On July 30, 2015 a
Party Discovery
was filed
involving a dispute between
Barbat, Maria,
and
United Property & Casualty Ins Co,
for Contract and Indebtedness
in the District Court of Broward County.
Preview
Case Number: CACE-15-013511 Division: 25
Filing # 30274988 E-Filed 07/30/2015 10:53:29 AM
IN THE CIRCUIT COURT OF THE 17!"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.:
MARIA BARBAT,
Plaintiffs,
vs.
UNITED PROPERTY &
CASUALTY INSURANCE COMPANY,
Defendant.
REQUEST FOR ADMISSIONS
Plaintiff, MARIA BARBAT, by and through the undersigned attorneys, pursuant to Fla.
R. Civ. P. 1.370, requests that the Defendant, UNITED PROPERTY & CASUALTY
INSURANCE COMPANY, within forty-five (45) days from the date of service of this request,
admit to the following Request for Admissions of fact:
1. Please admit that prior to May 13, 2015 Defendant issued a policy of insurance numbered
UHC 6265952 (hereinafter “subject policy”) to Plaintiff's regarding property located at
5315 NW 93" Avenue, Sunrise, FL 33351 (hereinafter “Home”).
2. Please admit that UNITED PROPERTY & CASUALTY INSURANCE COMPANY
opened claim number 201500005905 regarding a claim for damage being made by
Plaintiff's for damages allegedly sustained on or about May 13, 2015 to the Home.
3. Please admit the subject policy issued by Defendant to Plaintiff provided coverage for
damage caused to Plaintiff's Home as a result of a covered peril.
4. Please admit that the subject policy was in full force and effect for the Home on or about
May 13, 2015.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/30/2015 10:53:27 AM.****5. Please admit that the above-styled Court, in and for Broward County, Florida, has
jurisdiction over Plaintiffs’ claims against Defendant.
6. Please admit that Plaintiffs timely notified Defendant of the damage to Plaintiffs’ Home.
7. Please admit that Plaintiffs have complied with all prerequisites to receiving benefits
under the subject policy of insurance for the Home.
8. Please admit that there are no “exclusions” to coverage being raised by UNITED
PROPERTY & CASUALTY INSURANCE COMPANY as a reason to deny payment for
the Home’s claim.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished to the Defendant along with the Summons and Complaint.
Jaramillo, Correa & Martinez
Attorneys for Plaintiff
7700 N. Kendall Drive, Suite 805
Miami, FL 33156
Tel: (305) 598-7739; Fax: (305) 598-5034
Byte
ANDRES J. CORREA (FBN 89790)
2
JARAMILLO, CORREA & MARTINEZ, 7700 N, KENDALL DRIVE, SUITE 805, MIAMI, FL 33156
TELEPHONE 305-598-7739 FACSIMILE 305-598-5034 EMAIL: COURTMAIL@JCMLAWGROUP.COM
Preview
Case Number: CACE-15-013511 Division: 25 Filing # 30274988 E-Filed 07/30/2015 10:53:29 AM IN THE CIRCUIT COURT OF THE 17!" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: MARIA BARBAT, Plaintiffs, vs. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. REQUEST FOR ADMISSIONS Plaintiff, MARIA BARBAT, by and through the undersigned attorneys, pursuant to Fla. R. Civ. P. 1.370, requests that the Defendant, UNITED PROPERTY & CASUALTY INSURANCE COMPANY, within forty-five (45) days from the date of service of this request, admit to the following Request for Admissions of fact: 1. Please admit that prior to May 13, 2015 Defendant issued a policy of insurance numbered UHC 6265952 (hereinafter “subject policy”) to Plaintiff's regarding property located at 5315 NW 93" Avenue, Sunrise, FL 33351 (hereinafter “Home”). 2. Please admit that UNITED PROPERTY & CASUALTY INSURANCE COMPANY opened claim number 201500005905 regarding a claim for damage being made by Plaintiff's for damages allegedly sustained on or about May 13, 2015 to the Home. 3. Please admit the subject policy issued by Defendant to Plaintiff provided coverage for damage caused to Plaintiff's Home as a result of a covered peril. 4. Please admit that the subject policy was in full force and effect for the Home on or about May 13, 2015. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/30/2015 10:53:27 AM.****5. Please admit that the above-styled Court, in and for Broward County, Florida, has jurisdiction over Plaintiffs’ claims against Defendant. 6. Please admit that Plaintiffs timely notified Defendant of the damage to Plaintiffs’ Home. 7. Please admit that Plaintiffs have complied with all prerequisites to receiving benefits under the subject policy of insurance for the Home. 8. Please admit that there are no “exclusions” to coverage being raised by UNITED PROPERTY & CASUALTY INSURANCE COMPANY as a reason to deny payment for the Home’s claim. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the Defendant along with the Summons and Complaint. Jaramillo, Correa & Martinez Attorneys for Plaintiff 7700 N. Kendall Drive, Suite 805 Miami, FL 33156 Tel: (305) 598-7739; Fax: (305) 598-5034 Byte ANDRES J. CORREA (FBN 89790) 2 JARAMILLO, CORREA & MARTINEZ, 7700 N, KENDALL DRIVE, SUITE 805, MIAMI, FL 33156 TELEPHONE 305-598-7739 FACSIMILE 305-598-5034 EMAIL: COURTMAIL@JCMLAWGROUP.COM