Contract analysis

I. DEFINITIONS As used in this First Request for Admissions, the following terms shall have the meanings set forth below, unless otherwise indicated: A. "Policy" means the all-risk property and business-interruption insurance policy issued by Ironclad to VHG, bearing Policy Number IIC-PRP-2022-07541, with a policy period of July 1, 2022 through July 1, 2023, together with all endorsements, schedules, declarations pag

II. INSTRUCTIONS The following instructions apply to each Request for Admission contained herein:

1. Each Request for Admission shall be answered separately and fully in writing under oath, in accordance with Florida Rule of Civil Procedure 1.370.

2. If any admission cannot be made as to the entirety of a request, admit so much of the request as is true and qualify or deny the remainder. If an admission is qualified, the responding party shall set forth in detail the reasons for the qualification and shall specifically identify the portion of the request that is admitted and the portion that is denied or qualified.

3. When good faith requires that a party qualify an answer or deny only a part of the matter of which an admission is requested, the responding party shall specify so much of it as is true and qualify or deny the remainder.

4. If a response claims lack of sufficient information or knowledge to admit or deny, the response must state that the responding party has made reasonable inquiry and that the information known or readily obtainable by the responding party is insufficient to enable the responding party to admit or deny the matter. A responding party may not give lack of information or knowledge as a reason for failure to admit or de

5. Objections must state the specific grounds therefor with particularity. General or boilerplate objections are insufficient and will not be deemed proper under Florida Rule of Civil Procedure 1.370. An objection to any part of a request shall not excuse the obligation to admit or deny the remainder of the request to which no objection is made.

6. The use of the singular form of any word shall include the plural, and vice versa. The use of any gender shall include all genders. The connective "and" shall be construed as either disjunctive or conjunctive as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside its scope. Similarly, the connective "or" shall be construed as either disjunctive or conjun

7. Each request is continuing in nature, and Ironclad is required to supplement its responses should it obtain additional information affecting the truth or accuracy of any response previously served.

III. REQUESTS FOR ADMISSION A. The Policy and Its Issuance REQUEST FOR ADMISSION NO. 1: Admit that Ironclad Indemnity Corporation is a stock insurance company organized and existing under the laws of the State of Connecticut, domiciled in the State of Connecticut, with its principal office located at 55 Constitution Boulevard, Hartford, CT 06103. REQUEST FOR ADMISSION NO. 2: Admit that Ironclad issued to VHG the all-

I. Ironclad's Claims Handling REQUEST FOR ADMISSION NO. 58: Admit that Ironclad retained Arbor Claims Services LLC, an independent adjusting firm with its principal office at 3300 W. Cypress Street, Suite 400, Tampa, FL 33607, to adjust, investigate, and evaluate VHG's Hurricane Callista claim on Ironclad's behalf. REQUEST FOR ADMISSION NO. 59: Admit that Ironclad communicated with Pinnacle Surplus Lines Inc., the fi