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Filing # 129715176 E-Filed 06/29/2021 12:42:08 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-010660
ANNETTE BOWDEN, an individual, and
FRANKLIN BOWDEN, an individual,
Plaintiffs,
V
TOWER HILL PREFERRED INSURANCE
COMPANY, a Florida Corporation
Defendant.
DEFENDANT'S ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF'S
STATEMENT OF CLAIM AND DEMAND FOR JURY TRIAL
The Defendant, TOWER HILL PREFERRED INSURANCE COMPANY (hereinafter"Tower
Hill"), by and through the undersignedcounsel, hereby files its Answer and Affirmative Defenses to
the Complaint of Plaintiff's ANNETTE BOWDEN and FRANKLIN BOWDEN (hereinafter
"Plaintiff'). As grounds thereof, Tower Hill states the following:
1. Admitted for jurisdictional and venue purposes only. Otherwise, Denied and demand
strict proof thereo f.
2. TOWER HILL is without knowledge and therefore, denies same and demands strict
proof thereof.
3. TOWER HILL is without knowledge and therefore, denies same and demands strict
proof thereof.
4. Admitted that TOWER HILL was and is an insurance company that conducted
business in Broward County for venue purposes only.
5. Admitted.
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***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/29/2021 12:42:07 PM.****
6. Admitted
7. Denied and demand strict proof thereof.
FACTUAL BACKGROUND
8 Admitted to the extent that Tower Hill issued an insurance policy, number
9002485439, subject to all terms, conditions, limitations, and exclusions contained therein for the
property located at 6562 NW 16th Court, Margate, FL 33063. Tower Hill is in possession ofthe subject
policy. Further, Exhibit "A" speaks for itself. Tower Hill denies any remaining allegations or
inferences contained within Paragraph 8 and demands strict proof thereof.
9- Tower Hill asserts the "Best Evidence Rule" that the Policy, when viewed in its
entirety, is the best evidence of the agreement between the Parties. Tower Hill admits the policy was
in full force and effect, subj ect to all terms, conditions, limitations, and exclusions contained therein
for the policy period of January 30,2020 through January 30, 2021. Denied as to any remaining
allegations in Paragraph 9 or inference therein and demand strict proof thereof.
10. Denied and demands strict proof thereof.
11. Tower Hill asserts the "Best Evidence Rule" that the Policy, when viewed in its
entirety, is the best evidence ofthe agreement between the Parties. Denies as phrased as to the rest of
the allegations in Paragraph 11 or inference therein and demand strict proof thereof.
12. Denied and demand strict proof thereof.
13. Admitted to the extent that upon notice of the alleged loss, Tower Hill assigned claim
number 3300362544. Denied to the rest of the allegations in Paragraph 13 or inference therein and
demand strict proofthereof
14. Denied and demand strict proof thereof.
15. Denied and demand strict proof thereof.
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16. TOWER HILL is without knowledge and therefore, denies same and demands strict
proof thereo f.
17. Tower Hill states Chapter 627.428, Florida Statutes speaks for itself. Tower Hill denies
Plaintiffs are entitled to attorney's fees.
BREACH OF CONTRACT
18. Tower Hill adopts and reallegesparagraphs 1 through 14 above.
19. Denied.
20. Denied and demand strict proof thereof.
Tower Hill hereby specifically DENIES that Plaintiffis entitled to any of the relief sought in
the subj ect Complaint and moves to strike all damages prayed for in the "WHEREFORE" clause
following Paragraph 20 of Plaintiff's Complaint, including but not limited to interest, costs, fees and
demands strict proof thereof. Further, any and all allegations of the Complaint filed herein not
hereinbeforeor hereinafterspecifically Admitted are Denied, and strict proof is demanded thereof.
DEMAND FOR JURY TRIAL
Tower Hill hereby demands trial by jury for all issues so triable.
AFFIRMATIVE DEFENSES
Tower Hill expressly reserves the right to amend its affirmative defenses. Tower Hill
affirmatively states that it is entitled to compliance with and application of the entirety of the terms,
conditions, definitions and requirements of the subject policy. In addition, Tower Hill affirmatively
states as follows:
FIRST AFFIRMATIVEDEFENSE
The damages alleged in Plaintiff's Complaint, or a portion of same, are specifically excluded
from coverage by the subject property, as the Plaintifffailed to comply with the terms and conditions
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of the subject policy prior to filing suit against Tower Hill. In support thereof, the subject policy
states as follows:
SECTION 1 -
CONDITIONS
2. Your Duties After Loss is deleted and replacedby the following:
2. 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:
a. Give prompt notice to us or your insurance agent;
Except for Reasonable Emergency Measures taken under SECTION I -
ADDITIONAL
COVERAGES, 2. REASONABLE EMERGENCY MEASURES, there is no coverage for
repairs that begin the earlierof:
(1) 72 hours after we are notified of the loss;
(2) The time of loss inspection by us; or
(3) The time of other approval by us;
e. Protect the covered property from further damage. The following must be performed:
(1) Take reasonable emergency measured that are necessary to protect the covered property
from further damage, as provided under SECTION I ADDITIONAL COVERAGES 2.
-
Reasonable Emergency Measures.
A reasonable emergency measure under
2.e.(1) 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
(2) Keep an accurate record ofrepair expenses;
8. Suit Against Us.
If you and we fail to agree on a settlement,scope or repair, or method or repairregarding the
loss, prior to filing suit, you must notify us o f your disagreement in writing.
No legal action call be brought against us unless the Section I policy provisions have been
complied with and the action is started within 5 years from the date of loss.
Specifically, the Plaintiff completely failed to promptly give notice of the loss as the alleged
date of loss was November 8,2020, and Tower Hill was not notified until December 9,2020, which
was 32 days after the reported date of loss. Additionally, the Plaintiff failed to protect the property
from further damages as no tarpaulin was placed on the roof and no water mitigation was performed.
Further, Plaintiff had trees removed from the property and did not retain any receipts or provide
photographs of these downed trees. Lastly, after receiving the denial letter, Plaintiffs did not contact
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Tower Hill to dispute the loss prior to filing suit. Thus, the Insured failed to promptly report the loss,
failed to protect the property from further damages and failed to comply with various other post-loss
conditions and Tower Hill's investigationof the claim was prejudiced.
SECOND AFFIRMATIVE DEFENSE
The damages alleged in Plaintiff's Complaint, or a portion of same, are specifically excluded
from coverage by the subject policy, or were not caused by a covered peril under the provisions ofthe
subject policy and all applicable endorsements thereto, includingbut not limited to the following:
COVERAGE A -
DWELLING and COVERAGE B -
OTHER STRUCTURES
We insure against risk of direct loss to property described in Coverages A and B only if that
loss is a physical loss to property. We do not insure, however, for loss:
2. Caused by:
e. Any ofthe following:
(1) wear and tear, marring, deterioration;
(2) Inherent vice, latent defect, mechanical breakdown;
(6) Settling, shrinking, bulging or expansion, including resultant cracking, of pavements,
patios, foundations, walls, floors, roofs or ceilings;
In form HO 00 03,2.h. is added under COVERAGE A -
DWELLING AND COVERAGE
B -
OTHER STRUCTURES:
Specifically, Tower Hill's investigationrevealedthat there were no signs ofwindstorm damage
to this property's roof. The investigationdid reveal that this property has a roofthatwas approximately
twenty (20) years old at the time of the inspection and was in an overall aged condition. Additionally,
there were circular abrasions to the shingles indicating of repetitive scraping from tree branches over
years, and not a one time storm event.
THIRD AFFIRMATIVE DEFENSE
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The damages alleged in Plaintiff's Complaint, or a portion of same, are specifically excluded
from coverage by the subject policy, or were not caused by a covered peril under the provisions ofthe
subject policy and all applicable endorsements thereto, includingbut not limited to the following:
SECTION I -
EXCLUSIONS
2. We do noinsure for loss to property described in Coverages A and B caused by any of
the following. However, any ensuing loss to property described in Coverages A and B not
excepted in this policy is covered.
excluded or
c.
Faulty, inadequate or defective:
(1) Planning, zoning, development,surveying, siting;
(2) Design, specifications,workmanship,repair, construction,renovation, remodeling,
grading, compaction;
(3) Materials used in repairs, construction,renovation or remodeling; or
(4) Maintenance;
Ofpart or all of any property whether on or offthe "residence premises"
The following exclusions are added:
The following exclusions are added:
Neglect, Exclusion 1.e. is deleted and replaced by the following:
e.
Neglect, meaning neglect of any "insured" to use all reasonable means to save and
preserve property at and after the time of a loss.
k. Constant repeated seepage or leakage of water or steam, or the presence or condensation
or
of humidity, moisture
or vapor; which occurs over a period o f 14 or more days, unless the
resulting damage:
(1) Is unknown to all "insureds"; and
For the purpose o f this provision:
(1) Damage is not unknown if it would have been discovered during a reasonable inspection
by any "insured"; and
(2) Damage is not hidden:
(a) If visible on the surface o f walls, ceilings, or floors, or located within cabinets or similar
structures; or
Specifically, Tower Hill's investigation revealed that the roof exhibited signs of long-term
deterioration and deferred maintenance over a period of years and not a one-time storm event.
Additionally, the flat roof isn't properly sloped causing ponding of water. Lastly, the interior ceiling
stains and porch deterioration are dark in color and are lighter in color in the center of the stains
evidencing cycles ofwetting and drying occurring for more than 14 days and are readily apparent and
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visible to the naked eye. Lastly, despite readily apparent water intrusion, the Insureds failed to have a
tarp placed on the property and failed to have water mitigation performed in order to mitigate the
damages to the property.
THIRD AFFIRMATIVE DEFENSE
The damages alleged in Plaintiffs Complaint, or a portion of same, are specifically excluded
from coverage by the subject policy, or were not caused by a covered peril under the provisions ofthe
subject policy and all applicable endorsements thereto, includingbut not limited to the following:
EXISTING DAMAGE EXCLUSIONENDORSEMENT
Under Section I -
Exclusions, the following is added:
It is understoodand agreed that this policy is not intended to and does not provide coverage
for any damages which occurred prior to policy inception regardless of whether such
damages were apparent at the time of the inception of this policy.
It is also understoodand agreed that this policy is not intended to and does not provide
coverage for any claims or damages arising out of workmanship,repairs and/or lack of
repairs arising from damage which occurred prior to policy inception.
This exclusion does not apply in the event of a total loss caused by a covered peril.
Specifically, Tower Hill's investigationrevealed damages to the roof dating back to 2016 in
the same areas of damage being alleged in the subject loss. Therefore, Plaintiffis precluded from
recovery for the damages that pre-date the subject date of loss.
FOURTH AFFIRMATIVE DEFESE
In the event that Plaintiffis found to be entitled to recover in this action, Tower Hill is entitled
to a set-off for the full amount of any applicable deductible under the policy, which in this case is
$4,640.00, or
any endorsement to the policy or any endorsement to the policy.
WHEREFORE, the Defendant, TOWER HILL PREFERRED INSURANCE COMPANY,
demands Judgment against Plaintiffs, ANNETTE BOWDEN and FRANKLIN BOWDEN, for costs
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and all other damages this Court deems just and equitable, and further demands a trial by jury of all
issues so triable as o f right by a jury.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a complete copy ofthe foregoing instrument has been served on
June 29, 2021 on Bradley Weiss, Esq., Benson, Mucci & Weiss, P.L. 5561 North University Drive,
Suite 102, Coral Springs, FL 33067, counsel of record for the Plaintiffs, by electronic filing via the e-
portal to all e-mail addresses listed for counsel, and to
and
PARAFINCZUK WOLF, P.A.
Counsel for Defendant
110 East Broward Boulevard, Suite 1630
Ft. Lauderdale, Florida 33301
Telephone: (954) 462-6700
Facsimile: (954) 462-6567
By: /s/ Rachel C. Lucuara
JASON B. WOLF, ESQ.
Fla. Bar No. 42951
RACHEL COWEN LUCUARA, ESQ.
Fla. Bar No. 1010540
For Service of Court Documents Only:
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Filing # 129715176 E-Filed 06/29/2021 12:42:08 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-010660 ANNETTE BOWDEN, an individual, and FRANKLIN BOWDEN, an individual, Plaintiffs, V TOWER HILL PREFERRED INSURANCE COMPANY, a Florida Corporation Defendant. DEFENDANT'S ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF'S STATEMENT OF CLAIM AND DEMAND FOR JURY TRIAL The Defendant, TOWER HILL PREFERRED INSURANCE COMPANY (hereinafter"Tower Hill"), by and through the undersignedcounsel, hereby files its Answer and Affirmative Defenses to the Complaint of Plaintiff's ANNETTE BOWDEN and FRANKLIN BOWDEN (hereinafter "Plaintiff'). As grounds thereof, Tower Hill states the following: 1. Admitted for jurisdictional and venue purposes only. Otherwise, Denied and demand strict proof thereo f. 2. TOWER HILL is without knowledge and therefore, denies same and demands strict proof thereof. 3. TOWER HILL is without knowledge and therefore, denies same and demands strict proof thereof. 4. Admitted that TOWER HILL was and is an insurance company that conducted business in Broward County for venue purposes only. 5. Admitted. 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/29/2021 12:42:07 PM.**** 6. Admitted 7. Denied and demand strict proof thereof. FACTUAL BACKGROUND 8 Admitted to the extent that Tower Hill issued an insurance policy, number 9002485439, subject to all terms, conditions, limitations, and exclusions contained therein for the property located at 6562 NW 16th Court, Margate, FL 33063. Tower Hill is in possession ofthe subject policy. Further, Exhibit "A" speaks for itself. Tower Hill denies any remaining allegations or inferences contained within Paragraph 8 and demands strict proof thereof. 9- Tower Hill asserts the "Best Evidence Rule" that the Policy, when viewed in its entirety, is the best evidence of the agreement between the Parties. Tower Hill admits the policy was in full force and effect, subj ect to all terms, conditions, limitations, and exclusions contained therein for the policy period of January 30,2020 through January 30, 2021. Denied as to any remaining allegations in Paragraph 9 or inference therein and demand strict proof thereof. 10. Denied and demands strict proof thereof. 11. Tower Hill asserts the "Best Evidence Rule" that the Policy, when viewed in its entirety, is the best evidence ofthe agreement between the Parties. Denies as phrased as to the rest of the allegations in Paragraph 11 or inference therein and demand strict proof thereof. 12. Denied and demand strict proof thereof. 13. Admitted to the extent that upon notice of the alleged loss, Tower Hill assigned claim number 3300362544. Denied to the rest of the allegations in Paragraph 13 or inference therein and demand strict proofthereof 14. Denied and demand strict proof thereof. 15. Denied and demand strict proof thereof. 2 16. TOWER HILL is without knowledge and therefore, denies same and demands strict proof thereo f. 17. Tower Hill states Chapter 627.428, Florida Statutes speaks for itself. Tower Hill denies Plaintiffs are entitled to attorney's fees. BREACH OF CONTRACT 18. Tower Hill adopts and reallegesparagraphs 1 through 14 above. 19. Denied. 20. Denied and demand strict proof thereof. Tower Hill hereby specifically DENIES that Plaintiffis entitled to any of the relief sought in the subj ect Complaint and moves to strike all damages prayed for in the "WHEREFORE" clause following Paragraph 20 of Plaintiff's Complaint, including but not limited to interest, costs, fees and demands strict proof thereof. Further, any and all allegations of the Complaint filed herein not hereinbeforeor hereinafterspecifically Admitted are Denied, and strict proof is demanded thereof. DEMAND FOR JURY TRIAL Tower Hill hereby demands trial by jury for all issues so triable. AFFIRMATIVE DEFENSES Tower Hill expressly reserves the right to amend its affirmative defenses. Tower Hill affirmatively states that it is entitled to compliance with and application of the entirety of the terms, conditions, definitions and requirements of the subject policy. In addition, Tower Hill affirmatively states as follows: FIRST AFFIRMATIVEDEFENSE The damages alleged in Plaintiff's Complaint, or a portion of same, are specifically excluded from coverage by the subject property, as the Plaintifffailed to comply with the terms and conditions 3 of the subject policy prior to filing suit against Tower Hill. In support thereof, the subject policy states as follows: SECTION 1 - CONDITIONS 2. Your Duties After Loss is deleted and replacedby the following: 2. 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: a. Give prompt notice to us or your insurance agent; Except for Reasonable Emergency Measures taken under SECTION I - ADDITIONAL COVERAGES, 2. REASONABLE EMERGENCY MEASURES, there is no coverage for repairs that begin the earlierof: (1) 72 hours after we are notified of the loss; (2) The time of loss inspection by us; or (3) The time of other approval by us; e. Protect the covered property from further damage. The following must be performed: (1) Take reasonable emergency measured that are necessary to protect the covered property from further damage, as provided under SECTION I ADDITIONAL COVERAGES 2. - Reasonable Emergency Measures. A reasonable emergency measure under 2.e.(1) 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 (2) Keep an accurate record ofrepair expenses; 8. Suit Against Us. If you and we fail to agree on a settlement,scope or repair, or method or repairregarding the loss, prior to filing suit, you must notify us o f your disagreement in writing. No legal action call be brought against us unless the Section I policy provisions have been complied with and the action is started within 5 years from the date of loss. Specifically, the Plaintiff completely failed to promptly give notice of the loss as the alleged date of loss was November 8,2020, and Tower Hill was not notified until December 9,2020, which was 32 days after the reported date of loss. Additionally, the Plaintiff failed to protect the property from further damages as no tarpaulin was placed on the roof and no water mitigation was performed. Further, Plaintiff had trees removed from the property and did not retain any receipts or provide photographs of these downed trees. Lastly, after receiving the denial letter, Plaintiffs did not contact 4 Tower Hill to dispute the loss prior to filing suit. Thus, the Insured failed to promptly report the loss, failed to protect the property from further damages and failed to comply with various other post-loss conditions and Tower Hill's investigationof the claim was prejudiced. SECOND AFFIRMATIVE DEFENSE The damages alleged in Plaintiff's Complaint, or a portion of same, are specifically excluded from coverage by the subject policy, or were not caused by a covered peril under the provisions ofthe subject policy and all applicable endorsements thereto, includingbut not limited to the following: COVERAGE A - DWELLING and COVERAGE B - OTHER STRUCTURES We insure against risk of direct loss to property described in Coverages A and B only if that loss is a physical loss to property. We do not insure, however, for loss: 2. Caused by: e. Any ofthe following: (1) wear and tear, marring, deterioration; (2) Inherent vice, latent defect, mechanical breakdown; (6) Settling, shrinking, bulging or expansion, including resultant cracking, of pavements, patios, foundations, walls, floors, roofs or ceilings; In form HO 00 03,2.h. is added under COVERAGE A - DWELLING AND COVERAGE B - OTHER STRUCTURES: Specifically, Tower Hill's investigationrevealedthat there were no signs ofwindstorm damage to this property's roof. The investigationdid reveal that this property has a roofthatwas approximately twenty (20) years old at the time of the inspection and was in an overall aged condition. Additionally, there were circular abrasions to the shingles indicating of repetitive scraping from tree branches over years, and not a one time storm event. THIRD AFFIRMATIVE DEFENSE 5 The damages alleged in Plaintiff's Complaint, or a portion of same, are specifically excluded from coverage by the subject policy, or were not caused by a covered peril under the provisions ofthe subject policy and all applicable endorsements thereto, includingbut not limited to the following: SECTION I - EXCLUSIONS 2. We do noinsure for loss to property described in Coverages A and B caused by any of the following. However, any ensuing loss to property described in Coverages A and B not excepted in this policy is covered. excluded or c. Faulty, inadequate or defective: (1) Planning, zoning, development,surveying, siting; (2) Design, specifications,workmanship,repair, construction,renovation, remodeling, grading, compaction; (3) Materials used in repairs, construction,renovation or remodeling; or (4) Maintenance; Ofpart or all of any property whether on or offthe "residence premises" The following exclusions are added: The following exclusions are added: Neglect, Exclusion 1.e. is deleted and replaced by the following: e. Neglect, meaning neglect of any "insured" to use all reasonable means to save and preserve property at and after the time of a loss. k. Constant repeated seepage or leakage of water or steam, or the presence or condensation or of humidity, moisture or vapor; which occurs over a period o f 14 or more days, unless the resulting damage: (1) Is unknown to all "insureds"; and For the purpose o f this provision: (1) Damage is not unknown if it would have been discovered during a reasonable inspection by any "insured"; and (2) Damage is not hidden: (a) If visible on the surface o f walls, ceilings, or floors, or located within cabinets or similar structures; or Specifically, Tower Hill's investigation revealed that the roof exhibited signs of long-term deterioration and deferred maintenance over a period of years and not a one-time storm event. Additionally, the flat roof isn't properly sloped causing ponding of water. Lastly, the interior ceiling stains and porch deterioration are dark in color and are lighter in color in the center of the stains evidencing cycles ofwetting and drying occurring for more than 14 days and are readily apparent and 6 visible to the naked eye. Lastly, despite readily apparent water intrusion, the Insureds failed to have a tarp placed on the property and failed to have water mitigation performed in order to mitigate the damages to the property. THIRD AFFIRMATIVE DEFENSE The damages alleged in Plaintiffs Complaint, or a portion of same, are specifically excluded from coverage by the subject policy, or were not caused by a covered peril under the provisions ofthe subject policy and all applicable endorsements thereto, includingbut not limited to the following: EXISTING DAMAGE EXCLUSIONENDORSEMENT Under Section I - Exclusions, the following is added: It is understoodand agreed that this policy is not intended to and does not provide coverage for any damages which occurred prior to policy inception regardless of whether such damages were apparent at the time of the inception of this policy. It is also understoodand agreed that this policy is not intended to and does not provide coverage for any claims or damages arising out of workmanship,repairs and/or lack of repairs arising from damage which occurred prior to policy inception. This exclusion does not apply in the event of a total loss caused by a covered peril. Specifically, Tower Hill's investigationrevealed damages to the roof dating back to 2016 in the same areas of damage being alleged in the subject loss. Therefore, Plaintiffis precluded from recovery for the damages that pre-date the subject date of loss. FOURTH AFFIRMATIVE DEFESE In the event that Plaintiffis found to be entitled to recover in this action, Tower Hill is entitled to a set-off for the full amount of any applicable deductible under the policy, which in this case is $4,640.00, or any endorsement to the policy or any endorsement to the policy. WHEREFORE, the Defendant, TOWER HILL PREFERRED INSURANCE COMPANY, demands Judgment against Plaintiffs, ANNETTE BOWDEN and FRANKLIN BOWDEN, for costs 7 and all other damages this Court deems just and equitable, and further demands a trial by jury of all issues so triable as o f right by a jury. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a complete copy ofthe foregoing instrument has been served on June 29, 2021 on Bradley Weiss, Esq., Benson, Mucci & Weiss, P.L. 5561 North University Drive, Suite 102, Coral Springs, FL 33067, counsel of record for the Plaintiffs, by electronic filing via the e- portal to all e-mail addresses listed for counsel, and to and PARAFINCZUK WOLF, P.A. Counsel for Defendant 110 East Broward Boulevard, Suite 1630 Ft. Lauderdale, Florida 33301 Telephone: (954) 462-6700 Facsimile: (954) 462-6567 By: /s/ Rachel C. Lucuara JASON B. WOLF, ESQ. Fla. Bar No. 42951 RACHEL COWEN LUCUARA, ESQ. Fla. Bar No. 1010540 For Service of Court Documents Only: 8