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Case Number: CACE-20-017617 Division: 09
Filing # 115461869 E-Filed 10/22/2020 03:20:27 PM
IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY,
FLORIDA
HAVEN GROUP, INC., CASE NO:
Plaintiff,
vs.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
a
PLAINTIFF’S NOTICE OF SERVICE OF
FIRST INTERROGATORIES TO DEFENDANT
Pursuant to Rule 1.340, Florida Rules of Civil Procedure, the Plaintiff, HAVEN
GROUP, INC., by and through the undersigned counsel, propounds the following First
Interrogatories on the Defendant, CITIZENS PROPERTY INSURANCE
CORPORATION, to be answered in writing, under oath, within the time allowed in
accordance with the Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
T hereby certify that a copy of the foregoing was served upon the Defendant in
this action along with the Complaint.
By: = ~
JOHN A. SALCEDO
Florida Bar No: 14665
THE MINEO SALCEDO LAW FIRM, P.A.
Attorneys for Plaintiff
5600 Davie Road
Davie, FL 33314
T: (954) 463-8100
F; (954) 463-8106
Service@mineolaw.com
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/22/2020 03:20:25 PM.****FIRST INTERROGATORIES TO DEFENDANTS,
CITIZENS PROPERTY INSURANCE CORPORATION
1. What is your name, address, and, if you are answering for someone else, your
official position or relationship with the party to whom the interrogatories are directed?
2. Describe any and all policies of insurance which you contend cover or may cover
the allegations set forth in Plaintiff's complaint, detailing as to such policies the name of
the insurer, the number of the policy, the available limits of liability, and the name and
address of the custodian of the policy.
3. Please state with specificity any defenses to coverage that you have in this matter
and identify any documents supporting your defenses to coverage.4. Please state with specificity any conditions precedent or subsequent to the
Plaintiffs claims that you contend have not been fulfilled by the Plaintiff, if any exist.
5. Please state your reason(s) for your nonpayment and/or non-consideration of this
claim.
6. Please state the date that you received notice of this claim and the date that you
received notice of the incident which is the subject of this matter.7. Describe in detail how the incident described in the Plaintiff's Complaint
happened.
8. State separately the facts upon which you rely on for each affirmative defense in
your Answer to the Plaintiff's Complaint.
9. Do you contend any person or entity other than you is or may be liable in whole
or in part for the claims asserted against you in this lawsuit? If so, state the full name and
address of each such person or entity, the legal basis for your contention, the facts or
evidence upon which your contention is based, and whether or not you have notified each
such person or entity of your contention.10. List the names, addresses and telephone numbers of all persons who are believed
or known by you, your agents, or your attorneys to have any knowledge concerning any
of the issues in this lawsuit; and specify the subject matter about which the witness has
knowledge.
11. State the name and address of every person known to you, your agents, or your
attorneys who has knowledge about or possession, custody, or control of any estimate of
damage, model, plat, map, drawing, motion picture, video-tape, or photograph pertaining
to any fact or issue involved in this controversy; and describe as to each, what item such
person has, the name and address of the person who took or prepared it, and the date it
was taken or prepared.
12. Please provide a list of the names and current addresses of any and all individuals
employed by or agents or the Defendant who were in any way involved with the handling
of this claim, including those individuals who inspected, photographed or otherwise
visited the subject property for any purpose after the subject date of loss but prior to the
institution of this litigation. Please also provide a short statement of the persons
knowledge and involvement.13. List the names, residence addresses, business addresses and telephone numbers of
all persons believed or known by you, your agents, or attorneys to have heard Plaintiff
make any statement, remark, or comment concerning the subject loss and the substance
of any such statement, remark, or comment.
14. For any and all policy defenses which you reasonably believe are available with
regards to the claim made by the Plaintiff herein: Describe in detail the factual and legal
basis for any such defenses and give complete names, residence addresses, business
addresses, and telephone numbers of each person believed or known by you, your agents
or attorneys, to have knowledge of the facts which would provide the basis for any such
defense.
15. Please list any amounts that Defendant has paid to Plaintiff to date for the subject
claim and describe what each such payment was for.16. For each denied or withheld payment of claim listed above, state in detail the
legal ground and the factual basis upon which the claim was denied, the exact wording of
any policy provisions, or the exact wording of any statutory language or case law upon
which you base your denial or withholding of payment.
17. State the names, residence addresses, and business addresses of any and all
photographers, investigators, or videographers which are in any way related to this
lawsuit.
18. If you claim you were unable to pay Plaintiff's claim because you had insufficient
information or the notice of claim did not have sufficient support, state: When you first
realized that you had insufficient information, each and every effort made by you to
obtain the needed information, when you informed the Plaintiff of the need for further
information and when you gave up trying to obtain the needed information.19, If an appraisal of the subject property or its contents was performed, please state
the items that have been appraised, the amount that each such item was appraised for, the
name and address of any person who performed or contributed to said appraisal, and the
date of said appraisal.
I, , being duly sworn upon oath, state that the
foregoing Answers to Interrogatories are true and correct.
STATE OF FLORIDA )
) SS:
COUNTY OF )
The foregoing instrument was acknowledged before me, this day of
, 2020 by who is personally
known to me or, who has produced as
identification and who did take an oath.
NOTARY PUBLIC
My Commission Expires:
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Case Number: CACE-20-017617 Division: 09 Filing # 115461869 E-Filed 10/22/2020 03:20:27 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA HAVEN GROUP, INC., CASE NO: Plaintiff, vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. a PLAINTIFF’S NOTICE OF SERVICE OF FIRST INTERROGATORIES TO DEFENDANT Pursuant to Rule 1.340, Florida Rules of Civil Procedure, the Plaintiff, HAVEN GROUP, INC., by and through the undersigned counsel, propounds the following First Interrogatories on the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, to be answered in writing, under oath, within the time allowed in accordance with the Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE T hereby certify that a copy of the foregoing was served upon the Defendant in this action along with the Complaint. By: = ~ JOHN A. SALCEDO Florida Bar No: 14665 THE MINEO SALCEDO LAW FIRM, P.A. Attorneys for Plaintiff 5600 Davie Road Davie, FL 33314 T: (954) 463-8100 F; (954) 463-8106 Service@mineolaw.com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/22/2020 03:20:25 PM.****FIRST INTERROGATORIES TO DEFENDANTS, CITIZENS PROPERTY INSURANCE CORPORATION 1. What is your name, address, and, if you are answering for someone else, your official position or relationship with the party to whom the interrogatories are directed? 2. Describe any and all policies of insurance which you contend cover or may cover the allegations set forth in Plaintiff's complaint, detailing as to such policies the name of the insurer, the number of the policy, the available limits of liability, and the name and address of the custodian of the policy. 3. Please state with specificity any defenses to coverage that you have in this matter and identify any documents supporting your defenses to coverage.4. Please state with specificity any conditions precedent or subsequent to the Plaintiffs claims that you contend have not been fulfilled by the Plaintiff, if any exist. 5. Please state your reason(s) for your nonpayment and/or non-consideration of this claim. 6. Please state the date that you received notice of this claim and the date that you received notice of the incident which is the subject of this matter.7. Describe in detail how the incident described in the Plaintiff's Complaint happened. 8. State separately the facts upon which you rely on for each affirmative defense in your Answer to the Plaintiff's Complaint. 9. Do you contend any person or entity other than you is or may be liable in whole or in part for the claims asserted against you in this lawsuit? If so, state the full name and address of each such person or entity, the legal basis for your contention, the facts or evidence upon which your contention is based, and whether or not you have notified each such person or entity of your contention.10. List the names, addresses and telephone numbers of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. 11. State the name and address of every person known to you, your agents, or your attorneys who has knowledge about or possession, custody, or control of any estimate of damage, model, plat, map, drawing, motion picture, video-tape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. 12. Please provide a list of the names and current addresses of any and all individuals employed by or agents or the Defendant who were in any way involved with the handling of this claim, including those individuals who inspected, photographed or otherwise visited the subject property for any purpose after the subject date of loss but prior to the institution of this litigation. Please also provide a short statement of the persons knowledge and involvement.13. List the names, residence addresses, business addresses and telephone numbers of all persons believed or known by you, your agents, or attorneys to have heard Plaintiff make any statement, remark, or comment concerning the subject loss and the substance of any such statement, remark, or comment. 14. For any and all policy defenses which you reasonably believe are available with regards to the claim made by the Plaintiff herein: Describe in detail the factual and legal basis for any such defenses and give complete names, residence addresses, business addresses, and telephone numbers of each person believed or known by you, your agents or attorneys, to have knowledge of the facts which would provide the basis for any such defense. 15. Please list any amounts that Defendant has paid to Plaintiff to date for the subject claim and describe what each such payment was for.16. For each denied or withheld payment of claim listed above, state in detail the legal ground and the factual basis upon which the claim was denied, the exact wording of any policy provisions, or the exact wording of any statutory language or case law upon which you base your denial or withholding of payment. 17. State the names, residence addresses, and business addresses of any and all photographers, investigators, or videographers which are in any way related to this lawsuit. 18. If you claim you were unable to pay Plaintiff's claim because you had insufficient information or the notice of claim did not have sufficient support, state: When you first realized that you had insufficient information, each and every effort made by you to obtain the needed information, when you informed the Plaintiff of the need for further information and when you gave up trying to obtain the needed information.19, If an appraisal of the subject property or its contents was performed, please state the items that have been appraised, the amount that each such item was appraised for, the name and address of any person who performed or contributed to said appraisal, and the date of said appraisal. I, , being duly sworn upon oath, state that the foregoing Answers to Interrogatories are true and correct. STATE OF FLORIDA ) ) SS: COUNTY OF ) The foregoing instrument was acknowledged before me, this day of , 2020 by who is personally known to me or, who has produced as identification and who did take an oath. NOTARY PUBLIC My Commission Expires: