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Filing # 129545189 E-Filed 06/25/2021 03:53:56 PM
IN THE CIRCUIT COURT OF THE 19" JUDICIAL CIRCUIT
IN AND FOR ST. LUCIE COUNTY, FLORIDA
MELVIN T. FORBRECHT, JR and FIRE CASENO.: 2021-CA-0722
DESIGN BY MEL f/k/a FIRE EQUIPMENT Judge Elizabeth Metzger
SERVICES OF ST. LUCIE INC.,
Plaintiffs,
Vv.
FIRE EQUIPMENT SERVICES OF
FLORIDA, INC., and CAROL EGERS,
Defendants.
/
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICAL CIRCUIT
IN AND FOR ST. LUCIE COUNTY, FLORIDA
MELVIN T. FOLBRECHT, JR., and FIRE CASE NO. 2021-CA-0722
DESIGN BY MEL, f/k/a FIRE EQUIPMENT
SERVICES OF ST. LUCIE, INC.
Plaintiffs,
Vv.
FIRE EQUIPMENT SERVICES OF FLORIDA,
INC., and CAROL EGERS
Defendants.
/
DEFENDANT CAROL EGERS’ RESPONSE TO PLAINTIFF'S
REQUEST FOR ADMISSIONS
COMES NOW the Defendant, CAROL EGERS, by and through undersigned counsel,
and responds to Plaintiff, MELVIN T. FOLBRECHT, JR‘s, Request for Admissions propounded
to Defendant on April 19, 2021 as follows:
1. During calendar year 2019, you demanded a sum of $535,000 for your interest in FESFL.
ANSWER: Denied.
. You asserted that $535,000 was the fair market value of your interest in FES FL.
ANSWER: Denied.
. That throughout all the years of losses of FES FL, CAROL EGERS has taken any and
all available cash flow for salary, licensure and similar.
ANSWER: Denied
. Attached as Exhibit “A” is a true and correct copy of demand of MELVIN T.
FOLBRECHT, JR., for corporate inspection and copies.
ANSWER: Denied, no Exhibit “A” attached.
. MELVIN T. FOLBRECHT, JR., appeared with his counsel at the offices of FES FL on
March 23, 2021 at 9 o’clock a.m., set forth in Exhibit “A”.
ANSWER: Denied. Plaintiff and Counsel did appear, but no Exhibit “A” is
attached.
. CAROL EGERS failed and refused to allow inspection and copying on the basis that she
had a conflict in schedule.
ANSWER: Denied.
. In fact, CAROL EGERS did not leave the office within a half hour or otherwise but
temained at the office on March 23, 2021 after she had represented that she had a conflict
in her schedule.
ANSWER: Denied.
. CAROL EGERS on March 23, 2021 agreed to a corporate inspection to take place at the
corporate offices on April 1, 2021.ANSWER: Admitted.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Notice of
Appearance and Designation of Email Address has been furnished via the Florida Courts E-
Filing Portal to Robert J. Gorman & Associates, P.A., Robert J. Gorman, Esquire, attorney for
Plaintiff, at bob@rigpa.com: coni@rigpa.com and courtdocs@rjpa.com on this 25" day of June
2021.
/s/ Shaun T. Plymale, Esq.
Shaun T. Plymale, Esq.
Florida Bar No.: 0247390
Gerald F. Herrmann
Florida Bar No.: 368768
SPlymale@TreasureCoastlegal.com
GHerrmann@treasurecoastlegal.com
EWatson@TreasureCoastLegal.com
Litigation@TreasureCoastLegal.com
Attorneys for Defendant
Treasure Coast Legal
100 SW Albany Avenue, Suite 310
Stuart, FL 34994
(772) 283-2626 telephone
(772) 283-6262 facsimile
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Filing # 129545189 E-Filed 06/25/2021 03:53:56 PM IN THE CIRCUIT COURT OF THE 19" JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA MELVIN T. FORBRECHT, JR and FIRE CASENO.: 2021-CA-0722 DESIGN BY MEL f/k/a FIRE EQUIPMENT Judge Elizabeth Metzger SERVICES OF ST. LUCIE INC., Plaintiffs, Vv. FIRE EQUIPMENT SERVICES OF FLORIDA, INC., and CAROL EGERS, Defendants. / IN THE CIRCUIT COURT OF THE NINETEENTH JUDICAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA MELVIN T. FOLBRECHT, JR., and FIRE CASE NO. 2021-CA-0722 DESIGN BY MEL, f/k/a FIRE EQUIPMENT SERVICES OF ST. LUCIE, INC. Plaintiffs, Vv. FIRE EQUIPMENT SERVICES OF FLORIDA, INC., and CAROL EGERS Defendants. / DEFENDANT CAROL EGERS’ RESPONSE TO PLAINTIFF'S REQUEST FOR ADMISSIONS COMES NOW the Defendant, CAROL EGERS, by and through undersigned counsel, and responds to Plaintiff, MELVIN T. FOLBRECHT, JR‘s, Request for Admissions propounded to Defendant on April 19, 2021 as follows: 1. During calendar year 2019, you demanded a sum of $535,000 for your interest in FESFL. ANSWER: Denied. . You asserted that $535,000 was the fair market value of your interest in FES FL. ANSWER: Denied. . That throughout all the years of losses of FES FL, CAROL EGERS has taken any and all available cash flow for salary, licensure and similar. ANSWER: Denied . Attached as Exhibit “A” is a true and correct copy of demand of MELVIN T. FOLBRECHT, JR., for corporate inspection and copies. ANSWER: Denied, no Exhibit “A” attached. . MELVIN T. FOLBRECHT, JR., appeared with his counsel at the offices of FES FL on March 23, 2021 at 9 o’clock a.m., set forth in Exhibit “A”. ANSWER: Denied. Plaintiff and Counsel did appear, but no Exhibit “A” is attached. . CAROL EGERS failed and refused to allow inspection and copying on the basis that she had a conflict in schedule. ANSWER: Denied. . In fact, CAROL EGERS did not leave the office within a half hour or otherwise but temained at the office on March 23, 2021 after she had represented that she had a conflict in her schedule. ANSWER: Denied. . CAROL EGERS on March 23, 2021 agreed to a corporate inspection to take place at the corporate offices on April 1, 2021.ANSWER: Admitted. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Notice of Appearance and Designation of Email Address has been furnished via the Florida Courts E- Filing Portal to Robert J. Gorman & Associates, P.A., Robert J. Gorman, Esquire, attorney for Plaintiff, at bob@rigpa.com: coni@rigpa.com and courtdocs@rjpa.com on this 25" day of June 2021. /s/ Shaun T. Plymale, Esq. Shaun T. Plymale, Esq. Florida Bar No.: 0247390 Gerald F. Herrmann Florida Bar No.: 368768 SPlymale@TreasureCoastlegal.com GHerrmann@treasurecoastlegal.com EWatson@TreasureCoastLegal.com Litigation@TreasureCoastLegal.com Attorneys for Defendant Treasure Coast Legal 100 SW Albany Avenue, Suite 310 Stuart, FL 34994 (772) 283-2626 telephone (772) 283-6262 facsimile