On April 17, 2020 a
Request,Application
was filed
involving a dispute between
Davis Anthony Jr,
and
Security First Florida,
Security First Insurance Company,
for CONTRACT & INDEBTEDNESS
in the District Court of Brevard County.
Preview
Filing # 143310416 E-Filed 02/04/2022 11:58:50 AM
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
IN AND FOR BREVARD COUNTY, FLORIDA
ANTHONY DAVIS, JR., Case No.: 2020-CA-024628
Plaintiff,
VS.
SECURITY FIRST INSURANCE COMPANY,
Defendant.
DEFENDANT’S REQUEST TO PERMIT ENTRY UPON
LAND FOR INSPECTION AND OTHER PURPOSES
COMES NOW, the Defendant, SECURITY FIRST INSURANCE COMPANY
(“SECURITY FIRST”), by and through undersigned counsel, and pursuant to Florida Rule of Civil
Procedure 1.350(b), and the subject policy of insurance, and hereby requests access upon the
insured property for visual inspection, measuring, surveying, photographing, testing, or sampling
the property, which may include hydro jetting, in advance of a sewer camera inspection and
evaluation of the damage being claimed in this lawsuit.
Said inspection shall be performed by Security First’s consultants and the undersigned
counsel, and will take place at the property owned by Plaintiff, Anthony Davis, Jr., located at 4835
Key Biscayne Dr., Titusville, FL 32780. Said inspection is requested to take place at a mutually
agreeable time. The Defendant requests hours (4) hours for said inspection, and requests access to
the interior and exterior of the dwelling as well as the plumbing system. Defendant requests that
Plaintiff respond to this Request for Entry Upon Land within five (5) business days of filing same.
Filing 143310416 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished via Florida Court’s E-Filing Portal to: Gina Kimmel, Esq., Morgan & Morgan, P.A. 20
N_ Orange Avenue, 4h Floor, Orlando, Florida at LRolon@forthepeople.com;
gkimme!@forthepeople.com, on February 4, 2022.
Quintairos, Prieto, Wood and Boyer, P.A.
/s/ Ashley Ward-Singleton
Jennifer L. Velazco, Esq. FBN: 27199
Iniv Gabay, Esq. FBN: 37487
Ashley N. Ward-Singleton, FBN: 89426
1410 North Westshore Boulevard, Suite 200
Tampa, Florida 33607
T: 813-286-8818 / F: 813-286-9998
Attomeys for Defendant
Filing 143310416 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
Document Filed Date
February 04, 2022
Case Filing Date
April 17, 2020
Category
CONTRACT & INDEBTEDNESS
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Preview
Filing # 143310416 E-Filed 02/04/2022 11:58:50 AM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA ANTHONY DAVIS, JR., Case No.: 2020-CA-024628 Plaintiff, VS. SECURITY FIRST INSURANCE COMPANY, Defendant. DEFENDANT’S REQUEST TO PERMIT ENTRY UPON LAND FOR INSPECTION AND OTHER PURPOSES COMES NOW, the Defendant, SECURITY FIRST INSURANCE COMPANY (“SECURITY FIRST”), by and through undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350(b), and the subject policy of insurance, and hereby requests access upon the insured property for visual inspection, measuring, surveying, photographing, testing, or sampling the property, which may include hydro jetting, in advance of a sewer camera inspection and evaluation of the damage being claimed in this lawsuit. Said inspection shall be performed by Security First’s consultants and the undersigned counsel, and will take place at the property owned by Plaintiff, Anthony Davis, Jr., located at 4835 Key Biscayne Dr., Titusville, FL 32780. Said inspection is requested to take place at a mutually agreeable time. The Defendant requests hours (4) hours for said inspection, and requests access to the interior and exterior of the dwelling as well as the plumbing system. Defendant requests that Plaintiff respond to this Request for Entry Upon Land within five (5) business days of filing same. Filing 143310416 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via Florida Court’s E-Filing Portal to: Gina Kimmel, Esq., Morgan & Morgan, P.A. 20 N_ Orange Avenue, 4h Floor, Orlando, Florida at LRolon@forthepeople.com; gkimme!@forthepeople.com, on February 4, 2022. Quintairos, Prieto, Wood and Boyer, P.A. /s/ Ashley Ward-Singleton Jennifer L. Velazco, Esq. FBN: 27199 Iniv Gabay, Esq. FBN: 37487 Ashley N. Ward-Singleton, FBN: 89426 1410 North Westshore Boulevard, Suite 200 Tampa, Florida 33607 T: 813-286-8818 / F: 813-286-9998 Attomeys for Defendant Filing 143310416 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX