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Case Number:19-000035-CI
Filing # 82685576 E-Filed 12/31/2018 11:07:29 AM
IN THE CIRCUIT COURT OF THE
SIXTH JUDICIAL CIRCUIT OF FLORIDA
PINELLAS COUNTY, FLORIDA
CASE NUMBER:
JUDGE:
Synergy Contracting Group, Inc.,
a/a/o Teresa Gunter,
Plaintiff,
vs.
Safepoint Insurance Company,
Defendant.
/
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW Plaintiff, Synergy Contracting Group, Inc., a/a/o Teresa Gunter, by and
through the undersigned counsel and pursuant to Rule 1.370 of the Florida Rules of Civil
Procedure, and hereby files and submits to Defendant, Safepoint Insurance Company, (hereinafter
SAFEPOINT) the following requests for admissions and requests that Defendant admits to or
denies the following in writing, Within forty-five (45) days of the service of the Complaint herein:
1. Admit that prior to 9/5/2017 you issued a policy of homeowner’s insurance which provided
insurance coverage to a property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 .
RESPONSE:
2. Admit that the policy of homeowner’s insurance Which you issued to Teresa Gunter, provided
insurance coverage for water damage to the property located at 115 Steeplechase Lane, Palm
Harbor, FL 34684 as ofthe date ofthe water event described in the Complaint, Which occurred
on or about 9/5/2017.
***ELECTRONICALLY FILED 12/31/2018 11:07:27 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
RESPONSE:
. Admit that claim giving rise to this lawsuit was a covered loss by the insurance policy you
issued, Which is described in the Complaint, provided to Teresa Gunter, for damage caused to
the property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 ,
as a result of water
damage.
RESPONSE:
. Admit that the policy of homeowner’s insurance Which you provided to Teresa Gunter, for
the property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 ,
was in full force and
effect on or about 9/5/2017.
RESPONSE:
. Admit that pursuant to the terms of the homeowner’s insurance policy you issued to Teresa
Gunter, for the property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 you were
timely notified of the water event in question, which occurred on or about 9/5/2017.
RESPONSE:
. Admit that the water damage loss described in the Complaint, Which occurred on or about
9/5/2017 was a covered peril pursuant to the terms of the policy of homeowner’s insurance
Which you issued to Teresa Gunter, for the property located at 115 Steeplechase Lane, Palm
Harbor, FL 34684 .
RESPONSE:
7. Admit that you received the Plaintiff’ s assignment of benefits form (titled “ASSIGNMENT
OF INSURANCE BENEFITS”), Which is attached to the Complaint as part of Plaintiff’s
Exhibit “A,” prior to the filing of this law suit.
RESPONSE:
8. Admit that the Plaintiff submitted, and the Defendant did receive the invoice for water
mitigation services, sometimes referred to as emergency services, at least sixty (60) days prior
to the filing of this lawsuit.
RESPONSE:
9. Admit that the Plaintiff submitted, and the Defendant did receive the invoice for emergency
services, at least sixty (60) days prior to the filing of this lawsuit.
RESPONSE:
10. Admit that the Plaintiff submitted, and the Defendant did receive the invoice for rebuild
services, at least sixty (60) days prior to the filing of this lawsuit.
RESPONSE:
11. Admit that the Plaintiff submitted, and the Defendant did receive the invoice for dry—out
services, at least sixty (60) days prior to the filing of this lawsuit.
RESPONSE:
12. Admit that any payment(s) you issued on this claim for the services provided by the Plaintiff
should have been made directly to the Plaintiff.
RESPONSE:
13. Admit that above-named Defendant is correctly named in the Complaint, and style ofthe case.
RESPONSE:
14. Admit that the Plaintiff is entitled for full payment of the invoices attached to this Complaint,
after any payments made by the Defendant, and received by the Plaintiff.
RESPONSE:
15. Admit that the Defendant breached the policy of insurance by failing to remit payment to
SYNERGY for the balance of their invoices attached to the Complaint.
RESPONSE:
15. Admit that the Defendant owes the benefits for unpaid services as alleged in the Complaint to
the Plaintiff as alleged in the Complaint.
RESPONSE:
CERTIFICATE OF SERVICE
I DO HEREBY CERTIFY that a true and correct copy of this document Will be served
on the Defendant along With the Summons in this action.
/S/ Steven I. Battisti
Steven I.Battisti, Esquire
Battisti Law Group, PLLC
Florida Bar Number: 148490
841 Desert Mountain Court
Reunion, Florida 34747
Phone: (407) 584—7761
Steve@BattistiLawGroup.com
Attorney for the Plaintiff
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Case Number:19-000035-CI Filing # 82685576 E-Filed 12/31/2018 11:07:29 AM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT OF FLORIDA PINELLAS COUNTY, FLORIDA CASE NUMBER: JUDGE: Synergy Contracting Group, Inc., a/a/o Teresa Gunter, Plaintiff, vs. Safepoint Insurance Company, Defendant. / PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW Plaintiff, Synergy Contracting Group, Inc., a/a/o Teresa Gunter, by and through the undersigned counsel and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, and hereby files and submits to Defendant, Safepoint Insurance Company, (hereinafter SAFEPOINT) the following requests for admissions and requests that Defendant admits to or denies the following in writing, Within forty-five (45) days of the service of the Complaint herein: 1. Admit that prior to 9/5/2017 you issued a policy of homeowner’s insurance which provided insurance coverage to a property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 . RESPONSE: 2. Admit that the policy of homeowner’s insurance Which you issued to Teresa Gunter, provided insurance coverage for water damage to the property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 as ofthe date ofthe water event described in the Complaint, Which occurred on or about 9/5/2017. ***ELECTRONICALLY FILED 12/31/2018 11:07:27 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** RESPONSE: . Admit that claim giving rise to this lawsuit was a covered loss by the insurance policy you issued, Which is described in the Complaint, provided to Teresa Gunter, for damage caused to the property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 , as a result of water damage. RESPONSE: . Admit that the policy of homeowner’s insurance Which you provided to Teresa Gunter, for the property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 , was in full force and effect on or about 9/5/2017. RESPONSE: . Admit that pursuant to the terms of the homeowner’s insurance policy you issued to Teresa Gunter, for the property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 you were timely notified of the water event in question, which occurred on or about 9/5/2017. RESPONSE: . Admit that the water damage loss described in the Complaint, Which occurred on or about 9/5/2017 was a covered peril pursuant to the terms of the policy of homeowner’s insurance Which you issued to Teresa Gunter, for the property located at 115 Steeplechase Lane, Palm Harbor, FL 34684 . RESPONSE: 7. Admit that you received the Plaintiff’ s assignment of benefits form (titled “ASSIGNMENT OF INSURANCE BENEFITS”), Which is attached to the Complaint as part of Plaintiff’s Exhibit “A,” prior to the filing of this law suit. RESPONSE: 8. Admit that the Plaintiff submitted, and the Defendant did receive the invoice for water mitigation services, sometimes referred to as emergency services, at least sixty (60) days prior to the filing of this lawsuit. RESPONSE: 9. Admit that the Plaintiff submitted, and the Defendant did receive the invoice for emergency services, at least sixty (60) days prior to the filing of this lawsuit. RESPONSE: 10. Admit that the Plaintiff submitted, and the Defendant did receive the invoice for rebuild services, at least sixty (60) days prior to the filing of this lawsuit. RESPONSE: 11. Admit that the Plaintiff submitted, and the Defendant did receive the invoice for dry—out services, at least sixty (60) days prior to the filing of this lawsuit. RESPONSE: 12. Admit that any payment(s) you issued on this claim for the services provided by the Plaintiff should have been made directly to the Plaintiff. RESPONSE: 13. Admit that above-named Defendant is correctly named in the Complaint, and style ofthe case. RESPONSE: 14. Admit that the Plaintiff is entitled for full payment of the invoices attached to this Complaint, after any payments made by the Defendant, and received by the Plaintiff. RESPONSE: 15. Admit that the Defendant breached the policy of insurance by failing to remit payment to SYNERGY for the balance of their invoices attached to the Complaint. RESPONSE: 15. Admit that the Defendant owes the benefits for unpaid services as alleged in the Complaint to the Plaintiff as alleged in the Complaint. RESPONSE: CERTIFICATE OF SERVICE I DO HEREBY CERTIFY that a true and correct copy of this document Will be served on the Defendant along With the Summons in this action. /S/ Steven I. Battisti Steven I.Battisti, Esquire Battisti Law Group, PLLC Florida Bar Number: 148490 841 Desert Mountain Court Reunion, Florida 34747 Phone: (407) 584—7761 Steve@BattistiLawGroup.com Attorney for the Plaintiff