On October 09, 2019 a
Request for Admissions
was filed
involving a dispute between
Amaya, Jimmy,
Ramos, Amelis,
and
Citizens Property Insurance Corporation,
for Contract and Indebtedness
in the District Court of Broward County.
Preview
Filing # 98087536 E-Filed 10/30/2019 10:09:19 AM
IN THE CIRCUIT COURT OF THE
JIMMY AMAYA & AMELIS RAMOS, 17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY,
Plaintiffs, FLORIDA
7 CASE NO: CACE-19-021027
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
PLAINTIFFS’ FIRST REQUESTS FOR ADMISSION
COME NOY, the Plaintiffs, Jimmy Amaya and Amelis Ramos, pursuant
to Rule 1.370 of the Florida Rules of Civil Procedure, and request that the
Defendant, Citizens Property Insurance Corporation (“Citizens”), admit or
deny the truth of the matters set forth as follows:
1. Admit that Citizens issued insurance policy number 02411300 (“Pol-
icy”) with respect to the property located at 6635 Hope Street,
Hollywood, Florida 33024 (“insured location”), which was in full
force and effect on the date of loss cited in the Complaint.
2. Admit that Jimmy Amaya & Amelis Ramos are insureds under the
Policy.
3. Admit that Jimmy Amaya & Amelis Ramos are ownets of the insured
location as of the date of loss cited in the Complaint.
4. Admit that the loss and damages referenced in the Complaint were
covered under the policy.
Page | 1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/30/2019 10:09:19 AM.****6.
10.
11.
12.
13.
14.
Admit that notice of the claim was furnished timely.
Admit that Citizens has not been prejudiced in the reporting of the
claim.
Admit that Citizens did not tequest a sworn proof of loss.
Admit that Citizens agrees the loss is covered but disputes the value
of damages sought by the Plaintiff.
Admit that one or more sworn proofs of loss were received by
Citizens with respect to the loss described in the Complaint.
Admit that an underwriting inspection was performed with respect
to any policy issued by Citizens for the property located at 6635
Hope Street, Hollywood, Florida 33024.
Admit that Citizens insured the property located at 6635 Hope
Street, Hollywood, Florida 33024 in the condition in which it existed
at the time of policy inception.
Admit that Citizens has made a payment with respect to the loss de-
scribed in the Complaint.
Admit that Citizens representatives who were assigned to, involved
with, or otherwise assisted in the processing of the Plaintiffs’ claim
were Citizens agents acting within the scope and course of their
agency.
Admit that Citizens representatives never inspected the property fol-
lowing the loss described in the Complaint.
Admit that all premiums required to maintain the coverages afforded
Page | 216.
17.
18.
19.
20.
21.
22.
23.
under the Policy were paid.
Admit that Citizens did not request a recorded statement of the
Plaintiffs or any other insured or person with respect to the loss cited
in the Complaint.
Admit that Citizens did not request an examination under oath of
the Plaintiffs or any other insured or person with respect to the loss
cited in the Complaint.
Admit that Citizens does not possess a recorded statement or exam-
ination under oath transcript of the Plaintiffs or any other insured or
person with respect to the loss cited in the Complaint.
Admit that Citizens completed its investigation with respect to the
loss described in the Complaint.
Admit that Citizens has no evidence of intentional concealment,
misrepresentation of material fact, fraudulent conduct, or false state-
ments made during the claims process which could void coverage
under the Policy.
Admit that the Plaintiffs complied with all post-loss obligations set
forth in the Policy.
Admit that the Plaintiffs complied with all conditions precedent to
the filing of this lawsuit.
Admit that Citizens did not demand appraisal ot request mediation.
Page | 3CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on October 29, 2019 the original document
has been filed with the Clerk of the Court via the Florida Courts’ E-filing Portal
and that a true and correct copy was served via Electronic-Mail to:
Allegra Knopf, Esq.
ALLEN & NEWMAN, PLLC
Post Office Box 5483
Fort Lauderdale, Florida 33310
Email: — aknopf@allenandnewman.com; and
mpetez@allenandnewman.com
DANIEL CRUZ, Esquire
FBN: 31023
‘THE DIENER FIRM, P.A.
8751 W. Broward Boulevard
Suite 404
Plantation, FL 33324
Telephone: (954) 541-2117
Facsimile: (954) 541-2195
Service:
service@dienerfirm.com
daniel@dienerfirm.com
alissa@dienerfirm.com
Page | 4
Document Filed Date
October 30, 2019
Case Filing Date
October 09, 2019
Category
Contract and Indebtedness
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Filing # 98087536 E-Filed 10/30/2019 10:09:19 AM IN THE CIRCUIT COURT OF THE JIMMY AMAYA & AMELIS RAMOS, 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, Plaintiffs, FLORIDA 7 CASE NO: CACE-19-021027 CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. PLAINTIFFS’ FIRST REQUESTS FOR ADMISSION COME NOY, the Plaintiffs, Jimmy Amaya and Amelis Ramos, pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, and request that the Defendant, Citizens Property Insurance Corporation (“Citizens”), admit or deny the truth of the matters set forth as follows: 1. Admit that Citizens issued insurance policy number 02411300 (“Pol- icy”) with respect to the property located at 6635 Hope Street, Hollywood, Florida 33024 (“insured location”), which was in full force and effect on the date of loss cited in the Complaint. 2. Admit that Jimmy Amaya & Amelis Ramos are insureds under the Policy. 3. Admit that Jimmy Amaya & Amelis Ramos are ownets of the insured location as of the date of loss cited in the Complaint. 4. Admit that the loss and damages referenced in the Complaint were covered under the policy. Page | 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/30/2019 10:09:19 AM.****6. 10. 11. 12. 13. 14. Admit that notice of the claim was furnished timely. Admit that Citizens has not been prejudiced in the reporting of the claim. Admit that Citizens did not tequest a sworn proof of loss. Admit that Citizens agrees the loss is covered but disputes the value of damages sought by the Plaintiff. Admit that one or more sworn proofs of loss were received by Citizens with respect to the loss described in the Complaint. Admit that an underwriting inspection was performed with respect to any policy issued by Citizens for the property located at 6635 Hope Street, Hollywood, Florida 33024. Admit that Citizens insured the property located at 6635 Hope Street, Hollywood, Florida 33024 in the condition in which it existed at the time of policy inception. Admit that Citizens has made a payment with respect to the loss de- scribed in the Complaint. Admit that Citizens representatives who were assigned to, involved with, or otherwise assisted in the processing of the Plaintiffs’ claim were Citizens agents acting within the scope and course of their agency. Admit that Citizens representatives never inspected the property fol- lowing the loss described in the Complaint. Admit that all premiums required to maintain the coverages afforded Page | 216. 17. 18. 19. 20. 21. 22. 23. under the Policy were paid. Admit that Citizens did not request a recorded statement of the Plaintiffs or any other insured or person with respect to the loss cited in the Complaint. Admit that Citizens did not request an examination under oath of the Plaintiffs or any other insured or person with respect to the loss cited in the Complaint. Admit that Citizens does not possess a recorded statement or exam- ination under oath transcript of the Plaintiffs or any other insured or person with respect to the loss cited in the Complaint. Admit that Citizens completed its investigation with respect to the loss described in the Complaint. Admit that Citizens has no evidence of intentional concealment, misrepresentation of material fact, fraudulent conduct, or false state- ments made during the claims process which could void coverage under the Policy. Admit that the Plaintiffs complied with all post-loss obligations set forth in the Policy. Admit that the Plaintiffs complied with all conditions precedent to the filing of this lawsuit. Admit that Citizens did not demand appraisal ot request mediation. Page | 3CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on October 29, 2019 the original document has been filed with the Clerk of the Court via the Florida Courts’ E-filing Portal and that a true and correct copy was served via Electronic-Mail to: Allegra Knopf, Esq. ALLEN & NEWMAN, PLLC Post Office Box 5483 Fort Lauderdale, Florida 33310 Email: — aknopf@allenandnewman.com; and mpetez@allenandnewman.com DANIEL CRUZ, Esquire FBN: 31023 ‘THE DIENER FIRM, P.A. 8751 W. Broward Boulevard Suite 404 Plantation, FL 33324 Telephone: (954) 541-2117 Facsimile: (954) 541-2195 Service: service@dienerfirm.com daniel@dienerfirm.com alissa@dienerfirm.com Page | 4