On January 13, 2021 a
Party Discovery
was filed
involving a dispute between
Perez, Olivia L,
Perez, Rodolfo,
and
Boaz Security Llc,
Brickhouse Lodge Inc,
for Circuit Civil 3-D
in the District Court of Marion County.
Preview
Filing # 125663721 E-Filed 04/27/2021 11:17:48 AM
IN THE CIRCUIT COURT FOR THE FIFTH JUDICIAL CIRCUIT,
IN AND FOR MARION COUNTY, FLORIDA
RODOLFO PEREZ and CASE NO.: 2021-CA-75
OLIVIA LOPEZ PEREZ, husband and wife,
Plaintiffs,
v.
BRICKHOUSE LODGE, INC.,
A Florida For Profit Corporation,
Defendant.
/
PLAINTIFFS’ RESPONSE TO DEFENDANT’S REQUST FOR ADMISSIONS
The Plaintiffs, RODOLFO PEREZ and OLIVIA LOPEZ PEREZ, by and through their
undersigned counsel, hereby file their response to the Defendant, BRICKHOUSE LODGE,
INC.’s Request for Admissions served under certificate date March 30, 2021 as follows:
1. Denied.
2. Denied.
3. Denied.
4. Denied.
5. Denied.
6. Denied.
7. Denied.
8. Denied.
9. Denied.
Electronically Filed Marion Case # 21CA000075AX 04/27/2021 11:17:48 AM10. Denied.
ll. Denied.
12. Admit.
13. Admit.
14. Denied.
15. Denied.
16. Denied.
17. Plaintiffs object to paragraph 17 as it is not reasonably calculated to lead to the
discovery of admissible evidence in this case.
18. Denied.
19. Admit.
20. Denied.
21. Admit.
21.4sic) Denied.
24, Denied.
25. Admit.
26. Denied.
27. Denied.
I HEREBY CERTIFY that a copy hereof has been furnished by email/e-service to Ailin
C. Caballero, Esquire at acaballero@callahanfusco.com and eserve@callahanfusco.com and
Gabriel A. Costa, Esquire at gcosta@callahanfusco.com, on this a 1 ty day of April, 2021.BLANCHARD, MERRIAM
ADEL, KIRKLAND & Gi! P.A.
By:
ED ~GREEN, III, ESQUIRE
Florid: 0.: 0606111
Post Office Box 1869
Ocala, Florida 34478
Telephone: (352) 732-7218
Attorneys for Plaintiffs
tgreen@bmaklaw.com
Icaldwell@bmaklaw.com
Document Filed Date
April 27, 2021
Case Filing Date
January 13, 2021
Category
Circuit Civil 3-D
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Filing # 125663721 E-Filed 04/27/2021 11:17:48 AM IN THE CIRCUIT COURT FOR THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA RODOLFO PEREZ and CASE NO.: 2021-CA-75 OLIVIA LOPEZ PEREZ, husband and wife, Plaintiffs, v. BRICKHOUSE LODGE, INC., A Florida For Profit Corporation, Defendant. / PLAINTIFFS’ RESPONSE TO DEFENDANT’S REQUST FOR ADMISSIONS The Plaintiffs, RODOLFO PEREZ and OLIVIA LOPEZ PEREZ, by and through their undersigned counsel, hereby file their response to the Defendant, BRICKHOUSE LODGE, INC.’s Request for Admissions served under certificate date March 30, 2021 as follows: 1. Denied. 2. Denied. 3. Denied. 4. Denied. 5. Denied. 6. Denied. 7. Denied. 8. Denied. 9. Denied. Electronically Filed Marion Case # 21CA000075AX 04/27/2021 11:17:48 AM10. Denied. ll. Denied. 12. Admit. 13. Admit. 14. Denied. 15. Denied. 16. Denied. 17. Plaintiffs object to paragraph 17 as it is not reasonably calculated to lead to the discovery of admissible evidence in this case. 18. Denied. 19. Admit. 20. Denied. 21. Admit. 21.4sic) Denied. 24, Denied. 25. Admit. 26. Denied. 27. Denied. I HEREBY CERTIFY that a copy hereof has been furnished by email/e-service to Ailin C. Caballero, Esquire at acaballero@callahanfusco.com and eserve@callahanfusco.com and Gabriel A. Costa, Esquire at gcosta@callahanfusco.com, on this a 1 ty day of April, 2021.BLANCHARD, MERRIAM ADEL, KIRKLAND & Gi! P.A. By: ED ~GREEN, III, ESQUIRE Florid: 0.: 0606111 Post Office Box 1869 Ocala, Florida 34478 Telephone: (352) 732-7218 Attorneys for Plaintiffs tgreen@bmaklaw.com Icaldwell@bmaklaw.com