On January 30, 2023 a
Party Discovery
was filed
involving a dispute between
Zaleski, Andrea,
Zaleski, Lucian,
and
National General Insurance Company,
for CONTRACTS AND INDEBTEDNESS - CIRCUIT
in the District Court of Pinellas County.
Preview
Case Number:23-000460-CI
Filing # 165720483 E-Filed 01/30/2023 01:01:48 PM
IN THE CIRCUIT COURT OF THE
SIXTH JUDICIAL CIRCUIT IN AND
FOR PINELLAS COUNTY, FLORIDA
CASE NUMBER:
LUCIAN AND ANDREA ZALESKI,
Plaintiffs,
v.
NATIONAL GENERAL INSURANCE
COMPANY,
Defendant.
________________________________________/
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
Plaintiffs, Lucian and Andrea Zaleski, by and through the undersigned counsel, under
Florida Rule of Civil Procedure 1.370, submit to Defendant, National General Insurance
Company, the following requests for admissions for Defendant to admit or deny within forty-five
(45) days of the service of the Complaint herein:
1. Admit that you issued a policy of homeowners insurance that provided insurance
coverage to a property located at 9111 109th Avenue Seminole, Florida 33777.
RESPONSE:
2. Admit that the homeowners insurance policy you issued, which is described in the
Complaint, provided coverage for wind and/or hail damage.
RESPONSE:
3. Admit that the insurance policy you issued to Plaintiffs for the property located at 9111
109th Avenue Seminole, Florida 33777 was in full force and effect as of December 16, 2020.
RESPONSE:
***ELECTRONICALLY FILED 01/30/2023 02:56:15 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
4. Admit that the wind and/or hail loss described in the Complaint, which occurred on or
about December 16, 2020, was a covered event pursuant to the terms of the subject policy.
RESPONSE:
5. Admit that any payment you issued on this claim was in accordance with the terms of the
insurance policy at issue in this lawsuit.
RESPONSE:
6. Admit that above-named Defendant is properly named in this action.
RESPONSE:
7. Admit that Defendant’s adjuster(s) who worked on this claim did so in accordance with
Fla. Stat. § 626.878.
RESPONSE:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of this document will be served on
Defendant along with the Summons and the Complaint in this action.
Date: January 30, 2023
/s/John Windle
COHEN LAW GROUP
John Windle, Esq.
Florida Bar Number: 0125169
FOR THE FIRM
350 North Lake Destiny Road
Maitland, Florida 32751
Phone: (407) 478-4878
Fax: (407) 478-0204
Primary: jwindle@itsaboutjustice.law
Secondary: Rhaire@itsaboutjustice.law
Document Filed Date
January 30, 2023
Case Filing Date
January 30, 2023
Category
CONTRACTS AND INDEBTEDNESS - CIRCUIT
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Preview
Case Number:23-000460-CI Filing # 165720483 E-Filed 01/30/2023 01:01:48 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NUMBER: LUCIAN AND ANDREA ZALESKI, Plaintiffs, v. NATIONAL GENERAL INSURANCE COMPANY, Defendant. ________________________________________/ PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT Plaintiffs, Lucian and Andrea Zaleski, by and through the undersigned counsel, under Florida Rule of Civil Procedure 1.370, submit to Defendant, National General Insurance Company, the following requests for admissions for Defendant to admit or deny within forty-five (45) days of the service of the Complaint herein: 1. Admit that you issued a policy of homeowners insurance that provided insurance coverage to a property located at 9111 109th Avenue Seminole, Florida 33777. RESPONSE: 2. Admit that the homeowners insurance policy you issued, which is described in the Complaint, provided coverage for wind and/or hail damage. RESPONSE: 3. Admit that the insurance policy you issued to Plaintiffs for the property located at 9111 109th Avenue Seminole, Florida 33777 was in full force and effect as of December 16, 2020. RESPONSE: ***ELECTRONICALLY FILED 01/30/2023 02:56:15 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 4. Admit that the wind and/or hail loss described in the Complaint, which occurred on or about December 16, 2020, was a covered event pursuant to the terms of the subject policy. RESPONSE: 5. Admit that any payment you issued on this claim was in accordance with the terms of the insurance policy at issue in this lawsuit. RESPONSE: 6. Admit that above-named Defendant is properly named in this action. RESPONSE: 7. Admit that Defendant’s adjuster(s) who worked on this claim did so in accordance with Fla. Stat. § 626.878. RESPONSE: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this document will be served on Defendant along with the Summons and the Complaint in this action. Date: January 30, 2023 /s/John Windle COHEN LAW GROUP John Windle, Esq. Florida Bar Number: 0125169 FOR THE FIRM 350 North Lake Destiny Road Maitland, Florida 32751 Phone: (407) 478-4878 Fax: (407) 478-0204 Primary: jwindle@itsaboutjustice.law Secondary: Rhaire@itsaboutjustice.law