Party Discovery: Keith Forbes Plaintiff vs. Heritage Property & Casualty Insurance Company Defendant

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                                Filing# 139612409 E-Filed 12/02/2021 05:32:27 PM
 IN THE CIRCUIT COURT OF THE 177TH
 JUDICIAL CIRCUIT, IN AND FOR
 BROWARD COUNTY, FLORIDA
 CASE NO: CACE 20-017837
 KEITH FORBES,
 Plaintiff.
 VS.
 HERITAGE PROPERTY & CASUALTY
 INSURANCE COMPANY,
 Defendant.
 i
 DEFENDANT'S RESPONSES TO PLAINTIFF'S
 SECOND REQUEST FOR ADMISSIONS
 COMES NOW, the Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE
 COMPANY, by and through the undersigned counsel, to file these Responses to Plaintiff's
 Second Request for Admissions, pursuant to the applicableFlorida Rules of Civil Procedure.
 1.
 Admit that duringthe investigation
 of the Claim, you took no steps to determine the age
 of the roof at the Property.
 RESPONSE: Denied.
 2.
 Admit that during the investigationof the Claim, you did not research any historical
 roofingpermitsrespectiveto the Property.
 RESPONSE: Admit.
 3.
 Admit that during the investigationof the Claim, you did not research any historical
 photosof the Propertypriorto September 10,2017.
 RESPONSE: Denied as phrased.
 4.
 Admit that during the investigationof the Claim, you did not research any historical
 photos from September 10,2017 up and to September 4,2020.
 RESPONSE: Denied as phrased.
 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/02/2021 05:32:27 PM.****
 5.
 Admit that during the investigationof the Claim, you did not research any aerial or
 satellite photographs of the property.
 RESPONSE: Denied as phrased.
 6.
 Admit that during the investigationof the Claim, you did not research any historical
 weather data in the vicinityofthe property on or around September 10,2017.
 RESPONSE: Denied as phrased.
 7.
 Admit that during the investigationof the Claim, you did not research any other storm
 events between September 10,2017, and September 4,2020.
 RESPONSE: Denied as phrased.
 8.
 Admit that during the investigationof the Claim, neither Heritage nor anyone on
 Heritage'sbehalf requested a third-party,
 other than a field adjuster,to inspectthe
 Property to evaluate for causation of damages.
 RESPONSE: Admit.
 CERTIFICATE OF SERVICE
 I HEREBY CERTIFY that a true and correct copy of the foregoingwas served via E-
 portal to Aaron D. Silvers,Esq., Schilling& Silvers,PLLC, 1314 E. Las Olas Boulevard, Unit
 2191, Fort Lauderdale, FL 33301 at Asilvers@schilingsilvers.com;
 dariste@schilingsilvers.com;
 and Jschilling@schillingsilvers.com
 on this 19th day ofNovember, 2021, pursuant to Rule 2.516.
 COUNSEL FOR HERITAGE PROPERTY
 AND CASUALTY INSURANCE COMPANY
 1571 Sawgrass Corporate Parkway, Suite 400
 Sunrise,Florida 33323
 Telephone: (954) 315-1450 ext. 7648
 kdoyle@heritagepci.com
 jgoncalves@heritagepci.com
 sabugoush@heritagepci.com
 By: /s/ Kellyn E. Doyle
 KELLYN E. DOYLE, ESQUIRE
 Florida Bar No. 1010087
 2