On October 12, 2020 a
Request for Admissions - Party: Plaintiff The Kidwell Group LLC
was filed
involving a dispute between
The Kidwell Group Llc,
and
First Protective Insurance Company,
for CC Property Insurance Claims > $8,000 - $15,000
in the District Court of Broward County.
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Case Number: COSO-20-010539 Division: 61
Filing # 114792153 E-Filed 10/12/2020 11:08:18 AM
11092940 IN THE COUNTY COURT OF _ THE
SEVENTEENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
THE KIDWELL GROUP, LLC D/B/A AIR CASE NO.:
QUALITY ASSESSORS OF FLORIDA a/a/o DIV. NO.:
Adam Bray,
Plaintiff,
vs.
FIRST PROTECTIVE INSURANCE COMPANY
DBA FRONTLINE INSURANCE,
Defendant.
Pt
REQUE: IR ADMISSION:
Plaintiff, The Kidwell Group, LLC d/b/a Air Quality Assessors of Florida (hereinafter
“Plaintiff’) as assignee of Adam Bray (hereinafter “Insured”), by and through the undersigned
attorneys, pursuant to Fla. R. Civ. P. 1.370, requests that the Defendant, First Protective Insurance
Company dba Frontline Insurance (hereinafter “Defendant”), admit or deny the truth of the
following statements of fact and answer the following admissions in writing within forty-five (45)
days from the date of service thereof.
1. Defendant issued a policy of insurance to Insured (“Policy”) for the property located
at 3470 Ridgeland Rd, Davie, FL 33328 (“Dwelling”).
2. At all material times, Insured had an insurable interest in the Dwelling.
3. The Dwelling sustained direct physical damage, while the Policy was in full force and
effect (the “loss”).
4. Defendant was notified of the loss pursuant to the terms and conditions of the Policy.
5. Insured submitted an insurance claim to Defendant (the “claim”) pursuant to the terms
and conditions of the Policy.
6. Plaintiff did not cause prejudice to Defendant during its investigation of the claim.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/12/2020 11:08:18 AM.****10.
11.
12.
13.
As of the date of this lawsuit, there were no outstanding requests by Defendant for
documents or information in connection with its investigation and adjustment of the
claim.
Plaintiff complied with all duties after a loss pursuant to the Policy.
The Policy provides coverage for any and all sudden and accidental physical damage to
the Dwelling that is not otherwise excluded or excepted by the policy.
The Policy provides coverage for “all risks” of loss to the Dwelling.
The Policy provides benefits on a “Replacement Cost Value” basis for covered losses to
the Dwelling subject to the policy limits.
In the event of a covered loss to the Dwelling, the Policy provides benefits to repair or
replace damaged or destroyed property, without deducting for depreciation.
In the event of a covered loss to the Dwelling, the Policy requires Defendant to pay
benefits on a “Replacement Cost Value” basis, irrespective of whether Plaintiff actually
repairs or replaces the damaged property.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
to the Defendant along with the Summons and Complaint.
Ls HANS KENNON
HANS KENNON, ESQUIRE
Florida Bar No. 0059323
MORGAN & MORGAN, P.A.
20 N. Orange Avenue, 4th Floor
Orlando, FL 32801
(407) 420-6686 — Phone
(407) 245-3370 — Fax
Primary Email: Hkennon@forthepeople.com
Secondary Email: TWerle@forthepeople.com
Attorneys for Plaintiff
Document Filed Date
October 12, 2020
Case Filing Date
October 12, 2020
Category
CC Property Insurance Claims > $8,000 - $15,000
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Case Number: COSO-20-010539 Division: 61 Filing # 114792153 E-Filed 10/12/2020 11:08:18 AM 11092940 IN THE COUNTY COURT OF _ THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA THE KIDWELL GROUP, LLC D/B/A AIR CASE NO.: QUALITY ASSESSORS OF FLORIDA a/a/o DIV. NO.: Adam Bray, Plaintiff, vs. FIRST PROTECTIVE INSURANCE COMPANY DBA FRONTLINE INSURANCE, Defendant. Pt REQUE: IR ADMISSION: Plaintiff, The Kidwell Group, LLC d/b/a Air Quality Assessors of Florida (hereinafter “Plaintiff’) as assignee of Adam Bray (hereinafter “Insured”), by and through the undersigned attorneys, pursuant to Fla. R. Civ. P. 1.370, requests that the Defendant, First Protective Insurance Company dba Frontline Insurance (hereinafter “Defendant”), admit or deny the truth of the following statements of fact and answer the following admissions in writing within forty-five (45) days from the date of service thereof. 1. Defendant issued a policy of insurance to Insured (“Policy”) for the property located at 3470 Ridgeland Rd, Davie, FL 33328 (“Dwelling”). 2. At all material times, Insured had an insurable interest in the Dwelling. 3. The Dwelling sustained direct physical damage, while the Policy was in full force and effect (the “loss”). 4. Defendant was notified of the loss pursuant to the terms and conditions of the Policy. 5. Insured submitted an insurance claim to Defendant (the “claim”) pursuant to the terms and conditions of the Policy. 6. Plaintiff did not cause prejudice to Defendant during its investigation of the claim. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/12/2020 11:08:18 AM.****10. 11. 12. 13. As of the date of this lawsuit, there were no outstanding requests by Defendant for documents or information in connection with its investigation and adjustment of the claim. Plaintiff complied with all duties after a loss pursuant to the Policy. The Policy provides coverage for any and all sudden and accidental physical damage to the Dwelling that is not otherwise excluded or excepted by the policy. The Policy provides coverage for “all risks” of loss to the Dwelling. The Policy provides benefits on a “Replacement Cost Value” basis for covered losses to the Dwelling subject to the policy limits. In the event of a covered loss to the Dwelling, the Policy provides benefits to repair or replace damaged or destroyed property, without deducting for depreciation. In the event of a covered loss to the Dwelling, the Policy requires Defendant to pay benefits on a “Replacement Cost Value” basis, irrespective of whether Plaintiff actually repairs or replaces the damaged property. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the Defendant along with the Summons and Complaint. Ls HANS KENNON HANS KENNON, ESQUIRE Florida Bar No. 0059323 MORGAN & MORGAN, P.A. 20 N. Orange Avenue, 4th Floor Orlando, FL 32801 (407) 420-6686 — Phone (407) 245-3370 — Fax Primary Email: Hkennon@forthepeople.com Secondary Email: TWerle@forthepeople.com Attorneys for Plaintiff