On August 20, 2019 a
Party Discovery
was filed
involving a dispute between
Palm Pcb Llc,
and
American Integrity Insurance Company Of America,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 94480053 E-Filed 08/20/2019 04:55:01 PM.
IN THE CIRCUIT COURT FOR THE 14"
JUDICIAL CIRCUIT IN AND FOR BAY
COUNTY, FLORIDA
CASE NO, 19003170CA
PALM PCB, L.L.C.,
Plaintiff,
v.
AMERICAN INTEGRITY INSURANCE
COMPANY OF AMERICA,
Defendant.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS
Plaintiff, PALM PCB, L.L.C., by and through undersigned counsel, and pursuant to
Florida Rule of Civil Procedure 1.370, requests defendant to admit the following facts:
1. Admit that on the date of the alleged loss described in the Complaint that the
policy described in the Complaint that the policy described in the Complaint was in full force
and effect.
2. Admit that Palm PCB L.L.C. is an insured (hereinafter, the “insured”) under the
insurance policy described in the Complaint.
3. Admit that the premises described in the Complaint are the insured premises
under the insurance policy described in the Complaint.
4. Admit that prior to the institution of this action, the insured made a claim under
the policy described in the Complaint for the loss described in the Complaint.
5. Admit that Defendant assigned claim number CDP-00070427 to the subject loss
as described in Plaintiff's Complaint.6. Admit that prior to the institution of this action, that one or more of Defendant’s
adjusters, independent adjusters, third-party adjusters or employees were showed, or visited, or
inspected the alleged damaged property.
7. Admit that prior to the institution of this action, Defendant’s insured permitted
Defendant access to the premises described in the subject policy after the date of the alleged date
of loss.
8. Admit that prior to the institution of this action, Defendant did not request of its
insured in writing, that the insured submit to an examination under oath for the alleged loss
described in the Complaint.
9. Admit that Defendant did not take a recorded statement of its insured.
10. Admit that Defendant did not take an examination under oath of its insured.
11. Admit that the insured has fully cooperated with the Defendant with respect to all
requests for investigation and inspection of the subject premises.
12. Admit that the insured complied with all post loss obligations as set forth in the
insurance policy described in the Complaint.
13. Admit that Defendant completed its investigation into claim number CDP-
00070427.
14. Admit that Defendant acknowledged coverage for claim number CDP-00070427.
15. | Admit that coverage for the loss which is the subject of claim number CDP-
00070427 is not an issue in this litigation.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon
Defendant in this action along with the Summons and Complaint.
THE DIENER FIRM, P.A.
Attorneys for Plaintiff
8751 W. Broward Boulevard, Suite 404
Plantation, Florida 33324
Telephone: (954) 541-2117
Facsimile: (954) 541-2195
E-Mail: service@dienerfirm.com
By:__/s/Erik D. Diener
ERIK D. DIENER, ESQ.
Florida Bar No.: 013410
Document Filed Date
August 20, 2019
Case Filing Date
August 20, 2019
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Filing # 94480053 E-Filed 08/20/2019 04:55:01 PM. IN THE CIRCUIT COURT FOR THE 14" JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO, 19003170CA PALM PCB, L.L.C., Plaintiff, v. AMERICAN INTEGRITY INSURANCE COMPANY OF AMERICA, Defendant. / PLAINTIFF’S REQUEST FOR ADMISSIONS Plaintiff, PALM PCB, L.L.C., by and through undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.370, requests defendant to admit the following facts: 1. Admit that on the date of the alleged loss described in the Complaint that the policy described in the Complaint that the policy described in the Complaint was in full force and effect. 2. Admit that Palm PCB L.L.C. is an insured (hereinafter, the “insured”) under the insurance policy described in the Complaint. 3. Admit that the premises described in the Complaint are the insured premises under the insurance policy described in the Complaint. 4. Admit that prior to the institution of this action, the insured made a claim under the policy described in the Complaint for the loss described in the Complaint. 5. Admit that Defendant assigned claim number CDP-00070427 to the subject loss as described in Plaintiff's Complaint.6. Admit that prior to the institution of this action, that one or more of Defendant’s adjusters, independent adjusters, third-party adjusters or employees were showed, or visited, or inspected the alleged damaged property. 7. Admit that prior to the institution of this action, Defendant’s insured permitted Defendant access to the premises described in the subject policy after the date of the alleged date of loss. 8. Admit that prior to the institution of this action, Defendant did not request of its insured in writing, that the insured submit to an examination under oath for the alleged loss described in the Complaint. 9. Admit that Defendant did not take a recorded statement of its insured. 10. Admit that Defendant did not take an examination under oath of its insured. 11. Admit that the insured has fully cooperated with the Defendant with respect to all requests for investigation and inspection of the subject premises. 12. Admit that the insured complied with all post loss obligations as set forth in the insurance policy described in the Complaint. 13. Admit that Defendant completed its investigation into claim number CDP- 00070427. 14. Admit that Defendant acknowledged coverage for claim number CDP-00070427. 15. | Admit that coverage for the loss which is the subject of claim number CDP- 00070427 is not an issue in this litigation.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon Defendant in this action along with the Summons and Complaint. THE DIENER FIRM, P.A. Attorneys for Plaintiff 8751 W. Broward Boulevard, Suite 404 Plantation, Florida 33324 Telephone: (954) 541-2117 Facsimile: (954) 541-2195 E-Mail: service@dienerfirm.com By:__/s/Erik D. Diener ERIK D. DIENER, ESQ. Florida Bar No.: 013410