On August 27, 2014 a
Request,Application
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.
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Filing # 34757859 E-Filed 11/23/2015 10:44:19 AM
14211 IN THE CIRCUIT COURT OF THE 17th
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-14-016655 DIV. 02
DEBRA HINES,
Plaintiff,
vs.
HOMEOWNERS CHOICE PROPERTY &
CASUALTY INSURANCE COMPANY, INC.,
Defendant.
/
/
DEFENDANT’S REQUEST FOR ENTRY UPON LAND
COMES NOW, the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY
INSURANCE COMPANY, by and through its undersigned attorneys, pursuant to Fla. R. Civ. P.
1.350, and requests Plaintiff, DEBRA HINES, permit entry upon the land designated below for the
purpose of inspection and measuring, surveying, photographing, testing or sampling the property and
any structures thereon, in conjunction with the above-referenced cause, and within the scope of the
Fla. R. Civ. P. 1.280(b).
1. Property designated for inspection: 3816 S. Lake Terrace, Miramar, FL 33023.
2. Inspection requested: Defendant requests the Plaintiff permit entry upon the land, property,
and residence identified above for the purposes of inspection and measuring, surveying,
photographing, testing or sampling the property and any structures thereon.
3. Time, place and manner of inspection: Defendant requires access to the interior and
exterior of the residence and any structures on the property identified above for the purposes
of inspection and testing of the premises and any structures on the property to be conducted
by Defendant's consulting experts. Defendant requests Plaintiffs permit inspection of the
subject property as described above at a mutually convenient date and time for all parties and
persons involved to be coordinated by counsel for the respective parties.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/23/2015 10:44:19 AM.****CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
forwarded by electronic mail to: Ryan H. Sherman at eserviceSLPA@gmail.com, on this 23
day of November, 2015.
By:
HCL14211
GROELLE & SALMON, P.A.
Attorneys for Defendant
Waterford Plaza
7650 W. Courtney Campbell Causeway
Suite 800
Tampa, FL 33607
(813) 849-7200 (telephone)
(813) 849-7201 (fax)
gstcourtdocs@gspalaw.com
ROBERT T. SCHULTE, ESQ.
FBN: 88819
Document Filed Date
November 23, 2015
Case Filing Date
August 27, 2014
Category
Contract and Indebtedness
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Filing # 34757859 E-Filed 11/23/2015 10:44:19 AM 14211 IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-14-016655 DIV. 02 DEBRA HINES, Plaintiff, vs. HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, INC., Defendant. / / DEFENDANT’S REQUEST FOR ENTRY UPON LAND COMES NOW, the Defendant, HOMEOWNERS CHOICE PROPERTY & CASUALTY INSURANCE COMPANY, by and through its undersigned attorneys, pursuant to Fla. R. Civ. P. 1.350, and requests Plaintiff, DEBRA HINES, permit entry upon the land designated below for the purpose of inspection and measuring, surveying, photographing, testing or sampling the property and any structures thereon, in conjunction with the above-referenced cause, and within the scope of the Fla. R. Civ. P. 1.280(b). 1. Property designated for inspection: 3816 S. Lake Terrace, Miramar, FL 33023. 2. Inspection requested: Defendant requests the Plaintiff permit entry upon the land, property, and residence identified above for the purposes of inspection and measuring, surveying, photographing, testing or sampling the property and any structures thereon. 3. Time, place and manner of inspection: Defendant requires access to the interior and exterior of the residence and any structures on the property identified above for the purposes of inspection and testing of the premises and any structures on the property to be conducted by Defendant's consulting experts. Defendant requests Plaintiffs permit inspection of the subject property as described above at a mutually convenient date and time for all parties and persons involved to be coordinated by counsel for the respective parties. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 11/23/2015 10:44:19 AM.****CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been forwarded by electronic mail to: Ryan H. Sherman at eserviceSLPA@gmail.com, on this 23 day of November, 2015. By: HCL14211 GROELLE & SALMON, P.A. Attorneys for Defendant Waterford Plaza 7650 W. Courtney Campbell Causeway Suite 800 Tampa, FL 33607 (813) 849-7200 (telephone) (813) 849-7201 (fax) gstcourtdocs@gspalaw.com ROBERT T. SCHULTE, ESQ. FBN: 88819