On April 19, 2021 a
Party Discovery
was filed
involving a dispute between
Langere, Juliann,
and
Tower Hill Preferred Insurance Company,
for 3
in the District Court of Broward County.
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Filing # 134152760 E-Filed 09/08/2021 09:33:02 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CIVIL DIVISION
JULIANN LANGERE
CASE NO.: CACI 21-007839
Plaintiff,
VS.
TOWER HILL PREFERRED INSURANCE
COMPANY
Defendant.
PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
Plaintiff, JULIANN LANGERE (hereinafter referred to as "Plaintiff'), by and through
their undersigned counsel, and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure,
hereby requests that Defendant, TOWER HILL PREFERRED INSURANCE COMPANY
(hereinafter referred to as "Defendant"), respond to Plaintiff's First Request for Admissions to
Defendant within thirty (30) days of rece*t hereof, and admit or deny the following and as
grounds, the Plaintiffs allege as follows:
1. Defendantprovided insurance coverage fortheproperty located at 1812 Monte Carlo Way,
Coral Springs, FL 33071 (hereinafter the "Insured Property") under policy number
9002246781.
2. The Insured Property sustained damage caused by a covered peril during the policy period.
3. The damages associatedwith claim number 3300356131 are covered under policy number
9002246781 (hereinafter referred to as the "Policy").
4. Plaintiff timely reported the loss and damage to Defendant.
5. Defendant owes Plaintiff insurance monies for the damage to the Insured Property.
1
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/08/2021 09:33:02 AM.****
6. Plaintiff has complied with all conditions precedent prior to filing this suit as required by
the Policy.
7. Plaintiffhascooperated with Defendant's investigation under the terms of the Policy.
8. Defendant completed its investigation ofPlaintiff'sclaim prior to the date the Plaintifffiled
the lawsuit.
9. Defendanthas breached its policy of insurance by failing to pay all benefits due and owing
to Plaintiff under policy number 9002246781.
10. Plaintiff has complied with all conditions precedent to obtaining benefits under the policy
of insurance from Defendant.
11. Plaintiffhas complied with all conditions precedent to the maintenance of this action.
12. Pursuant to Fla. Stat. §627.428, Plaintiff is entitled to attorneys' fees and costs in the event
the Court enters a judgment or decree against Defendant in favor of Plaintiff in this action.
CERTIFICATE OF SERVICE
I HEREBY certify that a true and correct copy of the foregoing have been furnished via e-mail to
Brett R. Bloch, Esq, Esquire, on this 8th day of September, 2021.
CONSTABLE LAW, P.A.
/s/ James S. Constable
James S. Constable, Esquire
Florida Bar No. 68522
Allison S. Freeman, Esquire
Florida Bar No. 69539
CONSTABLE LAW, P.A.
-th
139 6? Ave S
Safety Harbor, Florida 34695
Telephone: (727) 797-0100
Facsimile: (727) 726-6917
20-2155 Attorneys for Plaintiff
2
Document Filed Date
September 08, 2021
Case Filing Date
April 19, 2021
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Filing # 134152760 E-Filed 09/08/2021 09:33:02 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION JULIANN LANGERE CASE NO.: CACI 21-007839 Plaintiff, VS. TOWER HILL PREFERRED INSURANCE COMPANY Defendant. PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT Plaintiff, JULIANN LANGERE (hereinafter referred to as "Plaintiff'), by and through their undersigned counsel, and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, hereby requests that Defendant, TOWER HILL PREFERRED INSURANCE COMPANY (hereinafter referred to as "Defendant"), respond to Plaintiff's First Request for Admissions to Defendant within thirty (30) days of rece*t hereof, and admit or deny the following and as grounds, the Plaintiffs allege as follows: 1. Defendantprovided insurance coverage fortheproperty located at 1812 Monte Carlo Way, Coral Springs, FL 33071 (hereinafter the "Insured Property") under policy number 9002246781. 2. The Insured Property sustained damage caused by a covered peril during the policy period. 3. The damages associatedwith claim number 3300356131 are covered under policy number 9002246781 (hereinafter referred to as the "Policy"). 4. Plaintiff timely reported the loss and damage to Defendant. 5. Defendant owes Plaintiff insurance monies for the damage to the Insured Property. 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/08/2021 09:33:02 AM.**** 6. Plaintiff has complied with all conditions precedent prior to filing this suit as required by the Policy. 7. Plaintiffhascooperated with Defendant's investigation under the terms of the Policy. 8. Defendant completed its investigation ofPlaintiff'sclaim prior to the date the Plaintifffiled the lawsuit. 9. Defendanthas breached its policy of insurance by failing to pay all benefits due and owing to Plaintiff under policy number 9002246781. 10. Plaintiff has complied with all conditions precedent to obtaining benefits under the policy of insurance from Defendant. 11. Plaintiffhas complied with all conditions precedent to the maintenance of this action. 12. Pursuant to Fla. Stat. §627.428, Plaintiff is entitled to attorneys' fees and costs in the event the Court enters a judgment or decree against Defendant in favor of Plaintiff in this action. CERTIFICATE OF SERVICE I HEREBY certify that a true and correct copy of the foregoing have been furnished via e-mail to Brett R. Bloch, Esq, Esquire, on this 8th day of September, 2021. CONSTABLE LAW, P.A. /s/ James S. Constable James S. Constable, Esquire Florida Bar No. 68522 Allison S. Freeman, Esquire Florida Bar No. 69539 CONSTABLE LAW, P.A. -th 139 6? Ave S Safety Harbor, Florida 34695 Telephone: (727) 797-0100 Facsimile: (727) 726-6917 20-2155 Attorneys for Plaintiff 2