On February 07, 2024 a
was filed
involving a dispute between
Pavlovic, Melinda,
and
Florida Insurance Guaranty Association, Inc.,
for Contracts
in the District Court of Charlotte County.
Preview
Filing # 191493456 E-Filed 02/07/2024 04:41:14 PM
IN THE CIRCUIT COURT OF THE
TWENTIETH JUDICIAL CIRCUIT IN
AND FOR CHARLOTTE COUNTY,
FLORIDA
MELINDA AND JOVICA PAVLOVIC,
CASE NO.: 24000354ca
Plaintiffs,
Vv.
FLORIDA INSURANCE GUARANTY ASSOCIATION,
Defendant.
/
PLAINTIFFS’ NOTICE OF SERVICE OF FIRST INTERROGATORIES TO
DEFENDANT
Plaintiffs, MELINDA AND JOVICA PAVLOVIC, through undersigned counsel, hereby
files its First Set of Interrogatories to Defendant, FLORIDA INSURANCE GUARANTY
ASSOCIATION, to be answered in writing and under oath within forty-five days after service as
provided by Florida Rule of Civil Procedure 1.340.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a certified copy of the foregoing has been served on Defendant.
The Law Offices of Robert David Malove
Attorneys for Plaintiff
200 SE 9" Street
Fort Lauderdale, Florida 33316
Phone: (954) 861-0384
Fax: (954) 333-6927
Email: jordan@robertmalovelaw.com
abrown@robertmalovelaw.com
fppleadings@robertmalovelaw.com
By: _/s/ Jordan B. Fertel__.
Jordan B. Fertel, Esq.
Florida Bar No.: 1032519
PLAINTIFFS’ FIRST INTERROGATORIES TO DEFENDANT
1 What is your name, address, and, if you are answering for someone else, your official
position or relationship with the party to whom the interrogatories are directed?
Answer:
Please state if you contend the loss as alleged in the complaint is not covered under the
subject insurance policy as referenced in the complaint. If so, please state:
a. specific language in the insurance policy that you are relying upon; and
b. specific facts that support this policy language.
Answer:
Please state with specificity any conditions precedent or subsequent to the Plaintiffs claims
that you contend were not fulfilled prior to the filing of this lawsuit.
Answer:
State only the facts upon which you rely on for each affirmative defense in your Answer
to Plaintiff's Complaint, including the name of any individual who provided such fact or
how such fact was determined by Defendant.
Answer:
5. List the names, addresses and telephone numbers of all persons who are believed or
known to have any knowledge concerning any of the issues in this lawsuit and specify the
subject matter about which the witness has knowledge. Please also provide _a short
statement of the persons knowledge and involvement.
Answer:
For each denied or withheld payment for the subject claim listed above, please state in
detail the legal ground and the factual basis upon which the claim was denied and the exact
wording of any statutory language or case law upon which you base your denial or
withholding of payment.
Answer:
7. Please state if any person who inspected the subject property for the instant claim prepared
any sort of report. If so, please state:
a. the date the report was prepared;
b. the conclusions of the report; and
Cc whether you relied upon the report in making a coverage determination for the
subject insurance claim.
Answer:
8. Please state the date that you received notice of this claim, including
a. who reported the claim;
b. the name of any individual who received the initial claim reporting; and
Cc what was specifically was reported.
Answer:
9. Please state the exact date Defendant anticipated litigation and provide an explanation as
to why Defendant anticipated litigation on this date.
Answer:
10. Please state the name of all individuals who entered notes and/or information on
Defendant’s internal log notes, attachments log page, payments log page and overview
page.
Answer:
Jurat Pag
Dated 202
Signature of Agent for Defendant
STATE OF
COUNTY OF
SWORN AND SUBSCRIBRED before me in the aforesaid County and State, the
undersigned authority, by means of 0 physical presence or OH online notarization, this
day of ’ 202_, the Agent for Defendant
, who deposed and stated that the information contained in
the foregoing Answers to Interrogatories is true and correct, to the best of his/her knowledge and
belief.
Notary Public
Commission No.
(Name of Notary typed, printed or stamped)
My commission expires:
Document Filed Date
February 05, 2024
Case Filing Date
February 07, 2024
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Filing # 191493456 E-Filed 02/07/2024 04:41:14 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA MELINDA AND JOVICA PAVLOVIC, CASE NO.: 24000354ca Plaintiffs, Vv. FLORIDA INSURANCE GUARANTY ASSOCIATION, Defendant. / PLAINTIFFS’ NOTICE OF SERVICE OF FIRST INTERROGATORIES TO DEFENDANT Plaintiffs, MELINDA AND JOVICA PAVLOVIC, through undersigned counsel, hereby files its First Set of Interrogatories to Defendant, FLORIDA INSURANCE GUARANTY ASSOCIATION, to be answered in writing and under oath within forty-five days after service as provided by Florida Rule of Civil Procedure 1.340. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a certified copy of the foregoing has been served on Defendant. The Law Offices of Robert David Malove Attorneys for Plaintiff 200 SE 9" Street Fort Lauderdale, Florida 33316 Phone: (954) 861-0384 Fax: (954) 333-6927 Email: jordan@robertmalovelaw.com abrown@robertmalovelaw.com fppleadings@robertmalovelaw.com By: _/s/ Jordan B. Fertel__. Jordan B. Fertel, Esq. Florida Bar No.: 1032519 PLAINTIFFS’ FIRST INTERROGATORIES TO DEFENDANT 1 What is your name, address, and, if you are answering for someone else, your official position or relationship with the party to whom the interrogatories are directed? Answer: Please state if you contend the loss as alleged in the complaint is not covered under the subject insurance policy as referenced in the complaint. If so, please state: a. specific language in the insurance policy that you are relying upon; and b. specific facts that support this policy language. Answer: Please state with specificity any conditions precedent or subsequent to the Plaintiffs claims that you contend were not fulfilled prior to the filing of this lawsuit. Answer: State only the facts upon which you rely on for each affirmative defense in your Answer to Plaintiff's Complaint, including the name of any individual who provided such fact or how such fact was determined by Defendant. Answer: 5. List the names, addresses and telephone numbers of all persons who are believed or known to have any knowledge concerning any of the issues in this lawsuit and specify the subject matter about which the witness has knowledge. Please also provide _a short statement of the persons knowledge and involvement. Answer: For each denied or withheld payment for the subject claim listed above, please state in detail the legal ground and the factual basis upon which the claim was denied and the exact wording of any statutory language or case law upon which you base your denial or withholding of payment. Answer: 7. Please state if any person who inspected the subject property for the instant claim prepared any sort of report. If so, please state: a. the date the report was prepared; b. the conclusions of the report; and Cc whether you relied upon the report in making a coverage determination for the subject insurance claim. Answer: 8. Please state the date that you received notice of this claim, including a. who reported the claim; b. the name of any individual who received the initial claim reporting; and Cc what was specifically was reported. Answer: 9. Please state the exact date Defendant anticipated litigation and provide an explanation as to why Defendant anticipated litigation on this date. Answer: 10. Please state the name of all individuals who entered notes and/or information on Defendant’s internal log notes, attachments log page, payments log page and overview page. Answer: Jurat Pag Dated 202 Signature of Agent for Defendant STATE OF COUNTY OF SWORN AND SUBSCRIBRED before me in the aforesaid County and State, the undersigned authority, by means of 0 physical presence or OH online notarization, this day of ’ 202_, the Agent for Defendant , who deposed and stated that the information contained in the foregoing Answers to Interrogatories is true and correct, to the best of his/her knowledge and belief. Notary Public Commission No. (Name of Notary typed, printed or stamped) My commission expires: