Preview
Filing # 38476427 E-Filed 03/01/2016 05:39:27 PM
15-352 IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
PAUL AND MARY SJOGREN, CASE NO: CACE-15-021927 Div 14
Plaintiff,
v.
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS
Defendant, Homeowners Choice Property & Casualty Insurance Company (HCI), serves
this, its response to plaintiffs’ first request for admissions propounded to defendant together with
the complaint and states:
1. Admitted.
2. Admitted for jurisdictional purposes only.
3. Admitted for jurisdictional purposes only.
4, Admitted.
5. Admitted for jurisdictional purposes only.
6. Denied.
7. Denied as stated. Admitted only that HCI issued policy number HCPC-HO3-264523-5 to
plaintiffs subject to the terms, conditions and exclusions contained therein.
8. Without knowledge, therefore denied.
9. Admitted.
10. Denied.
IL. Denied as stated. Admitted only that a claim was made on August 28, 2015, for alleged
damages to the property located at 13488 N.W. 5" Court, Plantation, Florida 33325.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 3/1/2016 5:39:27 PM.****15.
16.
17.
18.
20.
21.
22.
23.
24.
25.
26.
Admitted.
Admitted.
Denied as stated. Admitted only that HCI provided coverage to plaintiffs for the claim
reported on August 28, 2015, pursuant to the terms, conditions, and exclusions of the
insurance policy.
Denied.
Denied as stated. Admitted only that the policy of insurance provides coverage for
additional living expenses and fair rental value for the insured location subject to the
terms, conditions and exclusions contained therein.
Denied as stated. Admitted only that HCI received correspondence from plaintiffs’ public
adjuster demanding payment pursuant to the public adjuster’s estimate.
Denied.
Denied.
Denied as stated. Admitted only that HCI provided coverage to plaintiffs for the claim
reported on August 28, 2015, pursuant to the terms, conditions, and exclusions of the
insurance policy.
Admitted only that the policy number HCPC-HO3-264523-5 issued by HCI to plaintiffs
has effective dates of February 26, 2015, through February 26, 2016.
Admitted only that HCI provided coverage to plaintiffs for the claim reported on August
28, 2015, pursuant to the terms, conditions, and exclusions of the insurance policy.
Denied.
Denied.
Denied.
Admitted.27. Objection, this request is vague and ambiguous and will not lead to the discovery of
relevant admissible evidence.
28. Without knowledge, therefore denied.
29. Denied.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing was served
via Florida’s e-filing portal on this 1 day of March 2016 to STEPHANIE BALINT, ESQ., and
ROBERT L. GIOIA, ESQ., Homeowner Legal Solutions, LP., 200 S.E. 1st Street, Suite 708,
Miami, FL 33131 [sb@home-legal.com; ro@home-legal.com;pleadings@home-legal.com].
COLODNY FASS, P.A.
Attorneys for Defendant, Homeowners Choice
1401 N.W. 136 Avenue, Suite 200
Sunrise, FL 33323
Telephone: (954) 492-4010
Telefax: (954) 492-1144
By: /s/ Danielle V. Bullock
DANIELLE V. BULLOCK
Fla. Bar No. 68355
dbullock@colodnyfass.com
Preview
Filing # 38476427 E-Filed 03/01/2016 05:39:27 PM 15-352 IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA PAUL AND MARY SJOGREN, CASE NO: CACE-15-021927 Div 14 Plaintiff, v. HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / DEFENDANT’S RESPONSE TO PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS Defendant, Homeowners Choice Property & Casualty Insurance Company (HCI), serves this, its response to plaintiffs’ first request for admissions propounded to defendant together with the complaint and states: 1. Admitted. 2. Admitted for jurisdictional purposes only. 3. Admitted for jurisdictional purposes only. 4, Admitted. 5. Admitted for jurisdictional purposes only. 6. Denied. 7. Denied as stated. Admitted only that HCI issued policy number HCPC-HO3-264523-5 to plaintiffs subject to the terms, conditions and exclusions contained therein. 8. Without knowledge, therefore denied. 9. Admitted. 10. Denied. IL. Denied as stated. Admitted only that a claim was made on August 28, 2015, for alleged damages to the property located at 13488 N.W. 5" Court, Plantation, Florida 33325. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 3/1/2016 5:39:27 PM.****15. 16. 17. 18. 20. 21. 22. 23. 24. 25. 26. Admitted. Admitted. Denied as stated. Admitted only that HCI provided coverage to plaintiffs for the claim reported on August 28, 2015, pursuant to the terms, conditions, and exclusions of the insurance policy. Denied. Denied as stated. Admitted only that the policy of insurance provides coverage for additional living expenses and fair rental value for the insured location subject to the terms, conditions and exclusions contained therein. Denied as stated. Admitted only that HCI received correspondence from plaintiffs’ public adjuster demanding payment pursuant to the public adjuster’s estimate. Denied. Denied. Denied as stated. Admitted only that HCI provided coverage to plaintiffs for the claim reported on August 28, 2015, pursuant to the terms, conditions, and exclusions of the insurance policy. Admitted only that the policy number HCPC-HO3-264523-5 issued by HCI to plaintiffs has effective dates of February 26, 2015, through February 26, 2016. Admitted only that HCI provided coverage to plaintiffs for the claim reported on August 28, 2015, pursuant to the terms, conditions, and exclusions of the insurance policy. Denied. Denied. Denied. Admitted.27. Objection, this request is vague and ambiguous and will not lead to the discovery of relevant admissible evidence. 28. Without knowledge, therefore denied. 29. Denied. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing was served via Florida’s e-filing portal on this 1 day of March 2016 to STEPHANIE BALINT, ESQ., and ROBERT L. GIOIA, ESQ., Homeowner Legal Solutions, LP., 200 S.E. 1st Street, Suite 708, Miami, FL 33131 [sb@home-legal.com; ro@home-legal.com;pleadings@home-legal.com]. COLODNY FASS, P.A. Attorneys for Defendant, Homeowners Choice 1401 N.W. 136 Avenue, Suite 200 Sunrise, FL 33323 Telephone: (954) 492-4010 Telefax: (954) 492-1144 By: /s/ Danielle V. Bullock DANIELLE V. BULLOCK Fla. Bar No. 68355 dbullock@colodnyfass.com