On January 19, 2021 a
Request for Production
was filed
involving a dispute between
Joseph Welsh,
Patricia Welsh,
and
Tower Hill Prime Insurance Company,
for CA Contracts and Indebtedness
in the District Court of Lee County.
Preview
Filing # 119804376 E-Filed 01/19/2021 09:06:25 AM
IN THE CIRCUIT COURT OF THE
TWENTIETH JUDICIAL CIRCUIT IN AND
FOR LEE COUNTY, FLORIDA
CASE NUMBER:
JOSEPH AND PATRICIA WELSH,
Plaintiff,
vy.
TOWER HILL PRIME INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
Plaintiff, Joseph and Patricia Welsh, by and through the undersigned counsel, under
Florida Rule of Civil Procedure 1.370, submits to Defendant, Tower Hill Prime Insurance
Company, the following requests for admissions for Defendant to admit or deny within forty-five
(45) days of the service of the Complaint herein:
1. Admit that you issued a policy of homeowners insurance that provided insurance
coverage to a property located at 16703 CROWNSBURY WAY, FORT MYERS FL 33908.
RESPONSE:
2. Admit that the homeowners insurance policy you issued, which is described in the
Complaint, provided coverage for wind and water damage.
RESPONSE:
3. Admit that the insurance policy you issued to Plaintiff for the property located at 16703
CROWNSBURY WAY, FORT MYERS FL 33908 was in full force and effect as of September
8, 2020.
RESPONSE:
4. Admit that the wind and water loss described in the Complaint, which occurred on or
about September 8, 2020, was a covered event pursuant to the terms of the subject policy.
eFiled Lee County Clerk of Courts Page 1RESPONSE:
5. Admit that any payment you issued on this claim was in accordance with the terms of the
insurance policy at issue in this lawsuit.
RESPONSE:
6. Admit that above-named Defendant is properly named in this action.
RESPONSE:
7. Admit that Defendant’s adjuster(s) who worked on this claim did so in accordance with
Fla. Stat. § 626.878.
RESPONSE:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of this document will be served on
Defendant along with the Summons and the Complaint in this action.
Date: January 19, 2021
/s/Hershal E. Spangler IT
COHEN LAW GROUP
Hershal E. Spangler III, Esq.
Florida Bar Number: 1011117
FOR THE FIRM
350 North Lake Destiny Road
Maitland, Florida 32751
Phone: (407) 478-4878
Fax: (407) 478-0204
Primary: hspangler@itsaboutjustice.law
Secondary: cara@itsaboutjustice.law
eFiled Lee County Clerk of Courts Page 2
Document Filed Date
January 19, 2021
Case Filing Date
January 19, 2021
Category
CA Contracts and Indebtedness
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Filing # 119804376 E-Filed 01/19/2021 09:06:25 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR LEE COUNTY, FLORIDA CASE NUMBER: JOSEPH AND PATRICIA WELSH, Plaintiff, vy. TOWER HILL PRIME INSURANCE COMPANY, Defendant. / PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT Plaintiff, Joseph and Patricia Welsh, by and through the undersigned counsel, under Florida Rule of Civil Procedure 1.370, submits to Defendant, Tower Hill Prime Insurance Company, the following requests for admissions for Defendant to admit or deny within forty-five (45) days of the service of the Complaint herein: 1. Admit that you issued a policy of homeowners insurance that provided insurance coverage to a property located at 16703 CROWNSBURY WAY, FORT MYERS FL 33908. RESPONSE: 2. Admit that the homeowners insurance policy you issued, which is described in the Complaint, provided coverage for wind and water damage. RESPONSE: 3. Admit that the insurance policy you issued to Plaintiff for the property located at 16703 CROWNSBURY WAY, FORT MYERS FL 33908 was in full force and effect as of September 8, 2020. RESPONSE: 4. Admit that the wind and water loss described in the Complaint, which occurred on or about September 8, 2020, was a covered event pursuant to the terms of the subject policy. eFiled Lee County Clerk of Courts Page 1RESPONSE: 5. Admit that any payment you issued on this claim was in accordance with the terms of the insurance policy at issue in this lawsuit. RESPONSE: 6. Admit that above-named Defendant is properly named in this action. RESPONSE: 7. Admit that Defendant’s adjuster(s) who worked on this claim did so in accordance with Fla. Stat. § 626.878. RESPONSE: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this document will be served on Defendant along with the Summons and the Complaint in this action. Date: January 19, 2021 /s/Hershal E. Spangler IT COHEN LAW GROUP Hershal E. Spangler III, Esq. Florida Bar Number: 1011117 FOR THE FIRM 350 North Lake Destiny Road Maitland, Florida 32751 Phone: (407) 478-4878 Fax: (407) 478-0204 Primary: hspangler@itsaboutjustice.law Secondary: cara@itsaboutjustice.law eFiled Lee County Clerk of Courts Page 2