On June 30, 2021 a
Request,Application
was filed
involving a dispute between
Arbour Townhouse Condominium Association, Inc,
and
American Coastal Insurance Company,
for Contract & Indebtedness
in the District Court of Miami-Dade County.
Preview
Filing # 140716929 E-Filed 12/20/2021 05:34:17 PM
IN THE CIRCUIT COURT OF THE
11th JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
ARBOUR TOWNHOUSE CONDOMINIUM GENERAL JURISDICTION DIVISION
ASSOCIATION, INC., a Florida corporation,
CASE NO.: 21-015633 CA 08
Plaintiff,
v.
AMERICAN COASTAL INSURANCE
COMPANY, a Florida corporation,
Defendant.
/
ARBOUR TOWNHOUSE CONDOMINIUM ASSOCIATION, INC.’S
FIRST REQUEST FOR ADMISSIONS
Arbour Townhouse Condominium Association, Inc. (“Arbour Townhouse”), by and
through its undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.370, hereby
propounds this First Request for Admissions to American Coastal Insurance Company
(“Defendant”), and requests Defendant admit or deny each request within the time frame set forth
in the Florida Rules of Civil Procedure.
DEFINITIONS
1. The terms “you,” “your,” “Defendant” and shall refer to Defendant, American
Coastal Insurance Company, its principal, agents, partners, representatives, consultants, experts,
and its officers, directors, employees, attorneys, and all other persons acting or purporting to act
on its behalf, past or present
2. The words “and” and “or” shall be construed conjunctively or disjunctively as
necessary to make the request inclusive rather than exclusive.
3. “Policy” shall mean the subject policy bearing policy number AMC-32406-05.
RUIZ | GETMAN LAW, PLLC
CASE NO.: 21-015633 CA 08
4. “Property” shall mean the subject properties listed on the Declarations Page of the
subject Policy.
INSTRUCTIONS
1. The matter in a request is admitted unless you serve a written answer or objection
within thirty (30) days from your receipt of these Requests. If objection is made, the reasons shall
be stated specifically.
2. All answers not admitted shall either be denied, or you shall set forth in detail the
reasons why you cannot truthfully admit or deny the matter.
3. When good faith requires that you qualify your answer or deny only a part of the
matter of which an admission is requested, you shall specify so much of it as is true and qualify or
deny the remainder.
4. You may not provide lack of information or knowledge as a reason for failure to
admit or deny any request unless you state that you have made a reasonable inquiry and that the
information known or readily obtainable by you is insufficient to enable you to admit or deny the
request.
-2-
RUIZ | GETMAN LAW, PLLC
CASE NO.: 21-015633 CA 08
ARBOUR TOWNHOUSE’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
1. Admit that the Policy which forms the subject matter of this lawsuit was issued by
Defendant.
2. Admit that Defendant was providing insurance coverage to the Property at the time
of the loss described in the Complaint.
3. Admit that the cause of the damage at issue is covered under the Policy.
4. Admit Tropical Storm Eta is the cause of the damage.
5. Admit that Arbour Townhouse complied with all post-loss obligations required
under the Policy for the subject claim.
6. Admit that Arbour Townhouse complied with Defendant’s request to inspect the
Property for this claim.
7. Admit that Defendant took photographs of the damages during its inspection of the
subject claim.
8. Admit that Defendant conducted a complete and thorough investigation of the
subject loss.
9. Admit that Defendant denied the subject claim.
10. Admit that Defendant did not issue any payments to Arbour Townhouse for the
subject claim.
-3-
RUIZ | GETMAN LAW, PLLC
CASE NO.: 21-015633 CA 08
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this 20th day of December 2021, a true and correct
copy of this document is being served on Jeremy M. Mishali, Esq. at:
jwank@kelleykronenberg.com; jmishali@kelleykronenberg.com and
glamchick@kelleykronenberg.com from Kelley Kronenberg 10360 West State Road 84, Fort
Lauderdale, Florida 33324.
Respectfully submitted,
/s/ Amy E. Ruiz
Amy E. Ruiz, FBN: 99129
ARuiz@RuizGetmanLaw.com
Steven J. Getman, FBN: 67198
SGetman@RuizGetmanLaw.com
Ruiz | Getman Law, PLLC
6800 SW 40th Street, #394
Miami, Florida 33155
Telephone: 305.978.6311
Facsimile: 305.397.2760
Attorneys for Plaintiff, Arbour Townhouse
Condominium Association, Inc.
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RUIZ | GETMAN LAW, PLLC
Document Filed Date
December 20, 2021
Case Filing Date
June 30, 2021
Category
Contract & Indebtedness
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Filing # 140716929 E-Filed 12/20/2021 05:34:17 PM IN THE CIRCUIT COURT OF THE 11th JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA ARBOUR TOWNHOUSE CONDOMINIUM GENERAL JURISDICTION DIVISION ASSOCIATION, INC., a Florida corporation, CASE NO.: 21-015633 CA 08 Plaintiff, v. AMERICAN COASTAL INSURANCE COMPANY, a Florida corporation, Defendant. / ARBOUR TOWNHOUSE CONDOMINIUM ASSOCIATION, INC.’S FIRST REQUEST FOR ADMISSIONS Arbour Townhouse Condominium Association, Inc. (“Arbour Townhouse”), by and through its undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.370, hereby propounds this First Request for Admissions to American Coastal Insurance Company (“Defendant”), and requests Defendant admit or deny each request within the time frame set forth in the Florida Rules of Civil Procedure. DEFINITIONS 1. The terms “you,” “your,” “Defendant” and shall refer to Defendant, American Coastal Insurance Company, its principal, agents, partners, representatives, consultants, experts, and its officers, directors, employees, attorneys, and all other persons acting or purporting to act on its behalf, past or present 2. The words “and” and “or” shall be construed conjunctively or disjunctively as necessary to make the request inclusive rather than exclusive. 3. “Policy” shall mean the subject policy bearing policy number AMC-32406-05. RUIZ | GETMAN LAW, PLLC CASE NO.: 21-015633 CA 08 4. “Property” shall mean the subject properties listed on the Declarations Page of the subject Policy. INSTRUCTIONS 1. The matter in a request is admitted unless you serve a written answer or objection within thirty (30) days from your receipt of these Requests. If objection is made, the reasons shall be stated specifically. 2. All answers not admitted shall either be denied, or you shall set forth in detail the reasons why you cannot truthfully admit or deny the matter. 3. When good faith requires that you qualify your answer or deny only a part of the matter of which an admission is requested, you shall specify so much of it as is true and qualify or deny the remainder. 4. You may not provide lack of information or knowledge as a reason for failure to admit or deny any request unless you state that you have made a reasonable inquiry and that the information known or readily obtainable by you is insufficient to enable you to admit or deny the request. -2- RUIZ | GETMAN LAW, PLLC CASE NO.: 21-015633 CA 08 ARBOUR TOWNHOUSE’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT 1. Admit that the Policy which forms the subject matter of this lawsuit was issued by Defendant. 2. Admit that Defendant was providing insurance coverage to the Property at the time of the loss described in the Complaint. 3. Admit that the cause of the damage at issue is covered under the Policy. 4. Admit Tropical Storm Eta is the cause of the damage. 5. Admit that Arbour Townhouse complied with all post-loss obligations required under the Policy for the subject claim. 6. Admit that Arbour Townhouse complied with Defendant’s request to inspect the Property for this claim. 7. Admit that Defendant took photographs of the damages during its inspection of the subject claim. 8. Admit that Defendant conducted a complete and thorough investigation of the subject loss. 9. Admit that Defendant denied the subject claim. 10. Admit that Defendant did not issue any payments to Arbour Townhouse for the subject claim. -3- RUIZ | GETMAN LAW, PLLC CASE NO.: 21-015633 CA 08 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 20th day of December 2021, a true and correct copy of this document is being served on Jeremy M. Mishali, Esq. at: jwank@kelleykronenberg.com; jmishali@kelleykronenberg.com and glamchick@kelleykronenberg.com from Kelley Kronenberg 10360 West State Road 84, Fort Lauderdale, Florida 33324. Respectfully submitted, /s/ Amy E. Ruiz Amy E. Ruiz, FBN: 99129 ARuiz@RuizGetmanLaw.com Steven J. Getman, FBN: 67198 SGetman@RuizGetmanLaw.com Ruiz | Getman Law, PLLC 6800 SW 40th Street, #394 Miami, Florida 33155 Telephone: 305.978.6311 Facsimile: 305.397.2760 Attorneys for Plaintiff, Arbour Townhouse Condominium Association, Inc. -4- RUIZ | GETMAN LAW, PLLC