MOTION FOR SUMMARY JUDGMENT

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                          Filing # 140795053 E-Filed 12/21/2021 04:56:35 PM

IN THE COUNTY COURT OF THE SECOND JUDICIAL CIRCUIT
IN AND FOR GADSDEN COUNTY, FLORIDA

CHARLES PRESIDENT,
CASE NO.: 21-000001-CC
Petitioner,
Vv.

FOREMOST INSURANCE COMPANY
GRAND RAPIDS, MICHIGAN,

Respondent.
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DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
Defendant, Foremost Insurance Company (“Foremost”) moves for entry of
summary judgment in its favor. There is no genuine issue as to any material fact.

Foremost is entitled to judgment as a matter of law. Plaintiff has conclusively admitted

that the cause of loss of Plaintiff's claimed damage does not fall under the insurance

policy’s broad grant of coverage.

I. Facts.

1. Foremost issued mobile home insurance policy number 0660124651 to Charles
President for the property located at 8 Walters St. Havana, Florida 32333. See
Exhibit “A.”

2. The insurance policy insures against the risk of direct, sudden and accidental
physical loss to the property. In pertinent part, the insurance po…