On September 07, 2021 a
Request,Application
was filed
involving a dispute between
Reyes, Hildebrando,
and
Citizens Property Insurance Corporation,
for Insurance Claim
in the District Court of Miami-Dade County.
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Filing # 134089620 E-Filed 09/07/2021 10:40:37 AM
IN THE CIRCUIT COURT FOR THE 11TH
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
HILDEBRANDO REYES,
GENERAL JURISDICTION DIVISION
Plaintiff,
CASE NO.:
vs.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
/
REQUEST FOR ADMISSIONS
Plaintiff, HILDEBRANDO REYES (the “Insured”), by and through undersigned counsel,
and pursuant to the applicable Florida Rules of Civil Procedure, hereby requests Defendant,
CITIZENS PROPERTY INSURANCE CORPORATION (the “Insurance Company”), to admit or
deny the following items:
1. Admit that on the date of the alleged loss described in the Complaint that the
Policy was in full force and effect.
2. Admit that Plaintiff is the named Insured under the Policy described in the
Complaint.
3. Admit that the Property described in the Complaint is the insured premises under
the Policy.
4. Admit that prior to the filing of this lawsuit Plaintiff made a claim of loss under
the Policy for the date of loss described in the Complaint.
5. Admit that Defendant assigned a claim number to the Loss as described in the
Complaint.
6. Admit that the Defendant acknowledged this as a covered Loss and made
payment to Plaintiff.
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7. Admit that Plaintiff allowed Defendant access to the subject Property, after the
Loss described in the Complaint.
8. Admit that the Plaintiff submitted to a recorded statement.
9. Admit that Plaintiff submitted to Defendant a written estimate of repairs for the
damages that occurred as a result of the Loss.
10. Admit that Defendant did not make a request in writing for the Plaintiff to submit
to an examination under oath for the Loss.
11. Admit that Defendant did not make a request in writing for the Plaintiff to submit
a signed sworn proof of loss for the Loss to Defendant.
12. Admit that Plaintiff submitted a signed sworn proof of loss prior to the filing of
this lawsuit.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via U.S.
mail to: CITIZENS PROPERTY INSURANCE CORPORATION c/o The Florida Chief Financial
Officer as RA, 200 E. Gaines Street, Tallahassee, Florida 32399-4201, on this 2nd day of September,
2021.
The Law Offices of Grey & Mourin, P.A.
Counsel for the Insured
1400 N.W. 10th Avenue, Suite RG6
Miami, Florida 33136
Telephone No. (305) 325-8119
Facsimile No. (305) 325-0569
Email: eservice@greyandmourin.com
Secondary Email: Juan@greyandmourin.com
By: /s/Juan E. Mourin_______
Juan E. Mourin, Esq.
Florida Bar No. 103438
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Document Filed Date
September 07, 2021
Case Filing Date
September 07, 2021
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Filing # 134089620 E-Filed 09/07/2021 10:40:37 AM IN THE CIRCUIT COURT FOR THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA HILDEBRANDO REYES, GENERAL JURISDICTION DIVISION Plaintiff, CASE NO.: vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / REQUEST FOR ADMISSIONS Plaintiff, HILDEBRANDO REYES (the “Insured”), by and through undersigned counsel, and pursuant to the applicable Florida Rules of Civil Procedure, hereby requests Defendant, CITIZENS PROPERTY INSURANCE CORPORATION (the “Insurance Company”), to admit or deny the following items: 1. Admit that on the date of the alleged loss described in the Complaint that the Policy was in full force and effect. 2. Admit that Plaintiff is the named Insured under the Policy described in the Complaint. 3. Admit that the Property described in the Complaint is the insured premises under the Policy. 4. Admit that prior to the filing of this lawsuit Plaintiff made a claim of loss under the Policy for the date of loss described in the Complaint. 5. Admit that Defendant assigned a claim number to the Loss as described in the Complaint. 6. Admit that the Defendant acknowledged this as a covered Loss and made payment to Plaintiff. 1 7. Admit that Plaintiff allowed Defendant access to the subject Property, after the Loss described in the Complaint. 8. Admit that the Plaintiff submitted to a recorded statement. 9. Admit that Plaintiff submitted to Defendant a written estimate of repairs for the damages that occurred as a result of the Loss. 10. Admit that Defendant did not make a request in writing for the Plaintiff to submit to an examination under oath for the Loss. 11. Admit that Defendant did not make a request in writing for the Plaintiff to submit a signed sworn proof of loss for the Loss to Defendant. 12. Admit that Plaintiff submitted a signed sworn proof of loss prior to the filing of this lawsuit. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via U.S. mail to: CITIZENS PROPERTY INSURANCE CORPORATION c/o The Florida Chief Financial Officer as RA, 200 E. Gaines Street, Tallahassee, Florida 32399-4201, on this 2nd day of September, 2021. The Law Offices of Grey & Mourin, P.A. Counsel for the Insured 1400 N.W. 10th Avenue, Suite RG6 Miami, Florida 33136 Telephone No. (305) 325-8119 Facsimile No. (305) 325-0569 Email: eservice@greyandmourin.com Secondary Email: Juan@greyandmourin.com By: /s/Juan E. Mourin_______ Juan E. Mourin, Esq. Florida Bar No. 103438 2