On October 09, 2019 a
Party Discovery
was filed
involving a dispute between
Gonzalez, Adriana,
Gonzalez, Pedro,
and
Heritage Property And Casualt Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 96999746 E-Filed 10/09/201%-Q4204 Pade CACE-19-020995 Division: 08
IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA
ADRIANA GONZALEZ AND PEDRO CASE NO.
GONZALEZ,
Petitioners,
vs.
HERITAGE PROPERTY AND
CASUALTY INSURANCE COMPANY,
Respondent.
COMES NOW Petitioner, by and through the undersigned attorneys, and pursuant to the
applicable Florida Rules of Civil Procedure, hereby requests Respondent to admit or deny the
following items:
1, Admit that on the date of the alleged loss described in the Petition that the policy
described in the Petition was in full force and effect.
2. Admit that Petitioner is the named insured under the insurance policy described in
the Petition .
3. Admit that the premises described in the Petition are the insured premises under
the insurance policy described in the Petition.
4. Admit that prior to the institution of this action, Petitioner made a claim under the
Policy described in the petition for a loss which Petitioner claims occurred the date of loss
described in the petition.
5. Admit that Respondent assigned a claim number to the subject loss as described in
the petition.
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/09/2019 04:04:02 PM.****6. Admit that Petitioners permitted Respondent access to the premises described in
the subject policy after the date of the alleged loss.
7. Admit that as of the date of the filing if this lawsuit, that Respondent had denied
the Petitioner's claim for insurance benefits for the alleged loss described in the petition.
8. Admit that as of the date of the filing if this lawsuit, that Respondent had not made
any payment of insurance proceeds to Petitioners for the subject loss described in the petition.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served
upon Respondent by the Insurance Commissioner of the State of Florida.
VYACHESLAV BORSHCHUKOV, P.A.
ATTORNEYS FOR PETITIONERS
514SE 11TH Court
ForT LAUDERDALE, FLORIDA 33316
TELEPHONE (305) 503-5985
Fax No. (305) 503-5986
Email: g
BY:
AESLAV BORSHCHUKOV
Document Filed Date
October 09, 2019
Case Filing Date
October 09, 2019
Category
Other - Insurance Claim
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Filing # 96999746 E-Filed 10/09/201%-Q4204 Pade CACE-19-020995 Division: 08 IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA ADRIANA GONZALEZ AND PEDRO CASE NO. GONZALEZ, Petitioners, vs. HERITAGE PROPERTY AND CASUALTY INSURANCE COMPANY, Respondent. COMES NOW Petitioner, by and through the undersigned attorneys, and pursuant to the applicable Florida Rules of Civil Procedure, hereby requests Respondent to admit or deny the following items: 1, Admit that on the date of the alleged loss described in the Petition that the policy described in the Petition was in full force and effect. 2. Admit that Petitioner is the named insured under the insurance policy described in the Petition . 3. Admit that the premises described in the Petition are the insured premises under the insurance policy described in the Petition. 4. Admit that prior to the institution of this action, Petitioner made a claim under the Policy described in the petition for a loss which Petitioner claims occurred the date of loss described in the petition. 5. Admit that Respondent assigned a claim number to the subject loss as described in the petition. #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/09/2019 04:04:02 PM.****6. Admit that Petitioners permitted Respondent access to the premises described in the subject policy after the date of the alleged loss. 7. Admit that as of the date of the filing if this lawsuit, that Respondent had denied the Petitioner's claim for insurance benefits for the alleged loss described in the petition. 8. Admit that as of the date of the filing if this lawsuit, that Respondent had not made any payment of insurance proceeds to Petitioners for the subject loss described in the petition. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon Respondent by the Insurance Commissioner of the State of Florida. VYACHESLAV BORSHCHUKOV, P.A. ATTORNEYS FOR PETITIONERS 514SE 11TH Court ForT LAUDERDALE, FLORIDA 33316 TELEPHONE (305) 503-5985 Fax No. (305) 503-5986 Email: g BY: AESLAV BORSHCHUKOV