Party Discovery: THE KIDWELL GROUP LLC -VS- TYPTAP INSURANCE COMPANY

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                                IN THE COUNTY COURT OF THE
                                                  EIGHTEENTH JUDICIAL CIRCUIT IN AND
                                                  FOR SEMINOLE COUNTY, FLORIDA

                                                  CASE NO:       2024SC001916


THE KIDWELL GROUP LLC d/b/a AIR
QUALITY ASSESSORS OF FLORIDA a/a/o
Lourdes Reyes,

       Plaintiff,




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TYPTAP INSURANCE COMPANY,




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       Defendant.




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                                REQUEST FOR ADMISSIONS




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       COMES NOW Plaintiff, by and through the undersigned attorney, and pursuant to the




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applicable Florida Rules of Civil Procedure, hereby requests the Defendant to admit or deny the

following items:

       1.




          NO    Admit that on the date of loss specified in the Complaint filed in this case, the

insured assignor had a property insurance policy with TYPTAP INSURANCE COMPANY in




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full force and effect on the property located at 3408 West Saint John Street Tampa, FL 33607.

       2.       Admit that the above referenced insurance policy provided coverage to the

insured for damage caused to the property as a result of the subject loss.

       3.       Admit that the above referenced policy of insurance provided coverage for the

subject loss.

       4.       Admit that the Defendant was timely notified of the subject damage to the above

property.

       5.       Admit that Defendant received Plaintiff's Assignment of Benefits and Invoice for

payment.
         6.      Admit that the Plaintiff is the assignee under the insurance policy for the services

rendered by the Plaintiff.

         7.      Admit that the insured assigned their insurance benefits to the Plaintiff, for the

services rendered by the Plaintiff, through the Assignment of Benefits form received by the

Defendant during the claims submission process.

         8.      Admit that the signature on the Assignment of Benefits is that of the Insured or

the Insured's authorized representative.




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         9.      Admit that the Plaintiff has complied with all prerequisites to receiving benefits




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under the above policy.




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         10.     Admit that the above-named Defendant is properly named in this action.



filed.
         11.




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                 Admit that jurisdiction and venue are proper in the county in which this case was



         12.




            O F  Admit that the Defendant authored and/or drafted the insurance policy at issue in

this action, and Defendant has a true and correct copy of the subject insurance policy in its

possession.




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         13.     Admit that Defendant's adjuster who worked on this claim did so in accordance

with Fla. Stat. § 626.878.

         14.     Admit that any payment issued on this claim was in accordance with the terms of

the insurance policy at issue in this case.

         15.     Admit that the insured has complied with all of its conditions to coverage under

the policy of insurance.

         16.     Admit that the Defendant received the Plaintiff’s invoice with regard to the

subject claim.
                                CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that on this April 4, 2024, I electronically filed the foregoing with
the Clerk of Court by using the ECF system, which will send a notice to all counsel of record.

                                               /s/ William S England________
                                               William S England, Esquire
                                               Fla. Bar No.: 0098941
                                               Chad A. Barr, Esquire
                                               Fla. Bar No.: 55365
                                               Law Office of Chad A. Barr, P.A.
                                               238 N. Westmonte Dr., Suite 200
                                               Altamonte Springs, Florida 32714




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                                               Telephone: (407) 599-9036
                                               wseservice@chadbarrlaw.com (Primary)




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                                               will@chadbarrlaw.com (Secondary)




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