On June 08, 2018 a
Party Discovery
was filed
involving a dispute between
Perez, Armando,
and
Asi Preferred Insurance Corp,
for Circuit Civil
in the District Court of St. Lucie County.
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Filing # 73280647 E-Filed 06/08/2018 10:22:22 AM
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR
ST. LUCIE COUNTY, FLORIDA.
ARMANDO PEREZ, CASENO. 562018CAQ01071AXXXHC
Judge Janet C Croom
Plaintiff
ASI PREFERRED INSURANCE CORP.,
Defendant.
REQUEST FOR ADMISSIONS
Florida Bar #218261
COMES NOW the Plaintiff; by and through the undersigned attorneys, and pursuant to
the applicable Florida Rules of Civil Procedure, hereby Requests the Defendant to admit or deny
the following items:
1. Admit that on the date of the alleged loss described in the Complaint that the
policy described in the Complaint was in full force and effect.
2. Admit that Plaintiff is the named 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, Plaintiff made a claim under the
Policy described in the Complaint for a loss which Plaintiff claims occurred the date of loss
described in the Complaint...
5. Admit that Defendant assigned the claim number to the subject loss as described
in the Complaint,6. Admit that Plaintiff did not fail to comply with any request that may have been
made by Deféndant for Plaintiff to submit a Sworn Proof of Loss for the alleged loss.
7. Admit that Plaintiff did not fail to comply with any request that may have been
made by Defendant for Plaintiff'to submit to an examination under oath for the alleged loss.
8. Admit that Plaintiff permitted Defendant access to the premises described in the
subject policy after the date of the alleged loss.
9. Admit that Defendant acknowledged coverage for the loss described in the
Complaint.
10. Admit that Defendant made a payment of insurance benefits to, or for the benefit
of, Plaintiff for the alleged loss described in the Complaint.
11. Admit that Defendant acknowledged insurance coverage for claim number
496807-171013.
12. Admit that Defendant made a payment of insurance benefits to, or for the benefit
of, Plaintiff under claim number 496807-171013.
13. Admit that Defendant believes that Plaintiff is not entitled to any more insurance
benefits for claim number 496807-171013 than what has already been paid by Defendant prior
to the filing of this lawsuit.
14. Admit that prior to the service of process upon Defendant in this action that
Plaintiff notified Defendant that Plaintiff disagreed with Defendant’s evaluation as to the total
amount of the actual cash value of the loss.
15. Admit that prior to the service of process upon Defendant in this action that
Plaintiff submitted to Defendant a written estimate of repairs for the damage alleged to have
occurred by reason of the loss.
a DUBOFF16. Admit that prior to the service of process upon Defendant in this action that
Plaintiff submitted to Defendant a written estimate of repairs in an amount greater than the
amount of the estimate of damages relied upon by Defendant in making payment of insurance
benefits due Phintiff as a result of the loss.
17. Admit that there is a disagreement between the parties as to the total amount of
the actual cash value payment that Plaintiff was and is entitled to as a result of the loss.
CERTIFICATE OF SERVICE,
WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served
upon Defendant by the Florida Department of Financial Services together with the initial service
of process in this action.
Dusorr Law FIRM
ATTORNEYS FOR PLAINTIFF
680 N.E. 127 STREET
Nortu MIAMj, FLORIDA 33161
TELEPHONE (305) 899-0085
Fax No. (305) 899-0091
EMAIL; CourRTDOCUMENT@DuBOFFLAWFIRM.COM
BY: S/ KENNETH R. DUBOFF
KENNETH R. Duporr, Esq.
FLA. BAR#218261
— DUBOFE een
Document Filed Date
June 08, 2018
Case Filing Date
June 08, 2018
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Filing # 73280647 E-Filed 06/08/2018 10:22:22 AM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA. ARMANDO PEREZ, CASENO. 562018CAQ01071AXXXHC Judge Janet C Croom Plaintiff ASI PREFERRED INSURANCE CORP., Defendant. REQUEST FOR ADMISSIONS Florida Bar #218261 COMES NOW the Plaintiff; by and through the undersigned attorneys, and pursuant to the applicable Florida Rules of Civil Procedure, hereby Requests the Defendant to admit or deny the following items: 1. Admit that on the date of the alleged loss described in the Complaint that the policy described in the Complaint was in full force and effect. 2. Admit that Plaintiff is the named 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, Plaintiff made a claim under the Policy described in the Complaint for a loss which Plaintiff claims occurred the date of loss described in the Complaint... 5. Admit that Defendant assigned the claim number to the subject loss as described in the Complaint,6. Admit that Plaintiff did not fail to comply with any request that may have been made by Deféndant for Plaintiff to submit a Sworn Proof of Loss for the alleged loss. 7. Admit that Plaintiff did not fail to comply with any request that may have been made by Defendant for Plaintiff'to submit to an examination under oath for the alleged loss. 8. Admit that Plaintiff permitted Defendant access to the premises described in the subject policy after the date of the alleged loss. 9. Admit that Defendant acknowledged coverage for the loss described in the Complaint. 10. Admit that Defendant made a payment of insurance benefits to, or for the benefit of, Plaintiff for the alleged loss described in the Complaint. 11. Admit that Defendant acknowledged insurance coverage for claim number 496807-171013. 12. Admit that Defendant made a payment of insurance benefits to, or for the benefit of, Plaintiff under claim number 496807-171013. 13. Admit that Defendant believes that Plaintiff is not entitled to any more insurance benefits for claim number 496807-171013 than what has already been paid by Defendant prior to the filing of this lawsuit. 14. Admit that prior to the service of process upon Defendant in this action that Plaintiff notified Defendant that Plaintiff disagreed with Defendant’s evaluation as to the total amount of the actual cash value of the loss. 15. Admit that prior to the service of process upon Defendant in this action that Plaintiff submitted to Defendant a written estimate of repairs for the damage alleged to have occurred by reason of the loss. a DUBOFF16. Admit that prior to the service of process upon Defendant in this action that Plaintiff submitted to Defendant a written estimate of repairs in an amount greater than the amount of the estimate of damages relied upon by Defendant in making payment of insurance benefits due Phintiff as a result of the loss. 17. Admit that there is a disagreement between the parties as to the total amount of the actual cash value payment that Plaintiff was and is entitled to as a result of the loss. CERTIFICATE OF SERVICE, WE HEREBY CERTIFY that a true and correct copy of the foregoing was to be served upon Defendant by the Florida Department of Financial Services together with the initial service of process in this action. Dusorr Law FIRM ATTORNEYS FOR PLAINTIFF 680 N.E. 127 STREET Nortu MIAMj, FLORIDA 33161 TELEPHONE (305) 899-0085 Fax No. (305) 899-0091 EMAIL; CourRTDOCUMENT@DuBOFFLAWFIRM.COM BY: S/ KENNETH R. DUBOFF KENNETH R. Duporr, Esq. FLA. BAR#218261 — DUBOFE een