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Filing # 144545810 E-Filed 02/24/2022 01:21:18 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR
MIAMI DADE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO: 2021-023723-CA-01
LUIS MADRAZO,
Plaintiff(s),
v.
CITIZENS PROPERTY INSURANCE CORPORATION,
Defendant.
_________________________________/
DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFFS
COMES NOW, the Defendant, Citizens Property Insurance Corporation (“Citizens”) by
and through undersigned counsel, and pursuant to Fla. R. Civ. P. 1.370, hereby files this First
Request for Admissions to Plaintiff, LUIS MADRAZO, and demands that Plaintiff respond within
thirty (30) days from the date of service hereof.
REQUEST FOR ADMISSIONS
1. Admit that LUIS MADRAZO is currently the owners of the property located at 3400 NW
102nd Street, Miami, Florida 33147 (“Subject Property”).
2. Admit that prior to November 9, 2020, LUIS MADRAZO had obtained a Citizens
Homeowner’s Insurance Policy, identified under the policy number 01149800 (“Subject
Policy”) to insure the Subject Property.
3. Admit that LUIS MADRAZO is in possession of a true and correct copy of the Subject
Policy for the Subject Property for the time period September 20, 2020 to September 20,
2021.
4. Admit that on December 9, 2020, Plaintiff and/or their representatives, first notified
Citizens of an insurance claim under Citizens Policy Number 01149800, for a Loss to the
Subject Property purportedly occurring on November 9, 2020.
5. Admit that Plaintiff’s claim was assigned Claim No. 001-00-256768.
LAW OFFICE OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875
6. Admit that Plaintiff claims that the Loss to the Subject Property was caused by Tropical
Storm Eta on November 9, 2020.
7. Admit that Plaintiff observed damages to the Subject Property that Plaintiff maintains were
caused by Tropical Storm Eta on November 9, 2020.
8. Admit that all of the observed damages to Subject Property that Plaintiff maintains were
caused by Tropical Storm Eta on November 9, 2020 did not exist prior to November 9,
2020.
9. Admit that Plaintiff or people/entities known by Plaintiff’s have video or photographs
showing that the damages claimed by Plaintiff to have occurred on November 9, 2020 did
not exist prior to November 9, 2020
10. Admit that Citizens investigated the Subject Property on March 17, 2021.
11. Admit that Plaintiff had repairs performed to the interior of his house between November
9, 2020 and Citizens’ inspection on March 17, 2021.
12. Admit that Plaintiff and/or Plaintiff’s representatives have photographs or video displaying
the condition of the Subject Property immediately following Tropical Storm Eta on
November 9, 2020.
13. Admit that Plaintiff and/or Plaintiffs’ representatives have no documentation to support the
contention that the alleged damages occurred on November 9, 2020.
14. Admit that Plaintiffs and/or Plaintiffs’ representatives have no reports, documentation, or
other evidence to support the contention that there was a peril-created opening at the
Subject Property.
[CERTIFICATE OF SERVICE ON FOLLOWING PAGE]
LAW OFFICE OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via the
Florida Courts E-Filing Portal, pursuant to Fla. R. Jud. Admin. 2.516(b)(1), on February 24, 2022
to:
Ramon J. Diego, Esq. eservice@rjdiegolaw.com
Law Office of Ramon J. Diego, P.A.
The Presto Building
5001 SW 74th Court, Suite 103
Miami, Florida 33155
LAW OFFICES OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130
Telephone: 305.372.2877 / Facsimile: 305.372.2875
EService E-mail: eservice@hoffmanpa.com
By: /s/ John L. Bischof, Esq.
John D. Hoffman, Esq.
Board Certified Civil Trial Lawyer
Florida Bar No. 825859 / E-mail: john@hoffmanpa.com
Claudia Feldman, Esq.
Florida Bar No. 99646 / E-mail: claudia@hoffmanpa.com
John L. Bischof, Esq.
Florida Bar No. 179213 / E-mail: jbischof@hoffmanpa.com
LAW OFFICE OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875
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Filing # 144545810 E-Filed 02/24/2022 01:21:18 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI DADE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION CASE NO: 2021-023723-CA-01 LUIS MADRAZO, Plaintiff(s), v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. _________________________________/ DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFFS COMES NOW, the Defendant, Citizens Property Insurance Corporation (“Citizens”) by and through undersigned counsel, and pursuant to Fla. R. Civ. P. 1.370, hereby files this First Request for Admissions to Plaintiff, LUIS MADRAZO, and demands that Plaintiff respond within thirty (30) days from the date of service hereof. REQUEST FOR ADMISSIONS 1. Admit that LUIS MADRAZO is currently the owners of the property located at 3400 NW 102nd Street, Miami, Florida 33147 (“Subject Property”). 2. Admit that prior to November 9, 2020, LUIS MADRAZO had obtained a Citizens Homeowner’s Insurance Policy, identified under the policy number 01149800 (“Subject Policy”) to insure the Subject Property. 3. Admit that LUIS MADRAZO is in possession of a true and correct copy of the Subject Policy for the Subject Property for the time period September 20, 2020 to September 20, 2021. 4. Admit that on December 9, 2020, Plaintiff and/or their representatives, first notified Citizens of an insurance claim under Citizens Policy Number 01149800, for a Loss to the Subject Property purportedly occurring on November 9, 2020. 5. Admit that Plaintiff’s claim was assigned Claim No. 001-00-256768. LAW OFFICE OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875 6. Admit that Plaintiff claims that the Loss to the Subject Property was caused by Tropical Storm Eta on November 9, 2020. 7. Admit that Plaintiff observed damages to the Subject Property that Plaintiff maintains were caused by Tropical Storm Eta on November 9, 2020. 8. Admit that all of the observed damages to Subject Property that Plaintiff maintains were caused by Tropical Storm Eta on November 9, 2020 did not exist prior to November 9, 2020. 9. Admit that Plaintiff or people/entities known by Plaintiff’s have video or photographs showing that the damages claimed by Plaintiff to have occurred on November 9, 2020 did not exist prior to November 9, 2020 10. Admit that Citizens investigated the Subject Property on March 17, 2021. 11. Admit that Plaintiff had repairs performed to the interior of his house between November 9, 2020 and Citizens’ inspection on March 17, 2021. 12. Admit that Plaintiff and/or Plaintiff’s representatives have photographs or video displaying the condition of the Subject Property immediately following Tropical Storm Eta on November 9, 2020. 13. Admit that Plaintiff and/or Plaintiffs’ representatives have no documentation to support the contention that the alleged damages occurred on November 9, 2020. 14. Admit that Plaintiffs and/or Plaintiffs’ representatives have no reports, documentation, or other evidence to support the contention that there was a peril-created opening at the Subject Property. [CERTIFICATE OF SERVICE ON FOLLOWING PAGE] LAW OFFICE OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via the Florida Courts E-Filing Portal, pursuant to Fla. R. Jud. Admin. 2.516(b)(1), on February 24, 2022 to: Ramon J. Diego, Esq. eservice@rjdiegolaw.com Law Office of Ramon J. Diego, P.A. The Presto Building 5001 SW 74th Court, Suite 103 Miami, Florida 33155 LAW OFFICES OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 Telephone: 305.372.2877 / Facsimile: 305.372.2875 EService E-mail: eservice@hoffmanpa.com By: /s/ John L. Bischof, Esq. John D. Hoffman, Esq. Board Certified Civil Trial Lawyer Florida Bar No. 825859 / E-mail: john@hoffmanpa.com Claudia Feldman, Esq. Florida Bar No. 99646 / E-mail: claudia@hoffmanpa.com John L. Bischof, Esq. Florida Bar No. 179213 / E-mail: jbischof@hoffmanpa.com LAW OFFICE OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 ~ Telephone: 305.372.2877 Fax: 305.372.2875