ORLANDO — An insurance company has filed a complaint for declaratory relief after a man was shot by a member of Tactic Security Enforcement's security team at a local bar and grill.
Mt. Hawley Insurance Co.filed a complaint on Aug. 9 in U.S. District Court for the Middle District of Florida, Orlando Division, against the defendants alleging that they made no amendment to its existing policy to include the organization it is operating with.
According to the complaint, the plaintiff alleges that they issued a commercial general liability policy for Tactic Security Enforcement Inc. for its restaurant operations. However, the plaintiff claims the defendants were involved in a shooting incident on Aug. 5, 2015, that took place in Que Rico nightclub, a bar owned by Adsan Properties Inc., whose security services were provided by Tactic Security Enforcement Inc. Both defendants were sued by Carlos Rodriguez for allegedly shooting him during said incident.
The plaintiff seeks a complaint for declaratory relief regarding Tactic Security Enforcement Inc., Adsan Properties Inc. and Carlos Rodriguez because the defendants allegedly availed of a commercial general liability insurance policy that excluded coverage for bars, lounges and nightclubs, and the policy was not amended to include Adsan as an additional insured in Tactic's policy.
The plaintiff seeks for the court to take jurisdiction and adjudicate the rights of the parties, find that plaintiff has no obligation to defend or indemnify the defendants, find that Adsan does not qualify as an additional insured and award all costs incurred, as well as any other relief that it deems just and proper. The plaintiff is represented by Sina Bahadoran and John J. Cavo of Hinshaw & Culbertson LLP in Miami.
U.S. District Court for the Middle District of Florida, Orlando Division, case number 6:16-cv-01425