Party Discovery: MAZZA, CAITLIN vs. TYPTAP INSURANCE COMPANY

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                                Filing # 172722377 E-Filed 05/09/2023 10:04:07 AM


                     IN THE CIRCUIT COURT OF     TWENTIETH JUDICIAL CIRCUIT
                              IN AND FOR CHARLOTTE COUNTY, FLORIDA

         CAITLIN MAZZA,                                                     CASE NO:     23001802CA

                    Plaintiff,                                             DIVISION:

         vs.


         TYPTAP INSURANCE COMPANY,

                 Defendant.




                     PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS                       TO DEFENDANT

                 The Plaintiff, CAITLIN MAZZA, (hereinafter           referred to as “Plaintiff’), by and through
        the undersigned counsel, and pursuant to Rule 1.370            of the Florida Rules of Civil Procedure,
        hereby requests Defendant, TYPTAP INSURANCE                    COMPANY        (“Defendant”), respond to
        Plaintiff's First Request for Admissions to Defendant         within forty five (45) days of the date of
        service and admit or deny the following:

                            That all times material hereto, Plaintiff was and is the owner of that certain real
         property located at 100 LAMBERT            STREET, PORT CHARLOTTE, FL 33948, (hereinafter
         referred to as “Insured Property”).

                            That Defendant issued or renewed a policy of homeowner’s insurance, Policy
        Number:                       , (hereinafter referred to as the “Policy”) to Plaintiff on the Insured
        Property.

                          That at all times material hereto, the subject Policy of homeowner s insurance
         was/is in effect for the Insured Property.

                        That the above referenced Policy of insurance covers any and all damage to the
         Insured Property that was caused by hurricane

                            That the Policy is an all risk policy.

                            That there is damage to the structure located at the Insured Property.

                      That Plaintiff made a timely application for insurance benefits under the Policy of
         homeowner s insurance.

                            That Defendant has not sent to Plaintiff a notice of nonrenewal before this claim
         was initiated.
                            That Defendant has not sent to Plaintiff a notice of cancellation before this claim
         was initiated.
The Plaintiff first reported damage to the home on or abou          October
while the above referenced Policy was in effect.

                  That Defendant has not paid Plaintiff's claim.

                 That Plaintiffha complied with all conditions precedent to obtaining benefits
under Plaintiff's Policy of homeowner s insurance from Defendant.

                  That Plaintiff has complied with all conditions preceding to the maintenance of
this action.

                 That Defendant has breached its policy of insurance by failing to pay all benefits
to Plaintiff for claim of damages to the home located at Insured Property.

                  That Defendant owes prejudgment interest, expert fees, costs, and attorneys       fees
of this action.

                 That pursuant to Florida Statute 627.428, Plaintiff entitled to attorneys fees and
costs in the event that the Court enters judgment or decree against Defendant in favor of Plaintiff
in this action.


                                   CERTIFICATE OF SERVICE

         I HEREBY CERTIFY a true and correct copy of the foregoing Request for Admissions has
been served contemporaneously with the Complaint and Responses to same are due within forty
five (45) days from the date of service.

                                                                   /s/ James S. Jenkins, IIT
                                                                   James S. Jenkins, III, Esquire
                                                                   FBN: 56083
                                                                   Derek Hendricks, Esquire
                                                                   FBN: 48979
                                                                   Jenkins Law, P.L.
                                                                   275 96th Ave. N., Suite 5
                                                                   St. Petersburg, FL 33702
                                                                     service@jenkinslawpl.com