On April 30, 2021 a
Party Discovery
was filed
involving a dispute between
Darmalingum, Krish,
Darmalingum, Ranie,
and
for Circuit Civil
in the District Court of Lake County.
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35-2021-CA-000746-AXXX-XX
Filing # 125955666 E-Filed 04/30/2021 03:10:20 PM
IN THE CIRCUIT COURT OF THE
FIFTH JUDICIAL CIRCUIT, INAND FOR
LAKE COUNTY, FLORIDA
CASE NO.:
KRISH DARMALINGUM,
Plaintiff,
vs.
CLEAR BLUE INSURANCE COMPANY,
Defendant.
/
REQUEST FOR ADMISSIONS
Plaintiff(s), pursuant to Florida Rule of Civil Procedure 1.370, requests the
Defendant, CLEAR BLUE INSURANCE COMPANY, a corporation authorized and doing
business in the state of Florida, serve a response to the following request for admissions:
1. Defendant issued a policy of insurance to Plaintiff(s) (“Policy”) for the property
located at 3816 Glenford Dr., Clermont, FL 34711 (“Dwelling”).
2. Atall material times, Plaintiff(s) had an insurable interest in the Dwelling.
3. On or about 8/10/2020, the Dwelling sustained a sudden and accidental direct
physical loss while the Policy was in full force and effect (“loss”).
4. The loss triggered coverage under the subject insurance policy.
5. Defendant was notified of the loss pursuant to the terms and conditions of the
Policy.
6. Plaintiff(s) submitted an insurance claim to Defendant (“claim”) pursuant to the
terms and conditions of the Policy.
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 05/03/2021 09:09:30 AM7. Plaintiff(s) did not cause prejudice to Defendant during its investigation of the
claims.
8. As of the date of this lawsuit, there were no outstanding requests by Defendant for
documents or information in connection with its investigation of the loss or
adjustment of the claim.
9. Plaintiff(s) complied with all duties after a loss pursuant to the Policy.
10. The Policy provides coverage for any and all physical damage to the Dwelling that
is not otherwise excluded or excepted by the Policy.
11.The Policy provides coverage for “all risks” of loss to the Dwelling.
12.The Policy provides benefits on a “Replacement Cost Value” basis for covered
losses to the Dwelling subject to the policy limits.
13.In the event of a covered loss to the Dwelling, the Policy provides benefits to repair
or replace damaged or destroyed property, without deducting for depreciation.
14. In the event of a covered loss to the Dwelling, the Policy requires Defendant to pay
benefits on a “Replacement Cost Value” basis, irrespective of whether Plaintiff(s)
actually repairs or replaces the damaged property.
15.As of the date of this lawsuit, Defendant has not indemnified Plaintiff(s) pursuant
to the terms and conditions of the Policy.
CERTIFICATE OF SERVICE| HEREBY CERTIFY that | have served a true and correct copy of the foregoing
upon the Defendant's Registered Agent, State of Florida, Chief Financial Officer, 200 E.
Gaines St., Tallahassee, Florida, 32399, contemporaneously with the Summons and
Complaint.
{BOLTZ LEGAL
1221 E. Broadway St., Suite 1011
Oviedo, FL 32765
Telephone: (386) 868-5848
Fax: (386) 868-5847
ATTORNEY FOR PLAINTIFF
Primary: brookeboltz@boltzlegal.com
Secondary: blacy@boltzlegal.com
/s/_ BROOKE BOLTZ
BROOKE BOLTZ, ESQUIRE
Florida Bar No.: 54035
Document Filed Date
April 30, 2021
Case Filing Date
April 30, 2021
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35-2021-CA-000746-AXXX-XX Filing # 125955666 E-Filed 04/30/2021 03:10:20 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, INAND FOR LAKE COUNTY, FLORIDA CASE NO.: KRISH DARMALINGUM, Plaintiff, vs. CLEAR BLUE INSURANCE COMPANY, Defendant. / REQUEST FOR ADMISSIONS Plaintiff(s), pursuant to Florida Rule of Civil Procedure 1.370, requests the Defendant, CLEAR BLUE INSURANCE COMPANY, a corporation authorized and doing business in the state of Florida, serve a response to the following request for admissions: 1. Defendant issued a policy of insurance to Plaintiff(s) (“Policy”) for the property located at 3816 Glenford Dr., Clermont, FL 34711 (“Dwelling”). 2. Atall material times, Plaintiff(s) had an insurable interest in the Dwelling. 3. On or about 8/10/2020, the Dwelling sustained a sudden and accidental direct physical loss while the Policy was in full force and effect (“loss”). 4. The loss triggered coverage under the subject insurance policy. 5. Defendant was notified of the loss pursuant to the terms and conditions of the Policy. 6. Plaintiff(s) submitted an insurance claim to Defendant (“claim”) pursuant to the terms and conditions of the Policy. FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 05/03/2021 09:09:30 AM7. Plaintiff(s) did not cause prejudice to Defendant during its investigation of the claims. 8. As of the date of this lawsuit, there were no outstanding requests by Defendant for documents or information in connection with its investigation of the loss or adjustment of the claim. 9. Plaintiff(s) complied with all duties after a loss pursuant to the Policy. 10. The Policy provides coverage for any and all physical damage to the Dwelling that is not otherwise excluded or excepted by the Policy. 11.The Policy provides coverage for “all risks” of loss to the Dwelling. 12.The Policy provides benefits on a “Replacement Cost Value” basis for covered losses to the Dwelling subject to the policy limits. 13.In the event of a covered loss to the Dwelling, the Policy provides benefits to repair or replace damaged or destroyed property, without deducting for depreciation. 14. In the event of a covered loss to the Dwelling, the Policy requires Defendant to pay benefits on a “Replacement Cost Value” basis, irrespective of whether Plaintiff(s) actually repairs or replaces the damaged property. 15.As of the date of this lawsuit, Defendant has not indemnified Plaintiff(s) pursuant to the terms and conditions of the Policy. CERTIFICATE OF SERVICE| HEREBY CERTIFY that | have served a true and correct copy of the foregoing upon the Defendant's Registered Agent, State of Florida, Chief Financial Officer, 200 E. Gaines St., Tallahassee, Florida, 32399, contemporaneously with the Summons and Complaint. {BOLTZ LEGAL 1221 E. Broadway St., Suite 1011 Oviedo, FL 32765 Telephone: (386) 868-5848 Fax: (386) 868-5847 ATTORNEY FOR PLAINTIFF Primary: brookeboltz@boltzlegal.com Secondary: blacy@boltzlegal.com /s/_ BROOKE BOLTZ BROOKE BOLTZ, ESQUIRE Florida Bar No.: 54035