On December 04, 2019 a
Party Discovery
was filed
involving a dispute between
Vencius Redd, Margarita,
and
Castle Key Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
Preview
Filing # 105009970 E-Filed 03/17/2020 01:01:42 PM
19-0172 IN THE CIRCUIT COURT OF THE 147
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
CIVIL DIVISION
CASE NUMBER: 19-004413 CA
MARGARITA VENCIUS-REDD,
VS.
Plaintiff,
CASTLE KEY INDEMNITY COMPANY,
Defendant.
/
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS
COMES NOW, Plaintiff MARGARITA VENCIUS-REDD, by and through the
undersigned, pursuant to the Florida Rules of Civil Procedure, and propounds this Request for
Admissions to Defendant CASTLE KEY INDEMNITY COMPANY:
DEFINITIONS
. “Loss” shall refer to the monetary damages suffered by Plaintiff as alleged in the
Complaint.
“Property” shall refer to the real and/or personal property referred to in the Complaint.
. “Policy” shall refer to the insurance policy referred to the Complaint.
REQUESTS FOR ADMISSIONS
. Admit that, on the date of the Loss, the Policy was in full force and effect.
. Admit that prior to the institution of this action, Plaintiff made a claim under the Policy
for the Loss.
. Admit that Plaintiff permitted Defendant access to the Property at all times after the date
of the Loss.
. Admit that Defendant did not make a written request to Plaintiff for Plaintiff to submit to
an examination under oath.5. Admit that Defendant did not make a written request to Plaintiff for Plaintiff to submit to
Defendant a sworn proof of loss.
6. Admit that Defendant believes that Plaintiff is not entitled to any more insurance benefits
under the Policy for the Loss than the benefits Defendant has already paid to Plaintiff.
7. Admit that Defendant does not contend that any actions or omissions of the Plaintiff(s)
constitute fraud with respect to the Loss.
8. Admit that Defendant does not contend that any actions or omissions of the Plaintiff(s)
constitute lack of cooperation with respect to the Loss.
9. Admit that Defendant does not contend that any actions or omissions of the Plaintiff(s)
constitute material misrepresentation with respect to the Loss.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that a true and correct copy of foregoing was served on
the Defendant along with the Complaint and Summons this 17™ day of March, 2020.
CORREDOR & HUSSEINI, P.A.
/s/Maria E. Corredor____
Maria E. Corredor, Esq.
FBN: 76619
José C. Leon, Esq.
FBN: 125553
3905 N.W. 107th Avenue
Suite 502
Telephone: 305-670-1880
Facsimile: 305-670-1985
Email: jleon@chslaw.net
Email: service@corredorhusseinilaw.com
Attorneys for Plaintiff(s)
Document Filed Date
March 17, 2020
Case Filing Date
December 04, 2019
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Filing # 105009970 E-Filed 03/17/2020 01:01:42 PM 19-0172 IN THE CIRCUIT COURT OF THE 147 JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CIVIL DIVISION CASE NUMBER: 19-004413 CA MARGARITA VENCIUS-REDD, VS. Plaintiff, CASTLE KEY INDEMNITY COMPANY, Defendant. / PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS COMES NOW, Plaintiff MARGARITA VENCIUS-REDD, by and through the undersigned, pursuant to the Florida Rules of Civil Procedure, and propounds this Request for Admissions to Defendant CASTLE KEY INDEMNITY COMPANY: DEFINITIONS . “Loss” shall refer to the monetary damages suffered by Plaintiff as alleged in the Complaint. “Property” shall refer to the real and/or personal property referred to in the Complaint. . “Policy” shall refer to the insurance policy referred to the Complaint. REQUESTS FOR ADMISSIONS . Admit that, on the date of the Loss, the Policy was in full force and effect. . Admit that prior to the institution of this action, Plaintiff made a claim under the Policy for the Loss. . Admit that Plaintiff permitted Defendant access to the Property at all times after the date of the Loss. . Admit that Defendant did not make a written request to Plaintiff for Plaintiff to submit to an examination under oath.5. Admit that Defendant did not make a written request to Plaintiff for Plaintiff to submit to Defendant a sworn proof of loss. 6. Admit that Defendant believes that Plaintiff is not entitled to any more insurance benefits under the Policy for the Loss than the benefits Defendant has already paid to Plaintiff. 7. Admit that Defendant does not contend that any actions or omissions of the Plaintiff(s) constitute fraud with respect to the Loss. 8. Admit that Defendant does not contend that any actions or omissions of the Plaintiff(s) constitute lack of cooperation with respect to the Loss. 9. Admit that Defendant does not contend that any actions or omissions of the Plaintiff(s) constitute material misrepresentation with respect to the Loss. CERTIFICATE OF SERVICE IT IS HEREBY CERTIFIED that a true and correct copy of foregoing was served on the Defendant along with the Complaint and Summons this 17™ day of March, 2020. CORREDOR & HUSSEINI, P.A. /s/Maria E. Corredor____ Maria E. Corredor, Esq. FBN: 76619 José C. Leon, Esq. FBN: 125553 3905 N.W. 107th Avenue Suite 502 Telephone: 305-670-1880 Facsimile: 305-670-1985 Email: jleon@chslaw.net Email: service@corredorhusseinilaw.com Attorneys for Plaintiff(s)