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Filing # 162651162 E-Filed 12/08/2022 12:28:14 PM
IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT
DUVAL COUNTY, FLORIDA
ANGELA JORDAN & KETERYNA
SHEREMET CASE NO. 16-2022-CA-006036
Plaintiffs,
vs.
SECURITY FIRST INSURANCE
COMPANY,
Defendant.
/
DEFENDANT’S RESPONSE TO PLAINTIFF’S REQUEST FOR ADMISSIONS
Defendant, SECURITY FIRST INSURANCE COMPANY, by and through the
undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.370, and files this
Response to Plaintiff’s Request for Admissions and states as follows.
1 Security First Insurance Company’s engaged in the business of insurance.
Response: Admitted.
2. Security First Insurance Company issued an insurance policy to Angela Jordan and
Keterya Sherement.
Response: Admitted only that the Defendant issued a policy of homeowner’s
insurance to Angela Jordan and Keterya Sherement, for certain real property
located 1257 Jones Road, Jacksonville FL 32220 , for the policy period of August 26,
2019 through August 26, 2020, policy number P000293979, subject to all terms and
conditions, exclusions, endorsements, and limitation set forth in the policy of
insurance which speaks for itself. Otherwise, denied.
3. The insurance policy issued by Security First Insurance Company, was in full force
and effect on the date of the incident as alleged in the subject Complaint.
Response: Admitted that the policy was in full force. Otherwise Denied.
4. The premiums due and owing on this insurance policy were not delinquent at the time
of the subject accident.
Response: Admitted that the premiums were paid, otherwise Denied as phrased.
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 damaged caused to the insured.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/08/2022 01:11:29 PM
Response: Admitted only that the Defendant issued a policy of homeowner’s
insurance to Angela Jordan and Keteryna Sheremet, for certain real property
located 1257 Jones Road, Jacksonville FL 32220, for the policy period of August 26,
2019 through August 26, 2020, policy number P000293979, subject to all terms and
conditions, exclusions, endorsements, and limitation set forth in the policy of
insurance which speaks for itself. Otherwise, denied.
6. The policy provides coverage for water damage incurred by the insured.
Response: Admitted only that the Defendant issued a policy of homeowner’s
insurance to Angela Jordan and Keteryna Sheremet, for certain real property
located 1257 Jones Road, Jacksonville FL 32220, for the policy period of August 26,
2019 through August 26, 2020, policy number P000293979, subject to all terms and
conditions, exclusions, endorsements, and limitation set forth in the policy of
insurance which speaks for itself. Otherwise, denied.
7. The insurance coverage provisions of the policy were un effect on the date of the
subject incident.
Response: Admitted only that the Defendant issued a policy of homeowner’
insurance to Angela Jordan and Keteryna Sheremet, for certain real property
located 1257 Jones Road, Jacksonville FL 32220, for the policy period of August 26,
2019 through August 26, 2020, policy number P000293979, subject to all terms and
conditions, exclusions, endorsements, and limitation set forth in the policy of
insurance which speaks for itself. Otherwise, denied.
8. Security First Insurance Company was timely notified of the circumstances
surrounding he incident.
Response: Denied, Security First was notified of the August 4, 2020, incident on May
30, 2022, which was 664 days after the alleged loss and the delay prejudiced Security
First’s ability to investigate the alleged loss.
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.
Responded: Denied, Defendant did not receive notice of the alleged loss until 664
days after it allegedly occurred.
10. Security First Insurance Company agrees that there are no coverage issues in this
matter.
Response: Denied.
11. Security First Insurance Company refuses to make full payment for the loss submitted
to Security First Insurance Company by or behalf of the Plaintiff.
Response: Denied as phrased.
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 In the declaration
sheet of the policy.
Response: Denied as phrased.
13. Security First Insurance Company concedes that is liable for all amounts claimed the
complaint, interest, attorney’s fees and costs.
Response: Denied.
14. 14. Security First Insurance Company admits that it is in violation of Florida Statute
624.155(b)(1) in its handling of this claim.
Response: Denied.
15. Security First Insurance Company admits that is has not acted in good faith in
investigating and adjusting this claim.
Response: Denied.
CERTIFICATE OF SERVICE
The document contains no confidential or sensitive information or that any such
confidential or sensitive language has been properly protected by complying with the provisions
of Rule 2.420 and 2.425.
THEREBY CERTIFY that a true and correct copy of the foregoing Defendant’s Response
to Plaintiff's Request for Admissions has been furnished by Electronic Filing to Attorney for
Defendant, using the Florida Courts e-Filing Portal, which will send an automatic e-mail message
to the listed parties registered with the e-Filing Portal system on the 8 day of December 2022.
Attorney for Plaintiff
David R. Heil, Esq. FBN: 435422
DAVID R. HEIL, P.A.
Email: pleadings@heil-law.com david@heil-law.com
By/s/ David. G. Marcus.
David G. Marcus, Esq. FBN.: 1017428
Primary Email: David.Marcus@securityfirstflorida.com
Secondary Email: Cathy.Myers@SecurityFirstFlorida.com
Alternate Email: Veronica. Hatch@SecurityFirstFlorida.com
Attorney for Defendant
SECURITY FIRST INSURANCE COMPANY
Preview
Filing # 162651162 E-Filed 12/08/2022 12:28:14 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT DUVAL COUNTY, FLORIDA ANGELA JORDAN & KETERYNA SHEREMET CASE NO. 16-2022-CA-006036 Plaintiffs, vs. SECURITY FIRST INSURANCE COMPANY, Defendant. / DEFENDANT’S RESPONSE TO PLAINTIFF’S REQUEST FOR ADMISSIONS Defendant, SECURITY FIRST INSURANCE COMPANY, by and through the undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.370, and files this Response to Plaintiff’s Request for Admissions and states as follows. 1 Security First Insurance Company’s engaged in the business of insurance. Response: Admitted. 2. Security First Insurance Company issued an insurance policy to Angela Jordan and Keterya Sherement. Response: Admitted only that the Defendant issued a policy of homeowner’s insurance to Angela Jordan and Keterya Sherement, for certain real property located 1257 Jones Road, Jacksonville FL 32220 , for the policy period of August 26, 2019 through August 26, 2020, policy number P000293979, subject to all terms and conditions, exclusions, endorsements, and limitation set forth in the policy of insurance which speaks for itself. Otherwise, denied. 3. The insurance policy issued by Security First Insurance Company, was in full force and effect on the date of the incident as alleged in the subject Complaint. Response: Admitted that the policy was in full force. Otherwise Denied. 4. The premiums due and owing on this insurance policy were not delinquent at the time of the subject accident. Response: Admitted that the premiums were paid, otherwise Denied as phrased. 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 damaged caused to the insured. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/08/2022 01:11:29 PM Response: Admitted only that the Defendant issued a policy of homeowner’s insurance to Angela Jordan and Keteryna Sheremet, for certain real property located 1257 Jones Road, Jacksonville FL 32220, for the policy period of August 26, 2019 through August 26, 2020, policy number P000293979, subject to all terms and conditions, exclusions, endorsements, and limitation set forth in the policy of insurance which speaks for itself. Otherwise, denied. 6. The policy provides coverage for water damage incurred by the insured. Response: Admitted only that the Defendant issued a policy of homeowner’s insurance to Angela Jordan and Keteryna Sheremet, for certain real property located 1257 Jones Road, Jacksonville FL 32220, for the policy period of August 26, 2019 through August 26, 2020, policy number P000293979, subject to all terms and conditions, exclusions, endorsements, and limitation set forth in the policy of insurance which speaks for itself. Otherwise, denied. 7. The insurance coverage provisions of the policy were un effect on the date of the subject incident. Response: Admitted only that the Defendant issued a policy of homeowner’ insurance to Angela Jordan and Keteryna Sheremet, for certain real property located 1257 Jones Road, Jacksonville FL 32220, for the policy period of August 26, 2019 through August 26, 2020, policy number P000293979, subject to all terms and conditions, exclusions, endorsements, and limitation set forth in the policy of insurance which speaks for itself. Otherwise, denied. 8. Security First Insurance Company was timely notified of the circumstances surrounding he incident. Response: Denied, Security First was notified of the August 4, 2020, incident on May 30, 2022, which was 664 days after the alleged loss and the delay prejudiced Security First’s ability to investigate the alleged loss. 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. Responded: Denied, Defendant did not receive notice of the alleged loss until 664 days after it allegedly occurred. 10. Security First Insurance Company agrees that there are no coverage issues in this matter. Response: Denied. 11. Security First Insurance Company refuses to make full payment for the loss submitted to Security First Insurance Company by or behalf of the Plaintiff. Response: Denied as phrased. 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 In the declaration sheet of the policy. Response: Denied as phrased. 13. Security First Insurance Company concedes that is liable for all amounts claimed the complaint, interest, attorney’s fees and costs. Response: Denied. 14. 14. Security First Insurance Company admits that it is in violation of Florida Statute 624.155(b)(1) in its handling of this claim. Response: Denied. 15. Security First Insurance Company admits that is has not acted in good faith in investigating and adjusting this claim. Response: Denied. CERTIFICATE OF SERVICE The document contains no confidential or sensitive information or that any such confidential or sensitive language has been properly protected by complying with the provisions of Rule 2.420 and 2.425. THEREBY CERTIFY that a true and correct copy of the foregoing Defendant’s Response to Plaintiff's Request for Admissions has been furnished by Electronic Filing to Attorney for Defendant, using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the listed parties registered with the e-Filing Portal system on the 8 day of December 2022. Attorney for Plaintiff David R. Heil, Esq. FBN: 435422 DAVID R. HEIL, P.A. Email: pleadings@heil-law.com david@heil-law.com By/s/ David. G. Marcus. David G. Marcus, Esq. FBN.: 1017428 Primary Email: David.Marcus@securityfirstflorida.com Secondary Email: Cathy.Myers@SecurityFirstFlorida.com Alternate Email: Veronica. Hatch@SecurityFirstFlorida.com Attorney for Defendant SECURITY FIRST INSURANCE COMPANY