On August 02, 2021 a
Party Discovery
was filed
involving a dispute between
An, Vatana,
Chan, Boravy,
and
Universal Property And Casualty Insurance Company,
for CONTRACTS AND INDEBTEDNESS
in the District Court of Bay County.
Preview
Filing # 131844620 E-Filed 08/02/2021 02:00:05 PM
IN THE CIRCUIT COURT OF THE
FOURTEENTH JUDICIAL CIRCUIT IN AND
FOR BAY COUNTY, FLORIDA
CASE NUMBER: 21000967CA
JUDGE:
VATANA AN AND BORAVY CHAN,
Plaintiffs,
ve
UNIVERSAL PROPERTY AND CASUALTY
INSURANCE COMPANY
Defendant.
PLAINTIFFS’ FIRST REQUEST FOR ADMISSIONS TO DEFENDANT.
Through the Undersigned counsel, and under Florida Rule of Civil Procedure 1.370,
Plaintiffs Vatana An and Boravy Chan submit to Defendant, Universal Property and Casualty
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 8920 North Lagoon Drive Panama City, Florida, 32408
RESPONSE:
2. Admit that the homeowners insurance policy you issued, which is described in the
Complaint, provided coverage for Hurricane Sally damage.
RESPONSE:
3. Admit that the insurance policy you issued to the Plaintiffs for the property located at
8920 North Lagoon Drive Panama City, Florida, 32408 was in full force and effect as of
9/15/2017.
RESPONSE:4. Admit that the Hurricane Sally loss described in the Complaint, which occurred on or
about 9/15/2017, was a covered event pursuant to the terms of the subject policy.
RESPONSE:
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 DO HEREBY CERTIFY that a true and correct copy of this document will be served
on the Defendant along with the Summons in this action.
Date: August 2, 2021
/s/Brandon M Pharis
COHEN LAW GROUP
Brandon M Pharis
Florida Bar Number: 1015690
FOR THE FIRM
350 North Lake Destiny Road
Maitland, Florida 32751
Phone: (407) 478-4878
Fax: (407) 478-0204
Primary: bpharis@itsaboutjustice.law
Secondary: leah@itsaboutjustice.law
Document Filed Date
August 02, 2021
Case Filing Date
August 02, 2021
Category
CONTRACTS AND INDEBTEDNESS
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 131844620 E-Filed 08/02/2021 02:00:05 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NUMBER: 21000967CA JUDGE: VATANA AN AND BORAVY CHAN, Plaintiffs, ve UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY Defendant. PLAINTIFFS’ FIRST REQUEST FOR ADMISSIONS TO DEFENDANT. Through the Undersigned counsel, and under Florida Rule of Civil Procedure 1.370, Plaintiffs Vatana An and Boravy Chan submit to Defendant, Universal Property and Casualty 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 8920 North Lagoon Drive Panama City, Florida, 32408 RESPONSE: 2. Admit that the homeowners insurance policy you issued, which is described in the Complaint, provided coverage for Hurricane Sally damage. RESPONSE: 3. Admit that the insurance policy you issued to the Plaintiffs for the property located at 8920 North Lagoon Drive Panama City, Florida, 32408 was in full force and effect as of 9/15/2017. RESPONSE:4. Admit that the Hurricane Sally loss described in the Complaint, which occurred on or about 9/15/2017, was a covered event pursuant to the terms of the subject policy. RESPONSE: 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 DO HEREBY CERTIFY that a true and correct copy of this document will be served on the Defendant along with the Summons in this action. Date: August 2, 2021 /s/Brandon M Pharis COHEN LAW GROUP Brandon M Pharis Florida Bar Number: 1015690 FOR THE FIRM 350 North Lake Destiny Road Maitland, Florida 32751 Phone: (407) 478-4878 Fax: (407) 478-0204 Primary: bpharis@itsaboutjustice.law Secondary: leah@itsaboutjustice.law