On June 23, 2021 a
Motion-Secondary
was filed
involving a dispute between
Mazel Medical Center Inc,
and
United Automobile Insurance Company,
for Personal Injury Protection ($8,001 - $15,000)
in the District Court of Miami-Dade County.
Preview
Filing # 138594066 E-Filed 11/16/2021 10:47:42 AM
IN THE COUNTY COURT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO: 2021-020900-CC-26
MAZEL MEDICAL CENTER INC , a/a/o Leon Moreno
Plaintiff,
REPLY TO AFFIRMATIVE DEFENSES
vs.
UNITED AUTOMOBILE INSURANCE COMPANY ,
Defendant(s)
__________________________________/
COMES NOW the Plaintiff, by and through its undersigned counsel and replies to the
affirmative defense asserted by the Defendant, in its Answer and Affirmative Defenses to
Plaintiff's Complaint, as follows:
1. The Plaintiff provided proof of timely mailing to the incorrect insurer to the
Defendant. The Defendant failed to confirm the tracking number provided by the Plaintiff in its
initial correspondence.
CERTIFICATE OF SERVICE
I CERTIFY that a true and correct copy of the foregoing was furnished by ( ) mail, ( x )
e-mail, ( ) fax this 16 day of November, 2021 to: Andrea L Harris, Esq., P.O. BOX 694260,
Miami, FL 33269-9854, HC_Service@uaig.net (e-mail), (fax).
Andreu, Palma, Lavin & Solis, PLLC
815 NW 57th Avenue, Suite 401
Miami, FL 33126-2363
Tel. (305) 631-0175
Fax (305) 631-1816
By: _____/s/Yulexy Solis________
Yulexy Solis, Esq.
Bar No.: 91230
E-mails: pleadings4@andreupalma.com;ysolis@andreupalma.com
File # 20-05525
Document Filed Date
November 16, 2021
Case Filing Date
June 23, 2021
Category
Personal Injury Protection ($8,001 - $15,000)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 138594066 E-Filed 11/16/2021 10:47:42 AM IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO: 2021-020900-CC-26 MAZEL MEDICAL CENTER INC , a/a/o Leon Moreno Plaintiff, REPLY TO AFFIRMATIVE DEFENSES vs. UNITED AUTOMOBILE INSURANCE COMPANY , Defendant(s) __________________________________/ COMES NOW the Plaintiff, by and through its undersigned counsel and replies to the affirmative defense asserted by the Defendant, in its Answer and Affirmative Defenses to Plaintiff's Complaint, as follows: 1. The Plaintiff provided proof of timely mailing to the incorrect insurer to the Defendant. The Defendant failed to confirm the tracking number provided by the Plaintiff in its initial correspondence. CERTIFICATE OF SERVICE I CERTIFY that a true and correct copy of the foregoing was furnished by ( ) mail, ( x ) e-mail, ( ) fax this 16 day of November, 2021 to: Andrea L Harris, Esq., P.O. BOX 694260, Miami, FL 33269-9854, HC_Service@uaig.net (e-mail), (fax). Andreu, Palma, Lavin & Solis, PLLC 815 NW 57th Avenue, Suite 401 Miami, FL 33126-2363 Tel. (305) 631-0175 Fax (305) 631-1816 By: _____/s/Yulexy Solis________ Yulexy Solis, Esq. Bar No.: 91230 E-mails: pleadings4@andreupalma.com;ysolis@andreupalma.com File # 20-05525