On March 25, 2021 a
Party Discovery
was filed
involving a dispute between
Noel, Jimmy,
and
Citizens Property Insurance Corporation,
for Other - Insurance Claim
in the District Court of Broward County.
Preview
Filing # 127655882 E-Filed 05/27/2021 11:08:30 AM
21-10668
ACA
IN THE CIRCUIT COURT OF THE 17”!
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JIMMY NOEL, CASE NO. CACE 21-006186 (25)
(Judge Carol-Lisa Phillips)
Plaintiff,
v.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
/
DEFENDANT, CITIZENS PROPERTY INSURANCE CORPORATION’S
FIRST REQUESTS FOR ADMISSION TO PLAINTIFF, JIMMYNOEL
COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION
(hereinafter “Citizens”), a Florida Governmental Entity, by and through its undersigned counsel
and pursuant to Florida Rules of Civil Procedure 1.370, requests Plaintiff, Jimmy Noel, admit or
deny the following within thirty (30) days from the date of these First Requests for Admission.
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.
2. Admit that you have read the subject policy of insurance.
3. Admit the alleged loss occurred on or about November 10, 2020 and Citizens
assigned Claim Number EEE 76 to the alleged loss.
4. Admit the alleged loss was reported on November 10, 2020.
5. Admit the alleged loss relates to the insured property located at 1652 SW 70th
Avenue, North Lauderdale, FL 33068-4356.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/27/2021 11:08:29 AM.****Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
6. Admit the plumbing leak claimed was repaired before November 25, 2020.
7. Admit Citizens performed an inspection of the subject property on November 25,
2020.
8. Admit you retained water mitigation services on November 10, 2020.
9. Admit you received E-mail correspondence from Citizens dated November 12,
2020, advising of the terms of the Managed Repair Program policy endorsement of the subject
policy.
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.
11. Admit you received E-mail correspondence from Citizens dated December 30,
2020, following up regarding the unpaid premium amount and the option to opt in to the
Managed Repair Program pursuant to the applicable policy endorsement.
12. Admit that you did not respond to any correspondence from Citizens regarding
the option to opt in to the Managed Repair Program pursuant to the applicable policy
endorsement.
13. Admit you are in possession of receipts for repairs that were performed to the
insured property after November 10, 2020.
14. | Admit you are in possession of receipts for repairs that were performed to the
insured property before November 10, 2020.Jimmy Noel v. Citizens
CASE NO. CACE 21-006186 (25)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
sent by e-mail on this the 27th day of May, 2021, to Kenneth R. Duboff, Esq., Duboff Law
Firm, Attorneys for Plaintiff, courtdocument@dubofflawfirm.com.
BRONSTEIN & CARMONA, P.A.
Attorneys for Defendant
8000 Peters Road, Suite A-200
Fort Lauderdale, FL 33324
(954) 358-0444 — Phone
(954) 358-0445 — Fax
service@bronstein-carmona.com
By:_/s/Ana C. Arenas, Esq.
Ana C. Arenas
Florida Bar No.: 1020219
Document Filed Date
May 27, 2021
Case Filing Date
March 25, 2021
Category
Other - Insurance Claim
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Filing # 127655882 E-Filed 05/27/2021 11:08:30 AM 21-10668 ACA IN THE CIRCUIT COURT OF THE 17”! JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JIMMY NOEL, CASE NO. CACE 21-006186 (25) (Judge Carol-Lisa Phillips) Plaintiff, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / DEFENDANT, CITIZENS PROPERTY INSURANCE CORPORATION’S FIRST REQUESTS FOR ADMISSION TO PLAINTIFF, JIMMYNOEL COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION (hereinafter “Citizens”), a Florida Governmental Entity, by and through its undersigned counsel and pursuant to Florida Rules of Civil Procedure 1.370, requests Plaintiff, Jimmy Noel, admit or deny the following within thirty (30) days from the date of these First Requests for Admission. 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. 2. Admit that you have read the subject policy of insurance. 3. Admit the alleged loss occurred on or about November 10, 2020 and Citizens assigned Claim Number EEE 76 to the alleged loss. 4. Admit the alleged loss was reported on November 10, 2020. 5. Admit the alleged loss relates to the insured property located at 1652 SW 70th Avenue, North Lauderdale, FL 33068-4356. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/27/2021 11:08:29 AM.****Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) 6. Admit the plumbing leak claimed was repaired before November 25, 2020. 7. Admit Citizens performed an inspection of the subject property on November 25, 2020. 8. Admit you retained water mitigation services on November 10, 2020. 9. Admit you received E-mail correspondence from Citizens dated November 12, 2020, advising of the terms of the Managed Repair Program policy endorsement of the subject policy. 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. 11. Admit you received E-mail correspondence from Citizens dated December 30, 2020, following up regarding the unpaid premium amount and the option to opt in to the Managed Repair Program pursuant to the applicable policy endorsement. 12. Admit that you did not respond to any correspondence from Citizens regarding the option to opt in to the Managed Repair Program pursuant to the applicable policy endorsement. 13. Admit you are in possession of receipts for repairs that were performed to the insured property after November 10, 2020. 14. | Admit you are in possession of receipts for repairs that were performed to the insured property before November 10, 2020.Jimmy Noel v. Citizens CASE NO. CACE 21-006186 (25) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been sent by e-mail on this the 27th day of May, 2021, to Kenneth R. Duboff, Esq., Duboff Law Firm, Attorneys for Plaintiff, courtdocument@dubofflawfirm.com. BRONSTEIN & CARMONA, P.A. Attorneys for Defendant 8000 Peters Road, Suite A-200 Fort Lauderdale, FL 33324 (954) 358-0444 — Phone (954) 358-0445 — Fax service@bronstein-carmona.com By:_/s/Ana C. Arenas, Esq. Ana C. Arenas Florida Bar No.: 1020219