On December 28, 2020 a
Party Discovery
was filed
involving a dispute between
Guerra, Isabel,
Reyes, Giovanis,
and
People'S Trust Insurance Company,
for Contracts
in the District Court of Charlotte County.
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Filing # 118789259 E-Filed 12/28/2020 05:06:53 PM
IN THE CIRCUIT COURT OF THE
20TH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
CASENO: 20001164CA
GIOVANIS REYES and ISABEL GUERRA,
Plaintiffs,
Vv.
PEOPLE'S TRUST INSURANCE COMPANY,
Defendant.
PLAINTIFFS' FIRST SET OF INTERROGATORIES
Plaintiffs, GIOVANIS REYES and ISABEL GUERRA (collectively referred to hereafter as
the “Insured”), pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, propound the
following First Set of Interrogatories upon Defendant, PEOPLE'S TRUST INSURANCE
COMPANY (the “Insurance Company”), to be answered in writing, under oath, within the time
specified.
CERTIFICATE OF SERVICE
IHEREBY CERTIFY that a true and correct copy of the foregoing was served via U.S. mail
to: PEOPLE'S TRUST INSURANCE COMPANY c/o The Florida Chief Financial Officer as RA,
200 E. Gaines Street, Tallahassee, Florida 32399-4201, on this 28" day of December 2020.Your Insurance Attorney, PLLC.
2601 South Bayshore Drive 18th Floor
Coconut Grove, FL 33133
Phone No.: 1-888-570-5677
Fax: 1-888-745-5677
Email: JDP@Y ourinsuranceattorney.com
Secondary Email: YIA11@Yourinsuranceattormey.com
By. /s/ Joe DePrado
Joe DePrado, Esq.
Florida Bar No. 0127312
Edward De La Osa, Esq.
Florida Bar No. 1010022
Sullying Ceballos, Esq.
Florida Bar No. 1017956
Page 2 of 16
Document Filed Date
December 28, 2020
Case Filing Date
December 28, 2020
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Filing # 118789259 E-Filed 12/28/2020 05:06:53 PM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CASENO: 20001164CA GIOVANIS REYES and ISABEL GUERRA, Plaintiffs, Vv. PEOPLE'S TRUST INSURANCE COMPANY, Defendant. PLAINTIFFS' FIRST SET OF INTERROGATORIES Plaintiffs, GIOVANIS REYES and ISABEL GUERRA (collectively referred to hereafter as the “Insured”), pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, propound the following First Set of Interrogatories upon Defendant, PEOPLE'S TRUST INSURANCE COMPANY (the “Insurance Company”), to be answered in writing, under oath, within the time specified. CERTIFICATE OF SERVICE IHEREBY CERTIFY that a true and correct copy of the foregoing was served via U.S. mail to: PEOPLE'S TRUST INSURANCE COMPANY c/o The Florida Chief Financial Officer as RA, 200 E. Gaines Street, Tallahassee, Florida 32399-4201, on this 28" day of December 2020.Your Insurance Attorney, PLLC. 2601 South Bayshore Drive 18th Floor Coconut Grove, FL 33133 Phone No.: 1-888-570-5677 Fax: 1-888-745-5677 Email: JDP@Y ourinsuranceattorney.com Secondary Email: YIA11@Yourinsuranceattormey.com By. /s/ Joe DePrado Joe DePrado, Esq. Florida Bar No. 0127312 Edward De La Osa, Esq. Florida Bar No. 1010022 Sullying Ceballos, Esq. Florida Bar No. 1017956 Page 2 of 16