On December 04, 2019 a
Motion-Secondary
was filed
involving a dispute between
Carr, Jamie,
Carr, Jennifer,
and
Gulfstream Property & Casualty Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 103401829 E-Filed 02/17/2020 12:16:38 PM
IN THE CIRCUIT COURT OF THE 14"
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
CASE NO.: 19004412CA
JAMIE AND JENNIFER CARR,
Plaintiffs,
vs.
GULFSTREAM PROPERTY AND
CASUALTY INSURANCE COMPANY,
Defendant.
/
REPLY TO AFFIRMATIVE DEFENSES
COME NOW Plaintiffs, JAMIE AND JENNIFER CARR, by and through undersigned counsel
and hereby file this Reply to the Affirmative Defenses raised by the Defendant, GULFSTREAM
PROPERTY AND CASUALTY INSURANCE COMPANY, and state as follows:
The Plaintiffs deny each and every affirmative defense raised by the Defendant, GULFSTREAM
PROPERTY AND CASUALTY INSURANCE COMPANY, and demand strict proof thereof.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on this
17" day of February, 2020, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler Weihmuller
Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602, kmaus@butler.legal.
GED LAWYERS, LLP
Attorneys for the Plaintiff
7171 North Federal Highway
Boca Raton, FL 33487
Telephone: (561) 995-1966
Facsimile: (561) 241-0812
Primary Email: pdlitlaw@gedlawyers.com
Secondary Email:bluque@gedlawyers.com
BY:/s/ Scott M. Rosso
SCOTT M. ROSSO, ESQ.
Florida Bar No.: 505757
DAVID R. SHAHEEN, ESQ.
Florida Bar No.: 0117947
Document Filed Date
February 17, 2020
Case Filing Date
December 04, 2019
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Filing # 103401829 E-Filed 02/17/2020 12:16:38 PM IN THE CIRCUIT COURT OF THE 14" JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO.: 19004412CA JAMIE AND JENNIFER CARR, Plaintiffs, vs. GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. / REPLY TO AFFIRMATIVE DEFENSES COME NOW Plaintiffs, JAMIE AND JENNIFER CARR, by and through undersigned counsel and hereby file this Reply to the Affirmative Defenses raised by the Defendant, GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY, and state as follows: The Plaintiffs deny each and every affirmative defense raised by the Defendant, GULFSTREAM PROPERTY AND CASUALTY INSURANCE COMPANY, and demand strict proof thereof. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on this 17" day of February, 2020, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602, kmaus@butler.legal. GED LAWYERS, LLP Attorneys for the Plaintiff 7171 North Federal Highway Boca Raton, FL 33487 Telephone: (561) 995-1966 Facsimile: (561) 241-0812 Primary Email: pdlitlaw@gedlawyers.com Secondary Email:bluque@gedlawyers.com BY:/s/ Scott M. Rosso SCOTT M. ROSSO, ESQ. Florida Bar No.: 505757 DAVID R. SHAHEEN, ESQ. Florida Bar No.: 0117947