On April 09, 2019 a
Party Discovery
was filed
involving a dispute between
Cyr, Jessica,
Cyr, Timothy,
and
Edison Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 87718124 E-Filed 04/09/2019 04:21:08 PM
IN THE CIRCUIT COURT OF THE
FOURTEENTH JUDICIAL CIRCUIT IN
AND FOR BAY COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
TIMOTHY CYR and
JESSICA CYR,
CASE NO.: 19001054CA
Plaintiff,
FLORIDA BAR NO.: 127612
vs.
EDISON INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW, the Plaintiff, TIMOTHY CYR and JESSICA CYR, by and through
undersigned counsel, pursuant to Florida Rules of Civil Procedure 1.370, and hereby
serves, CITIZENS PROPERTY INSURANCE CORPORATION, with its First Request for
Admissions to be admitted or denied within forty-five (45) days after service thereof, and
in support thereof states:
1. Admit that you do not dispute the cause of loss as alleged in Paragraph 8 of the
Complaint.
2. Admit that you do not dispute the date of loss as alleged in Paragraph 8 of the
Complaint.
3. Admit that the policy described in Paragraph 5 of the Complaint was in full force
and effect on or about the date of loss alleged in Paragraph 8 of the Complaint.
4. Admit that Plaintiff(s) complied with all of the post loss duties under the policy
described in Paragraph 5 of the Complaint.5. Admit that Plaintiff(s) complied with all of the conditions precedent under the
policy described in Paragraph 5 of the Complaint.
6. Admit that Defendant's investigation of the loss described in Paragraph 8 of the
Complaint was not prejudiced by the acts or omissions of Plaintiff(s).
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was served
attached with the Original Summons and Complaint.
Thomas J. Morgan, Jr., Esquire
FLORIDA BAR NO.: 127612
MORGAN LAW GROUP, P.A.
Counsel for Plaintiff
55 Merrick Way, Suite 404
Coral Gables, Florida 33134
Phone: 305.569.9900
Fax : 305.443.6828
/tm
By: _ /s/ Thomas J. Morgan
Thomas J. Morgan, Jr.
Document Filed Date
April 09, 2019
Case Filing Date
April 09, 2019
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Filing # 87718124 E-Filed 04/09/2019 04:21:08 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA GENERAL JURISDICTION DIVISION TIMOTHY CYR and JESSICA CYR, CASE NO.: 19001054CA Plaintiff, FLORIDA BAR NO.: 127612 vs. EDISON INSURANCE COMPANY, Defendant. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW, the Plaintiff, TIMOTHY CYR and JESSICA CYR, by and through undersigned counsel, pursuant to Florida Rules of Civil Procedure 1.370, and hereby serves, CITIZENS PROPERTY INSURANCE CORPORATION, with its First Request for Admissions to be admitted or denied within forty-five (45) days after service thereof, and in support thereof states: 1. Admit that you do not dispute the cause of loss as alleged in Paragraph 8 of the Complaint. 2. Admit that you do not dispute the date of loss as alleged in Paragraph 8 of the Complaint. 3. Admit that the policy described in Paragraph 5 of the Complaint was in full force and effect on or about the date of loss alleged in Paragraph 8 of the Complaint. 4. Admit that Plaintiff(s) complied with all of the post loss duties under the policy described in Paragraph 5 of the Complaint.5. Admit that Plaintiff(s) complied with all of the conditions precedent under the policy described in Paragraph 5 of the Complaint. 6. Admit that Defendant's investigation of the loss described in Paragraph 8 of the Complaint was not prejudiced by the acts or omissions of Plaintiff(s). CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was served attached with the Original Summons and Complaint. Thomas J. Morgan, Jr., Esquire FLORIDA BAR NO.: 127612 MORGAN LAW GROUP, P.A. Counsel for Plaintiff 55 Merrick Way, Suite 404 Coral Gables, Florida 33134 Phone: 305.569.9900 Fax : 305.443.6828 /tm By: _ /s/ Thomas J. Morgan Thomas J. Morgan, Jr.