On December 18, 2015 a
Party Discovery
was filed
involving a dispute between
Manikuttiyil, Merly,
Manikuttiyil, Pious,
and
Florida Peninsula Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
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Case Number: CACE-15-022416 Division: 05
Filing # 35737329 E-Filed 12/18/2015 04:23:42 PM
IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA
PIOUS MANIKUTTIYIL AND MERLY CASE NO.
MANIKUTTIYIL,
Plaintiff,
vs.
FLORIDA PENINSULA INSURANCE
COMPANY,
Defendant.
REQUEST FOR ADMISSIONS
COMES NOW the 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 prior to the institution of this action, Plaintiff made a claim under the
Policy described in the complaint for a loss which Plaintiff claims occurred the date of loss described
in the complaint.
5. Admit that Defendant assigned the claim number to the subject loss as described in
the complaint.
6. Adimit that Plaintiff submitted to Defendant a written estimate of repairs for the
damage alleged to have occurred by reason of the loss.
7. Admit that Defendant did not make a request in writing for the Plaintiff to submit a
Swom Proof of Loss for the alleged loss.
8. Admit that Defendant did not make a request in writing for the Plaintiff to submit to
DUBOFF
** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/18/2015 4:23:40 PM.****an examination under oath for the alleged loss.
9. Admit that Plaintiff permitted Defendant access to the premises described in the
subject policy after the date of the alleged loss.
10. Admit that as of the date of the filing if this lawsuit, that Defendant had denied the
Plaintiff's claim for insurance benefits for the alleged loss described in the complaint.
11, Admit that as of the date of the filing if this lawsuit, that Defendant had not made any
payment of insurance proceeds to Plaintiff for the subject loss described in the complaint.
12. Admit that Defendant does not have any written document evidencing that the entire
insurance policy described in the complaint was delivered to Plaintiff prior to the alleged date of
loss.
13. Admit that Defendant does not have any written document evidencing that the entire
insurance policy described in the complaint prior was delivered to Plaintiff 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
Defendant by the Insurance Commissioner of the State of Florida.
DUBOFF LAW FIRM
ATTORNEYS FOR PLAINTIFF
680N.E. 127 STREET
NORTH MIAMI, FLORIDA 33161
TELEPHONE (305) 899-0085
Fax No. (305) 899-0091
CourtDocument@DuboffLawFirm.com
Robert@DuboffLawFirm.com
ROBERT A. REYNOLDS
FLA. BAR #747181
Fr
Document Filed Date
December 18, 2015
Case Filing Date
December 18, 2015
Category
Other - Insurance Claim
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Case Number: CACE-15-022416 Division: 05 Filing # 35737329 E-Filed 12/18/2015 04:23:42 PM IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA PIOUS MANIKUTTIYIL AND MERLY CASE NO. MANIKUTTIYIL, Plaintiff, vs. FLORIDA PENINSULA INSURANCE COMPANY, Defendant. REQUEST FOR ADMISSIONS COMES NOW the 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 prior to the institution of this action, Plaintiff made a claim under the Policy described in the complaint for a loss which Plaintiff claims occurred the date of loss described in the complaint. 5. Admit that Defendant assigned the claim number to the subject loss as described in the complaint. 6. Adimit that Plaintiff submitted to Defendant a written estimate of repairs for the damage alleged to have occurred by reason of the loss. 7. Admit that Defendant did not make a request in writing for the Plaintiff to submit a Swom Proof of Loss for the alleged loss. 8. Admit that Defendant did not make a request in writing for the Plaintiff to submit to DUBOFF ** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/18/2015 4:23:40 PM.****an examination under oath for the alleged loss. 9. Admit that Plaintiff permitted Defendant access to the premises described in the subject policy after the date of the alleged loss. 10. Admit that as of the date of the filing if this lawsuit, that Defendant had denied the Plaintiff's claim for insurance benefits for the alleged loss described in the complaint. 11, Admit that as of the date of the filing if this lawsuit, that Defendant had not made any payment of insurance proceeds to Plaintiff for the subject loss described in the complaint. 12. Admit that Defendant does not have any written document evidencing that the entire insurance policy described in the complaint was delivered to Plaintiff prior to the alleged date of loss. 13. Admit that Defendant does not have any written document evidencing that the entire insurance policy described in the complaint prior was delivered to Plaintiff 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 Defendant by the Insurance Commissioner of the State of Florida. DUBOFF LAW FIRM ATTORNEYS FOR PLAINTIFF 680N.E. 127 STREET NORTH MIAMI, FLORIDA 33161 TELEPHONE (305) 899-0085 Fax No. (305) 899-0091 CourtDocument@DuboffLawFirm.com Robert@DuboffLawFirm.com ROBERT A. REYNOLDS FLA. BAR #747181 Fr