On October 21, 2022 a
Motion-Secondary
was filed
involving a dispute between
Joanna Maiocco,
John Maiocco,
and
American Integrity Insurance Company Of Florida,
for Contract and Indebtedness Division: CV-E
in the District Court of Duval County.
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Filing # 163703353 E-Filed 12/27/2022 04:07:42 PM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT IN AND
FOR DUVAL COUNTY, FLORIDA
CASE NUMBER: 2022-CA-006122
JOANNA MAIOCCO
AND JOHN MAIOCCO,
PLAINTIFF,
Vv
AMERICAN INTEGRITY INSURANCE
COMPANY OF FLORIDA,
DEFENDANT.
PLAINTIFF’S REPLY TO DEFENDANT’S ANSWER AND AFFIRMATIVE
DEFENSES TO THE COMPLAINT
COMES NOW the Plaintiff, JOANNA MAIOCCO AND JOHN MAIOCCO, by and
through their undersigned attorneys and files this Reply to Defendant’s Answer and Affirmative
Defenses, and states as follows;
1 Plaintiff denies each of the allegations contained in Defendant’s Affirmative Defenses to
the Complaint and demands strict proof thereof.
2. Each of Defendant’s Affirmative Defenses to the Complaint constitutes a general denial,
Page 1 of 2
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/28/2022 01:36:41 PM
is legally insufficient, and should be disregarded.
3. Nothing has been proffered to this Court that would preclude Plaintiff from securing a
judgment in this instant matter.
I CERTIFY that on December 27, 2022, a true copy of the foregoing has been filed with the
Court via the e-portal which will send a notice of electronic filing to Counsel for Defendant, Elliot
W. Russ, Esquire, Post Office Box 26349, Tampa, FL 33623 at eruss@aiiflorida.com,
kmyers@aiflorida.com, and dwelcker@aiiflorida.com.
/s/ Anthony A. Fouladi
Anthony A. Fouladi, Esquire
Florida Bar No.: 91082
Serrano Cagan & Cagan
Francisco E. Serrano, II, Esq.
Florida Bar No.: 92034
2300 Maitland Center Pkwy
Suite 106
Maitland, FL 32751
Phone No.: (877)4SCC-LAW
Service: service@serranocagan.com
Primary: afouladi@serranocagan.com
Secondary: cholliday@serranocagan.com
Attorneys for Plaintiff
Page 2 of 2
Document Filed Date
December 27, 2022
Case Filing Date
October 21, 2022
Category
Contract and Indebtedness Division: CV-E
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Filing # 163703353 E-Filed 12/27/2022 04:07:42 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA CASE NUMBER: 2022-CA-006122 JOANNA MAIOCCO AND JOHN MAIOCCO, PLAINTIFF, Vv AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA, DEFENDANT. PLAINTIFF’S REPLY TO DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES TO THE COMPLAINT COMES NOW the Plaintiff, JOANNA MAIOCCO AND JOHN MAIOCCO, by and through their undersigned attorneys and files this Reply to Defendant’s Answer and Affirmative Defenses, and states as follows; 1 Plaintiff denies each of the allegations contained in Defendant’s Affirmative Defenses to the Complaint and demands strict proof thereof. 2. Each of Defendant’s Affirmative Defenses to the Complaint constitutes a general denial, Page 1 of 2 ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/28/2022 01:36:41 PM is legally insufficient, and should be disregarded. 3. Nothing has been proffered to this Court that would preclude Plaintiff from securing a judgment in this instant matter. I CERTIFY that on December 27, 2022, a true copy of the foregoing has been filed with the Court via the e-portal which will send a notice of electronic filing to Counsel for Defendant, Elliot W. Russ, Esquire, Post Office Box 26349, Tampa, FL 33623 at eruss@aiiflorida.com, kmyers@aiflorida.com, and dwelcker@aiiflorida.com. /s/ Anthony A. Fouladi Anthony A. Fouladi, Esquire Florida Bar No.: 91082 Serrano Cagan & Cagan Francisco E. Serrano, II, Esq. Florida Bar No.: 92034 2300 Maitland Center Pkwy Suite 106 Maitland, FL 32751 Phone No.: (877)4SCC-LAW Service: service@serranocagan.com Primary: afouladi@serranocagan.com Secondary: cholliday@serranocagan.com Attorneys for Plaintiff Page 2 of 2