Reply to Affirmative Defenses - Adriana Gonzalez, et al Plaintiff vs. Heritage Property and Casualt Insurance Company Defendant

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On October 9, 2019 an other - insurance claim case was filed by Gonzalez, Adriana, and Gonzalez, Pedro, represented by Borshchukov, Vyacheslav, Esq., against Heritage Property And Casualt Insurance Company, represented by Chackman, Richard A, and Figueroa, Pedro M. Ortiz, in the jurisdiction of Broward County. Judge Haimes, David A. presiding.

                        
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                          Filing # 105438116 E-Filed 03/25/2020 04:12:04 PM

IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA

ADRIANA GONZALEZ & PEDRO CASE NO.: CACE-19-020995
GONZALEZ,

Petitioners,
Vv.

HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY,

Respondent.

 

REPLY & DEMAND FOR JURY TRIAL
Florida Bar #68274

COMES NOW Petitioners, by and through the undersigned attomeys, and hereby file this
Reply to the affirmative defenses alleged by Respondent, and would state:

1. That each and every affirmative defense is hereby denied and strict proof thereof is
hereby demanded.

2. Respondent’s failure to comply with Section 627.421(1), Florida Statutes excused
Petitioners’ performance of the policy’s post loss requirements of an insured in the event of loss.

3. Respondent’s failure to comply with Section 627.421(1), Florida Statutes
constituted a…