On October 01, 2021 a
Request,Application
was filed
involving a dispute between
Troung, Phu,
and
Citizens Property Insurance Corporation,
for Contract & Indebtedness
in the District Court of Miami-Dade County.
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Filing # 135765546 E-Filed 10/01/2021 03:25:53 PM
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
PHU TROUNG,
CASE NO.:
Plaintiff,
FLORIDA BAR NO.: 127612
vs.
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW, the Plaintiff, PHU TROUNG, by and through undersigned counsel,
pursuant to Florida Rules of Civil Procedure 1.370, and hereby serves, CITIZENS PROPERTY
INSURANCE CORPORATION, with its First Request for Admissions to be admitted or denied
within forty-five (45) days after service thereof, and in support thereof states:
1. Admit that you do not dispute the cause of loss as alleged in Paragraph 8 of the
Complaint.
2. Admit that you do not dispute the date of loss as alleged in Paragraph 8 of the Complaint.
3. Admit that the policy described in Paragraph 5 of the Complaint was in full force and
effect on or about the date of loss alleged in Paragraph 8 of the Complaint.
4. Admit that Plaintiff(s) complied with all of the post loss duties under the policy described
in Paragraph 5 of the Complaint.
5. Admit that Plaintiff(s) complied with all of the conditions precedent under the policy
described in Paragraph 5 of the Complaint.
6. Admit that Defendant’s investigation of the loss described in Paragraph 8 of the
Complaint was not prejudiced by the acts or omissions of Plaintiff(s).
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served attached
with the Original Summons and Complaint.
Thomas J. Morgan, Jr., Esquire
FLORIDA BAR NO.: 127612
MORGAN LAW GROUP, P.A.
Counsel for Plaintiff
55 Merrick Way, Suite 404
Coral Gables, Florida 33134
Phone: 305.569.9900
Fax : 305.443.6828
/tm
By: /s/ Thomas J. Morgan
Thomas J. Morgan, Jr.
Document Filed Date
October 01, 2021
Case Filing Date
October 01, 2021
Category
Contract & Indebtedness
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Filing # 135765546 E-Filed 10/01/2021 03:25:53 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION PHU TROUNG, CASE NO.: Plaintiff, FLORIDA BAR NO.: 127612 vs. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW, the Plaintiff, PHU TROUNG, by and through undersigned counsel, pursuant to Florida Rules of Civil Procedure 1.370, and hereby serves, CITIZENS PROPERTY INSURANCE CORPORATION, with its First Request for Admissions to be admitted or denied within forty-five (45) days after service thereof, and in support thereof states: 1. Admit that you do not dispute the cause of loss as alleged in Paragraph 8 of the Complaint. 2. Admit that you do not dispute the date of loss as alleged in Paragraph 8 of the Complaint. 3. Admit that the policy described in Paragraph 5 of the Complaint was in full force and effect on or about the date of loss alleged in Paragraph 8 of the Complaint. 4. Admit that Plaintiff(s) complied with all of the post loss duties under the policy described in Paragraph 5 of the Complaint. 5. Admit that Plaintiff(s) complied with all of the conditions precedent under the policy described in Paragraph 5 of the Complaint. 6. Admit that Defendant’s investigation of the loss described in Paragraph 8 of the Complaint was not prejudiced by the acts or omissions of Plaintiff(s). CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served attached with the Original Summons and Complaint. Thomas J. Morgan, Jr., Esquire FLORIDA BAR NO.: 127612 MORGAN LAW GROUP, P.A. Counsel for Plaintiff 55 Merrick Way, Suite 404 Coral Gables, Florida 33134 Phone: 305.569.9900 Fax : 305.443.6828 /tm By: /s/ Thomas J. Morgan Thomas J. Morgan, Jr.