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**** CASE NUMBER: 502024CA002537XXXAMB Div: AG ****
Filing # 194324442 E-Filed 03/19/2024 12:01:03 PM
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.:
YOANDER HERNANDEZ and
SHERLEINS USIN,
Plaintiffs,
v.
TYPTAP INSURANCE COMPANY,
Defendant.
____________________________________/
PLAINTIFFS’ NOTICE OF SERVICE OF FIRST INTERROGATORIES TO
DEFENDANT, TYPTAP INSURANCE COMPANY
Plaintiffs, YOANDER HERNANDEZ and SHERLEINS USIN, by and through their
undersigned counsel, pursuant to Rules 1.280 and 1.340 of the Florida Rules of Civil Procedure,
and propound upon Defendant, TYPTAP INSURANCE COMPANY, the attached interrogatories
to be answered under oath and in writing within forty-five (45) days after service thereof.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served with the
Original Summons and Complaint.
SASIETA LAW, PLLC
Gables International Plaza
2655 Lejeune Road, Suite PH1-F,
Coral Gables, FL 33134
Phone: 305.340-9082
By: /s/ Kevin Diaz
Kevin Diaz, Esq.
Florida Bar No.: 1010216
Alejandro Sasieta, Esq.
Florida Bar No.: 109573
kevin@sasietalaw.com
paralegal@sasietalaw.com
lawclerk@sasietalaw.com
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 03/19/2024 12:01:03 PM
INTERROGATORIES TO DEFENDANT
“You(r)” as used in these Interrogatories means your corporation, company or partnership,
or anyone who handles, adjusts or investigates claims on its behalf.
1. State your complete corporate name, nature of your business, whether you are licensed to
do business in the State of Florida and whether your name as it appears in the Plaintiffs’
Complaint is correct.
2. State the name, residence address, business address, telephone number, and position/job
title of the individual answering these Interrogatories.
3. List the names, addresses and telephone numbers of all persons believed or known by you,
your agents or attorneys to have knowledge concerning any of the issues raised by the
pleadings, specifying the subject matter about which the witnesses have knowledge and
state whether you have obtained any statements (oral, written and/or recorded) from any of
said witnesses, list the dates any such witness statements were taken, by whom any such
witness statements were taken, and who has present possession, custody and control of any
such statements.
4. State any and all reason(s) relied upon by Defendant for denial, nonpayment and/or
reduction of Plaintiffs’ claim.
5. List the names, residence addresses, business addresses and telephone numbers of all
persons who, have in any way participated in the investigations, adjusting or handling of
the Plaintiffs’ claim involved herein and specify the date and the nature of the participation
of each such person.
6. Do you intend to call upon any expert witness at the trial of this case? If so, please identify
each witness as follows: his/her name, qualifications as an expert, substance of their
opinions to which they are expected to testify, summary of the factual grounds for each
opinion.
7. For any and all policy defenses which you reasonably believe are available with regard to
the claim made by the Plaintiffs herein: describe in detail the factual and legal basis for any
such defenses.
8. Provide a complete list of all payments made to or on behalf of the Plaintiffs for the subject
loss, specifying the nature of the services rendered, the provider of the services, the amount
of the charges, the date the charges were incurred, the date you first had notice of the
charges, and the date the charges were paid by you.
9. Please provide the name and contact information of the agent who sold Plaintiffs the
subject policy.
10. If Defendant is claiming that another individual or entity is liable for damages which are
subject to this lawsuit, please state with specificity who is said individual/entity and why.
11. Please identify all claims made by the Plaintiffs at the subject property.
12. Please state with specificity any conditions precedent or subsequent to the Plaintiffs claim
that you contend has not been fulfilled by Plaintiffs or Plaintiffs’ representatives.
13. If you are claiming you were prejudiced during the investigation of this claim, please state
with specificity in what way; specifically state each and every effort made by you to
overcome said prejudice.
14. If you were unable to pay Plaintiffs due to insufficient information, state; what information
was lacking in order to make a determination; when did you realize that you needed said
information; when did you inform the Plaintiffs or Plaintiffs’ representatives that you
needed said information.
____________________________
Affiant:
STATE OF FLORIDA ::
COUNTY OF __________ :
BEFORE ME, the undersigned authority, personally appeared _____________________,
who, being first duly sworn, on oath deposes and says that the foregoing Answers to Interrogatories
are true and correct, and that he/she has read the Answers to Interrogatories and knows the contents
thereof.
SWORN TO AND SUBSCRIBED before me this _______day of _____________, 2024.
_____________________________
NOTARY PUBLIC
My commission expires:
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**** CASE NUMBER: 502024CA002537XXXAMB Div: AG **** Filing # 194324442 E-Filed 03/19/2024 12:01:03 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: YOANDER HERNANDEZ and SHERLEINS USIN, Plaintiffs, v. TYPTAP INSURANCE COMPANY, Defendant. ____________________________________/ PLAINTIFFS’ NOTICE OF SERVICE OF FIRST INTERROGATORIES TO DEFENDANT, TYPTAP INSURANCE COMPANY Plaintiffs, YOANDER HERNANDEZ and SHERLEINS USIN, by and through their undersigned counsel, pursuant to Rules 1.280 and 1.340 of the Florida Rules of Civil Procedure, and propound upon Defendant, TYPTAP INSURANCE COMPANY, the attached interrogatories to be answered under oath and in writing within forty-five (45) days after service thereof. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served with the Original Summons and Complaint. SASIETA LAW, PLLC Gables International Plaza 2655 Lejeune Road, Suite PH1-F, Coral Gables, FL 33134 Phone: 305.340-9082 By: /s/ Kevin Diaz Kevin Diaz, Esq. Florida Bar No.: 1010216 Alejandro Sasieta, Esq. Florida Bar No.: 109573 kevin@sasietalaw.com paralegal@sasietalaw.com lawclerk@sasietalaw.com FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 03/19/2024 12:01:03 PM INTERROGATORIES TO DEFENDANT “You(r)” as used in these Interrogatories means your corporation, company or partnership, or anyone who handles, adjusts or investigates claims on its behalf. 1. State your complete corporate name, nature of your business, whether you are licensed to do business in the State of Florida and whether your name as it appears in the Plaintiffs’ Complaint is correct. 2. State the name, residence address, business address, telephone number, and position/job title of the individual answering these Interrogatories. 3. List the names, addresses and telephone numbers of all persons believed or known by you, your agents or attorneys to have knowledge concerning any of the issues raised by the pleadings, specifying the subject matter about which the witnesses have knowledge and state whether you have obtained any statements (oral, written and/or recorded) from any of said witnesses, list the dates any such witness statements were taken, by whom any such witness statements were taken, and who has present possession, custody and control of any such statements. 4. State any and all reason(s) relied upon by Defendant for denial, nonpayment and/or reduction of Plaintiffs’ claim. 5. List the names, residence addresses, business addresses and telephone numbers of all persons who, have in any way participated in the investigations, adjusting or handling of the Plaintiffs’ claim involved herein and specify the date and the nature of the participation of each such person. 6. Do you intend to call upon any expert witness at the trial of this case? If so, please identify each witness as follows: his/her name, qualifications as an expert, substance of their opinions to which they are expected to testify, summary of the factual grounds for each opinion. 7. For any and all policy defenses which you reasonably believe are available with regard to the claim made by the Plaintiffs herein: describe in detail the factual and legal basis for any such defenses. 8. Provide a complete list of all payments made to or on behalf of the Plaintiffs for the subject loss, specifying the nature of the services rendered, the provider of the services, the amount of the charges, the date the charges were incurred, the date you first had notice of the charges, and the date the charges were paid by you. 9. Please provide the name and contact information of the agent who sold Plaintiffs the subject policy. 10. If Defendant is claiming that another individual or entity is liable for damages which are subject to this lawsuit, please state with specificity who is said individual/entity and why. 11. Please identify all claims made by the Plaintiffs at the subject property. 12. Please state with specificity any conditions precedent or subsequent to the Plaintiffs claim that you contend has not been fulfilled by Plaintiffs or Plaintiffs’ representatives. 13. If you are claiming you were prejudiced during the investigation of this claim, please state with specificity in what way; specifically state each and every effort made by you to overcome said prejudice. 14. If you were unable to pay Plaintiffs due to insufficient information, state; what information was lacking in order to make a determination; when did you realize that you needed said information; when did you inform the Plaintiffs or Plaintiffs’ representatives that you needed said information. ____________________________ Affiant: STATE OF FLORIDA :: COUNTY OF __________ : BEFORE ME, the undersigned authority, personally appeared _____________________, who, being first duly sworn, on oath deposes and says that the foregoing Answers to Interrogatories are true and correct, and that he/she has read the Answers to Interrogatories and knows the contents thereof. SWORN TO AND SUBSCRIBED before me this _______day of _____________, 2024. _____________________________ NOTARY PUBLIC My commission expires: