida.
`
`

`

`training
`(33). Any and all documents, manuals, guidelines, books,
`material
`in the possession of Defendant on how to appraise an
`automobile glass replacement/repair job and/or claim in the State of
`Florida.
`
`(34). Any and all documents, polices, procedures and/or papers given to
`Defendant from SGC Network, Safelite Solutions, Inc. and/or Safelite
`Group, Inc., and any of its agents/entities on how to determine if a
`windshield or other automobile glass must be repaired rather than
`replaced.
`
`(35). Any and all documents provided to Defendant from SGC Network,
`Safelite Solutions, Inc. and/or Safelite Group, Inc., and any of its
`agents/entities pertaining to the subject automobile glass claim.
`
`(36). Any and all documents on inspections performed for any automobile
`glass claim of Plaintiff in this case for the past three (3) years.
`
`(37). Any and all documents on appraisals performed on any automobile
`glass claim of Plaintiff in this case for the past three (3) years.
`
`(38). Any and all publications relied upon in determining the amount to
`be paid to Plaintiff for the automobile glass claim that is the subject of
`this lawsuit including, but not limited to, books, manuals, data bases,
`computer programs, brochures, pamphlets, catalogues, guidebooks,
`booklets, and the like.
`
`(39). Any and all documents relied upon in the review of the subject
`automobile glass repair/ replacement claim.
`
`Printouts of any and all computer data relied upon in the review of
`(40).
`and determination of how much to reimburse Plaintiff for the subject
`automobile glass replacement claim.
`
`(41). Any and all documents, books, pamphlets, manuals, brochures,
`guidebooks, booklets, and the like utilized by Defendantfor the purpose
`of determining the reimbursem*nt amountfor the parts, labor, molding,
`and adhesive for the automobile glass claim that is the subject of this
`lawsuit.
`
`(either handwritten or
`logs
`call
`telephone
`all
`and
`(42). Any
`computerized), recordings, and transcripts documenting any and all
`conversations had between Defendant and the Insured for
`the
`automobile glass claim that
`is
`the subject of this
`lawsuit or
`conversations had between Defendant and Plaintiff for the automobile
`glass claim that is the subject of this lawsuit.
`
`

`

`(43). Any and all telephone scripts or other documents used by Defendant or
`provided to SGC Network, Safelite Solutions, Inc. and/or Safelite Group, Inc.
`for use during a phone call or other communication with the insured or glass
`shop when a claim is referred for inspection or appraisal.
`
`(44). Any andall telephone recordings of any conversations with the insured or
`Plaintiff for the claim at hand, including but not limited to, recordings between
`SGC Network, Safelite Solutions, Inc. and/or Safelite Group, Inc. and Plaintiff
`and insured.
`
`(45). A copy of any invoice, receipt, or other document(s) representing an
`administrative fee and/or handling fee paid by Defendant to any third party
`vendorin the instant claim.
`
`(46). Acopyof any andall utilization reports showing the numberof windshield/
`glass claims that are referred to Saftelite and its affiliates and all other “in-
`network”facilities/vendors through Defendant’s call center on a monthly basis
`for the past 3 years.
`
`(47). A list of the claims handled through Safelite andits affiliates for the past 3
`years, and a list of claims handled outside Safelite for the past 3 years.
`
`(48). A list of the claims handled through in-network glass repair and replacement
`shops for the past 3 years, and a list of claims handled through out of-network
`glass repair and replacementshopsfor the past 3 years.
`
`(49). Any andall documents reflecting that Plaintiff charges in this case
`exceeded the prevailing competitive price where the services were performed.
`
`(50). Copies of invoices, work orders and corresponding drafts for windshield
`replacement services whereby GEICO paid 150% of NAGS. See for example:
`
`Auto Glass America, LLC for windshield replacementservices for
`(A).
`date of loss 8/30/2016 and policy number 0161643350101038 (attached
`hereto as Exhibit A is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim). All exhibits attached herein shall be
`filed under separate cover.
`
`Auto Glass America, LLC for windshield replacementservices for
`(B).
`date of loss 4/05/2017 and policy number 0512876440101016 (attached
`hereto as Exhibit B is a copy ofthe invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacement services for
`(C).
`date of loss 7/20/2017 and policy number 0576397930101013 (attached
`
`

`

`hereto as Exhibit C is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(D).
`date of loss 1/06/2017 and policy number 0352857620101037 (attached
`hereto as Exhibit D is a copy ofthe invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(E).
`date of loss 8/16/2016 and policy number 0280348220101038 (attached
`hereto as Exhibit E is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(F).
`date of loss 1/27/2017 and policy number 0460526940101030 (attached
`hereto as Exhibit F is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(G).
`date of loss 1/26/2017 and policy number 0287653260101118 (attached
`hereto as Exhibit G is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(H).
`date of loss 11/04/16 and policy number 0549782320101034 (attached hereto
`as Exhibit H is a copy of the invoice, work order, and GEICO checkissued as
`full payment on said claim)..
`
`(1). Auto Glass America, LLC for windshield replacementservices for date of
`loss 7/31/2017 and policy number 0432367850101032 (attached hereto as
`Exhibit I is a copy of the invoice, work order, and GEICO check issued as
`full payment on said claim).
`
`(J). Auto Glass America, LLC for windshield replacementservices for date of
`loss 7/16/2017 and policy number 0521194490101020 (attached hereto as
`Exhibit J is a copy of the invoice, work order, and GEICO check issued as
`full payment on said claim).
`
`Auto Glass America, LLC for windshield replacement
`(K).
`services for date of loss 7/27/2017 and policy number 0354054190101310
`(attached hereto as Exhibit K is a copy of the invoice, work order, and
`GEICO check issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(L).
`date of loss 11/15/2015 and policy number 0377696600101059 (attached
`
`

`

`hereto as Exhibit L is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(M).
`date of loss 3/01/2017 and policy number 0316811860101012 (attached
`hereto as Exhibit M is a copy ofthe invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(N).
`date of loss 1/10/2017 and policy number 0512876440101024 (attached
`hereto as Exhibit N is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(O).
`date of loss 1/24/2017 and policy number 0469323170101026 (attached
`hereto as Exhibit O is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(P).
`date of loss 7/30/2017 and policy number 0116714500101099 (attached
`hereto as Exhibit P is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`(Q).
`Auto Glass America, LLC for windshield replacementservices for
`date of loss 1/06/2017 and policy number 0245627260101030 (attached
`hereto as Exhibit Q is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(R).
`date of loss 7/29/2017 and policy number 0129560690101240 (attached
`hereto as Exhibit R is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(S).
`date of loss 12/01/2016 and policy number 0268204940101160 (attached
`hereto as Exhibit S is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(T).
`date of loss 4/22/2017 and policy number 0385760160101055 (attached
`hereto as Exhibit T is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(U).
`date of loss 1/07/2017 and policy number 0450714250101038 (attached
`hereto as Exhibit U is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`

`

`Auto Glass America, LLC for windshield replacementservices for
`(V).
`date of loss 5/09/2017 and policy number 0469748080101023 (attached
`hereto as Exhibit V is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(W).
`date of loss 5/8/2017 and policy number 0524426800101044 (attached hereto
`as Exhibit W is a copy ofthe tnvoice, work order, and GEICO checkissued
`as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(X).
`date of loss 1/07/2017 and policy number 0548753370101019 (attached
`hereto as Exhibit X is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(Y).
`date of loss 5/30/2017 and policy number 0588142830101036 (attached
`hereto as Exhibit Y is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(Z).
`date of loss 1/07/2017 and policy number 0547753140101019 (attached
`hereto as Exhibit Z is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(AA).
`date of loss 6/15/2016 and policy number 0532465890101019 (attached
`hereto as Exhibit AA is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(BB).
`date of loss 7/28/2017 and policy number 0589094140101017 (attached
`hereto as Exhibit BB is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(CC).
`date of loss 11/20/2016 and policy number 0435362110101051 (attached
`hereto as Exhibit CC is a copy of the invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`Auto Glass America, LLC for windshield replacementservices for
`(DD).
`date of loss 1/26/2017 and policy number 0333671730101017 (attached
`hereto as Exhibit DD is a copy ofthe invoice, work order, and GEICO check
`issued as full payment on said claim).
`
`

`

`UPONoral examination before an officer of Premier Reporting Services, Inc., or any
`other notary public or officer authorized by law to take deposition in the State of Florida.
`The oral examination will continue from day to day until completed. This deposition is
`being taken for the purposes of discovery, for use at trial, or for such other purposesas are
`permitted under the rules of Court. Said deposition is to be taken pursuant to the Florida
`Rules of Civil Procedure.
`
`[CERTIFICATE OF SERVICE ON NEXT PAGE]
`
`

`

`CERTIFICATE OF SERVICE
`
`Thereby certify that a true and correct copy of the foregoing has been served via electronic mail
`on the date filed in the E-Filing Portal to Counsel of Record as listed on the E-Filing Portal.
`
`LAWRENCE M. KOPELMAN,P.A.
`One West Las Olas Boulevard, Suite 500
`Fort Lauderdale, Florida 33301
`Telephone: (954) 525-4100
`Direct: (954) 462-6855
`Facsimile: (954) 525-4300
`Designated Email: LMKGlass@kopelblank.com
`
`
`/S/ Lawrence M. Kopelman
`LAWRENCE M. KOPELMAN
`Florida Bar No.: 288845
`
`