Party Discovery: ANGELA JORDAN vs SECURITY FIRST INSURANCE COMPANY

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                                16-2022-CA-006036-XXXX-MA Div: CV-H

    Filing # 159563466 E-Filed 10/19/2022 03:10:40 PM


                                       IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT
                                                 IN AND FOR DUVAL COUNTY, FLORIDA

                                                                             CASE NO.:

            ANGELA JORDAN AND KETERYNA SHEREMET,

                        Plaintiffs,
            VS.

            SECURITY FIRST INSURANCE COMPANY,

                        Defendant.
                                                                         /

                                                    FIRST REQUEST FOR ADMISSIONS

                            Plaintiffs pursuant to Florida   Rule   of Civil Procedure   1.370(a),   requests   that Security   First

            Insurance Company make the following admissions in this action within forty-five (45) days:

                             1        Security First Insurance Company's engaged in the business of insurance.

                            2.        Security First Insurance Company issued an insurance policy to Angela Jordan and

            Keteryna Sheremet.

                            3.        This insurance policy issued by Security First Insurance Company, was in full force and

            effect on the date of the incident as stated in the subject Complaint.

                            4,        The premiums due and owing on this insurance policy were not delinquent at the time

            of the subject accident.

                             5.       This policy is an insurance policy and by its terms, Security First Insurance Company

            agreed to extend the protection afforded by the policy for damage caused to the insured.

                            6.        The policy provides coverage for water damage incurred by the insured.

                            7.        The insurance coverage provisions of the policy were in effect on the date of the subject

            incident.

                             8.       Security First Insurance Company was timely notified of the circumstances surrounding

            the incident.

                             9.       Security First Insurance Company       has been timely provided with approved forms

            authorizing Security First Insurance Company to obtain proof of expenses arising from the incident.




ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK,                            10/20/2022 10:08:27 AM
10.      Security First Insurance Company     agrees that there are no coverage issues in this

matter.

             11.      Security First Insurance Company refuses to make full payment for the loss submitted

to Security First Insurance Company by or on behalf of Plaintiffs.

             12.      Security First Insurance Company by and through the terms of the above-mentioned

insurance policy, agreed to be liable in the amount of the policy limits stated on the declaration sheet of the

policy.
             13.      Security First Insurance Company concedes that is liable for all amounts claimed in the

complaint, interest, attorney fees and costs.

             14.      Security First Insurance Company      admits that it is in violation of Florida Statute

624.155(b)(1) in its handling of this claim.

             15.      Security First Insurance Company       admits that it has not acted in good faith in

investigating and adjusting this claim.

            | HEREBY      CERTIFY that a true copy of the foregoing has been provided for service on the

Security First Insurance Company with a copy of the Complaint.


                                                            /siDavid R. Heil
                                                            DAVID R. HEIL, ESQUIRE
                                                            Florida Bar No. 435422
                                                            DAVID R. HEIL, P.A.
                                                            2324 Lee Road
                                                            Winter Park, Florida 32789
                                                            (407) 599-2100
                                                            Facsimile No. (407) 599-7733
                                                            Pleadings@heil-law.com
                                                            David@heil-law.com
                                                            Attorney for Plaintiff