Document for RAPHAEL, RUTH vs. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY

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                                Filing # 178592002 E-Filed 07/31/2023 03:46:21 PM


                         IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT,
                              IN AND FOR CHARLOTTE COUNTY, FLORIDA

                                                    CASE NO.: 23-001967-
        RUTH RAPHAEL,

               PLAINTIFF,

        v.

        UNIVERSAL PROPERTY & CASUALTY
        INSURANCE COMPANY,

              DEFENDANT.
        _____________________________________/

                                 PLAINTIFF’S REQUEST FOR ADMISSIONS

               Comes now the Plaintiff, RUTH RAPHAEL (“Plaintiff”), by and through undersigned

        counsel, and pursuant to Fla. R. Civ. P. 1.370, propounds upon Defendant the following requests

        for admission:

        1.     Please admit that Defendant is not in possession of any photographs showing that there
        were cracks in any ceiling drywall at the property prior to September 28, 2022.

        2.      Please admit that there were no cracks in any ceiling drywall at the property immediately
        prior to September 28, 2022.

        3.     Please admit that Defendant is not in possession of any photographs showing that there
        was any ceiling drywall damage at the property prior to September 28, 2022.

              Please admit that there was no ceiling drywall damage at the property immediately prior to
        September 28, 2022.

               Please admit that Defendant is not possession of any photographs showing that there was
        any side drywall damage at the property prior to September 28, 2022.

               Please admit that there was not any side drywall damage at the property immediately prior
        to September 28, 2022.

              Please admit that Defendant is not in possession of any photographs showing any flooring
        damage at the property prior to September 28, 2022.
      Please admit that there was not any flooring damage at the property immediately prior to
September 28, 2022.

       Please admit that Plaintiff requested mediation on or around February 14, 2023.

10.    Please admit that Plaintiff requested mediation on or around February 27, 2023.

11.    Please admit that Defendant was required under Florida law to conduct mediation if
requested by its insured.

       Please admit that Defendant did make any attempt to coordinate mediation.

13.     Please admit that Mr. David Wale, when he inspected the property, did not bring any tools
to the property for purposes of determining if there was water, moisture, mold or fungus in the side
or ceiling drywall or side drywall or flooring, such as a moisture meter.

       Please admit that Mr. David Wale, when he inspected the property, did not take any swabs
or samples for testing in order to determine or ascertain the presence or amount of fungus or mold.

        Please admit that Mr. David Wale, when he inspected the property, did not make any
attempt whatsoever to determine or ascertain the presence or amount of moisture, water, fungus or
mold, in the ceiling drywall, side drywall or flooring other than performing a purely visual
inspection, also known as looking.

                                CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that on July 31, 2023, a true and correct copy of the foregoing has

been furnished via E-service to: Jovani Monexil, Esq., upciceservice01@universalproperty.cpom,

vb0221@universalproperty.com, jm0418@universalproperty.com.

                                              By: ___ s/ Oren Reich___
                                              Mordechai L. Breier, Esq.
                                              Florida Bar No.: 0088186
                                              Oren Reich, Esq.
                                              Florida Bar No.: 0103371
                                              Michael Katz, Esq.
                                              Florida Bar No.: 1024707
                                              CONSUMER LAW OFFICE, P.A.
                                              16801 NE 6 Ave.
                                              North Miami Beach, FL 33162
                                              Phone: (305) 940-0924 | Fax: (305) 602-8204
                                              E-service: service@myconsumerlawoffice.com
E-mail: oreich@myconsumerlawoffice.com