On May 02, 2018 a
Party Discovery
was filed
involving a dispute between
Creekside Clearwater Llc,
and
Scottsdale Insurance Company,
for INSURANCE CLAIMS - CIRCUIT
in the District Court of Pinellas County.
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Case Number:18-002801-CI
Filing # 71550480 E-Filed 05/02/2018 10:35:48 AM
IN THE CIRCUIT COURT IN AND FOR
PINELLAS COUNTY, FLORIDA
CASE NO.
CREEKSIDE CLEARWATER, LLC,
Plaintifi(s),
vs.
SCOTTSDALE INSURANCE COMPANY,
Defendant.
I
REQUEST FOR ADMISSIONS
Plaintiff(s), pursuant to Florida Rule of Civil Procedure 1.370, request the
Defendant, SCOTTSDALE INSURANCE COMPANY, a corporation authorized and
doing business in the state of Florida, serve a response to the following request for
admissions:
1. Defendant issued a policy of insurance to Plaintiff(s) (“Policy”) for the
property located at 1280 Druid Road E, Clearwater, Florida (“Commercial property”).
2. At all material times, Plaintiff(s) had an insurable interest in the
Commercial property.
3. The Commercial property sustained direct physical damage as a result of
a water leak which occurred on or about October 4, 2017, while the Policy was in full
force and effect (the “Ioss”).
4. Defendant was notified of the loss pursuant to the terms and conditions of
the Policy.
***ELECTRONICALLY FILED 05/02/2018 10:35:46 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
5. Plaintiff(s) submitted an insurance claim to Defendant (the “claim”)
pursuant to the terms and conditions of the Policy.
6. Plaintiff(s) did not cause prejudice to Defendant during its investigation of
the claim.
7. As of the date of this lawsuit, there were no outstanding requests by
Defendant for documents or information in connection with its investigation and
adjustment of the claim.
8. Plaintiff(s) complied with all duties after a loss pursuant to the Policy.
9. The Policy provides coverage for any and all sudden and accidental
physical damage to the Commercial property that is not otherwise excluded or excepted
by the policy.
10. The Policy provides coverage for “all risks” of loss to the Commercial
property.
11. The Policy provides benefits on a “Replacement Cost Value” basis for
covered losses to the Commercial property subject to the policy limits.
12. In the event of a covered loss to the Commercial property, the Policy
provides benefits to repair or replace damaged or destroyed property, without deducting
for depreciation.
13. In the event of a covered loss to the Commercial property, the Policy
requires Defendant to pay benefits on a “Replacement Cost Value” basis, irrespective of
whether Plaintiff(s) actually repair or replace the damaged property.
Dated: May 2, 2018 /
Bradford L. Stewart
Florida Bar No. 015760
The Nation Law Firm, LLP
5151 S. Lakeland Drive, Suite 2
Lakeland, FL 33813
Telephone: (863) 940-5350
Facsimile: (863) 940-5380
Primary Email: mszutz@nation|aw.com
Secondary Email: bstewart@nationlaw.com
Attorneys for Plaintiff(s)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served
upon the Defendant’s Registered Agent, State of Florida, Chief Financial Officer, 200 E.
Gaines St., Tallahassee, FL 32399, by service of process ontemporaneously with the
Complaint in this matter.
Bradford LUStewart
Document Filed Date
May 02, 2018
Case Filing Date
May 02, 2018
Category
INSURANCE CLAIMS - CIRCUIT
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Case Number:18-002801-CI Filing # 71550480 E-Filed 05/02/2018 10:35:48 AM IN THE CIRCUIT COURT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NO. CREEKSIDE CLEARWATER, LLC, Plaintifi(s), vs. SCOTTSDALE INSURANCE COMPANY, Defendant. I REQUEST FOR ADMISSIONS Plaintiff(s), pursuant to Florida Rule of Civil Procedure 1.370, request the Defendant, SCOTTSDALE INSURANCE COMPANY, a corporation authorized and doing business in the state of Florida, serve a response to the following request for admissions: 1. Defendant issued a policy of insurance to Plaintiff(s) (“Policy”) for the property located at 1280 Druid Road E, Clearwater, Florida (“Commercial property”). 2. At all material times, Plaintiff(s) had an insurable interest in the Commercial property. 3. The Commercial property sustained direct physical damage as a result of a water leak which occurred on or about October 4, 2017, while the Policy was in full force and effect (the “Ioss”). 4. Defendant was notified of the loss pursuant to the terms and conditions of the Policy. ***ELECTRONICALLY FILED 05/02/2018 10:35:46 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 5. Plaintiff(s) submitted an insurance claim to Defendant (the “claim”) pursuant to the terms and conditions of the Policy. 6. Plaintiff(s) did not cause prejudice to Defendant during its investigation of the claim. 7. As of the date of this lawsuit, there were no outstanding requests by Defendant for documents or information in connection with its investigation and adjustment of the claim. 8. Plaintiff(s) complied with all duties after a loss pursuant to the Policy. 9. The Policy provides coverage for any and all sudden and accidental physical damage to the Commercial property that is not otherwise excluded or excepted by the policy. 10. The Policy provides coverage for “all risks” of loss to the Commercial property. 11. The Policy provides benefits on a “Replacement Cost Value” basis for covered losses to the Commercial property subject to the policy limits. 12. In the event of a covered loss to the Commercial property, the Policy provides benefits to repair or replace damaged or destroyed property, without deducting for depreciation. 13. In the event of a covered loss to the Commercial property, the Policy requires Defendant to pay benefits on a “Replacement Cost Value” basis, irrespective of whether Plaintiff(s) actually repair or replace the damaged property. Dated: May 2, 2018 / Bradford L. Stewart Florida Bar No. 015760 The Nation Law Firm, LLP 5151 S. Lakeland Drive, Suite 2 Lakeland, FL 33813 Telephone: (863) 940-5350 Facsimile: (863) 940-5380 Primary Email: mszutz@nation|aw.com Secondary Email: bstewart@nationlaw.com Attorneys for Plaintiff(s) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the Defendant’s Registered Agent, State of Florida, Chief Financial Officer, 200 E. Gaines St., Tallahassee, FL 32399, by service of process ontemporaneously with the Complaint in this matter. Bradford LUStewart