`
`IN THE CIRCUIT COURT OF THE 9th
`JUDICIAL CIRCUIT
`IN AND FOR
`ORANGE COUNTY, FLORIDA
`
`CASE NO.:
`
`
`Vevian Wahba
`
`
`
`Plaintiff,
`
`v.
`
`American Traditions Insurance Company
`
`Defendant.
`
`__________________________________/
`
`
`
`
`
`
`REQUEST FOR ADMISSIONS
`
`Plaintiff, Vevian Wahba pursuant to Florida Rule of Civil Procedure 1.370, request the
`
`Defendant, American Traditions 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 (“Policy”) for the property
`
`located at 14016 Sierra Vista Dr, Orlando FL, 32837 (“Dwelling”).
`
`2.
`
`3.
`
`At all material times, Plaintiff had an insurable interest in the Dwelling.
`
`The Dwelling sustained direct physical damage caused by wind while the Policy
`
`was in full force and effect (the “loss”).
`
`4.
`
`Defendant was notified of the loss pursuant to the terms and conditions of the
`
`Policy.
`
`5.
`
`Plaintiff submitted an insurance claim to Defendant (the “claim”) pursuant to the
`
`terms and conditions of the Policy.
`
`6.
`
`Plaintiff did not cause prejudice to Defendant during its investigation of the claim.
`
`
`
`7.
`
`As of the date of this lawsuit, there were no outstanding requests by Defendant for
`
`documents or information in connection with its investigation and adjustment of the claim.
`
`8.
`
`9.
`
`Plaintiff complied with all duties after a loss pursuant to the Policy.
`
`The Policy provides coverage for any and all sudden and accidental physical
`
`damage to the Dwelling that is not otherwise excluded or excepted by the policy.
`
`10.
`
`11.
`
`The Policy provides coverage for “all risks” of loss to the Dwelling.
`
`The Policy provides benefits on a “Replacement Cost Value” basis for covered
`
`losses to the Dwelling subject to the Policy limits.
`
`12.
`
`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.
`
`13.
`
`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 actually repair or
`
`replace the damaged property.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[CONTINUED ON THE FOLLOWING PAGE]
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing has been
`
`electronically filed with the Florida Courts E-Filing Portal System this 4th day of May 2023 and
`
`copies furnished by initial Service of Process.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Cordova Law Firm, PLLC
`/s/ Alejandra Ares
`Alejandra Ares, Esq.
`Florida Bar No.: 1026134
`Cordova Law Firm, PLLC
`496 Delaney Avenue, Ste 508
`Orlando, FL 32801
`Phone: (321) 267-3682
`Fax: (407) 442-0654
`Primary Email:
`alejandra@justcallmyattorney.com
`Secondary Email:
`Shanna@justcallmyattorney.com
`Attorney for Plaintiffs
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
