Document for ROYAL, THEODORE vs CITIZENS PROPERTY INSURANCE CORPORATION

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Filing # 191327315 E-Filed 02/06/2024 10:26:15 AM


                                                                      IN THE CIRCUIT COURT OF THE
                                                                      THIRTEENTH JUDICIAL CIRCUIT IN
                                                                      AND FOR HILLSBOROUGH COUNTY,
                                                                      FLORIDA

                                                                      CASE NO.:
             THEODORE ROYAL
             AND ALISIA ROYAL,

                       Plaintiffs,

             v.

             CITIZENS PROPERTY INSURANCE CORPORATION,

                   Defendant.
             __________________________________/

                                                REQUEST FOR ADMISSIONS

                       Plaintiffs, THEODORE ROYAL AND ALISIA ROYAL, pursuant to Florida Rule of

             Civil Procedure 1.370, request the Defendant, CITIZENS PROPERTY INSURANCE

             CORPORATION, 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 Plaintiffs (“Policy”) for the property

             located at 3804 Coral Dr., Tampa, FL 33619 (“Dwelling”).

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

                       3.      The Dwelling sustained direct physical damage caused by wind damage 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.      Plaintiffs submitted an insurance claim to Defendant (the “claim”) pursuant to the

             terms and conditions of the Policy.




2/6/2024 10:26 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
                    6.      Plaintiffs 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.      Plaintiffs 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 of a covered loss to the Dwelling, the Policy requires Defendant to pay

             benefits on a “Replacement Cost Value” basis, irrespective of whether Plaintiffs actually repair or

             replace the damaged property.




                                      [CONTINUED ON THE FOLLOWING PAGE]




2/6/2024 10:26 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
                                              CERTIFICATE OF SERVICE

                    I HEREBY CERTIFY that a true and correct copy of the foregoing has been

             electronically filed with the Florida Courts E-Filing Portal System this February 6, 2024 and copies

             furnished by initial Service of Process.




                                                                Cordova Law Firm, PLLC
                                                                /s/ Leslie Cabrera
                                                                Leslie Cabrera, Esq.
                                                                Florida Bar No.: 1025277
                                                                Cordova Law Firm, PLLC
                                                                496 Delaney Avenue, Ste 508
                                                                Orlando, FL 32801
                                                                Phone: (321) 267-3682
                                                                Fax: (407) 442-0654
                                                                Primary Email:
                                                                leslie@justcallmyattorney.com
                                                                Secondary Email:
                                                                adrianam@justcallmyattorney.com
                                                                Attorney for Plaintiffs




2/6/2024 10:26 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3