Jury Demand in Peter Treppeda, et al Plaintiff vs. United Property & Casualty Insurance Company, Inc., et al Defendant| Trellis.Law

On April 13, 2021 a Jury Demand was filed involving a dispute between Treppeda, Monica, Treppeda, Peter, and United Property & Casualty Insurance Company, Inc., Universal Property & Casualty Insurance Company, for Contract and Indebtedness in the District Court of Broward County.

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Filing # 128445160 E-Filed 06/09/2021 05:07:04 PM

,TH
IN THE CIRCUIT COURT OF THE 17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA

PETER AND MONICA TREPPEDA, CASE NO: CACE-21-007431

Plaintiffs,

VS.

UNIVERSALPROPERTY & CASUALTY
INSURANCE COMPANY,

Defendant.
i

DEFENDANT UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY'S
ANSWER, DEFENSES, AND DEMAND FOR JURY TRIAL

Defendant, Universal Property & Casualty Insurance Company ("Universal"), by and

through the undersigned counsel, hereby files its Answer and Defenses to Plaintiffs' Complaint

and states as follows:

1. Universal denies the allegations contained within Paragraph 1 and strict proof

thereof is hereby demanded.

2. Universal is without knowledge and therefore denies the allegations contained

within Paragraph 2 and hereby demands strict proof thereof.

3 With respect to the allegations contained within Paragraph 3, Universal states that

it is a Florida corporation, located in Broward County, Florida, and authorized to issue

homeowners' insurance policies throughout the State of Florida. Universal denies all other

allegations and strict proofthereof is hereby demanded.

4. With respect to the allegations contained within Paragraph 4, Universal states that

venue is proper as the subject property is located within Broward County, Florida. Universal

denies all other allegations and strict proofthereof is hereby demanded.

***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/09/2021 05:07:00 PM.****
Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

5. With respect to the allegations contained within Paragraph 5, Universal states that

it issued Policy No. XXX-XXX-985 ("Policy") to Peter and Monica Treppeda for the property

located at 16425 Sapphire P. Weston, FL 33331 ("insured property") for the one-year policy period

of January 18, 2020 through January 18, 2021, subject to all terms, conditions, definitions,

limitations, exclusions and endorsements. In addition, Universal states that the Policy speaks for

itself. Universal denies all other allegations and strict proof thereof is hereby demanded.

6. With respect to the allegations contained within Paragraph 6, Universal states that

the Policy speaks for itself. Universal denies all other allegations and strict proofthereofishereby

demanded.

7. Universal denies the allegations contained within Paragraph 7 and strict proof

thereof is hereby demanded.

8. Universal denies the allegations contained within Paragraph 8 and strict proof

thereof is hereby demanded.

9. Universal denies the allegations contained within Paragraph 9 and strict proof

thereof is hereby demanded.

10. With respect to the allegations contained within Paragraph 10, Universal states that

upon the untimely notification of the alleged damages, Universal assigned claim number FL20-

0153899-P420 to the alleged loss. Universal denies all other allegations and strict proofthereof is

hereby demanded.

11. Universal denies the allegations contained within Paragraph 11 and strict proof

thereof is hereby demanded.

12. Universal denies the allegations contained within Paragraph 12 and strict proof

thereof is hereby demanded.

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

13. Universal denies the allegations contained within Paragraph 13 with specificity.

Specifically, but not limited to, the Plaintiffs failed to promptly report the alleged loss, failed to

comply with Defendant's document request, and failed to protect the property from further

damage. Therefore, the Plaintiffs failed to comply with policy conditions. Based on the foregoing,

the Plaintiffs have failed to comply with the conditions precedent to filing the subject lawsuit.

14. Universal denies the allegations contained within Paragraph 14 and strict proo f

thereof is hereby demanded.

15. With respect to the allegations contained within Paragraph 15, Universal states that

Fla. Stat. § 627.428 speaks for itself. Universal denies any inference therefrom and denies all other

allegations and strict proofthereof is hereby demanded.

Universal denies any and all other allegations not specifically addressed above.

COUNT I -
BREACH OF CONTRACT

16. Universal re-avers and incorporates its responses to Paragraphs 1 through 15 above

as if stated fully herein.

17. With respect to the allegations containedwithin Paragraph 17, Universal states the

Policy speaks for itself. Universal denies all other allegations and strict proof thereof is hereby

demanded.

18. Universal denies the allegations contained within Paragraph 18 and strict proof

thereof is hereby demanded.

19. With respect to the allegations containedwithin Paragraph 19, Universal states the

Policy speaks for itself. Universal denies all other allegations and strict proof thereof is hereby

demanded.

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Case No.: CACE-21-007431

20. Universal denies the allegations contained within Paragraph 20 and strict proof

thereof is hereby demanded.

21. Universal denies the allegations contained within Paragraph 21 and strict proof

thereof is hereby demanded.

Universal denies any and all other allegations not specifically addressed above.

Universal denies any and all relief requested in Plaintiffs' "Wherefore" Clause including

any entitlement to the reliefrequested therein.

DEFENSES

FIRST DEFENSE
Failure to Mitigate

Universal asserts that the alleged damages were caused and worsened by a failure to

mitigate at or after the time of the alleged date of loss. Specifically, Plaintiffs reported that the

alleged damages occurred on November 8,2020, however upon inspection on December 14,2020,

Plaintiffs had not yet contracted for or completed any mitigation services, such as installation of a

roof tarp. Therefore, Plaintiffs are not entitled to recover in this action accordingly.

The policy provides in pertinent part as follows:

UPCIC HO3 15 05 18

SECTION I -

CONDITIONS

C. Duties After Loss.
In caseof a loss to covered property, we have no duty to provide coverage under
this policy if the failure to comply with the following duties is prejudicial to us.
These duties must be performed either by you, an "insured" seeking coverage, or

a representative of either:

4. Protect the covered property from further damage. If emergency measures are

required, the following must be performed:
a. Take reasonable emergency measures that are necessary to protect the
covered property from further damage, as provided under Additional Coverage 2.

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

A reasonable emergency measure under 4.a. above may include a permanent repair
when necessary to protect the covered property from further damage or
toprevent unwanted entry to the property. To the degree reasonably possible, the
damaged property must be retained for us to inspect; and
b. Keep an accurate record ofrepair expenses;
***

H. SuitAgainst Us. No action can be brought against us unless there has been fill
compliance with all of the terms under Section I of this policy and the action is
started within 5 years after the date of loss.

SECOND DEFENSE
Excluded Peril -

Neglect

Universal asserts that its liability, if any, is only in accordance with the terms, provisions,

conditions, limitations and exclusions of its Policy, including, but not limited to, all applicable

policy limits and policy dates.

Specifically,Universal references the following language contained within the Policy:

UPCIC HO3 15 05 18

SECTION I -

EXCLUSIONS

A. We do not insure for loss caused directly or indirectlyby any of the following.
Such loss is excluded regardless of any other cause or event contributing
concurrently or in any sequence to the loss. These exclusions apply whether or not
the loss event result sin widespreaddamage or affects a substantial area.

***

5. Neglect, meaning neglect of an "insured" to use all reasonable means to save

and preserve property at and after the time of a loss.

Universal particularly asserts this defense due to the lack of any evidence that reasonable

means were used to save and preserve the alleged damaged property at and after the date of alleged

loss upon untimely notice claim. Specifically, Plaintiffs reported that the alleged damages

occurred on November 8,2020, however, upon inspection on December 14, 2020, Plaintiffs had

not yet contracted for or completed any mitigation services, such as installation of a roof tarp.

Based on the foregoing, Plaintiffs neglected to use all reasonablemeans to save and preserve the

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

subject property. Therefore, the alleged damages claimed in this suit caused directly or indirectly

by neglect are excluded under the subject Policy.

THIRD DEFENSE
Conditions Precedent: Prompt Notice: Late Reporting and Prejudice to Defendant

Universal asserts that the alleged claim is subject to a failure to provide "prompt" notice to

Universal as required under the Policy. Specifically, Plaintiffs untimely reported the alleged loss

to Universal approximately three (3) days after it allegedly occurred, which was a material breach

ofthe policy and resulted in prejudice to Universal, as Universal was not able to inspectthe alleged

loss at the time it allegedly occurred. This delay effectively deprived Universal of a fair

opportunity to fully investigate the alleged loss and subjects Universal to the potential

indemnification for worsened damages and increased repair costs.

The policy provides in pertinent part

UPCIC HO3 15 05 18

SECTION I -

CONDITIONS

C. Duties After Loss
In of a loss to covered property, we have no duty to provide coverage under
case

this policy if the failure to comply with the following duties is prejudicial to us.
These duties must be performed either by you, an "insured" seeking coverage, or

a representative of either:

1. Give prompt notice to us or our agent;
Except for Reasonable Emergency Measures taken under Additional Coverage
there is coverage for repairs that begin before the earlier of:
no

a. 72 hours after we are notified of the loss;
b. The time of loss inspection by us; or
c. The time of other approval by us.
***

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

FOURTH DEFENSE
Condition Precedent -

Provide Requested Documents

Universal asserts that Plaintiffhas failed to provide requested documents, including but not

limited to emergency mitigation service invoice/documents, dry out logs and contract and color

photos; receipts for repairs completed; copies of all receipts, contracts, estimates, invoices, reports

or permits; photos ofthe damaged propertyprior to any repairs/emergencymitigation service; and

proof of repairs. This was a material breach of the policy and resulted in prejudice to Universal,

as Universal was deprived o f its right to timely obtain a sworn statement under oath o f the alleged

claim and of a fair opportunity to fully investigate the alleged loss, thereby being subjected to

potential indemnification for worsened damages and increased repair costs. The alleged claims in

this suit are thereforealso premature in nature and no relief can be granted until such time as there

is compliance with all conditions and requirements pursuant to the terms of the Policy.

Specifically,Universal references the following language containedwithin the Policy:

UPCIC HO3 15 05 18

SECTION I -
CONDITIONS

C. Duties After Loss
In case of a loss to covered property, we have no duty to provide coverage under
this policy if the failure to comply with the following duties is prejudicial to us.
These duties must be performed either by you, an "insured" seeking coverage, or a
representative of either:

7. As often as we reasonablyrequire:
b. Provide us with records and documentswe request and permit us to make copies;

***

H. SuitAgainst Us. No action can be broughtagainst us unless there has been full
compliance with all of the terms under Section I of this policy and the action is
started within 5 years after the date of loss.

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

FIFTH DEFENSE
Conditions Precedent -

Keep Accurate Record of Repair Expenses

Universal asserts that Plaintiff failed to keep and/or provide any record of any ofthe repairs

made and has provided no documentation to support that repairs were completed and/or to

demonstrate the extent of damages to property and/or provide an inventory of alleged damaged

contents, which is a condition precedent to recover pursuant to the terms of the Policy. This was

a material breach of the policy and resulted in prejudice to Universal such that no action can be

brought against Universal pursuant to the subject Policy terms.

UPCIC HO3 15 05 18

SECTION I -

CONDITIONS

C. Duties After Loss.
In case of a loss to covered property, we haveduty to provide coverage under
no

this policy if the failure to
comply with the
following duties is prejudicial to us.
These duties must be performed either by you, an "insured" seeking coverage, or
a representative of either:

4. Protect the covered property from further damage. If emergency measures are

required, the following must be performed:
a. Take reasonable emergency measures that are necessary to protect the covered

property from further damage, as provided under Additional Coverage 2.

A reasonable emergency measure under 4.a above may include a permanent repair
when necessary to protect the covered property from further damage or to prevent
unwanted entry to the property. To the degree reasonably possible, the damaged
property must be retained for us to inspect; and

b. Keep an accurate record ofrepair expenses;

6. Prepare an inventory of damaged personal property showing the quantity,
description, actual cash value and amount of loss. Attach all bills, receipts and
related documentsthat justify the figures in the inventory;

***

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

SIXTH DEFENSE
Plaintiffs'Failure to Comply with Post-Loss Duty -

Submit to Recorded Statement

Universal affirmatively asserts that this lawsuit should be dismissed with prejudice as a

matter of law, due to the Plaintiffs' failure to comply with her post-loss duty under the Policy to

submit to a recorded statement. The Policy provides in relevant part:

UPCIC HO3 15 05 18

SECTION I -

CONDITIONS

7. As often as we reasonably require:

c. Any and all "insureds" must submit to recorded statements when requested by
tls;

Universal requested that Plaintiffs submit to a recorded statement. The Plaintiffs have

failed to do so as of the date of the filing of this response. Therefore, this lawsuit should be

dismissed with prejudice as a matter of law.

SEVENTH DEFENSE
Exclusion -

Faulty, Inadequate or Defective Workmanship and/Maintenance
Universal asserts that its liability, if any, is only in accordance with the terms, provisions,

conditions, limitations and exclusions of its Policy, including, but not limited to, all applicable

policy limits and policy dates.

Specifically,Universal references the following language containedwithin the Policy:

UPCIC HO3 15 05 18

SECTION I -

EXCLUSIONS

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

B. We do not insure for loss to property described in Coverage A and B caused by
any ofthe following. However, any ensuing loss to property described in Coverage
A and B not excluded or accepted in this policy is covered.

3. Faulty, inadequate or defective:
***

b. Design, specifications, workmanship, repair, construction, renovation,
remodeling,grading, compaction;
c. Materials used in repair, construction, renovation or remodeling; or

d. Maintenance;

ofpart or all of any property whether on or offthe "residence premises."

Universal particularly asserts this defense in that its inspection of the untimely reported

claim suggests that the alleged damaged property, such as the roof, ceiling, drywall, base molding

and flooring in the dining room and ceiling in the garage, have been subjected to the performance

of faulty, inadequate or defective workmansh* and/or maintenance either before and/or after the

alleged date of loss, such that the alleged damages are excluded under the subjectPolicy.

EIGHTH DEFENSE
Absence of Damage and Excessive Damages

Universal asserts that damages are being sought in this action for areas and/or items ofthe

home that were not caused by the alleged loss, including but not limited to roof, exterior stuceo,

paint and patio/pool enclosure, entry/foyer, kitchen, living room, hallway, laminate flooring
st
throughout the entire 1 floor of the insured property and contents. As such, there is no coverage

for these areas of the home. Further, this action involves claims for damages that includes

numerous repairs that are excessive, inaccurate, unwarranted, upgrades or related to areas and/or

items of the insured property that were not damaged, which is precluded as a matter of law.

NINTH DEFENSE
Exclusion -

Flood/Rising Water
Universal asserts that its liability, if any, is only in accordance with the terms, provisions,

conditions, limitations and exclusions of its Policy, including, but not limited to, all applicable

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

policy limits and policy dates. Universal particularly asserts this defense to the extent that upon

inspection it appears that the alleged damages to the dining room ofthe insured property appeared

to be the result of flood/surfacewater entering the insured property.

Specifically,Universal references the following language contained within the Policy:

UPCIC HO3 15 05 18

SECTION I -

EXCLUSIONS

A. We do not insure for loss caused directly or indirectlyby any of the following.
Such loss is excluded regardless of any other cause or event contributing
concurrently or in any sequence to the loss. These exclusions apply whether or not
the loss event results in widespreaddamage or affects a substantial area.

3. Water
This means:
a. Flood, surface water, waves, including tidal wave and tsunami, tides, tidal water,
overflow ofany body ofwater, or spray from any ofthese, all whether or not driven
by wind, including storm surge;
b. Water which:
(1) Backs up through sewers or drains; or
(2) Overflows or is otherwise discharged from a sump, sump pump or related
equipment;
c. Water below the surface ofthe ground, including water which exerts pressure on,
or seeps, leaks or flows through a building, sidewalk, driveway, patio, foundation,
swimming pool other structure; or
or

d. Waterborne material carried or otherwise moved by any of the water referred to
in A.3.a. through A.3.c. ofthis exclusion.

This Exclusion A.3. applies regardless of whether any of the above, in A.3.a.
through A.3.d., is caused by an act of nature or is otherwise caused.

This Exclusion A.3. applies to, but is not limited to, escape, overflow or discharge,
for any reason, of water or waterborne material from a dam, levee, seawall or any
other boundary or containment system.

TENTH DEFENSE
Exclusion -

Constant or Repeated Seepage

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

Universal affirmatively asserts that its liability, if any, is only in accordance with the terms,

provisions, conditions, limitations and exclusions of its Policy, including, but not limited to, all

applicablepolicy limits and policy dates.

Specifically,Universalreferences the following language containedwithin the Policy:

UPCIC HO3 15 05 18

SECTION I -

PERILS INSURED AGAINST

A. Coverage A Dwelling And Coverage B Other Structures
- -

1. We insure against direct physical loss to property described in Coverages A and
B. However, loss does not include and we will not pay for any "diminution in
value".
2. We do not insure, however, for loss:
***

c. Caused by:
***

(5)Constant or repeated seepage or leakage of water or steam or the presence or

condensation of humidity, moisture or vapor, over a period of weeks, months or

years, unless such seepage or leakage of water or steam or the presence or
condensation ofhumidity, moisture or vapor, and the resulting damage is unknown
to all "insureds" and is hidden within the walls or ceilings or beneath the floors or
above the ceilings of a structure;

The damages alleged by Plaintiffs are the result of visible constant and repeated seepage

that occurred over a period of weeks, months, or years. Specifically, Plaintiffs reported that the

alleged damages occurred on November 8,2020, however upon inspection on December 14,2020,

Plaintiffs had not yet contracted for or completed any mitigation services, such as installation of a

roof tarp, thereby allowing water to constantly seep and leak into the subject property for more

than one (1) month. Therefore, any such damages are excluded under the Policy.

ELEVENTH DEFENSE
Perils Insured Against -

Direct Physical Loss

Universal asserts that pursuant to the subject Policy, Universal's liability under the Policy

for a covered loss is limited to actual damages. However, Plaintiffs submitted an estimate for

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

repair or replacement of several areas and/or items ofthe property, including but not limited to the

roof, exterior stuceo, paint and patio/pool enclosure, entry/foyer, kitchen, living room, hallway
st
s
and laminate flooring throughout the entire l floor of the property and contents, that have not

sustained any direct physical loss from the claimed wind-related storm damage. The Universal

policy insures against "direct loss... only ifthat loss is a
physical loss to property." See Policy,

page 14 of 34. The phrase "direct physical loss" has been defined to mean actual damage. Actual

damage is visible physical damage that can be observed. See Homeowners ChoiceProperO&

Casualo' v. Maspons, 211 So.3d 1067 (Fla. 3d DCA 2017) ("'Direct' and 'physical' modify loss

and impose the requirement that the damage be actual.").

TWELFTH DEFENSE
No Physical Loss to Property

Universal asserts that upon its inspection ofthe insured property after the untimely reported

claim there is no "direct physical damage" to the property caused from the loss as alleged in the

reported claim and in this lawsuit. Therefore, this initial burden cannot be met which precludes

coverage for the alleged damages in this action.

THIRTEENTH DEFENSE
No Coverage by Waiver or Estoppel

Universal asserts that it has not waived any of its defenses nor is it estopped from asserting

any and all defenses as they pertain to coverage, exclusions, or payments made toward the alleged

claims in the Complaint. Under Florida law, coverage cannot be created or extended through

estoppel or waiver. See Doe v. Allstate Ins. Co., 653 So. 2d 371 (Fla. 1995); Crown Life Ins. Co.

v. Mc Bride, 517 So. 2d 660 (Fla. 1987); Gamero v. Foremost Ins. Co., 208 So. 3d 1195 (Fla. 3d

DCA 2017). Furthermore, Plaintiffs failed to state a claim for waiver and/or estoppel. To have

waiver, the Plaintiffmust demonstrate that the Universalhad (1) the existence of a right, privilege,

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

advantage or benefit that can be waived; (2) the actual or constructiveknowledge of that right; and

(3) the intention to relinquish that right. See Leonardo v. State Farm Fire & Cas. Co., 675 So. 2d

176, 178 (Fla. 4th DCA 1996).

To have estoppel, there must be (1) a representationas to a material fact that is contradicted

by a later asserted position; (2) reliance on that representation; and (3) a change in position

detrimental to the party relying on the representationand caused by the representation. See Lloyds

Underwriters at London v. Keystone Equip. Fin. Corp., 25 So. 3d 89,93 (Fla. 4th DCA 2009).

Universal asserts that Plaintiffs failed to establish or plead any of the aforementioned elements in

their Complaint, and as such, Universal has not waived any of its defenses nor is it estopped from

asserting any and all defenses as they pertain to coverage, exclusions or payment of the claim.

FOURTEENTH DEFENSE
Windstorm Exterior Paint or Waterproofing Material

Universal asserts that its liability, if any, is only in accordance with the terms, provisions,

conditions, limitations and exclusions of its Policy, including, but not limited to, all applicable

policy limits, policy dates and applicable Florida Statutes. Specifically,Universal references the

following language contained within the Policy form HO 23 70 05 13 which excludes coverage

for the alleged loss to the extent Universal's inspection of the subject loss suggests potential

windstormto paint or
waterproofing material of the subject property:

WINDSTORM OR IIAIL EXTERIOR PAINT OR WATERPROOFING
EXCLUSION

We will not pay for loss caused by windstorm or hail, including windstorm during
a hurricane, to:

1. Paint; or
2. Waterproofingmaterial;

applied to the exterior of any building or structure covered under this policy, unless
the building or structure to which such loss occurs also sustains other loss by
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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

windstorm or hail in the course ofthe same storm event. But such coverage applies
only if windstorm or hail is a covered Peril Insured Against under Section I.

All other provisions of this policy apply.

FIFTEENTH DEFENSE
Failure to Provide Notice for Loss of Use and Personal Property

Universal asserts that Plaintiffs' claim for loss of use and personal property should be

barred in whole for failing to satisfy a condition precedent for filing suit. Specifically, Plaintiffs

failed to submit a Sworn Proof of Loss claiming a loss of use or personal property as part of their

Loss in Plaintiffs' Sworn Proof of Loss dated December 19,2020.

The policy states in pertinent part

UPCIC HO3 15 05 18

SECTION I -

CONDITIONS

a representative of either:
9. Send to us, within 60 days after our request, your signed, sworn proof of loss
which sets forth, to the best of your knowledge and belief.
a. The time and cause of loss;
b. The interests of all "insureds" and all others in the property involved and allliens
on the property;

c. Other insurance which may cover the loss;
d. Changes in title occupancy of the property during the term of the
or policy;
e. Specifications of damaged buildings and detailed repair estimates;
f. The inventory of damaged personal property described in C.6. above;
g. Receipts for additional living expenses incurred and records that support the fair
rental value loss; and

Pursuant to the Policy, Plaintiffs failed to provide Universal notice of any damaged

personal property or for incurred additional living expenses for loss of use. Under Florida law,

Universal shall not be responsible for paying any monies if it was not advised as to the basis for a

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

dispute during the adjustment process and/or it did not receive notice of a supplemental claim

pursuant to the above Policy language. See Slayton v. Universal Property & Casualty, Ins. Co.,

103 So. 3d 934 (Fla. 5th DCA 2012).

Universal reserves the right to add additional affirmative defenses and avoidances which

may become known as
discovery proceeds.

WHEREFORE, Universal Property and Casualty Insurance Company, having answered

the Complaint and demonstrated by virtue of its denials and Affirmative Defenses that Plaintiffs

are not entitled to relief against Universal, respectfully requests this Court enter a judgment in its

favor and for any other or further relief it may be entitled to under law or that this Court deems

just or equitable.

DEMAND FOR JURY TRIAL

UNIVERSALPROPERTY & CASUALTY INSURANCE COMPANY demands a jury

trial of all matters so triable.

[REMAINDER OF PAGE INTENTIONALLYLEFT BLANKI

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Peter and Monica Treppeda v. UPCIC
Case No.: CACE-21-007431

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via

EService to: Daniel M. Ilani, Esq., the Property People FL, PA.

and Counsel for Plaintiffs,

on the 9th day of June, 2021.

Attorney for Defendant
Universal Property & Casualty Ins. Co.
P.O. Box 9388
FortLauderdale, FL 33310
Telephone: 833-658-8594
Facsimile: 954-958-1262

By-. /sl Lindsay C. Tropnas
Lindsay C. Tropnas, Esq.
Florida Bar No. 1003699

For Service of Court Documents onlv:

Primary:
Secondary:
Tertiary:

Case Info

Judge

Robinson, Michael A. Track Judge’s New Case

Case No.

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Document Filed Date

June 09, 2021

Case Filing Date

April 13, 2021

County

Parties

Ilani, Daniel Moshe Attorney for the Plaintiff
Morgan, Michel Alexis, ESQ. Attorney for the Defendant
Treppeda, Monica Plaintiff
Treppeda, Peter Plaintiff
United Property & Casualty Insurance Company, Inc. Defendant
Universal Property & Casualty Insurance Company Defendant
Rafael Reyes Attorney
Joseph Henn Attorney
Nicole Houman Attorney
Annette Vera Attorney
Joseph Prillaman Attorneys for Plaintiffs
Daniel Lake Attorneys for Defendants
Lindsay Tropnas Attorney
Daniel Feld Attorney
Cindy Niad-Hannah Attorney
Alicia Pokhoy Attorney

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Jury Demand: Peter Treppeda, et al Plaintiff vs. United Property & Casualty Insurance Company, Inc., et al Defendant

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