On January 04, 2021 a
Party Discovery
was filed
involving a dispute between
and
for COUNTY CIVIL (15,001 to 30,000)
in the District Court of Gadsden County.
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Filing # 118966256 E-Filed 01/04/2021 09:40:07 AM
IN THE COUNTY COURT IN AND FOR GADSDEN COUNTY, FLORIDA
CHARLES PRESIDENT, CASE NO.
Petitioner,
v.
FOREMOST INSURANCE COMPANY
GRAND RAPIDS, MICHIGAN
Respondent.
REQUEST FOR ADMISSIONS
COMES NOW Petitioner, by and through the undersigned attorneys, and pursuant to the
applicable Florida Rules of Civil Procedure, hereby requests Respondent to admit or deny the
following items:
1. Admit that on the date of the alleged loss described in the Petition that the policy
described in the Petition was in full force and effect.
2. Admit that Petitioner is the named insured under the insurance policy described in
the Petition.
3. Admit that the premises described in the Petition are the insured premises under the
insurance policy described in the Petition.
4. Admit that prior to the institution of this action, Petitioner made a claim under the
Policy described in the petition for a loss which Petitioner claims occurred the date of loss described
in the petition.
5. Admit that Respondent assigned a claim number to the subject loss as described in
the petition.
6. Admit that Petitioner permitted Respondent access to the premises described in the
subject policy after the date of the alleged loss.
7. Admit that as of the date of the filing if this lawsuit, that Respondent had denied the
Petitioner's claim for insurance benefits for the alleged loss described in the petition.
8. Admit that as of the date of the filing if this lawsuit, that Respondent had not made
—nany payment of insurance proceeds to Petitioner for the subject loss described in the petition.
9. Admit Respondent is aware ofno reasons to limit, exclude or bar coverage from the
subject loss other than those described in Respondent's denial letter attached to the Petition in this
action.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served
upon Respondent by the Insurance Commissioner of the State of Florida.
DUROFF LAW FIRM
ATTORNEYS FOR PETITIONER
680 N.E. 127 STREET
NortH MIAMI, FLORIDA 33161
TELEPHONE (305) 899-0085
Fax No. (305) 899-0091
COURTDOCUMENT@DUBOFFLAWFIRM.COM
By: _/S KENNETH R. DUBOFF
KENNETH R. DUBOFF, ESQ.
FLA. BAR #218261
mm
Document Filed Date
January 04, 2021
Case Filing Date
January 04, 2021
Category
COUNTY CIVIL (15,001 to 30,000)
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Filing # 118966256 E-Filed 01/04/2021 09:40:07 AM IN THE COUNTY COURT IN AND FOR GADSDEN COUNTY, FLORIDA CHARLES PRESIDENT, CASE NO. Petitioner, v. FOREMOST INSURANCE COMPANY GRAND RAPIDS, MICHIGAN Respondent. REQUEST FOR ADMISSIONS COMES NOW Petitioner, by and through the undersigned attorneys, and pursuant to the applicable Florida Rules of Civil Procedure, hereby requests Respondent to admit or deny the following items: 1. Admit that on the date of the alleged loss described in the Petition that the policy described in the Petition was in full force and effect. 2. Admit that Petitioner is the named insured under the insurance policy described in the Petition. 3. Admit that the premises described in the Petition are the insured premises under the insurance policy described in the Petition. 4. Admit that prior to the institution of this action, Petitioner made a claim under the Policy described in the petition for a loss which Petitioner claims occurred the date of loss described in the petition. 5. Admit that Respondent assigned a claim number to the subject loss as described in the petition. 6. Admit that Petitioner permitted Respondent access to the premises described in the subject policy after the date of the alleged loss. 7. Admit that as of the date of the filing if this lawsuit, that Respondent had denied the Petitioner's claim for insurance benefits for the alleged loss described in the petition. 8. Admit that as of the date of the filing if this lawsuit, that Respondent had not made —nany payment of insurance proceeds to Petitioner for the subject loss described in the petition. 9. Admit Respondent is aware ofno reasons to limit, exclude or bar coverage from the subject loss other than those described in Respondent's denial letter attached to the Petition in this action. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon Respondent by the Insurance Commissioner of the State of Florida. DUROFF LAW FIRM ATTORNEYS FOR PETITIONER 680 N.E. 127 STREET NortH MIAMI, FLORIDA 33161 TELEPHONE (305) 899-0085 Fax No. (305) 899-0091 COURTDOCUMENT@DUBOFFLAWFIRM.COM By: _/S KENNETH R. DUBOFF KENNETH R. DUBOFF, ESQ. FLA. BAR #218261 mm