Party Discovery: JOANNA MAIOCCO vs AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA

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                                16-2022-CA-006122-XXXX-MA Div: CV-E

    Filing # 159711770 E-Filed 10/21/2022 11:48:19 AM
            IN THE CIRCUIT COURT              OF THE FOURTH
            JUDICIAL          CIRCUIT IN AND      FOR DUVAL
            COUNTY, FLORIDA

            CASE NUMBER:

            JOANNA MAIOCCO AND JOHN
            MAIOCCO,

            Plaintiff,
            V.


            AMERICAN INTEGRITY INSURANCE
            COMPANY OF FLORIDA,

            Defendant.




                         PLAINTIFF'S FIRST REQUEST            FOR ADMISSIONS         TO DEFENDANT

                     COMES NOW Plaintiff, JOANNA MAIOCCO AND JOHN MAIOCCO, by and through

            the undersigned     counsel and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, and

            hereby files and submits to Defendant, AMERICAN INTEGRITY INSURANCE COMPANY OF

            FLORIDA, the following requests for admissions and requests that Defendant admits to or denies

            the following in writing, within forty-five (45) days of the service of the Complaint herein:


                 1   Admit that prior to 6/7/2022 you issued a policy of homeowner's insurance which provided

                     insurance coverage to a property located at 14579 Falling Waters Dr Jacksonville, FL

                     32258.

                     RESPONSE:

                     Admit that the policy of homeowner's insurance which you issued to Plaintiff covered

                     the property located at 14579 Falling Waters Dr Jacksonville, FL 32258 as of the date of

                     thecovered event described in the Complaint, which was on or about 6/7/2022.

                     RESPONSE:




ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK,                  10/24/2022 04:07:43 PM
Admit that the insurance policy you issued, which is described in the Complaint, provided

coverage to Plaintiff for damage caused to the property located at 14579 Falling Waters Dr

Jacksonville, FL 32258 as a result of damage.

RESPONSE:


Admit that the policy of homeowner's insurance which you provided to Plaintiff for the

property located at 14579 Falling Waters Dr Jacksonville, FL 32258 was in full force and

effect as of 6/7/2022.

RESPONSE:


Admit that pursuant to the terms of the homeowner's insurance policy you issued to Plaintiff

for the property located   at 14579 Falling Waters Dr Jacksonville, FL 32258, you were

timely notified of the covered loss in question, which occurred on or about 6/7/2022.

RESPONSE:


Admit that the covered loss described in the Complaint, which occurred on or about

6/7/2022 was a covered event pursuant to the terms of the policy of homeowner's insurance

which you issued to Plaintiff for the property located at 14579 Falling Waters Dr Jacksonville,

FL 32258.

RESPONSE:

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:
Admit that above-named Defendant is properly named in this action.

       RESPONSE:

       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 DO HEREBY        CERTIFY that a true and correct copy of this document will be served

on the Defendant along with the Summons in this action.


Date: October 21, 2022


                                               /s/ Francisco E. Serrano, II
                                               Francisco E. Serrano, Esq.
                                               Florida Bar No.: 92034
                                               Serrano Cagan & Cagan
                                               2300 Maitland Center Pkwy
                                               Suite 106
                                               Maitland, FL 32751
                                               Phone No.: (877)4SCC-LAW
                                               Service: service@serranocagan.com
                                               Primary: fserrano@serranocagan.com
                                               Attorney for Plaintiff