Party Discovery: ANTHONY DAVIS J VS SECURITY

• 
• 
• 
• 

						
                                
Preview
                                Filing # 106408909 E-Filed 04/17/2020 04:39:46 PM



                                                                      IN THE CIRCUIT COURT OF THE
                                                                      EIGHTEENTH JUDICIAL CIRCUIT IN
                                                                      AND FOR BREVARD COUNTY, FL

                                                                      CASE NO.

            ANTHONY DAVIS JR.,

                      Plaintiff,

            Vv

            SECURITY FIRST INSURANCE COMPANY
            DBA SECURITY FIRST FLORIDA,

                      Defendant.
                                                               /

                                                 REQUEST FOR ADMISSIONS

                      Plaintiff, ANTHONY       DAVIS JR., pursuant to Florida Rule of Civil Procedure 1.370,

            requests the Defendant,            SECURITY   FIRST INSURANCE         COMPANY     DBA SECURITY

            FIRST FLORIDA,          a corporation authorized       and doing business in the state of Florida,

            serve a response to the following request for admissions:

                      1        Defendant issued a policy of insurance to Plaintiff (“Policy”) for the property

            located at 4835 Key Biscayne Drive, Titusville, FL 32780 (“Dwelling”).

                      2        At all material times, Plaintiff had an insurable interest in the Dwelling.

                      3        The Dwelling sustained direct physical damage caused by water while the

            Policy was in full force and effect (the “loss”).

                      4        Defendant was notified of the loss pursuant to the terms and conditions of the

            Policy.

                      5.       Plaintiff submitted an insurance claim to Defendant (the “claim”) pursuant to

            the terms and conditions of the Policy.



 Filing 106408909                         VS                                                  05-2020-CA-024628-XXXX-XX
6      Plaintiff did not cause prejudice to Defendant during its investigation of the

           claim.

                    7      As of the date of this lawsuit,      there were     no outstanding   requests   by

           Defendant for documents or information in connection with its investigation and adjustment

           of the claim.

                    8      Plaintiff complied with all duties after a loss pursuant to the Policy.

                    9      The Policy provides coverage for any and all sudden and accidental physical

           damage to the Dwelling that is not otherwise excluded or excepted by the policy.

                    10.    The Policy provides coverage for “all risks” of loss to the Dwelling.

                    11.    The   Policy provides benefits on a “Replacement Cost Value” basis for

           covered losses to the Dwelling subject to the Policy limits.

                    12.    In the event of a covered loss to the Dwelling, the Policy provides benefits to

           repair or replace damaged or destroyed property, without deducting for depreciation.

                    13.    In the event ofa covered loss to the Dwelling, the Policy requires Defendant

           to pay benefits on a “Replacement Cost Value” basis, irrespective of whether Plaintiff

           actually repairs or replaces the damaged property.

                    Dated this 17 day of April, 2020.

                                                        TI   NATIO)      LAW FIRM, LLP
                                                                 v           mee


                                                         Corey B. Justus, Esquire
                                                         Florida Bar No. 113864
                                                         570 Crown Oak Centre Drive
                                                         Longwood, FL 32750
                                                         Telephone:    (407) 339-1104
                                                         Facsimile: (407) 339-1118
                                                         Primary Email: lobrien@nationlaw.com
                                                         Secondary Email: cjustus@nationlaw.com
                                                         Attorneys for Plaintiff


Filing 106408909                      VS                                                  05-2020-CA-024628-XXXX-XX