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Filing # 80654196 E-Filed 11/12/2018 10:29:24 AM
IN THE CIRCUIT COURT OF THE
NINETEENTH JUDICIAL CIRCUIT IN AND
FOR ST. LUCIE COUNTY, FLORIDA
CASE NO.: 2018-CA-001071
DIVISION: (Judge Janet C. Croom)
ARMANDO PEREZ,
Plaintiff,
Vv.
ASI PREFERRED INSURANCE CORP.,
Defendant.
/
DEFENDANT, ASI PREFERRED INSURANCE CORP.’S
FIRST REQUEST FOR ADMISSIONS
COMES NOW, Defendant, ASI PREFERRED INSURANCE CORP. (hereinafter “ASI”),
by and through its undersigned counsel, and pursuant to Rule 1.370 of the Florida Rules of Civil
Procedure, requests that the Plaintiff, ARMANDO PEREZ, serve a written admission or denial
addresses to the matter within thirty (30) days after service of this request.
DEFINITIONS
(a) The words “you,” “your,” “yourself,” and/or “Plaintiff” means ARMANDO PEREZ and any
agents, representatives or other persons acting, or purporting to act, on behalf of ARMANDO
PEREZ including, unless privileged, his attorneys.
(b) The term “subject property” refers to the real property, dwelling and/or appurtenant structures
and/or premises at issue in this suit located at 3709 SW Haines St., Port St. Lucie, FL 34953.
(c) “Policy” shall mean the policy of insurance numbered FLP182469, with effective dates
February 20, 2017 through February 20, 2018, issued to Armando Perez for the property
located at 3709 SW Haines St., Port St. Lucie, FL 34593.(d) The terms “claim,” “loss,” or “subject loss” shall mean the event and/or incident involving
alleged loss occurring on September 12, 2017 to the property located at 3709 SW Haines St.,
Port St. Lucie, FL 34953, as alleged in the Complaint.
(e) The singular shall include the plural and vice versa; the terms “and” or “or” shall be both
conjunctive and disjunctive; and the term “including” means “including without
limitation”.
(f “Representative” shall mean: any attorney, independent contractor or any other person
acting at the direction or on behalf of another.
(g) All other words have their plain and ordinary meaning.
REQUEST FOR ADMISSIONS
1. Please admit that you made a claim to ASI on or about September 14, 2017, for damage caused
by Hurricane Irma on September 12, 2017.
RESPONSE:
2. Please admit that you made repairs to the roof of the subject property before ASI had the
opportunity to inspect the damage.
RESPONSE:
3. Please admit that on November 6, 2017, you deposited a check issued by ASI in the amount of
$5,365.84 for damages caused by Hurricane Irma on September 12, 2017.
RESPONSE:CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished via electronic
delivery to Kenneth R. Duboff, Esquire, Duboff Law Firm, 680 NE 127 Street, North Miami, FL
33161 via the following designated e-mail address: CourtDocument@DuboffLawFirm.com on
this 12" day of November, 2018.
Libibe
HAELA D. SCHEIHING, AtPORNEY AT LAW
Florida Bar Number 0931853
Southeast Law Group, P.A.
1825 Business Park Blvd., Suite A
Daytona Beach, FL 32114
Office: (386) 274-1700
Attorneys for Defendant
mscheihing@southeastlaw.com
kmarye@southeastlaw.com
dfrantzman@southeastlaw.com
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Filing # 80654196 E-Filed 11/12/2018 10:29:24 AM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA CASE NO.: 2018-CA-001071 DIVISION: (Judge Janet C. Croom) ARMANDO PEREZ, Plaintiff, Vv. ASI PREFERRED INSURANCE CORP., Defendant. / DEFENDANT, ASI PREFERRED INSURANCE CORP.’S FIRST REQUEST FOR ADMISSIONS COMES NOW, Defendant, ASI PREFERRED INSURANCE CORP. (hereinafter “ASI”), by and through its undersigned counsel, and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, requests that the Plaintiff, ARMANDO PEREZ, serve a written admission or denial addresses to the matter within thirty (30) days after service of this request. DEFINITIONS (a) The words “you,” “your,” “yourself,” and/or “Plaintiff” means ARMANDO PEREZ and any agents, representatives or other persons acting, or purporting to act, on behalf of ARMANDO PEREZ including, unless privileged, his attorneys. (b) The term “subject property” refers to the real property, dwelling and/or appurtenant structures and/or premises at issue in this suit located at 3709 SW Haines St., Port St. Lucie, FL 34953. (c) “Policy” shall mean the policy of insurance numbered FLP182469, with effective dates February 20, 2017 through February 20, 2018, issued to Armando Perez for the property located at 3709 SW Haines St., Port St. Lucie, FL 34593.(d) The terms “claim,” “loss,” or “subject loss” shall mean the event and/or incident involving alleged loss occurring on September 12, 2017 to the property located at 3709 SW Haines St., Port St. Lucie, FL 34953, as alleged in the Complaint. (e) The singular shall include the plural and vice versa; the terms “and” or “or” shall be both conjunctive and disjunctive; and the term “including” means “including without limitation”. (f “Representative” shall mean: any attorney, independent contractor or any other person acting at the direction or on behalf of another. (g) All other words have their plain and ordinary meaning. REQUEST FOR ADMISSIONS 1. Please admit that you made a claim to ASI on or about September 14, 2017, for damage caused by Hurricane Irma on September 12, 2017. RESPONSE: 2. Please admit that you made repairs to the roof of the subject property before ASI had the opportunity to inspect the damage. RESPONSE: 3. Please admit that on November 6, 2017, you deposited a check issued by ASI in the amount of $5,365.84 for damages caused by Hurricane Irma on September 12, 2017. RESPONSE:CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished via electronic delivery to Kenneth R. Duboff, Esquire, Duboff Law Firm, 680 NE 127 Street, North Miami, FL 33161 via the following designated e-mail address: CourtDocument@DuboffLawFirm.com on this 12" day of November, 2018. Libibe HAELA D. SCHEIHING, AtPORNEY AT LAW Florida Bar Number 0931853 Southeast Law Group, P.A. 1825 Business Park Blvd., Suite A Daytona Beach, FL 32114 Office: (386) 274-1700 Attorneys for Defendant mscheihing@southeastlaw.com kmarye@southeastlaw.com dfrantzman@southeastlaw.com