On December 10, 2019 a
Motion-Secondary
was filed
involving a dispute between
Bodner, Donna,
and
Tower Hill Select Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
Preview
Filing # 102853807 E-Filed 02/06/2020 11:15:36 AM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
CIVIL DIVISION
DONNA BODNER,
Plaintiff, Case No. 19-004473-CA
vs.
TOWER HILL SELECT
INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S REPLY TO AFFIRMATIVE DEFENSES
COMES NOW the Plaintiff, DONNA BODNER, by and through the undersigned
counsel, and hereby files Plaintiff's Reply to Defendant, TOWER HILL SELECT
INSURANCE COMPANY ’S Affirmative Defenses 1-11, as follows:
1. Plaintiff denies each and every affirmative defense asserted by Defendant and
demands strict proof thereof.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on February 6, 2020, the foregoing has been electronically
filed with the Clerk of Court by using the Florida Courts eFiling Portal system which will send a
Notice of Electronic Filing to all counsel of record as follows: Gregory M. Shoemaker,
Esquire, Wade, Palmer & Shoemaker, 14 North Palafox Street, Pensacola, Florida 32502
(gshoemaker@wpslawyers.com, ssmith@wpslawyers.com cschreiner@wpslawyers.com).
lif David J, Pettinato-
DAVID J. PETTINATO, ESQUIRE
Florida Bar Number: 062324
MERLIN LAW GROUP, P.A.
777 S. Harbour Island Blvd., Suite 950
Tampa, Florida 33602
Tel.: (813) 229-1000 / Fax: (813) 229-3692
Attorney for Plaintiff
dpettinato@merlinlawgroup.com
smerriett@merlinlawgroup.com
trodriguez@merlinlawgroup.com
Document Filed Date
February 06, 2020
Case Filing Date
December 10, 2019
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Filing # 102853807 E-Filed 02/06/2020 11:15:36 AM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CIVIL DIVISION DONNA BODNER, Plaintiff, Case No. 19-004473-CA vs. TOWER HILL SELECT INSURANCE COMPANY, Defendant. / PLAINTIFF’S REPLY TO AFFIRMATIVE DEFENSES COMES NOW the Plaintiff, DONNA BODNER, by and through the undersigned counsel, and hereby files Plaintiff's Reply to Defendant, TOWER HILL SELECT INSURANCE COMPANY ’S Affirmative Defenses 1-11, as follows: 1. Plaintiff denies each and every affirmative defense asserted by Defendant and demands strict proof thereof. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on February 6, 2020, the foregoing has been electronically filed with the Clerk of Court by using the Florida Courts eFiling Portal system which will send a Notice of Electronic Filing to all counsel of record as follows: Gregory M. Shoemaker, Esquire, Wade, Palmer & Shoemaker, 14 North Palafox Street, Pensacola, Florida 32502 (gshoemaker@wpslawyers.com, ssmith@wpslawyers.com cschreiner@wpslawyers.com). lif David J, Pettinato- DAVID J. PETTINATO, ESQUIRE Florida Bar Number: 062324 MERLIN LAW GROUP, P.A. 777 S. Harbour Island Blvd., Suite 950 Tampa, Florida 33602 Tel.: (813) 229-1000 / Fax: (813) 229-3692 Attorney for Plaintiff dpettinato@merlinlawgroup.com smerriett@merlinlawgroup.com trodriguez@merlinlawgroup.com