Document for Louis Charles Plaintiff vs. American Integrity Insurance Company of Florida Defendant

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                                Case Number: CACE-19-011697 Division: 02

Filing # 90398501 E-Filed 05/31/2019 03:16:15 PM

IN THE CIRCUIT COURT FOR THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

Louis Charles,

vs.

Plaintiff,
CASE NO.:

American Integrity Insurance Company of Florida,

Defendant.

PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW, the Plaintiff, Louis Charles, by and through the undersigned counsel and

pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, and hereby files and submits to the

Defendant, American Integrity Insurance Company of Florida, the following requests for

admissions and requests that the Defendant admits to or denies the following in writing, within

forty five (45) days of the service of the Complaint herein:

1.

Admit that prior to May 14, 2018 you issued a policy of homeowners’ insurance which
provided insurance coverage to a property located at 419 SW 80th Ave., North Lauderdale,
FL 33068.

RESPONSE:

Admit that the policy of homeowners’ insurance which Defendant provided to Plaintiff
covered the property located at 419 SW 80th Ave., North Lauderdale, FL 33068 as of the date
of the loss described in the Complaint, which was on or about May 14, 2018.

RESPONSE:

Admit that the insurance policy Defendant issued which is described in the Complaint
provided coverage to Plaintiff for damage caused to the property located at 419 SW 80th Ave.,
North Lauderdale, FL 33068 as a result of loss described in the Complaint.

RESPONSE:

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/31/2019 03:16:13 PM.****. Admit that the policy of homeowners’ insurance which Defendant provided to Plaintiff for
the property located at 419 SW 80th Ave., North Lauderdale, FL 33068 was in full force and
effect as of May 14, 2018.

RESPONSE:

. Admit that pursuant to the terms of Defendant’s homeowners’ insurance policy issued to
Plaintiff for the property located at 419 SW 80th Ave., North Lauderdale, FL 33068,
Defendant was timely notified of the loss in question which occurred on or about May 14,
2018.

RESPONSE:

. Admit that the loss described in the Complaint which occurred on or about May 14, 2018 was
a covered event pursuant to the terms of the policy of homeowners’ insurance which
Defendant issued to the Plaintiff for the property located at 419 SW 80th Ave., North
Lauderdale, FL 33068.

RESPONSE:

. Admit that Defendant received notice of the loss described in the Complaint at least 90 days
prior to the filing of this law suit or before the claim was denied or underpayment issued.

RESPONSE:

. Admit that Plaintiff is the recipient of the benefits related to the subject claim under the
insurance policy which Defendant issued to Plaintiff for the property located at 419 SW 80th
Ave., North Lauderdale, FL 33068 as it pertains to the loss which occurred on or about May
14, 2018.

RESPONSE:

. Admit that any payment Defendant issued on this claim was in accordance with the terms of
the insurance policy at issue in this lawsuit.

RESPONSE:10. Admit that above-named Defendant is properly named in this action.

RESPONSE:

CERTIFICATE OF SERVICE

I DO HEREBY CERTIFY that a true and correct copy of this document will be served

on the Defendant along with the Complaint and Demand for Jury Trial and Summons in this action.

DATED: May 31, 2019

JENNIFER J. SMITH, ESQ.
Florida Bar No.: 057322
KUHN RASLAVICH, P.A.
7700 Congress Ave. Suite 3111
Boca Raton, FL 33487
Telephone: (954)372-3272
Facsimi

Counsel for Plaintiff