RESPONSE TO REQ TO PRODUCE - TO PLT F/B DFT

On November 6, 2017 a contract & debt case was filed by Norma Castellon, and Yovani Castellon, represented by Andrew M Brodsky, Chastity Grace Delgado, Glenda M Almela, Jennifer Jimenez, and Samuel Gold, against Southern Fidelity Insurance Company, represented by Jennifer Jimenez, Lauren Maione-Walsh, Michelle E. Hardin, and Tamar Gelin, in the jurisdiction of Palm Beach County.

                        
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Filing # 66672725 E-Filed 01/17/2018 05:24:45 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502017CA012165XXXXMBAE YOVANI CASTELLON, Plaintiff, VS. SOUTHERN FIDELITY INSURANCE COMPANY, Defendant. 1 i RESPONSE TO PLAINTIFE’S FIRST REQUEST FOR PRODUCTION COMES NOW, the Defendant, SOUTHERN FIDELITY INSURANCE COMPANY, by and through the undersigned counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby responds to Plaintiff's First Request for Production as follows: 1, A true and correct certified copy of the insurance policy provided by the Insurance Company to the Insured, for which this lawsuit is premised, including but not limited to, declaration sheet(s), all addendums and attachments. RESPONSE: A copy of the subject policy is attached hereto. 2. Each and every timesheet, log and all other documents reflecting time spent by the Insurance Company at the Property. RESPONSE: Defendant object…

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