On July 28, 2021 a
Proof of Service
was filed
involving a dispute between
Barrata, Daniel J,
Helms, Stacey L,
and
Edison Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
Preview
Filing # 135446007 E-Filed 09/28/2021 11:07:25 AM
2152302
IN THE CIRCUIT COURT OF THE 14TH JUDICIAL
CIRCUIT IN AND FOR BAY COUNTY, FLORIDA
CASE NO. 21000941CA
STACEY L. HELMS and DANIEL J. BARRATA,
as Trustees of the WILLIAM E. CRAWFORD
REVOCABLE TRUST,
Plaintiffs,
Vv.
EDISON INSURANCE COMPANY,
Defendant.
/
DEFENDANT, EDISON INSURANCE COMPANY, NOTICE OF PROPOUNDING
FIRST SET OF INTERROGATORIES TO PLAINTIFFS, STACEY L. HELMS AND
DANIEL J. BARRATA, AS TRUSTEES OF THE WILLIAM E. CRAWFORD
REVOCABLE TRUST
Defendant, EDISON INSURANCE COMPANY, by and through undersigned
counsel, propounds its Interrogatories consisting of 11 in number to Plaintiffs, STACEY
L. HELMS and DANIEL J. BARRATA, as Trustees of the WILLIAM E. CRAWFORD
REVOCABLE TRUST, and demand that their answer under oath, in writing, within thirty
(30) days from the receipt hereof, so as to furnish Defendant with all responsive information
available to the Plaintiffs, their agents, attorneys or any other persons acting on Plaintiffs’
behalf, according to Rule 1.340 of the Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a copy hereof has been furnished by service through the
eportal to Hans Peter B. Haahr, Esq., Haahr Law Group, PL, 4159 Central Avenue, St.
Petersburg, FL 33713, Attorney for Plaintiff on this 28'" day of September, 2021.CASE NO. 21000941CA
CONROY SIMBERG
Attorney for Defendant, Edison Insurance Company
125 West Romana Street, Suite 320
Pensacola, FL 32502
Telephone: (850) 436-6605
Facsimile: (850) 436-2102
Primary Email: eservicepns@conroysimberg.com
Secondary Email: pluna@conroysimberg.com
By: /s/ Patrick Wade Luna
Patrick Wade Luna, Esquire
Florida Bar No. 102206
Document Filed Date
September 28, 2021
Case Filing Date
July 28, 2021
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Filing # 135446007 E-Filed 09/28/2021 11:07:25 AM 2152302 IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO. 21000941CA STACEY L. HELMS and DANIEL J. BARRATA, as Trustees of the WILLIAM E. CRAWFORD REVOCABLE TRUST, Plaintiffs, Vv. EDISON INSURANCE COMPANY, Defendant. / DEFENDANT, EDISON INSURANCE COMPANY, NOTICE OF PROPOUNDING FIRST SET OF INTERROGATORIES TO PLAINTIFFS, STACEY L. HELMS AND DANIEL J. BARRATA, AS TRUSTEES OF THE WILLIAM E. CRAWFORD REVOCABLE TRUST Defendant, EDISON INSURANCE COMPANY, by and through undersigned counsel, propounds its Interrogatories consisting of 11 in number to Plaintiffs, STACEY L. HELMS and DANIEL J. BARRATA, as Trustees of the WILLIAM E. CRAWFORD REVOCABLE TRUST, and demand that their answer under oath, in writing, within thirty (30) days from the receipt hereof, so as to furnish Defendant with all responsive information available to the Plaintiffs, their agents, attorneys or any other persons acting on Plaintiffs’ behalf, according to Rule 1.340 of the Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy hereof has been furnished by service through the eportal to Hans Peter B. Haahr, Esq., Haahr Law Group, PL, 4159 Central Avenue, St. Petersburg, FL 33713, Attorney for Plaintiff on this 28'" day of September, 2021.CASE NO. 21000941CA CONROY SIMBERG Attorney for Defendant, Edison Insurance Company 125 West Romana Street, Suite 320 Pensacola, FL 32502 Telephone: (850) 436-6605 Facsimile: (850) 436-2102 Primary Email: eservicepns@conroysimberg.com Secondary Email: pluna@conroysimberg.com By: /s/ Patrick Wade Luna Patrick Wade Luna, Esquire Florida Bar No. 102206