On December 13, 2019 a
Party Discovery
was filed
involving a dispute between
Varnes, Cynthia,
Varnes, Travis,
and
Security First Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 100298746 E-Filed 12/13/2019 02:31:12 PM
IN THE CIRCUIT COURT OF THE
FOURTEENTH JUDICIAL CIRCUIT IN AND
FOR BAY COUNTY, FLORIDA
CASE NUMBER: 19004515CA
TRAVIS AND CYNTHIA VARNES,
Plaintiff,
ve
SECURITY FIRST INSURANCE COMPANY D/B/A SECURITY FIRST FLORIDA,
Defendant,
/
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT.
COMES NOW, Plaintiff, Travis and Cynthia Varnes, by and through the undersigned
counsel and pursuant to Florida Rule of Civil Procedure 1.370, and hereby files and submits to
Defendant, Security First Insurance Company d/b/a Security First Florida, the following requests
for admissions for Defendant to admit or deny within forty-five (45) days of the service of the
Complaint herein:
1. Admit that you issued a policy of homeowners insurance that provided insurance
coverage to a property located at 5639 Martin Court, Panama City, FL 32404.
RESPONSE:
2. Admit that the homeowners insurance policy you issued, which is described in the
Complaint, provided coverage for hurricane damage.
RESPONSE:
3. Admit that the insurance policy you issued to Plaintiff for the property located at 5639
Martin Court, Panama City, FL 32404 was in full force and effect as of October 11, 2018.
RESPONSE:4. Admit that the hurricane loss described in the Complaint, which occurred on or about
October 11, 2018, was a covered event pursuant to the terms of the subject policy.
RESPONSE:
5. Admit that any payment you issued on this claim was in accordance with the terms of the
insurance policy at issue in this lawsuit.
RESPONSE:
6. Admit that above-named Defendant is properly named in this action.
RESPONSE:
7. Admit that Defendant’s adjuster(s) who worked on this claim did so in accordance with
Fla. Stat. § 626.878.
RESPONSE:
CERTIFICATE OF SERVICE
1 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.
Date: December 13, 2019
/s/Michael D. Quintero
Cohen Law Group
Michael D. Quintero
FOR THE FIRM
Florida Bar Number: 91963
350 North Lake Destiny Road
Maitland, Florida 32751
Phone: (407) 478-4878
Fax: (407) 478-0204
Email: mquintero@itsaboutjustice.law
Document Filed Date
December 13, 2019
Case Filing Date
December 13, 2019
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Filing # 100298746 E-Filed 12/13/2019 02:31:12 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NUMBER: 19004515CA TRAVIS AND CYNTHIA VARNES, Plaintiff, ve SECURITY FIRST INSURANCE COMPANY D/B/A SECURITY FIRST FLORIDA, Defendant, / PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT. COMES NOW, Plaintiff, Travis and Cynthia Varnes, by and through the undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.370, and hereby files and submits to Defendant, Security First Insurance Company d/b/a Security First Florida, the following requests for admissions for Defendant to admit or deny within forty-five (45) days of the service of the Complaint herein: 1. Admit that you issued a policy of homeowners insurance that provided insurance coverage to a property located at 5639 Martin Court, Panama City, FL 32404. RESPONSE: 2. Admit that the homeowners insurance policy you issued, which is described in the Complaint, provided coverage for hurricane damage. RESPONSE: 3. Admit that the insurance policy you issued to Plaintiff for the property located at 5639 Martin Court, Panama City, FL 32404 was in full force and effect as of October 11, 2018. RESPONSE:4. Admit that the hurricane loss described in the Complaint, which occurred on or about October 11, 2018, was a covered event pursuant to the terms of the subject policy. RESPONSE: 5. Admit that any payment you issued on this claim was in accordance with the terms of the insurance policy at issue in this lawsuit. RESPONSE: 6. Admit that above-named Defendant is properly named in this action. RESPONSE: 7. Admit that Defendant’s adjuster(s) who worked on this claim did so in accordance with Fla. Stat. § 626.878. RESPONSE: CERTIFICATE OF SERVICE 1 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. Date: December 13, 2019 /s/Michael D. Quintero Cohen Law Group Michael D. Quintero FOR THE FIRM Florida Bar Number: 91963 350 North Lake Destiny Road Maitland, Florida 32751 Phone: (407) 478-4878 Fax: (407) 478-0204 Email: mquintero@itsaboutjustice.law