On December 28, 2017 a
NOT. OF SERV. OF PROPOSAL FOR SETTLEMENT Doc # 84
was filed
involving a dispute between
Jovanovic, Rada,
and
Esurance Property And Casualty Insurance Company,
Gibney, Dawn,
Gibney, Joseph,
Gibney, Vincent,
for AUTO NEGLIGENCE - CIRCUIT
in the District Court of Pinellas County.
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Filing # 93933975 E-Filed 08/09/2019 12:53:21 PM
IN THE CIRCUIT COURT OF THE SIXTH
JUDICIAL CIRCUIT, IN A1\D FOR PINELLAS
COUNTY, FLORIDA. C]VIL DIVISION.
RADA JOVANOVIC,
Plaintiff,
_VS_
JOSEPH GIBNEY, VINCENT GIBNEY,
DAWN GIBNEY, and ESURANCE CASE NO.: 17—007580-CI-11
PROPERTY AND CASUALTY
INSURANCE COMPANY,
Defendants.
/
NOTICE OF SERVICE OF PROPOSAL FOR SETTLEMENT
PLEASE TAKE NOTICE that Plaintiff, RADA JOVANOVIC, by and through the undersigned
counsel, hereby notifies the Court that, pursuant to Rule 1.442 of the Florida Rules 0f Civil Procedure
and Florida Statutes §768.79, has served a Proposal for Settlement upon Defendant, ESURANCE
PROPERTY AND CASUALTY INSURANCE COMPANY, this
9th
day of August 2019.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E—
Mail 9th
and by Certified Mail, Return Receipt Requested (Article #7016 1370 0001 4253 9089) this
day of August 2019 to: Cosmo Bloom, Esquire, Law Office of Ellen H. Ehrenpreis, 4300 West
Cypress Street, Suite 500, Tampa, FL 33607 at tampageic0@geico.com , Attorney for Gibneys; and
Ryan Boda, Esquire, Law Offices of Robert J.Smith, 101 East Kennedy Blvd., Suite 2125, Tampa, FL
33602 at TAMPALEGAL@ALLSTATE.COM ,Attorney for Esurance.
/s/Sumeet Kaul
Sumeet Kaul, Esquire
Morgan & Morgan Tampa, P.A.
One Tampa City Center
201 N. Franklin Street, 7th Floor
Tampa, FL 33602
Tele: (813) 223-5505
Fax: (813) 223-5402
Primary Email: SKPleadings@forthepeople.com
Secondary Email:
Florida Bar #: 905682
Attorney for Plaintiff
***ELECTRONICALLY FILED 08/09/2019 12 53:21 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
Document Filed Date
August 09, 2019
Case Filing Date
December 28, 2017
Category
AUTO NEGLIGENCE - CIRCUIT
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Filing # 93933975 E-Filed 08/09/2019 12:53:21 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT, IN A1\D FOR PINELLAS COUNTY, FLORIDA. C]VIL DIVISION. RADA JOVANOVIC, Plaintiff, _VS_ JOSEPH GIBNEY, VINCENT GIBNEY, DAWN GIBNEY, and ESURANCE CASE NO.: 17—007580-CI-11 PROPERTY AND CASUALTY INSURANCE COMPANY, Defendants. / NOTICE OF SERVICE OF PROPOSAL FOR SETTLEMENT PLEASE TAKE NOTICE that Plaintiff, RADA JOVANOVIC, by and through the undersigned counsel, hereby notifies the Court that, pursuant to Rule 1.442 of the Florida Rules 0f Civil Procedure and Florida Statutes §768.79, has served a Proposal for Settlement upon Defendant, ESURANCE PROPERTY AND CASUALTY INSURANCE COMPANY, this 9th day of August 2019. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E— Mail 9th and by Certified Mail, Return Receipt Requested (Article #7016 1370 0001 4253 9089) this day of August 2019 to: Cosmo Bloom, Esquire, Law Office of Ellen H. Ehrenpreis, 4300 West Cypress Street, Suite 500, Tampa, FL 33607 at tampageic0@geico.com , Attorney for Gibneys; and Ryan Boda, Esquire, Law Offices of Robert J.Smith, 101 East Kennedy Blvd., Suite 2125, Tampa, FL 33602 at TAMPALEGAL@ALLSTATE.COM ,Attorney for Esurance. /s/Sumeet Kaul Sumeet Kaul, Esquire Morgan & Morgan Tampa, P.A. One Tampa City Center 201 N. Franklin Street, 7th Floor Tampa, FL 33602 Tele: (813) 223-5505 Fax: (813) 223-5402 Primary Email: SKPleadings@forthepeople.com Secondary Email: Florida Bar #: 905682 Attorney for Plaintiff ***ELECTRONICALLY FILED 08/09/2019 12 53:21 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***