On October 03, 2018 a
Motion-Secondary
was filed
involving a dispute between
Rabe, Toxi,
and
Safe Harbor Insurance Company,
in the District Court of Clay County.
Preview
Filing # 80830039 E-Filed 11/15/2018 09:55:17 AM
IN THE CIRCUIT COURT OF THE 4TH JUDICIAL CIRCUIT
IN AND FOR CLAY COUNTY, FLORIDA
CASE NO.: 2018CA001049
TOXI RABE,
Plaintiff,
vs.
SAFE HARBOR
INSURANCE COMPANY,
Defendant.
PLAINTIFF’S REPLY TO DEFENDANT’S
ANSWER AND AFFIRMATIVE DEFENSES
Plaintiff, TOXI RABE, by and through undersigned counsel, hereby file this Reply to the
Defendant’s, SAFE HARBOR INSURANCE COMPANY, Answer and Affirmative Defenses, and as
grounds would state as follows:
Each and every affirmative defense is denied and strict proof is demanded on each.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via Email,
pursuant to Rule 2.516(b)(1) to: Michelle Diverio, Esq., LYDECKER | DIAZ, via transmission of Notice
of Electronic Filing generated by eservice@myficourtaccess.com and/or was sent by electronic mail
to the above addressees, November 15, 2018.
ARNESEN WEBB, P.A.
Attorneys for Plaintiff
197 S. Federal Highway, Ste. 300
Boca Raton, FL 33432
Telephone: (561)-757-6000
Facsimile: (877)-241-2411
aris@insurancelawyers.or
eservice@insurancelawyers.org
By /s/ Paris R. Webb
PARIS R. WEBB
Florida Bar No.: 713074
Document Filed Date
November 15, 2018
Case Filing Date
October 03, 2018
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 80830039 E-Filed 11/15/2018 09:55:17 AM IN THE CIRCUIT COURT OF THE 4TH JUDICIAL CIRCUIT IN AND FOR CLAY COUNTY, FLORIDA CASE NO.: 2018CA001049 TOXI RABE, Plaintiff, vs. SAFE HARBOR INSURANCE COMPANY, Defendant. PLAINTIFF’S REPLY TO DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES Plaintiff, TOXI RABE, by and through undersigned counsel, hereby file this Reply to the Defendant’s, SAFE HARBOR INSURANCE COMPANY, Answer and Affirmative Defenses, and as grounds would state as follows: Each and every affirmative defense is denied and strict proof is demanded on each. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via Email, pursuant to Rule 2.516(b)(1) to: Michelle Diverio, Esq., LYDECKER | DIAZ, via transmission of Notice of Electronic Filing generated by eservice@myficourtaccess.com and/or was sent by electronic mail to the above addressees, November 15, 2018. ARNESEN WEBB, P.A. Attorneys for Plaintiff 197 S. Federal Highway, Ste. 300 Boca Raton, FL 33432 Telephone: (561)-757-6000 Facsimile: (877)-241-2411 aris@insurancelawyers.or eservice@insurancelawyers.org By /s/ Paris R. Webb PARIS R. WEBB Florida Bar No.: 713074