On September 23, 2022 a
REQUEST FOR ADMISSIONS
was filed
involving a dispute between
Peters, Barbara,
and
Geico General Insurance Compan,
Lazenby, Gail John,
for Circuit Civil 3-D
in the District Court of Marion County.
Preview
Filing # 158026726 E-Filed 09/23/2022 12:13:54 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT,
IN AND FOR MARION COUNTY, FLORIDA
CASE NO:
BARBARA PETERS,
Plaintiff,
vs.
GAIL JOHN LAZENBY and
GEICO GENERAL
INSURANCE COMPANY,
Defendants.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT.
GEICO GENERAL INSURANCE COMPANY
COMES NOW the Plaintiff, BARBARA PETERS, by and through the undersigned
counsel and pursuant to Rule 1.370, Florida Rules Of Civil Procedure, hereby request(s) that
Defendant, GEICO GENERAL INSURANCE COMPANY, admit the following within forty-
five (45) days from the date of service hereof:
1. Please admit that this action brought against the Defendant GEICO GENERAL
INSURANCE COMPANY properly and correctly names the Defendant to be sued in this
cause.
2. Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought before
the Circuit Court in Marion County, Florida.
3. Please admit that the service of process against the Defendant GEICO GENERAL
INSURANCE COMPANY was proper.
4. Please admit that this is an action for damages in excess of Thirty Thousand Dollars
($30,000.00) arising in Marion County, Florida.
5. Please admit that Gail John Lazenby was negligent in the operation of a motor vehicle
which resulted in the subject collision with Plaintiff's vehicle.
Electronically Filed Marion Case # 22CA001988AX, 09/23/2022 12:13:54 PM10.
11.
Please admit that Gail John Lazenby was an underinsured motorist.
Please admit that Plaintiff was injured in the subject crash.
Please admit that Plaintiff suffered a permanent injury within a reasonable degree of medical
probability resulting from the subject crash.
Please admit that Plaintiff was not guilty of negligence which caused or contributed to the
subject crash.
Please admit that Plaintiff incurred medical expenses for treatment of injuries resulting from
the subject crash.
Please admit that Plaintiffs medical expenses were reasonable and necessary for the care
and treatment of the injuries sustained in the subject crash.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
said
Defendant along with the Summons and Complaint.
/S/ JONATHAN THOMSON’
Jonathan Thomson, ESQ.
FBN 076270
Morgan & Morgan, P.A.
20 N. Orange Avenue
Suite 1600
Orlando, FL 32801
Telephone: (407) 420-1414
Facsimile: (407) 204-2247
Primary email: jonathant@forthepeople.com
Secondary email:
heathermorgan@forthepeople.com;
qthomas@forthepeople.com
Attorneys for Plaintiff
we
Document Filed Date
September 23, 2022
Case Filing Date
September 23, 2022
Category
Circuit Civil 3-D
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Preview
Filing # 158026726 E-Filed 09/23/2022 12:13:54 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA CASE NO: BARBARA PETERS, Plaintiff, vs. GAIL JOHN LAZENBY and GEICO GENERAL INSURANCE COMPANY, Defendants. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT. GEICO GENERAL INSURANCE COMPANY COMES NOW the Plaintiff, BARBARA PETERS, by and through the undersigned counsel and pursuant to Rule 1.370, Florida Rules Of Civil Procedure, hereby request(s) that Defendant, GEICO GENERAL INSURANCE COMPANY, admit the following within forty- five (45) days from the date of service hereof: 1. Please admit that this action brought against the Defendant GEICO GENERAL INSURANCE COMPANY properly and correctly names the Defendant to be sued in this cause. 2. Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought before the Circuit Court in Marion County, Florida. 3. Please admit that the service of process against the Defendant GEICO GENERAL INSURANCE COMPANY was proper. 4. Please admit that this is an action for damages in excess of Thirty Thousand Dollars ($30,000.00) arising in Marion County, Florida. 5. Please admit that Gail John Lazenby was negligent in the operation of a motor vehicle which resulted in the subject collision with Plaintiff's vehicle. Electronically Filed Marion Case # 22CA001988AX, 09/23/2022 12:13:54 PM10. 11. Please admit that Gail John Lazenby was an underinsured motorist. Please admit that Plaintiff was injured in the subject crash. Please admit that Plaintiff suffered a permanent injury within a reasonable degree of medical probability resulting from the subject crash. Please admit that Plaintiff was not guilty of negligence which caused or contributed to the subject crash. Please admit that Plaintiff incurred medical expenses for treatment of injuries resulting from the subject crash. Please admit that Plaintiffs medical expenses were reasonable and necessary for the care and treatment of the injuries sustained in the subject crash. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon said Defendant along with the Summons and Complaint. /S/ JONATHAN THOMSON’ Jonathan Thomson, ESQ. FBN 076270 Morgan & Morgan, P.A. 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 Telephone: (407) 420-1414 Facsimile: (407) 204-2247 Primary email: jonathant@forthepeople.com Secondary email: heathermorgan@forthepeople.com; qthomas@forthepeople.com Attorneys for Plaintiff we