On May 28, 2021 a
Party Discovery
was filed
involving a dispute between
Velazquez, Michelle,
and
Universal Property & Casualty Insurance Company,
for 3
in the District Court of Broward County.
Preview
Filing # 127774715 E-Filed 05/28/2021 03:04:48 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
MICHELLE VELAZQUEZ, CIVIL DIVISION
Plaintiff. CASE NO.:
V
UNIVERSALPROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
PLAINTIFF'S REQUEST FOR ADMISSIONS
Plaintiff, Michelle Velazquez, (Plaintiff), by and through their undersigned counsel and
pursuant to the applicable Rules of Civil Procedure, request Defendant, Universal Property &
Casualty Insurance Company (Defendant), to admit or deny the following:
1. Admit that Defendant and Plaintiffhad an insurance policy in effect, insuring the Property
described in the Complaint against certain losses.
2. Admit that the damage described in the Complaint is covered by the Policy.
3. Admit Defendant was notified of the loss prior to the inception of this lawsuit.
4. Admit Defendant was promptly notified of the loss.
5. Admit Defendant inspected the Property.
6. Admit Defendant inspected the damage.
7. Admit if Defendant requested a sworn statement in proof of loss from Plaintiff.
8. Admit Plaintiff complied with the EUO provisions of the Policy.
9. Admit Defendantreceived documentationfrom Plaintiff in support of their loss.
10. Admit Defendanthas received an estimate of damage from Plaintiff.
1
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/28/2021 03:04:44 PM.****
11. Admit Defendant has received invoices, estimates, or receipts evidencingrepairs made to the
Property.
12. Admit Plaintiff has made repairs to the Property following the loss.
13. Admit the field adjuster who inspected the Property is not an expert in determining cause of
damage.
14. Admit Defendant did not properly indemnify Plaintiff.
15. Admit Plaintiffhaskept an accurate record ofrepairs and expenses.
16. Admit Plaintiff mitigated the damage to the Property.
17. Admit Plaintiff made reasonable and necessary repairs to the Property following the loss.
18. Admit that Defendant insured the property in the condition the property existed at the time of
the Policy' s inception.
19. Admit the damage was caused by a covered loss.
20. Admit the damage was not caused by marring, deterioration,or wear and tear.
21. Admit the damage was not caused by settling, shrinking, bulging or expansion.
22. Admit the damage was not caused by repeated leakage or seepage.
23. Admit that the damage was not caused by improper installation.
24. Admit the damage was caused by a covered loss, as set forth in Plaintiff's Complaint.
25. Admit that Plaintiff has complied with all post-loss conditions precedent to the filing of this
lawsuit.
26. Admit that Defendantis required to pay Plaintiff's attorney's fees and costs pursuant to Florida
Statute Section 627.428.
[CERTIFICATEOF SERVICE ON NEXT PAGEI
2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy ofthe foregoing was served at the same
time as Plaintiff' s Complaint.
VARGAS GONZALEZ
BALDWIN DELOMBARD, LLP.
,rd
815 Ponce De Leon Blvd-, 3? Floor
Coral Gables, FL 33134
Tel: 305.631.2528
Fax: 305.631.2741
E-mail:
E-mail.
By- /S/
Karla Lopez, Esq.
Fla. Bar No.: 1007678
3
Document Filed Date
May 28, 2021
Case Filing Date
May 28, 2021
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Filing # 127774715 E-Filed 05/28/2021 03:04:48 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA MICHELLE VELAZQUEZ, CIVIL DIVISION Plaintiff. CASE NO.: V UNIVERSALPROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i PLAINTIFF'S REQUEST FOR ADMISSIONS Plaintiff, Michelle Velazquez, (Plaintiff), by and through their undersigned counsel and pursuant to the applicable Rules of Civil Procedure, request Defendant, Universal Property & Casualty Insurance Company (Defendant), to admit or deny the following: 1. Admit that Defendant and Plaintiffhad an insurance policy in effect, insuring the Property described in the Complaint against certain losses. 2. Admit that the damage described in the Complaint is covered by the Policy. 3. Admit Defendant was notified of the loss prior to the inception of this lawsuit. 4. Admit Defendant was promptly notified of the loss. 5. Admit Defendant inspected the Property. 6. Admit Defendant inspected the damage. 7. Admit if Defendant requested a sworn statement in proof of loss from Plaintiff. 8. Admit Plaintiff complied with the EUO provisions of the Policy. 9. Admit Defendantreceived documentationfrom Plaintiff in support of their loss. 10. Admit Defendanthas received an estimate of damage from Plaintiff. 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/28/2021 03:04:44 PM.**** 11. Admit Defendant has received invoices, estimates, or receipts evidencingrepairs made to the Property. 12. Admit Plaintiff has made repairs to the Property following the loss. 13. Admit the field adjuster who inspected the Property is not an expert in determining cause of damage. 14. Admit Defendant did not properly indemnify Plaintiff. 15. Admit Plaintiffhaskept an accurate record ofrepairs and expenses. 16. Admit Plaintiff mitigated the damage to the Property. 17. Admit Plaintiff made reasonable and necessary repairs to the Property following the loss. 18. Admit that Defendant insured the property in the condition the property existed at the time of the Policy' s inception. 19. Admit the damage was caused by a covered loss. 20. Admit the damage was not caused by marring, deterioration,or wear and tear. 21. Admit the damage was not caused by settling, shrinking, bulging or expansion. 22. Admit the damage was not caused by repeated leakage or seepage. 23. Admit that the damage was not caused by improper installation. 24. Admit the damage was caused by a covered loss, as set forth in Plaintiff's Complaint. 25. Admit that Plaintiff has complied with all post-loss conditions precedent to the filing of this lawsuit. 26. Admit that Defendantis required to pay Plaintiff's attorney's fees and costs pursuant to Florida Statute Section 627.428. [CERTIFICATEOF SERVICE ON NEXT PAGEI 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy ofthe foregoing was served at the same time as Plaintiff' s Complaint. VARGAS GONZALEZ BALDWIN DELOMBARD, LLP. ,rd 815 Ponce De Leon Blvd-, 3? Floor Coral Gables, FL 33134 Tel: 305.631.2528 Fax: 305.631.2741 E-mail: E-mail. By- /S/ Karla Lopez, Esq. Fla. Bar No.: 1007678 3