Response to Motion to Dismiss

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                          Filing # 126620295 E-Filed 05/11/2021 09:52:20 PM

OSCAR DIAZ, an individual, IN THE CIRCUIT COURT OF THE 17TH
a JUDICIAL CIRCUIT IN AND FOR
Plaintiff, BROWARD COUNTY, FLORIDA
ue GENERAL JURISDICTION DIVISION

UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY, a_ Florida

corporation,

CASE NO.: CACE-20-017329

Defendant.
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PLAINTIFF’S RESPONSE AND MEMORANDUM OF LAW IN OPPOSITION TO

DEFENDANT’S MOTION TO DISMISS COUNT I OF THE PLAINTIFF’S
COMPLAINT

1, This is an action against the Defendant for breach of contract and declaratory relief
under an insurance policy with policy # 1501-1802-2007 (the “Policy”) concerning the home of
the Plaintiff located at 311 NW 76" Ter, Pembroke Pines, Florida 33024 (the “Property”).

2. The Defendant issued the Policy to the Plaintiff; said Policy was in full force and
effect on or about May 18,2020, which provided coverage for the covered water event (the “Loss”).

3. The Plaintiff notified the Defendant of the claim and they were provided Claim
Numbe…