On October 15, 2019 a
Reply to Affirmative Defenses
was filed
involving a dispute between
Cayobit, Ricardo,
Cayubit, Roland,
and
United Property And Casualty Insurance Company,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 104117728 E-Filed 02/28/2020 04:59:50 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY,
FLORIDA
RICARDO CAYOBIT AND ROLAND CAYUBIT,
Plaintiff,
UNITED PROPERTY AND CASUALTY INSURANCE
COMPANY,
Defendant.
Case No.: CACE 19-021361 (25)
PLAINTIFF’S REPLY
COMES NOW the Plaintiffs, RICARDO CAYOBIT AND ROLAND CAYUBIT (the
“Plaintiffs”), by and through the undersigned attorneys,
and serves this Reply to Defendant’s, UNITED
PROPERTY AND CASUALTY INSURANCE COMPANY (“Defendant”) Affirmative Defenses and
says: The Plaintiffs deny each and every Affirmative Defense asserted by Defendant referenced herein
and demands strict proof thereof. In addition, Plaintiffs state that by Defendant’s own actions and
coverage determination, Defendant has waived the right to raise the Sixth Affirmative Defenses in this
matter and is thus estopped from asserting same as a defense.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that on February 28, 2020, a true and correct copy of the foregoing has
been served via the Florida Courts E-Filing Portal upon Brown, Kimberley, Peterson Bernard, 707 SE 3rd
Avenue, Suite 500, Fort Lauderdac, FL 33316, Attorneys for Defendant, e-service:
ailene.rogers@petersonbernard.com; kimberley.bron@petersonbernard.com.
Respectfully submitted,
LEVY & PARTNERS, PLLC
Attorneys for Plaintiff
3230 Stirling Road, Suite 1
Hollywood, Florida 33021
(954) 727-8570 - Telephone
(954) 241-6857 — Facsimile
Robin@lawlp.com - Email
Maritza@lawlp.com — Secondary Service
By: /s/ Robin A. Richison, Esq.
Robin A. Richison, Esq.
Florida Bar No: 42009
Ely R. Levy, Esq.
Florida Bar No.: 15452
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/28/2020 04:59:50 PM.****
Preview
Filing # 104117728 E-Filed 02/28/2020 04:59:50 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RICARDO CAYOBIT AND ROLAND CAYUBIT, Plaintiff, UNITED PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. Case No.: CACE 19-021361 (25) PLAINTIFF’S REPLY COMES NOW the Plaintiffs, RICARDO CAYOBIT AND ROLAND CAYUBIT (the “Plaintiffs”), by and through the undersigned attorneys, and serves this Reply to Defendant’s, UNITED PROPERTY AND CASUALTY INSURANCE COMPANY (“Defendant”) Affirmative Defenses and says: The Plaintiffs deny each and every Affirmative Defense asserted by Defendant referenced herein and demands strict proof thereof. In addition, Plaintiffs state that by Defendant’s own actions and coverage determination, Defendant has waived the right to raise the Sixth Affirmative Defenses in this matter and is thus estopped from asserting same as a defense. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that on February 28, 2020, a true and correct copy of the foregoing has been served via the Florida Courts E-Filing Portal upon Brown, Kimberley, Peterson Bernard, 707 SE 3rd Avenue, Suite 500, Fort Lauderdac, FL 33316, Attorneys for Defendant, e-service: ailene.rogers@petersonbernard.com; kimberley.bron@petersonbernard.com. Respectfully submitted, LEVY & PARTNERS, PLLC Attorneys for Plaintiff 3230 Stirling Road, Suite 1 Hollywood, Florida 33021 (954) 727-8570 - Telephone (954) 241-6857 — Facsimile Robin@lawlp.com - Email Maritza@lawlp.com — Secondary Service By: /s/ Robin A. Richison, Esq. Robin A. Richison, Esq. Florida Bar No: 42009 Ely R. Levy, Esq. Florida Bar No.: 15452 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/28/2020 04:59:50 PM.****