On August 27, 2014 a
Party Discovery
was filed
involving a dispute between
Hines, Debra,
and
Homeowners Choice Prop & Casualty Ins Co,
for Contract and Indebtedness
in the District Court of Broward County.
Preview
Filing # 39208098 E-Filed 03/18/2016 03:06:51 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CIVIL DIVISION
DEBRA HINES
Plaintiff,
CASE NO.: CACE-14-016655
vs. DIVISION: 02
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.
a Florida Corporation
Defendant.
/
/
PLAINTIFF’S RESPONSES TO DEFENDANT’S
FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF
Plaintiff, DEBRA HINES, by and through the undersigned counsel, and pursuant to rule
1.370 of the Florida Rules and Civil Procedures, hereby responds to Defendant’s First Request for
Admissions as follows:
1. RESPONSE: Admitted.
2. RESPONSE: Admitted.
3. RESPONSE: Admitted.
4. RESPONSE: After reasonable search and inquiry, admitted.
5. RESPONSE: Admitted.
6. RESPONSE: Denied.
7. RESPONSE: Admitted some damage was pointed out by a third party; denied as to
remainder.
8. RESPONSE: Denied as phrased.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 3/18/2016 3:06:51 PM.****10.
12.
13.
14.
15.
16.
17.
18.
20.
21.
RESPONSE: Denied as phrased.
RESPONSE: Denied as phrased.
. RESPONSE: Denied.
RESPONSE: Denied.
RESPONSE: Denied.
RESPONSE: Denied.
RESPONSE: Admitted.
RESPONSE: Without knowledge, therefore denied.
RESPONSE: Admitted.
RESPONSE: Objection, calls for a legal and expert conclusion.
. RESPONSE: Objection, calls for a legal and expert conclusion.
RESPONSE: Objection, calls for a legal and expert conclusion.
RESPONSE: Denied.
is)CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document has been
electronically filed with the Clerk of Court using the Florida Courts E-Filing Portal and served
via Florida Courts E-Filing Portal Electronic Mail to: Jonathan T. Hall, Esq.,
grobinson@ gspalaw.com and gstcourtdocs@gspalaw.com, Groelle & Salmon, PA, 7650 Courtney
Campbell Cswy., Ste. 800, Tampa, FL 33067 and Ryan H. Sherman, Esq.,
eservicesIpa@ gmail.com on this 18" day of March 2016.
/s/ Morgan Barfield
Morgan Barfield, Esq.
Co-Counsel for Plaintiffs
Corless Barfield Trial
Group, LLC
4350 W. Cypress Street
Suite 910
Tampa, Florida 33607
(813) 258-4998
(813) 258-4988 — Facsimile
MBarfield@CorlessBarfield.com
Document Filed Date
March 18, 2016
Case Filing Date
August 27, 2014
Category
Contract and Indebtedness
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Filing # 39208098 E-Filed 03/18/2016 03:06:51 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION DEBRA HINES Plaintiff, CASE NO.: CACE-14-016655 vs. DIVISION: 02 HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC. a Florida Corporation Defendant. / / PLAINTIFF’S RESPONSES TO DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF Plaintiff, DEBRA HINES, by and through the undersigned counsel, and pursuant to rule 1.370 of the Florida Rules and Civil Procedures, hereby responds to Defendant’s First Request for Admissions as follows: 1. RESPONSE: Admitted. 2. RESPONSE: Admitted. 3. RESPONSE: Admitted. 4. RESPONSE: After reasonable search and inquiry, admitted. 5. RESPONSE: Admitted. 6. RESPONSE: Denied. 7. RESPONSE: Admitted some damage was pointed out by a third party; denied as to remainder. 8. RESPONSE: Denied as phrased. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 3/18/2016 3:06:51 PM.****10. 12. 13. 14. 15. 16. 17. 18. 20. 21. RESPONSE: Denied as phrased. RESPONSE: Denied as phrased. . RESPONSE: Denied. RESPONSE: Denied. RESPONSE: Denied. RESPONSE: Denied. RESPONSE: Admitted. RESPONSE: Without knowledge, therefore denied. RESPONSE: Admitted. RESPONSE: Objection, calls for a legal and expert conclusion. . RESPONSE: Objection, calls for a legal and expert conclusion. RESPONSE: Objection, calls for a legal and expert conclusion. RESPONSE: Denied. is)CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document has been electronically filed with the Clerk of Court using the Florida Courts E-Filing Portal and served via Florida Courts E-Filing Portal Electronic Mail to: Jonathan T. Hall, Esq., grobinson@ gspalaw.com and gstcourtdocs@gspalaw.com, Groelle & Salmon, PA, 7650 Courtney Campbell Cswy., Ste. 800, Tampa, FL 33067 and Ryan H. Sherman, Esq., eservicesIpa@ gmail.com on this 18" day of March 2016. /s/ Morgan Barfield Morgan Barfield, Esq. Co-Counsel for Plaintiffs Corless Barfield Trial Group, LLC 4350 W. Cypress Street Suite 910 Tampa, Florida 33607 (813) 258-4998 (813) 258-4988 — Facsimile MBarfield@CorlessBarfield.com