On May 30, 2019 a
Party Discovery
was filed
involving a dispute between
Roofing Revolution,
and
American Integrity Insurance Company Of Florida,
for Insurance Claim
in the District Court of Collier County.
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Filing # 102517327 E-Filed 01/30/2020 04:09:51 PM
IN THE CIRCUIT COURT OF THE 20TH
JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA
Case No.: 11-2019-CA-002157-0001-XX
ROOF REVOLUTION, INC. A/A/O DARYL
F. BURT,
Plaintiff,
v.
AMERICAN INTEGRITY INSURANCE
COMPANY OF FLORIDA,
Defendant.
/
DEFENDANT, AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA’S,
RESPONSES AND OBJECTIONS TO PLAINTIFF’S SECOND REQUEST FOR
ADMISSIONS
Defendant, AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA
(“American Integrity”), pursuant to Rule 1.370, Florida Rules of Civil Procedure, files its
Responses and Objections to Plaintiff's Second Request for Admissions, and states:
RESPONSES AND OBJECTIONS
1. Respondent has not provided Petitioner with a written factual or evidentiary basis to
support its Affirmative Defense numbered [1].
Response: Denied.
2. Respondent has not provided Petitioner with a written factual or evidentiary basis to
support its Affirmative Defense numbered [2].
Response: Denied.
3. Respondent has not provided Petitioner with a written factual or evidentiary basis to
support its Affirmative Defense numbered [3].
Response: Denied.
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 01/30/2020 04:26:53 PMCase No.: 11-2019-CA-002157-0001-XX
Page 2 of 3
4. Respondent has not provided Petitioner with a written factual or evidentiary basis to
support its Affirmative Defense numbered [4].
Response: Denied.
5. Respondent has not provided Petitioner with a written factual or evidentiary basis to
support its Affirmative Defense numbered [5].
Response: Denied.
6. Respondent has not provided Petitioner with a written factual or evidentiary basis to
support its Affirmative Defense numbered [6].
Response: Denied.
7. Respondent has not provided Petitioner with a written factual or evidentiary basis to
support its Affirmative Defense numbered [7].
Response: Denied.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30" day of January, 2020, this document was
filed using the Florida Courts E-Filing Portal. This document is being served on all counsel and
pro se parties of record by the Florida Courts E-Filing Portal, pursuant to and in compliance with
Fla. R. Jud. Admin. 2.516. The mailing and electronic addresses are: Harold Y. Levy, Esq., HL
Law Group, P.A., 2601 East Oakland Park Boulevard, Suite 503, Fort Lauderdale, FL 33306, (954)
713-1212/(954) 760-4239 (F).
KELLEY KRONENBERG
/s/ Alison J. Trejo
Alison J. Trejo, Esq.
Fla. Bar No.: 115377Case No.: 11-2019-CA-002157-0001-XX
Page 3 of 3
atrejo@kelleykronenberg.com
Jeffrey M. Wank, Esq.
Fla. Bar No.: 68010
jwank@kelleykronenberg.com
10360 W. State Road 84
Fort Lauderdale, FL 33324
Telephone: (954) 370-9970
Facsimile: (954) 382-1988
Attorneys for American Integrity Insurance
Company
Address for service of pleadings only:
jwank@kelleykronenberg.com
atrejo@kelleykronenberg.com
Icorrea@kelleykronenberg.com
Case Filing Date
May 30, 2019
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Filing # 102517327 E-Filed 01/30/2020 04:09:51 PM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA Case No.: 11-2019-CA-002157-0001-XX ROOF REVOLUTION, INC. A/A/O DARYL F. BURT, Plaintiff, v. AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA, Defendant. / DEFENDANT, AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA’S, RESPONSES AND OBJECTIONS TO PLAINTIFF’S SECOND REQUEST FOR ADMISSIONS Defendant, AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA (“American Integrity”), pursuant to Rule 1.370, Florida Rules of Civil Procedure, files its Responses and Objections to Plaintiff's Second Request for Admissions, and states: RESPONSES AND OBJECTIONS 1. Respondent has not provided Petitioner with a written factual or evidentiary basis to support its Affirmative Defense numbered [1]. Response: Denied. 2. Respondent has not provided Petitioner with a written factual or evidentiary basis to support its Affirmative Defense numbered [2]. Response: Denied. 3. Respondent has not provided Petitioner with a written factual or evidentiary basis to support its Affirmative Defense numbered [3]. Response: Denied. FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 01/30/2020 04:26:53 PMCase No.: 11-2019-CA-002157-0001-XX Page 2 of 3 4. Respondent has not provided Petitioner with a written factual or evidentiary basis to support its Affirmative Defense numbered [4]. Response: Denied. 5. Respondent has not provided Petitioner with a written factual or evidentiary basis to support its Affirmative Defense numbered [5]. Response: Denied. 6. Respondent has not provided Petitioner with a written factual or evidentiary basis to support its Affirmative Defense numbered [6]. Response: Denied. 7. Respondent has not provided Petitioner with a written factual or evidentiary basis to support its Affirmative Defense numbered [7]. Response: Denied. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 30" day of January, 2020, this document was filed using the Florida Courts E-Filing Portal. This document is being served on all counsel and pro se parties of record by the Florida Courts E-Filing Portal, pursuant to and in compliance with Fla. R. Jud. Admin. 2.516. The mailing and electronic addresses are: Harold Y. Levy, Esq., HL Law Group, P.A., 2601 East Oakland Park Boulevard, Suite 503, Fort Lauderdale, FL 33306, (954) 713-1212/(954) 760-4239 (F). KELLEY KRONENBERG /s/ Alison J. Trejo Alison J. Trejo, Esq. Fla. Bar No.: 115377Case No.: 11-2019-CA-002157-0001-XX Page 3 of 3 atrejo@kelleykronenberg.com Jeffrey M. Wank, Esq. Fla. Bar No.: 68010 jwank@kelleykronenberg.com 10360 W. State Road 84 Fort Lauderdale, FL 33324 Telephone: (954) 370-9970 Facsimile: (954) 382-1988 Attorneys for American Integrity Insurance Company Address for service of pleadings only: jwank@kelleykronenberg.com atrejo@kelleykronenberg.com Icorrea@kelleykronenberg.com