Response to Request for Admissions - 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 # 99691116 E-Filed 12/03/2019 10:55:29 AM

IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA

ADRIANA GONZALEZ AND PEDRO CASE NO. CACE-19-020995
GONZALEZ,

Plaintiff,
v.

HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY,

Defendant.

 

 

TIFF’S RESPONSE TO DEFENDANT'S FIRST REQUESTS FOR
ADMISSION
Florida Bar #68274

 

Plaintiffs, Adriana Gonzalez and Pedro Gonzalez, by and through his undersigned
counsel and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, hereby files and
serves his Responses to Defendant, Heritage Property & Casualty Insurance Comapny’s
Request for Admissions.

General Objections

1. Plaintiff objects to the Requests to the extent they are immaterial, overly broad,
vague, ambiguous, and not reasonably calculated to lead to the discovery of
admissible evidence.

2. Plaintiffobjects to the Requests to the extent that they seek to impose any obligation
not expressly set forth in the Florida Rules of Civil Procedure.

3. Plaintiff objects to…