Party Discovery: Manuel Vallina , et al Plaintiff vs. St Johns Insurance Company Inc Defendant

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                                Filing # 126961988 E-Filed 05/17/2021 04:16:30 PM


        IN THE CIRCUIT COURT OF THE
        17TH JUDICIAL CIRCUIT IN AND FOR
        BROWARD COUNTY, FLORIDA

        CASE NO.: CACE 21-003778 (14)

        MANUEL VALLINA and
        MARYBET VALLINA,

                  Plaintiffs,

        Vv.


         ST. JOHNS INSURANCE COMPANY, INC.,

                  Defendant.
                                                           /

             DEFENDANT’S RESPONSES TO PLAINTIFFS’ RE                  UEST FOR ADMISSIONS

                  The Defendant, ST. JOHNS INSURANCE COMPANY,               INC., by and through its

        undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.370, hereby files

         its Responses to Plaintiffs’ Request for Admissions, as follows:

         1        Admit that you do not dispute the cause of loss as alleged in Paragraph 8 of the
                  Complaint.

                  Admitted to the extent that a covered loss occurred at the insured premises,
                  but denied that all of the damages claimed by Plaintiffs resulted from this loss.

                  Admit that you do not dispute the date of loss as alleged in Paragraph 8 of the
                  Complaint.

                  Admitted.

                  Admit that the policy described in Paragraph 5 of the Complaint was in full force
                  and effect on or about the date of loss alleged in Paragraph 8 of the Complaint.

                  Admitted.




              #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN,    CLERK 05/17/2021 04:16:28 PM.**#*
Vallina, Mane1 & Manbet   v. St. John sin s Co.
                                                           Case No.: CACE 21-003778 (14)
                                                                             Page 2 of 2

       Admit that Plaintiff(s) complied with all of the post loss duties under the policy
       described in Paragraph 5 of the Complaint.

       Denied.

       Admit that Plaintiff(s) complied with all of the conditions precedent under the
       policy described in Paragraph 5 of the Complaint.

       Denied.

       Admit that Defendant’s investigation of the loss described in Paragraph 8 of the
       Complaint was not prejudiced by the acts or omissions of Plaintiff(s).

       Admitted.


                              CERTIFICATE OF SERVICE

       I HEREBY     CERTIFY that a true and correct copy of the Defendant’s Responses

to Plaintiffs’ Request for Admissions was sent on May 17, 2021 to Counsel of Record via

the Florida Electronic Filing Portal.

                                         s/ Aron R. Rudman, Esq.
                                         Aron R. Rudman, Esq.
                                         Florida Bar No.: 106650
                                         Attorney for Defendant
                                         VERNIS & BOWLING OF BROWARD, P.A.
                                         5821 Hollywood Blvd.
                                         Hollywood, FL 33021
                                         Tel: (954) 927-5330; Fax: (954) 927-5320
                                         Email: arudman@florida-law.com