On October 19, 2022 a
Proof of Service
was filed
involving a dispute between
Angela Jordan,
Keteryna Sheremet,
and
Security First Insurance Company,
for Contract and Indebtedness Division: CV-H
in the District Court of Duval County.
Preview
Filing # 162875437 E-Filed 12/12/2022 05:11:57 PM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT IN AND
FOR DUVAL COUNTY, FLORIDA
CASE NO.: 16-2022-CA-006036-XXXX-MA
ANGELA JORDAN AND KETERYNA SHEREMET,
Plaintiffs,
vs.
SECURITY FIRST INSURANCE COMPANY,
Defendant.
/
NOTICE OF SERVICE OF AFFIRMATIVE DEFENSE INTERROGATORIES
TO DEFENDANT, SECURITY FIRST INSURANCE COMPANY
Plaintiffs, ANGELA JORDAN AND KETERYNA SHEREMET, hereby give(s) Notice of
Service of Interrogatories numbered 1 through 10, directed to Defendant, SECURITY FIRST
INSURANCE COMPANY, to be answered in writing on or before thirty (30) days from the date of
the certificate of service hereof, at the offices of DAVID R. HEIL, P.A., 2324 Lee Road, Winter
Park, FL 32789.
| HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically
filed with the Clerk of the Courts by using the ECF system which will send a notice of electronic
filing to the following: DAVID G. MARCUS, ESQUIRE, Security First Insurance Company,
(David. Marcus@securityfirstflorida.com; Cathy.Myers@securityfirstflorida.com;
Veronica.Hatch@securityfirstflorida.com), this 12" day of December, 2022.
/s/David R. Heil
DAVID R. HEIL, ESQUIRE
Florida Bar No. 0435422
DAVID R. HEIL, P.A.
2324 Lee Road
Winter Park, Florida 32789
david@heil-law.com
pleadings@heil-law.com
Telephone No. (407) 599-2100
Facsimile No. (407) 599-7733
Attorney for Plaintiff(s)
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/12/2022 10:01:29 PM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT IN AND
FOR DUVAL COUNTY, FLORIDA
CASE NO.: 16-2022-CA-006036-XXXX-MA
ANGELA JORDAN AND KETERYNA SHEREMET,
Plaintiffs,
vs.
SECURITY FIRST INSURANCE COMPANY,
Defendant.
AFFIRMATIVE DEFENSE INTERROGATORIES TO
DEFENDANT, SECURITY FIRST INSURANCE COMPANY
1 What is the name and address of the person answering these interrogatories,
and, if applicable, the person's official position or relationship with the party to whom the
interrogatories are directed?
ANSWER:
2 Please state the facts upon which you rely for affirmative defense number 1 in
your answer.
ANSWER:
3. Please state the facts upon which you rely for affirmative defense number 2 in
your answer.
ANSWER:
4. Please state the facts upon which you rely for affirmative defense number 3 in
your answer.
ANSWER:
5. Please state the facts upon which you rely for affirmative defense number 4 in
your answer.
ANSWER:
6. Please state the facts upon which you rely for affirmative defense number 5 in
your answer.
ANSWER:
7. Please state the facts upon which you rely for affirmative defense number 6 in
your answer.
ANSWER:
8. Please state the facts upon which you rely for affirmative defense number 7 in
your answer.
ANSWER:
9. Please state the facts upon which you rely for affirmative defense number 8 in
your answer.
ANSWER:
10. Please state the person or persons with most knowledge of the basis of the
affirmative defenses and state if more than one which person has most knowledge of the individual
affirmative defense.
ANSWER:
By:
STATE OF FLORIDA
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared
who, is personally known to me or produced
as identification, and who did/did not take an oath, deposes
and states that the foregoing answers to interrogatories are true and correct to the best of his/her
knowledge.
SWORN TO AND SUBSCRIBED before me in the State and County aforesaid, this
day of , 2022.
NOTARY PUBLIC
Printed:
My Commission No.:
My Commission Expires:
Document Filed Date
December 12, 2022
Case Filing Date
October 19, 2022
Category
Contract and Indebtedness Division: CV-H
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Filing # 162875437 E-Filed 12/12/2022 05:11:57 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA CASE NO.: 16-2022-CA-006036-XXXX-MA ANGELA JORDAN AND KETERYNA SHEREMET, Plaintiffs, vs. SECURITY FIRST INSURANCE COMPANY, Defendant. / NOTICE OF SERVICE OF AFFIRMATIVE DEFENSE INTERROGATORIES TO DEFENDANT, SECURITY FIRST INSURANCE COMPANY Plaintiffs, ANGELA JORDAN AND KETERYNA SHEREMET, hereby give(s) Notice of Service of Interrogatories numbered 1 through 10, directed to Defendant, SECURITY FIRST INSURANCE COMPANY, to be answered in writing on or before thirty (30) days from the date of the certificate of service hereof, at the offices of DAVID R. HEIL, P.A., 2324 Lee Road, Winter Park, FL 32789. | HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically filed with the Clerk of the Courts by using the ECF system which will send a notice of electronic filing to the following: DAVID G. MARCUS, ESQUIRE, Security First Insurance Company, (David. Marcus@securityfirstflorida.com; Cathy.Myers@securityfirstflorida.com; Veronica.Hatch@securityfirstflorida.com), this 12" day of December, 2022. /s/David R. Heil DAVID R. HEIL, ESQUIRE Florida Bar No. 0435422 DAVID R. HEIL, P.A. 2324 Lee Road Winter Park, Florida 32789 david@heil-law.com pleadings@heil-law.com Telephone No. (407) 599-2100 Facsimile No. (407) 599-7733 Attorney for Plaintiff(s) ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/12/2022 10:01:29 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA CASE NO.: 16-2022-CA-006036-XXXX-MA ANGELA JORDAN AND KETERYNA SHEREMET, Plaintiffs, vs. SECURITY FIRST INSURANCE COMPANY, Defendant. AFFIRMATIVE DEFENSE INTERROGATORIES TO DEFENDANT, SECURITY FIRST INSURANCE COMPANY 1 What is the name and address of the person answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed? ANSWER: 2 Please state the facts upon which you rely for affirmative defense number 1 in your answer. ANSWER: 3. Please state the facts upon which you rely for affirmative defense number 2 in your answer. ANSWER: 4. Please state the facts upon which you rely for affirmative defense number 3 in your answer. ANSWER: 5. Please state the facts upon which you rely for affirmative defense number 4 in your answer. ANSWER: 6. Please state the facts upon which you rely for affirmative defense number 5 in your answer. ANSWER: 7. Please state the facts upon which you rely for affirmative defense number 6 in your answer. ANSWER: 8. Please state the facts upon which you rely for affirmative defense number 7 in your answer. ANSWER: 9. Please state the facts upon which you rely for affirmative defense number 8 in your answer. ANSWER: 10. Please state the person or persons with most knowledge of the basis of the affirmative defenses and state if more than one which person has most knowledge of the individual affirmative defense. ANSWER: By: STATE OF FLORIDA COUNTY OF BEFORE ME, the undersigned authority, personally appeared who, is personally known to me or produced as identification, and who did/did not take an oath, deposes and states that the foregoing answers to interrogatories are true and correct to the best of his/her knowledge. SWORN TO AND SUBSCRIBED before me in the State and County aforesaid, this day of , 2022. NOTARY PUBLIC Printed: My Commission No.: My Commission Expires: