Party Discovery: Jimmy Noel Plaintiff vs. Citizens Property Insurance Corporation Defendant

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                                Filing # 128567729 E-Filed 06/11/2021 10:32:48 AM
 IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA
 JIMMY NOEL,
 CASE NO. CACE-21-006186 Div: 25
 Plaintiff,
 V
 CITIZENS PROPERTY INSURANCE
 CORPORATION,
 Defendant.
 PLAINTIFF'S RESPONSE TO REOUEST FOR ADMISSIONS
 Florida Bar #218261
 COMES NOW Plaintiff, by and through the undersigned attorneys, and hereby files this
 response to the Request for Admissions, and would state:
 1.
 Admit that you have a copy of the subject policy of insurance issued to Jimmy
 Noel subject to the terms, conditions, exclusions, and endorsements, for the
 policy period of May 20,2020 through May 20, 2021.
 As to RequestNo. 1. Denied as phrased. Therefore, denied.
 2.
 Admit that you have read the subject policy of insurance.
 As to RequestNo. 1. Admitted.
 3.
 Admit the alleged loss occurred on or about November10, 2020 and Citizens
 assigned Claim Number REDACTED to the alleged loss.
 As to RequestNo. 3. Admitted.
 4.
 Admit the alleged loss was reported on November 10, 2020.
 As to RequestNo. 4. Admitted.
 5.
 Admit the alleged loss relates to the insured property located at 1652 SW 70th
 Avenue, North Lauderdale, FL 33068-4356.
 As to RequestNo. 5. Admitted.
 6.
 Admit the plumbing leak claimed was repairedbefore November 25,2020.
 DUBOFF
 *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/11/2021 10:32:48 AM.****
 As to RequestNo. 6. Denied as phrased.
 7.
 Admit Citizens performed an inspectionof the subject property on November
 25,2020.
 As to RequestNo. 7. Admitted.
 8.
 Admit you retained water mitigation services on November 10, 2020.
 As to RequestNo. 8. Admitted.
 9.
 Admit you received E-mail correspondencefrom Citizens dated November12,
 2020, advising ofthe termsofthe Managed RepairProgrampolicy endorsement
 of the subject policy.
 As to RequestNo. 9. Denied as phrased. Therefore, denied.
 10.
 Admit you received E-mail correspondence from Citizens dated December 18,
 2020, advising of an unpaid premium amount and advising of the option to opt
 in to the Managed Repair Program pursuant to the applicable policy
 endorsement.
 As to RequestNo. 10. Denied as phrased. Therefore, denied.
 11.
 Admit you received E-mail correspondence from Citizens dated December 30,
 2020, followingup regardingthe unpaid premiumamount and the option to opt
 in to the Managed Repair Program pursuant to the applicable policy
 endorsement.
 As to RequestNo. 11. Denied as phrased. Therefore, denied.
 12.
 Admit that you did not respondto any correspondencefrom Citizens regarding
 the option to opt in to the Managed Repair Program pursuantto the applicable
 policy endorsement.
 As to RequestNo. 12. Denied as phrased. Therefore, denied.
 13.
 Admit you are in possession of receipts for repairs that were performedto the
 insured property after November 10, 2020.
 As to RequestNo. 13. Denied as phrased. Therefore, denied.
 14.
 Admit you are in possession of receipts for repairs that were performedto the
 insured property before November 10, 2020.
 As to RequestNo. 14. Denied as phrased. Therefore, denied.
 DUBOFF
 CERTIFICATE OF SERVICE
 WE HEREBY CERTIFY that on this
 11th
 day of
 June
 2021, a true and
 ,
 correct copy of the foregoing was emailed to: Ana C. Arenas, Esq., Bronstein & Carmona, P.A.,
 8000 Peters Road, Suite A-200, Fort Lauderdale, Florida, 33324,
 DUBOFF LAW FIRM
 ATTORNEYS FOR PLAINTIFF
 680 NE 127 STREET
 NORTH MIAMI, FLORIDA 33161
 TELEPHONE
 (305) 899-0085
 FAX No.
 (305) 899-0091
 BY: S/KENNETH R. DUBOFF, ESQ.
 KENNETH R. DUBOFF
 Fla. Bar #218261
 DUBOFF