On April 15, 2021 a
Party Discovery
was filed
involving a dispute between
Quang Vo,
and
Fednat Insurance Company,
for CONTRACT & DEBT
in the District Court of Palm Beach County.
Preview
wes CASE NUMBER: 502021CA004846XXXXMB Div: AN ****
Filing # 124965977 E-Filed 04/15/2021 09:49:18 AM
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA.
QUANG VO, CASE NUMBER:
Plaintiff,
Vv.
FEDNAT INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS FROM DEFENDANT
COMES NOW the Plaintiff, Quang Vo, by and through the undersigned counsel, pursuant
to Florida Rules of Civil Procedure 1.370, and hereby files its First Request for Admissions on
Defendant, FedNat Insurance Company, to be responded to within forty-five (45) days of service.
I. Adinit tiat prior to Sepieniver 10, 2017 that FeaNat iisuraiice Compaiiy issued a
policy which provided insurance coverage to a property located at 9428 Fox Trot Lane, Boca
Raton, FL 33496.
2. Admit that on September 10, 2017 policy number FE-0000711453-01 was in full
force and effect which provided insurance coverage to the Insured Property located at 9428 Fox
Trot Lane, Boca Raton, FL 33496.
3. Admit that the insurance policy described in the complaint provided homeowners
insurance coverage for the property located at 9428 Fox Trot Lane, Boca Raton, FL 33496, which
included coverage for damage caused by wind, rain, and debris strikes.
4, Admit that the Plaintiff in this matter has standing to bring this subject action.
5. Admit that the Plaintiff has not made any material misrepresentations in the
annlination far inenranca with tha Nafandant
Gppicauon 101 iioulanice Witt Ue a7eacuuGnl,
Page 1 of 3
CHEN. DAIAARCACUAAIINTY Cl INCEDU ARDIIV7ZN FLED NAM EINNDA NO. A049 ANA
Pm. PAL DLA VUUINE TT, FL, JUOL IE mDnNueey, ULUIAN, Ute.) uo.tg. 1U mit6. Admit that Claim number HO0520327068 is covered under the subject insurance
policy.
7. Admit that Defendant accepted coverage for the subject insurance claim.
8. Admit that Defendant was allowed access to inspect the subject property.
9. Admit that Defendant was able and did conclude its investigation of the subject
loss.
10. Admit that Defendant has not been prejudiced in any way in the timing of the
reporting of the claim by the Plaintiff.
11. | Admit that FedNat Insurance Company bound the subject policy to insure the
property located at 9428 Fox Trot Lane, Boca Raton, FL 33496 in the condition it was in on the
day the policy became effective.
12. Admit that the Defendant hired a field adjuster to inspect the subject property.
13. Admit that the field adjuster was monetarily compensated by the Defendant for
their services.
14. Admit that the field adjuster who worked on the subject insurance claim failed to
do so in accordance with Fia. Stat. Section 626.878.
15. Admit that the Defendant did not retain an engineer to inspect the property prior to
the initiation of this suit.
(Onutifiaate of Cawetan an Palle
CErunCale U1 our vice Ul YUU
Page 2 of 3CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a correct, true and full copy of the foregoing was served on
the Defendant, FedNat Insurance Company, along with the Summons and Complaint in this action.
KS LAW GROUP, PLLC
947 Longdale Avenue
Longwood, Florida 32750
[Lhatherine A. hnepfle
Katherine A. Krepfle, Esquire
Attorney for the Plaintiff
Florida Bar Number: 1010532
Talanh ana: (ANI OLN LOLE
LELepnone: (4us) FVU-UFVS
Facsimile: (407) 960-6996
Primary: Eservice@KSLawGroup.net
Secondary: KKrepfle@KSLawGroup.net
Page 3 of 3
Document Filed Date
April 15, 2021
Case Filing Date
April 15, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
wes CASE NUMBER: 502021CA004846XXXXMB Div: AN **** Filing # 124965977 E-Filed 04/15/2021 09:49:18 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA. QUANG VO, CASE NUMBER: Plaintiff, Vv. FEDNAT INSURANCE COMPANY, Defendant. / PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS FROM DEFENDANT COMES NOW the Plaintiff, Quang Vo, by and through the undersigned counsel, pursuant to Florida Rules of Civil Procedure 1.370, and hereby files its First Request for Admissions on Defendant, FedNat Insurance Company, to be responded to within forty-five (45) days of service. I. Adinit tiat prior to Sepieniver 10, 2017 that FeaNat iisuraiice Compaiiy issued a policy which provided insurance coverage to a property located at 9428 Fox Trot Lane, Boca Raton, FL 33496. 2. Admit that on September 10, 2017 policy number FE-0000711453-01 was in full force and effect which provided insurance coverage to the Insured Property located at 9428 Fox Trot Lane, Boca Raton, FL 33496. 3. Admit that the insurance policy described in the complaint provided homeowners insurance coverage for the property located at 9428 Fox Trot Lane, Boca Raton, FL 33496, which included coverage for damage caused by wind, rain, and debris strikes. 4, Admit that the Plaintiff in this matter has standing to bring this subject action. 5. Admit that the Plaintiff has not made any material misrepresentations in the annlination far inenranca with tha Nafandant Gppicauon 101 iioulanice Witt Ue a7eacuuGnl, Page 1 of 3 CHEN. DAIAARCACUAAIINTY Cl INCEDU ARDIIV7ZN FLED NAM EINNDA NO. A049 ANA Pm. PAL DLA VUUINE TT, FL, JUOL IE mDnNueey, ULUIAN, Ute.) uo.tg. 1U mit6. Admit that Claim number HO0520327068 is covered under the subject insurance policy. 7. Admit that Defendant accepted coverage for the subject insurance claim. 8. Admit that Defendant was allowed access to inspect the subject property. 9. Admit that Defendant was able and did conclude its investigation of the subject loss. 10. Admit that Defendant has not been prejudiced in any way in the timing of the reporting of the claim by the Plaintiff. 11. | Admit that FedNat Insurance Company bound the subject policy to insure the property located at 9428 Fox Trot Lane, Boca Raton, FL 33496 in the condition it was in on the day the policy became effective. 12. Admit that the Defendant hired a field adjuster to inspect the subject property. 13. Admit that the field adjuster was monetarily compensated by the Defendant for their services. 14. Admit that the field adjuster who worked on the subject insurance claim failed to do so in accordance with Fia. Stat. Section 626.878. 15. Admit that the Defendant did not retain an engineer to inspect the property prior to the initiation of this suit. (Onutifiaate of Cawetan an Palle CErunCale U1 our vice Ul YUU Page 2 of 3CERTIFICATE OF SERVICE I HEREBY CERTIFY that a correct, true and full copy of the foregoing was served on the Defendant, FedNat Insurance Company, along with the Summons and Complaint in this action. KS LAW GROUP, PLLC 947 Longdale Avenue Longwood, Florida 32750 [Lhatherine A. hnepfle Katherine A. Krepfle, Esquire Attorney for the Plaintiff Florida Bar Number: 1010532 Talanh ana: (ANI OLN LOLE LELepnone: (4us) FVU-UFVS Facsimile: (407) 960-6996 Primary: Eservice@KSLawGroup.net Secondary: KKrepfle@KSLawGroup.net Page 3 of 3