On December 21, 2021 a
Party Notice
was filed
involving a dispute between
Borras, Alfred,
Perdomo Borras, Dania,
and
Universal Property & Casualty Insurance Company,
for 3
in the District Court of Broward County.
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Filing# 144352098 E-Filed 02/22/2022 12:25:57 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICAL
CIRCUIT
IN
AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-022304
ALFRED BORRAS AND DANIA PERDOMO BORRAS,
Plaintiffs,
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
NOTICE OF FILING SUPPLEMENTAL, PERSUASIVE AUTHORITY
IN SUPPORT OF UNIVERSAL'S MOTION TO DISMISS
FOR NON-COMPLIANCE WITH FLA. STAT. 6 627.70152
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
("Defendant"),by and through its undersigned counsel, hereby files the followingattached
supplemental,persuasiveauthorityin support of its Motion to Dismiss for Non-Compliance with
Fla. Stat. § 627.70152:
15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY
A. October 19, 2021 Order by Circuit Court Judge Janis Brustares Keyser in Palm Beach
County grantingDefendant's Motion to Dismiss for Non-Compliance with Fla. Stat. §
627.70152 [FloridaE-Portal FilingNo. 136857942, which was E-Filed 10/19/2021 at
3:44:50 PMI. See Exhibit "A".
B. October 12, 2021 Order by Circuit Court Judge Bradley Harper in Palm Beach County
granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. §
627.70152 [FloridaE-Portal FilingNo. 136410051, which was E-Filed 10/12/202 1 at
4:18:26 PMI. See Exhibit "B".
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/22/2022 12:25:56 PM.****
Alfred Borras et al v. UPCIC
Case No.: CACE-21-022304
Page 2 of 3
18TH JUDICIAL CIRCUIT IN AND FOR SEMINOLE COUNTY
C. October 7, 2021 Order by County Court Judge Frederic Schott in Seminole County
granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. §
627.70152 [FloridaE-Portal FilingNo. 136184425, which was E-Filed 10/08/2021 at
11:22:30 AMJ. See Eihibit"C'.
19T,w JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY
D. October 15, 2021 Order by Circuit Court Judge Laurie E. Buchanan in St. Lucie County
granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. §
627.70152 [Florida E-Portal FilingNo. 136675435, which was E-Filed 10/15/2021 at
4:32:05 PMI. See Exhibit "D".
17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY
E. November 2, 2021 Order by Circuit Court Judge Michael Robinson in Broward County
granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. §
627.70152 [Florida E-Portal FilingNo. 137774753 E-Filed 11/02/2021 06:59:56
PM/. See Exhibit "E".
F. November 16, 2021 Order by Circuit Court Judge John Bowman in Broward County
granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. §
627.70152 [Florida E-Portal Filing No. 138662502 E-Filed 11/16/2021 07:56:12
PM/. See Exhibit "F".
G. January 4,2022 Order by Circuit Court Judge Carlos A. Rodriguez in Broward County
granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. §
627.70152 [Florida E-Portal Filing No. 141347830 E-Filed 01/04/2022 06:42:08
PM/. See Exhibit "G".
5 r,w JUDICIAL CIRCUIT IN AND FOR MARION COUNTY
H. September 27, 2021 Order by County Court Judge R. James McCune, Jr. in Marion
County grantingDefendant's Motion to Dismiss for Non-Compliance with Fla. Stat. §
627.70152 [FloridaE-Portal FilingNo. 135632322, which was E-Filed 09/30/2021 at
9:57:25 AM].See, Exhibit "H".
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
Alfred Borras et al v. UPCIC
Case No.: CACE-21-022304
Page 3 of 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via
eService to: Joshua Neuman, Esq., Insurance Litigation Group P.A., service@ilgpa.com,
steven@ilgpa.com,Counsel for Plaintiffs',
on the 22nd day of February,2022.
Attorneyfor Defendant
Universal Property& CasualtyInsurance Company
P.O. Box 9388
Fort Lauderdale, Florida 33309
Telephone: (954) 958-3319
Toll-Free: 1-833-658-8594 (JudgesOnly)
Facsimile: (954)958-1262
By: /s/ Jasmine Jackson
Jasmine Jackson, Esq.
Florida Bar No. 1007979
For Service of Court Documents onlv:
Primary: upciceservice06@universalproperty.com
Secondary:jal130@universalproperty.com
*Please do not send any inquiriesor schedulingmatters to upciceservice@universalpropertv.com
or upciceservice06@universalpropertv.com.
Document Filed Date
February 22, 2022
Case Filing Date
December 21, 2021
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Filing# 144352098 E-Filed 02/22/2022 12:25:57 PM IN THE CIRCUIT COURT OF THE 17TH JUDICAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-022304 ALFRED BORRAS AND DANIA PERDOMO BORRAS, Plaintiffs, VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. NOTICE OF FILING SUPPLEMENTAL, PERSUASIVE AUTHORITY IN SUPPORT OF UNIVERSAL'S MOTION TO DISMISS FOR NON-COMPLIANCE WITH FLA. STAT. 6 627.70152 Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY ("Defendant"),by and through its undersigned counsel, hereby files the followingattached supplemental,persuasiveauthorityin support of its Motion to Dismiss for Non-Compliance with Fla. Stat. § 627.70152: 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY A. October 19, 2021 Order by Circuit Court Judge Janis Brustares Keyser in Palm Beach County grantingDefendant's Motion to Dismiss for Non-Compliance with Fla. Stat. § 627.70152 [FloridaE-Portal FilingNo. 136857942, which was E-Filed 10/19/2021 at 3:44:50 PMI. See Exhibit "A". B. October 12, 2021 Order by Circuit Court Judge Bradley Harper in Palm Beach County granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. § 627.70152 [FloridaE-Portal FilingNo. 136410051, which was E-Filed 10/12/202 1 at 4:18:26 PMI. See Exhibit "B". *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/22/2022 12:25:56 PM.**** Alfred Borras et al v. UPCIC Case No.: CACE-21-022304 Page 2 of 3 18TH JUDICIAL CIRCUIT IN AND FOR SEMINOLE COUNTY C. October 7, 2021 Order by County Court Judge Frederic Schott in Seminole County granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. § 627.70152 [FloridaE-Portal FilingNo. 136184425, which was E-Filed 10/08/2021 at 11:22:30 AMJ. See Eihibit"C'. 19T,w JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY D. October 15, 2021 Order by Circuit Court Judge Laurie E. Buchanan in St. Lucie County granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. § 627.70152 [Florida E-Portal FilingNo. 136675435, which was E-Filed 10/15/2021 at 4:32:05 PMI. See Exhibit "D". 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY E. November 2, 2021 Order by Circuit Court Judge Michael Robinson in Broward County granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. § 627.70152 [Florida E-Portal FilingNo. 137774753 E-Filed 11/02/2021 06:59:56 PM/. See Exhibit "E". F. November 16, 2021 Order by Circuit Court Judge John Bowman in Broward County granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. § 627.70152 [Florida E-Portal Filing No. 138662502 E-Filed 11/16/2021 07:56:12 PM/. See Exhibit "F". G. January 4,2022 Order by Circuit Court Judge Carlos A. Rodriguez in Broward County granting Defendant's Motion to Dismiss for Non-Compliance with Fla. Stat. § 627.70152 [Florida E-Portal Filing No. 141347830 E-Filed 01/04/2022 06:42:08 PM/. See Exhibit "G". 5 r,w JUDICIAL CIRCUIT IN AND FOR MARION COUNTY H. September 27, 2021 Order by County Court Judge R. James McCune, Jr. in Marion County grantingDefendant's Motion to Dismiss for Non-Compliance with Fla. Stat. § 627.70152 [FloridaE-Portal FilingNo. 135632322, which was E-Filed 09/30/2021 at 9:57:25 AM].See, Exhibit "H". [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Alfred Borras et al v. UPCIC Case No.: CACE-21-022304 Page 3 of 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via eService to: Joshua Neuman, Esq., Insurance Litigation Group P.A., service@ilgpa.com, steven@ilgpa.com,Counsel for Plaintiffs', on the 22nd day of February,2022. Attorneyfor Defendant Universal Property& CasualtyInsurance Company P.O. Box 9388 Fort Lauderdale, Florida 33309 Telephone: (954) 958-3319 Toll-Free: 1-833-658-8594 (JudgesOnly) Facsimile: (954)958-1262 By: /s/ Jasmine Jackson Jasmine Jackson, Esq. Florida Bar No. 1007979 For Service of Court Documents onlv: Primary: upciceservice06@universalproperty.com Secondary:jal130@universalproperty.com *Please do not send any inquiriesor schedulingmatters to upciceservice@universalpropertv.com or upciceservice06@universalpropertv.com.