On December 05, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Gedeon, Boldwin,
Jacques, Jean,
and
Safepoint Ins Co,
for Other - Insurance Claim
in the District Court of Broward County.
Preview
Filing # 40409235 E-Filed 04/18/2016 05:03:39 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE-15-021433
BOLDWIN GEDEON AND JEAN JACQUES,
Plaintiffs,
vs.
SAFEPOINT INSURANCE COMPANY,
Defendant.
PSS ett
PLAINTIFFS’ MOTION FOR LEAVE TO AMEND COMPLAINT
Plaintiffs, BOLDWIN GEDEON AND JEAN JACQUES, by and through
undersigned counsel, hereby file their Motion for Leave to Amend the Complaint
pursuant to Rule 1.190(a) of the Florida Rule of Civil Procedure as follows:
1. This is an action for homeowner’s insurance benefits.
2. Plaintiffs filed their complaint on or about December 18, 2015. Plaintiffs Boldwin
Gedeon and Jean Jacques are listed as Plaintiffs in the complaint.
3. However, Edeline Gedeon, the wife of Boldwin Gedeon, is an additional insured
under the policy and is otherwise an indispensable and necessary party to this
action.
4. Plaintiffs are requesting leave to amend their complaint to add Edeline Gedeon to
this lawsuit. A copy of the Amended Complaint is attached as Exhibit A.
5. Pursuant to Florida Rule of Civil Procedures, leave of court shall be given freely
when justice so requires.
6. Plaintiffs hereby certify that this Motion is not for the purposes of undue delay
and/or harassment.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/18/2016 5:03:39 PM.****7. Plaintiffs also advise that counsel for Defendant has no objection to this Motion.
WHEREFORE, Plaintiffs respectfully request that this honorable Court grant this
Motion and any other relief that this court deems necessary and proper.
CERTIFICATE OF SERVICE
We HEREBY CERTIFY that a true and correct copy of the foregoing was served
by e-mail via the Florida Courts E-filing Portal system on this 18'" day of April 2016, upon:
Hope Zelinger, BRESSLER, AMERY & ROSS PC Attorney for Defendant, Service E-mail:
miainsurance@bressler.com, hzelinger@bressler.com, and kelsasser@bressler.com.
HOMEOWNER LEGAL SOLUTIONS, LP
Attorneys for Plaintiff
200 SE First Street, Suite 708
Miami, FL 33131
305.777.1050 Telephone
305.777.1051 Facsimile
By: — £5/ Stephanie Balint, Sag.
£3 / Robert L. Givia, Gra.
Stephanie Balint, Esq.
Florida bar No. 530050
sb@home-legal.com
Robert L. Gioia, Esq.
Florida bar No. 0533661
rg@home-legal.com
oleadings@home-legal.com
Document Filed Date
April 18, 2016
Case Filing Date
December 05, 2015
Category
Other - Insurance Claim
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Preview
Filing # 40409235 E-Filed 04/18/2016 05:03:39 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE-15-021433 BOLDWIN GEDEON AND JEAN JACQUES, Plaintiffs, vs. SAFEPOINT INSURANCE COMPANY, Defendant. PSS ett PLAINTIFFS’ MOTION FOR LEAVE TO AMEND COMPLAINT Plaintiffs, BOLDWIN GEDEON AND JEAN JACQUES, by and through undersigned counsel, hereby file their Motion for Leave to Amend the Complaint pursuant to Rule 1.190(a) of the Florida Rule of Civil Procedure as follows: 1. This is an action for homeowner’s insurance benefits. 2. Plaintiffs filed their complaint on or about December 18, 2015. Plaintiffs Boldwin Gedeon and Jean Jacques are listed as Plaintiffs in the complaint. 3. However, Edeline Gedeon, the wife of Boldwin Gedeon, is an additional insured under the policy and is otherwise an indispensable and necessary party to this action. 4. Plaintiffs are requesting leave to amend their complaint to add Edeline Gedeon to this lawsuit. A copy of the Amended Complaint is attached as Exhibit A. 5. Pursuant to Florida Rule of Civil Procedures, leave of court shall be given freely when justice so requires. 6. Plaintiffs hereby certify that this Motion is not for the purposes of undue delay and/or harassment. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/18/2016 5:03:39 PM.****7. Plaintiffs also advise that counsel for Defendant has no objection to this Motion. WHEREFORE, Plaintiffs respectfully request that this honorable Court grant this Motion and any other relief that this court deems necessary and proper. CERTIFICATE OF SERVICE We HEREBY CERTIFY that a true and correct copy of the foregoing was served by e-mail via the Florida Courts E-filing Portal system on this 18'" day of April 2016, upon: Hope Zelinger, BRESSLER, AMERY & ROSS PC Attorney for Defendant, Service E-mail: miainsurance@bressler.com, hzelinger@bressler.com, and kelsasser@bressler.com. HOMEOWNER LEGAL SOLUTIONS, LP Attorneys for Plaintiff 200 SE First Street, Suite 708 Miami, FL 33131 305.777.1050 Telephone 305.777.1051 Facsimile By: — £5/ Stephanie Balint, Sag. £3 / Robert L. Givia, Gra. Stephanie Balint, Esq. Florida bar No. 530050 sb@home-legal.com Robert L. Gioia, Esq. Florida bar No. 0533661 rg@home-legal.com oleadings@home-legal.com