On December 04, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Vencius Redd, Margarita,
and
Castle Key Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 106090682 E-Filed 04/09/2020 04:32:26 PM
IN THE CIRCUIT COURT OF THE
FOURTEENTH JUDICIAL CIRCUIT, IN AND FOR
BAY COUNTY, FLORIDA
MARGARITA VENCIUS-REDD,
Plaintiff,
vs.
CASE NO.: 19-004413CA
CASTLE KEY INDEMNITY COMPANY,
Defendant.
/
DEFENDANT, CASTLE KEY INDEMNITY COMPANY’S, MOTION FOR
PROTECTIVE ORDER REGARDING DISCOVERY SERVED BY PLAINTIFF
Defendant, Castle Key Indemnity Company, pursuant to Florida Rule of Civil Procedure
1.280(c), files this Motion for Protective Order regarding the Request for Admissions, Request to
Produce and Interrogatories served by Plaintiff with the Complaint, and as grounds therefor
states the following:
1 Plaintiff's Complaint stems from damage sustained to her home on October 10,
2018. The parties failed to agree as to the amount of loss involved with the claim and
accordingly, Castle Key Indemnity Company has invoked the appraisal clause of the subject
insurance policy. See Defendant’s April 9, 2020 Motion to Dismiss Complaint and Alternative
Motion to Compel Appraisal.
2. In light of Castle Key Indemnity Company’s invocation of the appraisal clause,
this claim should be resolved in the appraisal process. Plaintiff's Request for Admissions,
Request to Produce and Interrogatories are not applicable to the appraisal process and are
unnecessary.3. It is therefore respectfully requested that this Court enter an order relieving Castle
Key Indemnity Company of any responsibility to serve responses to Plaintiff's Request for
Admissions, Request to Produce and Interrogatories served with the Complaint in this action.
WHEREFORE, Defendant, Castle Key Indemnity Company, respectfully requests that
this Court enter an order relieving it of any responsibility to serve responses to Plaintiff's
Request for Admissions, Request to Produce and Interrogatories served with the Complaint in
this action.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing has been furnished by e-mail to
the following, this 9" day of April, 2020:
MARIA E. CORREDOR, ESQUIRE
JOSE C. LEON, ESQUIRE
CORREDOR & HUSSEINI, P.A.
3905 N.W. 107" Avenue, Suite 502
Doral, FL 33178
Telephone: 305-670-1880
Facsimile: 305-670-1985
Email: jleon@chslaw.net
Email: service@corredorhusseinilaw.com
(Counsel for Plaintiff)13389138.v1
s/ Darryl L. Gavin
DARRYL L. GAVIN
Florida Bar No.: 0705195
E-mail: dgavin@rumberger.com (primary)
docketingorlando@rumberger.com and
dgavinsecy@rumberger.com (secondary)
RUMBERGER, KIRK, & CALDWELL, P.A.
300 South Orange Avenue
Suite 1400
Orlando, Florida 32801
Tel: 407.872.7300
Fax: 407.841.2133
Attorneys for Defendant
Document Filed Date
April 09, 2020
Case Filing Date
December 04, 2019
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Filing # 106090682 E-Filed 04/09/2020 04:32:26 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT, IN AND FOR BAY COUNTY, FLORIDA MARGARITA VENCIUS-REDD, Plaintiff, vs. CASE NO.: 19-004413CA CASTLE KEY INDEMNITY COMPANY, Defendant. / DEFENDANT, CASTLE KEY INDEMNITY COMPANY’S, MOTION FOR PROTECTIVE ORDER REGARDING DISCOVERY SERVED BY PLAINTIFF Defendant, Castle Key Indemnity Company, pursuant to Florida Rule of Civil Procedure 1.280(c), files this Motion for Protective Order regarding the Request for Admissions, Request to Produce and Interrogatories served by Plaintiff with the Complaint, and as grounds therefor states the following: 1 Plaintiff's Complaint stems from damage sustained to her home on October 10, 2018. The parties failed to agree as to the amount of loss involved with the claim and accordingly, Castle Key Indemnity Company has invoked the appraisal clause of the subject insurance policy. See Defendant’s April 9, 2020 Motion to Dismiss Complaint and Alternative Motion to Compel Appraisal. 2. In light of Castle Key Indemnity Company’s invocation of the appraisal clause, this claim should be resolved in the appraisal process. Plaintiff's Request for Admissions, Request to Produce and Interrogatories are not applicable to the appraisal process and are unnecessary.3. It is therefore respectfully requested that this Court enter an order relieving Castle Key Indemnity Company of any responsibility to serve responses to Plaintiff's Request for Admissions, Request to Produce and Interrogatories served with the Complaint in this action. WHEREFORE, Defendant, Castle Key Indemnity Company, respectfully requests that this Court enter an order relieving it of any responsibility to serve responses to Plaintiff's Request for Admissions, Request to Produce and Interrogatories served with the Complaint in this action. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing has been furnished by e-mail to the following, this 9" day of April, 2020: MARIA E. CORREDOR, ESQUIRE JOSE C. LEON, ESQUIRE CORREDOR & HUSSEINI, P.A. 3905 N.W. 107" Avenue, Suite 502 Doral, FL 33178 Telephone: 305-670-1880 Facsimile: 305-670-1985 Email: jleon@chslaw.net Email: service@corredorhusseinilaw.com (Counsel for Plaintiff)13389138.v1 s/ Darryl L. Gavin DARRYL L. GAVIN Florida Bar No.: 0705195 E-mail: dgavin@rumberger.com (primary) docketingorlando@rumberger.com and dgavinsecy@rumberger.com (secondary) RUMBERGER, KIRK, & CALDWELL, P.A. 300 South Orange Avenue Suite 1400 Orlando, Florida 32801 Tel: 407.872.7300 Fax: 407.841.2133 Attorneys for Defendant