On December 21, 2012 a
Answer
was filed
involving a dispute between
Nocento, Hubert,
and
All State Property And Casualty Ins Co,
for Contract and Indebtedness
in the District Court of Broward County.
Preview
Filing # 31843188 E-Filed 09/09/2015 12:59:04 PM
0142126531.1
Total Pages: 1
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CIVIL DIVISION
HUBERT NOCENTO, CASE NO.
CACE 12035355 03
PLAINTIFF,
VS.
ALLSTATE PROPERTY AND CASUALTY
INSURANCE COMPANY,
DEFENDANT.
DEFENDANT’S ANSWER TO COMPLAINT
Defendant, ALLSTATE PROPERTY AND CASUALTY INSURANCE COMPANY, by
and through the undersigned counsel, answers the Complaint as follows:
1. Defendant denies the allegations in all Paragraphs unless otherwise specifically
admitted.
2. Defendant admits the existence of a policy of automobile insurance which provides
coverage subject to the conditions, limitations, and provisions of the policy, and that the policy
was in effect on the date of the accidents alleged in the Complaint.
3. Foran affirmative defense, Defendant alleges that any recovery should be reduced or
barred by Plaintiff's failure to mitigate the damages alleged.
4. For an additional affirmative defense, Defendant alleges that any recovery should be
reduced or barred by any settlement, judgment, or payment of any kind by any individual or
entity in connection with the subject matter of the incident described in the Complaint.
WHEREFORE, Defendant demands trial by Jury of all issues so triable as a matter of
right by Jury.
THEREBY CERTIFY that on the 9th day of September » 2015,
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/9/2015 12:59:04 PM.****DEFENDANT(S) ANSWER TO COMPLAINT
CASE NO, CACE12035355 03
pursuant to Administrative Order No. AOSC13-49, a copy of the foregoing Answer has been
electronically filed and served using the Florida Courts E-Filing Portal to:
Plaintiff is Pro Se
Hubert Nocento
215 NW 60th Avenue
Margate, Florida 33063
bobolitu@hotmail.com
LAW OFFICES OF HOLLY W. CARROLL
110 SE 6th Street, Suite 1800
Ft. Lauderdale, FL 33301-5015
Telephone: (954) 760-4878
Toll Free: (877) 250-9958 ext 7604878
Attorney Direct: (954) 767-1394
Fax: (877) 838-0840
7 Yn
By: A sm ss
YASSER R. KADER
FL Bar No. 682691
Attomey for Defendant(s)
ALLSTATE PROPERTY AND CASUALTY
INSURANCE COMPANY
PRINCIPAL E-MAIL ADDRESS:
FTLAUDERDALELEGAL@ALLSTATE.COM
Personal E-mail Address
(NOT for Service of Pleadings and Documents):
Yasser.Kader@Allstate.com
Document Filed Date
September 09, 2015
Case Filing Date
December 21, 2012
Category
Contract and Indebtedness
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Filing # 31843188 E-Filed 09/09/2015 12:59:04 PM 0142126531.1 Total Pages: 1 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION HUBERT NOCENTO, CASE NO. CACE 12035355 03 PLAINTIFF, VS. ALLSTATE PROPERTY AND CASUALTY INSURANCE COMPANY, DEFENDANT. DEFENDANT’S ANSWER TO COMPLAINT Defendant, ALLSTATE PROPERTY AND CASUALTY INSURANCE COMPANY, by and through the undersigned counsel, answers the Complaint as follows: 1. Defendant denies the allegations in all Paragraphs unless otherwise specifically admitted. 2. Defendant admits the existence of a policy of automobile insurance which provides coverage subject to the conditions, limitations, and provisions of the policy, and that the policy was in effect on the date of the accidents alleged in the Complaint. 3. Foran affirmative defense, Defendant alleges that any recovery should be reduced or barred by Plaintiff's failure to mitigate the damages alleged. 4. For an additional affirmative defense, Defendant alleges that any recovery should be reduced or barred by any settlement, judgment, or payment of any kind by any individual or entity in connection with the subject matter of the incident described in the Complaint. WHEREFORE, Defendant demands trial by Jury of all issues so triable as a matter of right by Jury. THEREBY CERTIFY that on the 9th day of September » 2015, *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/9/2015 12:59:04 PM.****DEFENDANT(S) ANSWER TO COMPLAINT CASE NO, CACE12035355 03 pursuant to Administrative Order No. AOSC13-49, a copy of the foregoing Answer has been electronically filed and served using the Florida Courts E-Filing Portal to: Plaintiff is Pro Se Hubert Nocento 215 NW 60th Avenue Margate, Florida 33063 bobolitu@hotmail.com LAW OFFICES OF HOLLY W. CARROLL 110 SE 6th Street, Suite 1800 Ft. Lauderdale, FL 33301-5015 Telephone: (954) 760-4878 Toll Free: (877) 250-9958 ext 7604878 Attorney Direct: (954) 767-1394 Fax: (877) 838-0840 7 Yn By: A sm ss YASSER R. KADER FL Bar No. 682691 Attomey for Defendant(s) ALLSTATE PROPERTY AND CASUALTY INSURANCE COMPANY PRINCIPAL E-MAIL ADDRESS: FTLAUDERDALELEGAL@ALLSTATE.COM Personal E-mail Address (NOT for Service of Pleadings and Documents): Yasser.Kader@Allstate.com