On August 25, 2021 a
Party Discovery
was filed
involving a dispute between
Dominique Howard,
and
Typtap Insurance Company,
for CONTRACT & DEBT
in the District Court of Palm Beach County.
Preview
wes CASE NUMBER: 502021CA010075XXXXMB Div: AN ****
Filing # 133401114 E-Filed 08/25/2021 02:35:46 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,
IN AND FOR PALM BEACH COUNTY, FLORIDA
DOMINIQUE HOWARD,
Plaintiff,
v. CASE NO.:
munT AR TET ALTA FAK AAT
LIP LAr UNSURANUB CUTAN TI,
Defendant.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS
The Plaintiff, Dominique Howard, by and through the undersigned counsel, and pursuant to
Rule 1.370, Florida Rules of Civil Procedure, requests that the Defendant, TYPTAP INSURANCE
COMPANY, to admit or deny the following:
1. Admit that the insurance policy which forms the subject matter of this lawsuit was issued by
the Insurance Company.
2. Admit that the Insurance Company was providing insurance coverage to the property located
at 690 West 37th Street, West Palm Beach, FL 33404 at the time of the peril described in the
Insured’s Complaint.
3. Admit that the cause of the damage at issue is covered under the insurance policy.
4. Admit that the Insured made a claim against the Insurance Company for insurance coverage to
the Insureds’ property.
5. Admit that the Insurance Company was provided an estimate prepared on behalf of the
Insureds.
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED NainEINNN, NO.26- Ae DNA
PILL. PAL DLA VUUINE TT, PL, JUOL IE mDNUeeY, ULLIAN, Yureui2ue | Ue.0u.tU Fit10.
ll.
12.
13.
14.
Admit that the Insurance Company has failed and/or has refused to pay the Insureds’
claim as described in the Complaint.
Admit that the only reason for the Insurance Company’s denial of payment on the subject claim
is a result of its determination that the damage to the Insureds’ property is not the result of a
covered peril under the subject Policy of insurance.
Admit that the Insurance Company did not make a payment of insurance benefits to or for the
benefit of the Insured for the alleged loss described in the Complaint.
Admit that the Insurance Company acknowledges that the Insureds’ estimate pertaining to
repairs is accurate and correct.
Admit that the Insured submitted to the Insurance Company a written estimate of repairs for
the damages to have occurred by reason of the loss described in the Complaint.
Admit that the damage, as detailed in the Insureds’ estimate, is covered under the applicable
insurance policy.
Admit that the Insurance Company’s litigation of the instant action is for the purpose of
delaying and/ or avoiding payment to the Insureds.
Admit that the Insureds have complied with all post-loss conditions precedent to the filing of
Admit that the Insurance Company assumes liability to the Insureds for the damage sustained
to their property.15. Admit that the Insurance Company is required to pay the Insureds’ attorney’s fees and costs
pursuant to Florida Statute Section 627.428.
16. Admit that the Insured has provided documents to the Insurance Company to aid their
investigation.
17. Admit that the Insureds have allowed the Insurance Company to inspect the property at issue
and to examine the damage.
18. Admit that the Insureds have made themselves available to the Insurance Company to aid their
investigation, including allowing his property to be inspected or submitting to an examination
under oath.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon
the Defendant in this action along with the Complaint.
By: /s/Kevin Weisser
KEVIN WEISSER
Florida Bar No: 98828
WEISSER ELAZAR & KANTOR, PLLC
Attorneys for Plaintiff
800 East Broward Boulevard, Suite 510
Fort Lauderdale, FL 33301
T: (954) 486-2623
F: (954) 572-8695
Email: KW@WEKLaw.com
JK@WEKLaw.com
DG@WEKLaw.com
Document Filed Date
August 25, 2021
Case Filing Date
August 25, 2021
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wes CASE NUMBER: 502021CA010075XXXXMB Div: AN **** Filing # 133401114 E-Filed 08/25/2021 02:35:46 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA DOMINIQUE HOWARD, Plaintiff, v. CASE NO.: munT AR TET ALTA FAK AAT LIP LAr UNSURANUB CUTAN TI, Defendant. / PLAINTIFF’S REQUEST FOR ADMISSIONS The Plaintiff, Dominique Howard, by and through the undersigned counsel, and pursuant to Rule 1.370, Florida Rules of Civil Procedure, requests that the Defendant, TYPTAP INSURANCE COMPANY, to admit or deny the following: 1. Admit that the insurance policy which forms the subject matter of this lawsuit was issued by the Insurance Company. 2. Admit that the Insurance Company was providing insurance coverage to the property located at 690 West 37th Street, West Palm Beach, FL 33404 at the time of the peril described in the Insured’s Complaint. 3. Admit that the cause of the damage at issue is covered under the insurance policy. 4. Admit that the Insured made a claim against the Insurance Company for insurance coverage to the Insureds’ property. 5. Admit that the Insurance Company was provided an estimate prepared on behalf of the Insureds. CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLED NainEINNN, NO.26- Ae DNA PILL. PAL DLA VUUINE TT, PL, JUOL IE mDNUeeY, ULLIAN, Yureui2ue | Ue.0u.tU Fit10. ll. 12. 13. 14. Admit that the Insurance Company has failed and/or has refused to pay the Insureds’ claim as described in the Complaint. Admit that the only reason for the Insurance Company’s denial of payment on the subject claim is a result of its determination that the damage to the Insureds’ property is not the result of a covered peril under the subject Policy of insurance. Admit that the Insurance Company did not make a payment of insurance benefits to or for the benefit of the Insured for the alleged loss described in the Complaint. Admit that the Insurance Company acknowledges that the Insureds’ estimate pertaining to repairs is accurate and correct. Admit that the Insured submitted to the Insurance Company a written estimate of repairs for the damages to have occurred by reason of the loss described in the Complaint. Admit that the damage, as detailed in the Insureds’ estimate, is covered under the applicable insurance policy. Admit that the Insurance Company’s litigation of the instant action is for the purpose of delaying and/ or avoiding payment to the Insureds. Admit that the Insureds have complied with all post-loss conditions precedent to the filing of Admit that the Insurance Company assumes liability to the Insureds for the damage sustained to their property.15. Admit that the Insurance Company is required to pay the Insureds’ attorney’s fees and costs pursuant to Florida Statute Section 627.428. 16. Admit that the Insured has provided documents to the Insurance Company to aid their investigation. 17. Admit that the Insureds have allowed the Insurance Company to inspect the property at issue and to examine the damage. 18. Admit that the Insureds have made themselves available to the Insurance Company to aid their investigation, including allowing his property to be inspected or submitting to an examination under oath. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the Defendant in this action along with the Complaint. By: /s/Kevin Weisser KEVIN WEISSER Florida Bar No: 98828 WEISSER ELAZAR & KANTOR, PLLC Attorneys for Plaintiff 800 East Broward Boulevard, Suite 510 Fort Lauderdale, FL 33301 T: (954) 486-2623 F: (954) 572-8695 Email: KW@WEKLaw.com JK@WEKLaw.com DG@WEKLaw.com