Party Discovery: Taina Dessin, et al Plaintiff vs. Citizens Property Insurance Corporation Defendant

• 
• 
• 
• 

						
                                
Preview
                                Case Number: CACE-21-007786 Division: 14
Filing # 125107251 E-Filed 04/16/2021 06:14:40 PM


          IN THE CIRCUIT COURT IN AND FOR THE SEVENTEENTH JUDICIAL CIRCUIT
                 OF THE STATE OF FLORIDA, IN AND FOR BROWARD COUNTY
                                     CIVIL DIVISION

        TAINA DESSIN,

                            Plaintiff,
                                                                 Case No.:
        vs.


        CITIZENS PROPERTY INSURANCE
        CORPORATION,

                            Defendant.
                                                             /

                                            REQUEST FOR ADMISSIONS

        The Plaintiff, Taina Dessin (hereinafter referred to as the “Plaintiff’), by and through the

        undersigned counsel, hereby requests the Defendant, Citizens Property Insurance Corporation,

        (hereinafter referred to as the “Defendant”), to admit or deny the following:

               1   Please admit that the Plaintiff is the title owner of a property located at 6362 Royal Palm

                   Blvd. Margate, FL 33063 (hereinafter referred to as the “Subject Property”).

                   Please admit that the Plaintiff has a policy of insurance with the Defendant (the “Policy”)

                   that was in effect on July 23, 2020.

                   Please admit that the Plaintiff made a property insurance claim (the “Subject Claim”) to

                   the Defendant for damage to the Subject Property.

                   Please admit that the Defendant assigned claim number HEEE06                 the Subject

                   Claim.

                   Please admit that the Defendant has failed and/or refused to pay the Plaintiff the full cost

                   to repair the damage to the Subject Property related to the Subject Claim.

                   Please admit that the Plaintiff has met all conditions precedent to payment under the




              #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN,            CLERK 04/16/2021 06:14:37 PM.**#*
Policy for the Subject Claim.

       Please admit that the Subject Property was damaged on or about July 23, 2020.

       Please admit that the Subject Property was damaged by water loss on or about July 23,

       2020.

       Please admit that water cannot be eliminated as a cause of the damage incurred by the

       Subject Property on or about July 23, 2020.

   10. Please admit that damage caused by water is covered under the Policy.

   11 Please admit that the Plaintiff's has cooperated with the Defendant with respect to the

       Defendant’s requests for investigation and inspection of the Subject Property.

   12. Please admit that the Defendant has agreed to provide coverage for the Subject Claim.

                                       CERTIFICATE OF SERVICE

       I HEREBY    CERTIFY that a true and correct copy of the foregoing was served upon the

Defendant along with the Summons and Complaint served in this matter.

                                                     WILLIAMS LAW P.A.


                                                     “je fe
                                                     Kyle B. Staggs, Esq.
                                                     1715 West Cleveland Street
                                                     Tampa, Florida 33606
                                                     Pleadings@williamspa.com
                                                     Eservice@williamspa.com
                                                     Kyle@williamspa.com
                                                     TELEPHONE: (813) 288-4999
                                                     FACSIMILE: (813) 288-4944
                                                     F.B.N.: 125472
                                                     Attorney for the Plaintiff