On August 24, 2021 a
Party Discovery
was filed
involving a dispute between
Doreste, Claircilia,
and
American Security Insurance Company,
for 3
in the District Court of Broward County.
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Filing# 137572989 E-Filed 10/29/2021 04:03:45 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
Case No.: CACE-21-016223
CLAIRCILIA DORESTE,
Plaintiff,
V.
AMERICAN SECURITY INSURANCE
COMPANY,
Defendant.
I
AMERICAN SECURITY INSURANCE COMPANY'S ANSWERS AND OBJECTIONS TO
PLAINTIFFS' REQUEST FOR ADMISSIONS
AMERICAN SECURITY INSURANCE COMPANY ("American SecuritY'),
pursuant to
Florida Rule of Civil Procedure 1.370, files its Response and Objections to Plaintiffs' Request for
Admissions, and states:
1. Admit that you do not dispute the cause of loss as alleged in Paragraph 8 of the
Complaint.
Response: Denied.
2. Admit that you do not dispute the date of loss as alleged in Paragraph 8 of the
Complaint.
Response: Denied.
3. Admit that the policy described in Paragraph 5 ofthe Complaint was in full force and
effect on or about the date of loss allegedin Paragraph 8 of the Complaint.
Response: Admitted, for which coverage was subject to the terms, conditions, exclusions and
limitations of the policy.
4. Admit that complied with
Plaintiff(s) all of the post loss duties under the policy
described in Paragraph 5 ofthe Complaint.
Response: Denied.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/29/2021 04:03:44 PM.****
5. Admit that complied with
Plaintiff(s) all of the conditions precedent under the policy
described in Paragraph 5 ofthe Complaint.
Response: Denied.
6.Admit that Defendant's investigationof the loss described in Paragraph 8 of the
Complaint was not prejudicedby the acts or omissions of Plaintiff(s).
Response: Denied.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29' ith
day of October, 2021, this document was filed using
the Florida Courts E-FilingPortal. This document is being served on all counsel and pro se parties
o f record by the Florida Courts E-Filing Portal,pursuant to and in compliance with Fla. R. Jud.
Admin. 2.516. The mailing and electronic addresses are: Francisco Garcia, Morgan Law Group
P.A.mlg.eservice@morganlawgroup.net;fgarcia@morganlawgroup.net;msalva@morganlawgrou
p.com;hgarcia@morganlawgroup.com;aleon@morganlawgroup.net, 55 Merrick Way, Suite 404,
Coral Gables, FL 33134, (305) 569-9900/(305) 443-6828 (F),Attorney for Plaintiff,
Clairecilia
Doreste.
KELLEY KRONENBERG
/si Andrew.J. Zaslow
Andrew J. Zaslow, Esq.
Fla. Bar No.: 125324
azaslow@kelleykronenberg.com
JeffreyM. Wank, Esq.
Fla. Bar No.. 68010
jwank@kelleykronenberg.com
10360 West State Road 84
Fort Lauderdale, FL 33324
Telephone: (954) 370-9970
Facsimile: (954) 382-1988
Attorneys for American SecurityInsurance
Company
Address for service ofpleadingsonly
jwank@kelleykronenberg.com
azaslow@kelleykronenberg.com
cwillis@kellykronenberg.com
Document Filed Date
October 29, 2021
Case Filing Date
August 24, 2021
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Filing# 137572989 E-Filed 10/29/2021 04:03:45 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE-21-016223 CLAIRCILIA DORESTE, Plaintiff, V. AMERICAN SECURITY INSURANCE COMPANY, Defendant. I AMERICAN SECURITY INSURANCE COMPANY'S ANSWERS AND OBJECTIONS TO PLAINTIFFS' REQUEST FOR ADMISSIONS AMERICAN SECURITY INSURANCE COMPANY ("American SecuritY'), pursuant to Florida Rule of Civil Procedure 1.370, files its Response and Objections to Plaintiffs' Request for Admissions, and states: 1. Admit that you do not dispute the cause of loss as alleged in Paragraph 8 of the Complaint. Response: Denied. 2. Admit that you do not dispute the date of loss as alleged in Paragraph 8 of the Complaint. Response: Denied. 3. Admit that the policy described in Paragraph 5 ofthe Complaint was in full force and effect on or about the date of loss allegedin Paragraph 8 of the Complaint. Response: Admitted, for which coverage was subject to the terms, conditions, exclusions and limitations of the policy. 4. Admit that complied with Plaintiff(s) all of the post loss duties under the policy described in Paragraph 5 ofthe Complaint. Response: Denied. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/29/2021 04:03:44 PM.**** 5. Admit that complied with Plaintiff(s) all of the conditions precedent under the policy described in Paragraph 5 ofthe Complaint. Response: Denied. 6.Admit that Defendant's investigationof the loss described in Paragraph 8 of the Complaint was not prejudicedby the acts or omissions of Plaintiff(s). Response: Denied. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 29' ith day of October, 2021, this document was filed using the Florida Courts E-FilingPortal. This document is being served on all counsel and pro se parties o f record by the Florida Courts E-Filing Portal,pursuant to and in compliance with Fla. R. Jud. Admin. 2.516. The mailing and electronic addresses are: Francisco Garcia, Morgan Law Group P.A.mlg.eservice@morganlawgroup.net;fgarcia@morganlawgroup.net;msalva@morganlawgrou p.com;hgarcia@morganlawgroup.com;aleon@morganlawgroup.net, 55 Merrick Way, Suite 404, Coral Gables, FL 33134, (305) 569-9900/(305) 443-6828 (F),Attorney for Plaintiff, Clairecilia Doreste. KELLEY KRONENBERG /si Andrew.J. Zaslow Andrew J. Zaslow, Esq. Fla. Bar No.: 125324 azaslow@kelleykronenberg.com JeffreyM. Wank, Esq. Fla. Bar No.. 68010 jwank@kelleykronenberg.com 10360 West State Road 84 Fort Lauderdale, FL 33324 Telephone: (954) 370-9970 Facsimile: (954) 382-1988 Attorneys for American SecurityInsurance Company Address for service ofpleadingsonly jwank@kelleykronenberg.com azaslow@kelleykronenberg.com cwillis@kellykronenberg.com