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  • SIERCKS, GERALD vs. CHANDLER, RAY CALVIN et al CA - Auto Negligence document preview
  • SIERCKS, GERALD vs. CHANDLER, RAY CALVIN et al CA - Auto Negligence document preview
						
                                

Preview

IN THE CIRCUIT COURT IN THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO.: 08-CA-12968-0 GERALD SIERCKS, Plaintiff, vs. RAY CALVIN CHANDLER, LINDA DIANN CHANDLER and ROBERT D. CHANDLER, Defendants. ___________________________/ REQUEST FOR ADMISSIONS Plaintiff, GERALD SIERCKS, by and through his undersigned attorney, under Fla. R. Civ. P. 1.370(a), request Defendant, USAA CASUALTY INSURANCE COMPANY, to make the following admissions in this action: 1. Plaintiff had in full force and effect with this Defendant a policy of uninsured/underinsured motorist coverage on the date of loss. 2. That the uninsured/underinsured motorist coverage available to the Plaintiff on the date of loss was stackable. 3. That the Plaintiff had available to him uninsured/underinsured motorist coverage from more than one policy of automobile liability insurance. 4. That the Plaintiff sustained a permanent injury as contemplated in Chapter 627, Florida Statutes, as a result of the automobile accident of November 4, 2006. 5. That the Plaintiff was wearing an available and operational seatbelt and shoulder harness at the time of the accident which is the subject matter of this claim. 6. That the Plaintiff was not negligent in the occurrence of the motor vehicle accident which is the subject matter of this claim. 7. That the Plaintiff was involved in an automobile accident on November 4, 2006 with an uninsured or underinsured motorist as contemplated in the policy of automobile liability insurance which included uninsured/underinsured motorist coverage with this Defendant. 8. That the Plaintiff was not negligent and did not cause the motor vehicle accident sued on in this matter. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served along with the complaint in this matter. STEVEN J. KIRSCHNER, P.A. Attorney for Plaintiff 1555 Howell Branch Road Suite C201 Winter Park, FL 32789 (407) 740-5225 By: /S/ STEVEN J. KIRSCHNER STEVEN J. KIRSCHNER Fla. Bar No. 472506