Response to Request for Admissions

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                          Filing # 90697394 E-Filed 06/06/2019 02:44:57 PM

IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL DIVISION

UCMS LLC, dba
UNIVERSAL CONTRACTING OF FLORIDA,
a foreign LLC, a/a/o Thomas Catalina,

Plaintiffs,
CASE NO: 19-CA-1871
vs.

UNIVERSAL INSURANCE COMPANY
OF NORTH AMERICA, a Florida Corporation,

Defendant.
/

DEFENDANT’S ANSWERS TO PLAINTIFF’S REQUESTS FOR ADMISSIONS

COMES NOW, Defendant, UNIVERSAL INSURANCE COMPAY OF NORTH AMERICA, by

and through its undersigned counsel, and responds to Plaintiffs Requests for Admission as follows:

1. Deny.
Deny.
Admit
Admit.
Deny.
Deny.
Deny.

Admit coverage was extended subject to and under a reservation of rights.

SPAN nNn PWN

Objection: improper bad faith/claim file discovery in a breach of contract action, ambiguous,
overbroad, work product, trade secrets, and not reasonably calculated to lead to the discovery of
admissible evidence.

10. Objection: improper bad faith/claim file discovery…