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Filing # 146654513 E-Filed 03/29/2022 04:30:40 PM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY,
FLORIDA
HIGH POINT WEST CONDOMINIUM
NO. 2 INC.,
Piaintiif,
ve
CERTAIN UNDERWRITERS AT LLOYD'S
LONDON (Subscribing to Policy Numbers
AOP-200083, AQS-200273, MDM-200273,
PND_9NNI72\ and unt CT ORAT
INDIARLUUZ / J, ana ca Viwuwnn
SPECIALTY SE, and XL CATLIN CASE NO. 2021-CA-007514
INSURANCE COMPANY US, LTD, and
GENERAL SECURITY INDEMNITY
COMPANY OF ARIZONA, and CRUM &
FORSTER SPECIALTY INSURANCE
COMPANY, and WESTERN WORLD
INSURANCE COMPANY, and SAFETY
SPECIALTY INSURANCE COMPANY, and
THE PRINCETON EXCESS AND
SURPLUS LINES INSURANCE
COMPANY,
Defendants.
DEFENDANTS' NOTICE OF FILING IN SUPPORT OF DEFENDANTS' MOTION FOR
RECONSIDERATION
COMES NOW, Defendants, CERTAIN UNDERWRITERS AT LLOYD'S LONDON
(Subscribing to Policy Numbers AOP-200083, AQS-200273, MDM-200273, RNR-200273), HDI
GLOBAL SPECIALTY SE, and XL CATLIN INSURANCE COMPANY US, LTD, GENERAL
SECURITY INDEMNITY COMPANY OF ARIZONA, CRUM & FORSTER SPECIALTY
INSURANCE COMPANY, WESTERN WORLD INSURANCE COMPANY, SAFETY
SPECIAL TV INSTIRANCE COMPANY and THE PRINCETON RYCRSS AND STIRPTTIC
Drea NOU VU GU ky CU a
CHEN. DAIAARCACUAAIINTY Cl INeGEDU ARDIIV7ZA FLED n2INAINNND NAAN. AN DAA
Pn. PAL DLA VUUINE TT, FL, JUOL I mDNUeeY, ULLIAN, voremeues. Ut.oU.tU ivLINES INSURANCE COMPANY, by and through the Undersigned Counsel and hereby serve
Defendants' Notice of Filing in Support of Defendants' Motion for Reconsideration and in support
thereof attach as follows:
EXHIBIT A1: Bound! Schedule of Values” made part of the subject policy by reference
and incorporation. Access to the Attached Exhibit Al can be made by clicking on the hyperlink
directly above. A copy of the corresponding Policy is attached to Defendants' Motion for
Reconsideration as Exhibit A.
Dated: March 29, 2022
‘The Schedule of Values provides the list of all covered premises, buildings, and additional
coverages that were afforded at the time of binding the subject policy. The Schedule provides for
the individual coverages, total insured value, and deductible applicable for each piece of property
the Insured has requested and sought coverage for the applicable policy period. The Schedule is
incorporated into the Policy per numerous references within the Policy. For Example, Defendants
direct the Court to page 76 of Defendants' Motion for Reconsideration, at exhibit A, Calendar Year
Hurricane Deductibie Endorsement which provides the Scheduie of insured Properiy as: “Per
Schedule of Values on file with the Company." Additionally on Page 56 of Defendants' Motion
for Reconsideration at Exhibit A, General Conditions, E. Definitions, it provides: Location(s)
means locations as listed on the Schedule of Locations attached to this policy or as listed on the
latest schedule on file with us."
? The attached Exhibit Al Pages 1-4 should be read side-by side rather than vertically. All
four pages side-by side form the full Schedule of Values. Alternatively, the entire chart is
reproduced immediately following on page 5 with an option to zoom into the Schedule of Values
via the converted PDF.Respectfully submitted,
/s/ Melissa Victoria Jordon
KIMBERLY M. JONES, ESQ.
Florida Bar No. 29069
MELISSA V. JORDON, ESQ.
Florida Bar No. 123576
WOOD, SMITH,
HENNING & BERMAN LLP
701 Brickell Avenue, Suite 1640
Miami, FL 33131
mjordon@wshblaw.com
kjones@wshblaw.com
Lneer an
Counsel for Defendants
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this March 29, 2022, a copy of the foregoing was served
via the Florida e-Portal filing system which will send notice to all counsel of record.
/s/ Melissa Victoria Jordon
MELISSA V. JORDON, ESQ.
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Filing # 146654513 E-Filed 03/29/2022 04:30:40 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA HIGH POINT WEST CONDOMINIUM NO. 2 INC., Piaintiif, ve CERTAIN UNDERWRITERS AT LLOYD'S LONDON (Subscribing to Policy Numbers AOP-200083, AQS-200273, MDM-200273, PND_9NNI72\ and unt CT ORAT INDIARLUUZ / J, ana ca Viwuwnn SPECIALTY SE, and XL CATLIN CASE NO. 2021-CA-007514 INSURANCE COMPANY US, LTD, and GENERAL SECURITY INDEMNITY COMPANY OF ARIZONA, and CRUM & FORSTER SPECIALTY INSURANCE COMPANY, and WESTERN WORLD INSURANCE COMPANY, and SAFETY SPECIALTY INSURANCE COMPANY, and THE PRINCETON EXCESS AND SURPLUS LINES INSURANCE COMPANY, Defendants. DEFENDANTS' NOTICE OF FILING IN SUPPORT OF DEFENDANTS' MOTION FOR RECONSIDERATION COMES NOW, Defendants, CERTAIN UNDERWRITERS AT LLOYD'S LONDON (Subscribing to Policy Numbers AOP-200083, AQS-200273, MDM-200273, RNR-200273), HDI GLOBAL SPECIALTY SE, and XL CATLIN INSURANCE COMPANY US, LTD, GENERAL SECURITY INDEMNITY COMPANY OF ARIZONA, CRUM & FORSTER SPECIALTY INSURANCE COMPANY, WESTERN WORLD INSURANCE COMPANY, SAFETY SPECIAL TV INSTIRANCE COMPANY and THE PRINCETON RYCRSS AND STIRPTTIC Drea NOU VU GU ky CU a CHEN. DAIAARCACUAAIINTY Cl INeGEDU ARDIIV7ZA FLED n2INAINNND NAAN. AN DAA Pn. PAL DLA VUUINE TT, FL, JUOL I mDNUeeY, ULLIAN, voremeues. Ut.oU.tU ivLINES INSURANCE COMPANY, by and through the Undersigned Counsel and hereby serve Defendants' Notice of Filing in Support of Defendants' Motion for Reconsideration and in support thereof attach as follows: EXHIBIT A1: Bound! Schedule of Values” made part of the subject policy by reference and incorporation. Access to the Attached Exhibit Al can be made by clicking on the hyperlink directly above. A copy of the corresponding Policy is attached to Defendants' Motion for Reconsideration as Exhibit A. Dated: March 29, 2022 ‘The Schedule of Values provides the list of all covered premises, buildings, and additional coverages that were afforded at the time of binding the subject policy. The Schedule provides for the individual coverages, total insured value, and deductible applicable for each piece of property the Insured has requested and sought coverage for the applicable policy period. The Schedule is incorporated into the Policy per numerous references within the Policy. For Example, Defendants direct the Court to page 76 of Defendants' Motion for Reconsideration, at exhibit A, Calendar Year Hurricane Deductibie Endorsement which provides the Scheduie of insured Properiy as: “Per Schedule of Values on file with the Company." Additionally on Page 56 of Defendants' Motion for Reconsideration at Exhibit A, General Conditions, E. Definitions, it provides: Location(s) means locations as listed on the Schedule of Locations attached to this policy or as listed on the latest schedule on file with us." ? The attached Exhibit Al Pages 1-4 should be read side-by side rather than vertically. All four pages side-by side form the full Schedule of Values. Alternatively, the entire chart is reproduced immediately following on page 5 with an option to zoom into the Schedule of Values via the converted PDF.Respectfully submitted, /s/ Melissa Victoria Jordon KIMBERLY M. JONES, ESQ. Florida Bar No. 29069 MELISSA V. JORDON, ESQ. Florida Bar No. 123576 WOOD, SMITH, HENNING & BERMAN LLP 701 Brickell Avenue, Suite 1640 Miami, FL 33131 mjordon@wshblaw.com kjones@wshblaw.com Lneer an Counsel for Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this March 29, 2022, a copy of the foregoing was served via the Florida e-Portal filing system which will send notice to all counsel of record. /s/ Melissa Victoria Jordon MELISSA V. JORDON, ESQ.