On October 16, 2020 a
Party Discovery
was filed
involving a dispute between
Fis, Isabell,
and
Citizens Property Insurance Company,
for * CC Damages >$15,000 - $30,000
in the District Court of Broward County.
Preview
Case Number: CONO-20-019439 Division: 73
Filing # 115138345 E-Filed 10/16/2020 05:51:33 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.:
ISABELL FIS,
Plaintiff,
v.
CITIZENS PROPERTY
INSURANCE COMPANY,
Defendant.
/
TIFF ISABELL FIS FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
CITIZENS PROPERTY INSURANCE COMPANY
COMES NOW, Plaintiff, ISABELL FIS by and though undersigned counsel, and hereby
request pursuant to Rule 1.370 f the Florida Rules of Civil Procedure, that the Defendant,
CITIZENS PROPERTY INSURANCE COMPANY, admit or deny the truth of the following
matters within forty-five (45) days of service herein:
1. Admit that the insurance policy referenced in the Complaint provided coverage to the
insured for damage caused to the Property as a result of the loss described in the Complaint.
2. Admit that the policy of homeowners’ insurance described in the Complaint was in full
force and effect as of Date of Loss.
3. Admit that pursuant to the terms of the homeowners’ insurance policy issued to Insured for
the Property, Your were timely notified of the Loss in question that occurred on or about
the Date of Loss.
4. Admit that the Loss described in the Complaint, which was on or about the Date of Loss,
was a covered event pursuant to the terms of the policy of homeowners’ insurance which
You issued to Insured for the Property.
5. As applicable, admit that You received Plaintiff's assignment of benefits documentation as
part of Plaintiff's Exhibit “A” prior to the filing of this lawsuit.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/19/2020 02:37:27 PM.****10.
11
Admit that Plaintiff is insured under the insurance policy which You issued to Plaintiff for
the Property as it pertains to the Loss which occurred on or about the Date of Loss.
As applicable, admit that Plaintiff assigned rights under the policy of homeowners’
insurance which You issued for the Property pursuant to appropriated assignment of
benefits documentation.
Admit that Plaintiff has complied with all conditions precedent to receiving benefits under
the insurance policy at issue in this matter, which You issued to Plaintiff for the property
at issue in this lawsuit.
Admit that any payment issued on this claim was in accordance with the terms of the
insurance policy at issue in this lawsuit.
Admit that any payment issued on this claim was paid pursuant to the “Reasonable
Repairs” coverage.
. As applicable, admit that Defendant is not aware of any dual interest, mortgage holder or
lienholder with record security interest pertaining to the services rendered as described in
the invoice(s) attached to the Complaint.
Respectfully Submitted,
/S/ Steven C. Kletzkin
Steven C. Kletzkin, Esq.
Steven C. Kletzkin, PLLC
Primary Email: sck@sckpllc.com
Secondary email: diana@sckpllc.com
Pleadings email: admin@sckpllc.com
4400 N Federal Highway, Suite 210
Boca Raton, Fl 33431
Fla Bar No. 0079001
Phone : (561) 962-5942
Fax: (561) 207-7790
[Certificate of Service on the Following Page]CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of this document was served with the
Complaint on this 16" day of October, 2020.
/S/ Steven C. Kletzkin
Steven C. Kletzkin, Esq.
Steven C. Kletzkin, PLLC
Primary Email: sck@sckpllc.com
Secondary email: diana@sckplle.com
Pleadings email: admin@sckpllc.com
4400 N Federal Highway, Suite 210
Boca Raton, Fl 33431
Fla Bar No. 0079001
Phone : (561) 962-5942
Fax: (561) 207-7790
Document Filed Date
October 16, 2020
Case Filing Date
October 16, 2020
Category
* CC Damages >$15,000 - $30,000
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Case Number: CONO-20-019439 Division: 73 Filing # 115138345 E-Filed 10/16/2020 05:51:33 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: ISABELL FIS, Plaintiff, v. CITIZENS PROPERTY INSURANCE COMPANY, Defendant. / TIFF ISABELL FIS FIRST REQUEST FOR ADMISSIONS TO DEFENDANT CITIZENS PROPERTY INSURANCE COMPANY COMES NOW, Plaintiff, ISABELL FIS by and though undersigned counsel, and hereby request pursuant to Rule 1.370 f the Florida Rules of Civil Procedure, that the Defendant, CITIZENS PROPERTY INSURANCE COMPANY, admit or deny the truth of the following matters within forty-five (45) days of service herein: 1. Admit that the insurance policy referenced in the Complaint provided coverage to the insured for damage caused to the Property as a result of the loss described in the Complaint. 2. Admit that the policy of homeowners’ insurance described in the Complaint was in full force and effect as of Date of Loss. 3. Admit that pursuant to the terms of the homeowners’ insurance policy issued to Insured for the Property, Your were timely notified of the Loss in question that occurred on or about the Date of Loss. 4. Admit that the Loss described in the Complaint, which was on or about the Date of Loss, was a covered event pursuant to the terms of the policy of homeowners’ insurance which You issued to Insured for the Property. 5. As applicable, admit that You received Plaintiff's assignment of benefits documentation as part of Plaintiff's Exhibit “A” prior to the filing of this lawsuit. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/19/2020 02:37:27 PM.****10. 11 Admit that Plaintiff is insured under the insurance policy which You issued to Plaintiff for the Property as it pertains to the Loss which occurred on or about the Date of Loss. As applicable, admit that Plaintiff assigned rights under the policy of homeowners’ insurance which You issued for the Property pursuant to appropriated assignment of benefits documentation. Admit that Plaintiff has complied with all conditions precedent to receiving benefits under the insurance policy at issue in this matter, which You issued to Plaintiff for the property at issue in this lawsuit. Admit that any payment issued on this claim was in accordance with the terms of the insurance policy at issue in this lawsuit. Admit that any payment issued on this claim was paid pursuant to the “Reasonable Repairs” coverage. . As applicable, admit that Defendant is not aware of any dual interest, mortgage holder or lienholder with record security interest pertaining to the services rendered as described in the invoice(s) attached to the Complaint. Respectfully Submitted, /S/ Steven C. Kletzkin Steven C. Kletzkin, Esq. Steven C. Kletzkin, PLLC Primary Email: sck@sckpllc.com Secondary email: diana@sckpllc.com Pleadings email: admin@sckpllc.com 4400 N Federal Highway, Suite 210 Boca Raton, Fl 33431 Fla Bar No. 0079001 Phone : (561) 962-5942 Fax: (561) 207-7790 [Certificate of Service on the Following Page]CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this document was served with the Complaint on this 16" day of October, 2020. /S/ Steven C. Kletzkin Steven C. Kletzkin, Esq. Steven C. Kletzkin, PLLC Primary Email: sck@sckpllc.com Secondary email: diana@sckplle.com Pleadings email: admin@sckpllc.com 4400 N Federal Highway, Suite 210 Boca Raton, Fl 33431 Fla Bar No. 0079001 Phone : (561) 962-5942 Fax: (561) 207-7790