On July 17, 2015 a
Party Discovery
was filed
involving a dispute between
Richards, Albert,
and
Safepoint Ins Comp,
for Contract and Indebtedness
in the District Court of Broward County.
Preview
Case Number: CACE-15-012433 Division: 02
Filing # 29786747 E-Filed 07/17/2015 01:14:23 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
ALBERT RICHARDS,
Plaintiff(s),
Vv.
SAFEPOINT INSURANCE COMPANY,
Defendant. Case No.:
REQUEST FOR ADMISSIONS
COMES NOW, Plaintiff by and through the undersigned attorneys and pursuant to the applicable
Florida Rules of Civil Procedure, hereby requests the Defendant to admit or deny the following items:
1, Admit that on the date of the alleged loss described in the Complaint that the policy described in
the Complaint was in full force and effect.
2. Admit that Plaintiff is the named insured under the insurance policy described in the Complaint.
3. Admit that the premises described in the Complaint are the insured premises under the insurance
policy described in the Complaint.
4. Admit that the only reason for the Defendant’s denial of payment on the subject claim is a result
of Defendant’s determination that the damage to Plaintiff’s Property is not the result of a covered peril under the
subject Policy of insurance.
5. Admit that Defendant did not make a payment of insurance benefits to, or for the benefit of
Plaintiff for the alleged loss described in the Complaint.
6. Admit that Plaintiff submitted to Defendant a written estimate of repairs for the damage alleged
to have occurred by reason of the alleged loss described in the Complaint.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/17/2015 1:14:22 PM.****7. Admit that the Plaintiff has fully cooperated with the Defendant with respect to all requests for
investigation and inspection of the subject Premises.
8. Admit that Defendant did not take a recorded statement of the Plaintiff with regard to the subject
loss.
9. Admit that the Plaintiff has complied with all post loss obligations requested by the Defendant as
set forth in the insurance policy.
10. Admit that there is a disagreement between the Plaintiff and Defendant as to the amount of the
alleged loss described in the Complaint.
11. Admit that prior to the institution of this lawsuit, Defendant received a written demand for full
payment under the Policy submitted by or on behalf of Plaintiff for the subject loss.
12. Admit that prior to the date of the filing of this lawsuit; Defendant did not request of Plaintiff, in
writing, that Plaintiff submit to an examination under oath for the alleged loss described in the Complaint.
13. | Admit that prior to the date of the filing of this lawsuit; Defendant did not request of Plaintiff, in
writing, that Plaintiff send to Defendant, a signed sworn proof of loss for the alleged loss described in the
Complaint.
14. Admit that prior to the date of the filing of this lawsuit, that one or more of Defendant's agents or
adjusters or employees were showed, or visited, or inspected the alleged damaged property described in the
Complaint.
15. Admit that Defendant does not have any written document evidencing that the entire insurance
policy described in the complaint was delivered to Plaintiff.
16. Admit that Defendant did not deliver a copy of the entire insurance policy described in the
complaint prior to the filing of this lawsuit.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon
Respondent by the Insurance Commissioner of the State of Florida.
MILITZOK & LEVY, P.A.
Attorneys for Plaintiff
The Yankee Clipper Law Center
3230 Stirling Road, Suite 1
Hollywood, Florida 33021
(954) 727-8570 - Telephone
Robin@mllawfl.com - E-Mail
angela@mllawfl.com - Secondary Service
FLService@mllawfl.com - E-Service
By: /s/ Robin A. Richison
ROBIN A. RICHISON, ESQ.
Florida Bar No.: 42009
Document Filed Date
July 17, 2015
Case Filing Date
July 17, 2015
Category
Contract and Indebtedness
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Case Number: CACE-15-012433 Division: 02 Filing # 29786747 E-Filed 07/17/2015 01:14:23 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ALBERT RICHARDS, Plaintiff(s), Vv. SAFEPOINT INSURANCE COMPANY, Defendant. Case No.: REQUEST FOR ADMISSIONS COMES NOW, Plaintiff by and through the undersigned attorneys and pursuant to the applicable Florida Rules of Civil Procedure, hereby requests the Defendant to admit or deny the following items: 1, Admit that on the date of the alleged loss described in the Complaint that the policy described in the Complaint was in full force and effect. 2. Admit that Plaintiff is the named insured under the insurance policy described in the Complaint. 3. Admit that the premises described in the Complaint are the insured premises under the insurance policy described in the Complaint. 4. Admit that the only reason for the Defendant’s denial of payment on the subject claim is a result of Defendant’s determination that the damage to Plaintiff’s Property is not the result of a covered peril under the subject Policy of insurance. 5. Admit that Defendant did not make a payment of insurance benefits to, or for the benefit of Plaintiff for the alleged loss described in the Complaint. 6. Admit that Plaintiff submitted to Defendant a written estimate of repairs for the damage alleged to have occurred by reason of the alleged loss described in the Complaint. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/17/2015 1:14:22 PM.****7. Admit that the Plaintiff has fully cooperated with the Defendant with respect to all requests for investigation and inspection of the subject Premises. 8. Admit that Defendant did not take a recorded statement of the Plaintiff with regard to the subject loss. 9. Admit that the Plaintiff has complied with all post loss obligations requested by the Defendant as set forth in the insurance policy. 10. Admit that there is a disagreement between the Plaintiff and Defendant as to the amount of the alleged loss described in the Complaint. 11. Admit that prior to the institution of this lawsuit, Defendant received a written demand for full payment under the Policy submitted by or on behalf of Plaintiff for the subject loss. 12. Admit that prior to the date of the filing of this lawsuit; Defendant did not request of Plaintiff, in writing, that Plaintiff submit to an examination under oath for the alleged loss described in the Complaint. 13. | Admit that prior to the date of the filing of this lawsuit; Defendant did not request of Plaintiff, in writing, that Plaintiff send to Defendant, a signed sworn proof of loss for the alleged loss described in the Complaint. 14. Admit that prior to the date of the filing of this lawsuit, that one or more of Defendant's agents or adjusters or employees were showed, or visited, or inspected the alleged damaged property described in the Complaint. 15. Admit that Defendant does not have any written document evidencing that the entire insurance policy described in the complaint was delivered to Plaintiff. 16. Admit that Defendant did not deliver a copy of the entire insurance policy described in the complaint prior to the filing of this lawsuit.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon Respondent by the Insurance Commissioner of the State of Florida. MILITZOK & LEVY, P.A. Attorneys for Plaintiff The Yankee Clipper Law Center 3230 Stirling Road, Suite 1 Hollywood, Florida 33021 (954) 727-8570 - Telephone Robin@mllawfl.com - E-Mail angela@mllawfl.com - Secondary Service FLService@mllawfl.com - E-Service By: /s/ Robin A. Richison ROBIN A. RICHISON, ESQ. Florida Bar No.: 42009