On May 07, 2019 a
Party Discovery
was filed
involving a dispute between
Td Auto Finance Llc,
and
Soto, Merli O Valle,
for Contract and Indebtedness
in the District Court of Collier County.
Preview
Filing # 90754763 E-Filed 06/07/2019 01:09:25 PM
IN THE CIRCUIT COURT IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL DIVISION
TD.AUTO FINANCE; LLC,
Plaintiff,
vs. CASE NO,:. 11-2019-CA-001850
MERLI O VALLE SOTO,
Defendant.
REC UEST:-FOR! ADMISSIONS
TO: Merli-O'Valle Soto
7025 Sierra Club Circle
‘Apt. 6204
Naples, FL.34113
INSTRUCTIONS
The Requests for Admissions, as\separatély set forth below piirsuant-with Florida Rule
of Civil Procedure 1.370, shall be admitted unless, within.thirty (30) days after service,
the sworn written ariswér or objection:addréssed to the Requests is served, upon,
counsel for Plaintiff and:filed with the Clerk‘of Court. Answers shall:specifically deny
the Request or set forth in detail ‘the réasons;why the Request cannot truthfully be-
admitted’ or denied, A denial shall fairly meet the substance:of the Request, and when:
.good faith, Tequires that a party qualify its answer or: deny. only apart of the Request,
so much oftit:as is true shall-be specified, and the remainder:shall be qualified or
denied. Lack of information or knowledge shall not be given as-a reason for failure to
admit or. deny. unless.a reasonable inquiry:that the information known to:or‘réadily
obtainable-is insufficient to. enable an admission or-denial. It if is believed that:a
‘Request presents a genuine issue for trial, the Request.may not, on that: ground alone,
be objected to; the Request may either be denied, or, the reasons why the Request
cannot be:admitted or denied’ set forth.
Plaintiff propounds the following Request for Adriissions pursuant to’ Rule.
1.370;.Florida Rules of Civil Procedure, and.requests that'the Defendant, admit:within.
the time provided by the Rule, the truth of the facts set forth as follows:
1. ‘Lam authorized to make these.admissions.
2. I did sign the contract attached to Plaintiff’s:complaint:.
3. Idid not make’payments asiagreed to in the contract attached to
Plaintiff's: complaint.
4. The vehicle:and/or collateral referred to in'the contract: attached
to Plaintiffs complaint was repossessed by. the Plaintiff.
#44217
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 06/07/2019 01:09:25 PM5. The vehicle and/or collateral referred to in the contract attached
to Plaintiff's complaint was returned to the Plaintiff.
6. __ Plaintiff: did'send me a Notice telling me they were going to sell the
vehicle‘and/or collateral if I did not pay them the’ balance owed.
7 I was unable to make the payments pursuant to the contract
attached to Plaintiff's complaint.
8. I did not attend or object to the sale of the vehicle and/or
collateral referred to in the contract attached to Plaintiff’s
complaint.
9. The vehicle and/or collateral was sold by the Plaintiff at a private
or public sale and a fair value for the collateral was obtained.
10. Ido admit owing some monies to the Plaintiff.
11. T-admit owing the full balance to the Plaintiff as is alleged in the
complaint.
12. I do not have any defenses. to this action.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that'a true and correct.copy of the foregoing has been
forwarded this June 06, 2019, to: Merli O Valle Soto, 7025: Sierra Club Circle, Apt.
6204, Naples, FL 34113.
(94 faa, O8
THOMAS L. AVRUTIS, ESQUIRE
Florida Bar #0369365
SCOTT D. FOELLER, ESQUIRE
Florida Bar #0002143
Email Service: PEEADINGS@HODGESAVRUTIS.COM
#44217
Case Filing Date
May 07, 2019
Category
Contract and Indebtedness
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Preview
Filing # 90754763 E-Filed 06/07/2019 01:09:25 PM IN THE CIRCUIT COURT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL DIVISION TD.AUTO FINANCE; LLC, Plaintiff, vs. CASE NO,:. 11-2019-CA-001850 MERLI O VALLE SOTO, Defendant. REC UEST:-FOR! ADMISSIONS TO: Merli-O'Valle Soto 7025 Sierra Club Circle ‘Apt. 6204 Naples, FL.34113 INSTRUCTIONS The Requests for Admissions, as\separatély set forth below piirsuant-with Florida Rule of Civil Procedure 1.370, shall be admitted unless, within.thirty (30) days after service, the sworn written ariswér or objection:addréssed to the Requests is served, upon, counsel for Plaintiff and:filed with the Clerk‘of Court. Answers shall:specifically deny the Request or set forth in detail ‘the réasons;why the Request cannot truthfully be- admitted’ or denied, A denial shall fairly meet the substance:of the Request, and when: .good faith, Tequires that a party qualify its answer or: deny. only apart of the Request, so much oftit:as is true shall-be specified, and the remainder:shall be qualified or denied. Lack of information or knowledge shall not be given as-a reason for failure to admit or. deny. unless.a reasonable inquiry:that the information known to:or‘réadily obtainable-is insufficient to. enable an admission or-denial. It if is believed that:a ‘Request presents a genuine issue for trial, the Request.may not, on that: ground alone, be objected to; the Request may either be denied, or, the reasons why the Request cannot be:admitted or denied’ set forth. Plaintiff propounds the following Request for Adriissions pursuant to’ Rule. 1.370;.Florida Rules of Civil Procedure, and.requests that'the Defendant, admit:within. the time provided by the Rule, the truth of the facts set forth as follows: 1. ‘Lam authorized to make these.admissions. 2. I did sign the contract attached to Plaintiff’s:complaint:. 3. Idid not make’payments asiagreed to in the contract attached to Plaintiff's: complaint. 4. The vehicle:and/or collateral referred to in'the contract: attached to Plaintiffs complaint was repossessed by. the Plaintiff. #44217 FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 06/07/2019 01:09:25 PM5. The vehicle and/or collateral referred to in the contract attached to Plaintiff's complaint was returned to the Plaintiff. 6. __ Plaintiff: did'send me a Notice telling me they were going to sell the vehicle‘and/or collateral if I did not pay them the’ balance owed. 7 I was unable to make the payments pursuant to the contract attached to Plaintiff's complaint. 8. I did not attend or object to the sale of the vehicle and/or collateral referred to in the contract attached to Plaintiff’s complaint. 9. The vehicle and/or collateral was sold by the Plaintiff at a private or public sale and a fair value for the collateral was obtained. 10. Ido admit owing some monies to the Plaintiff. 11. T-admit owing the full balance to the Plaintiff as is alleged in the complaint. 12. I do not have any defenses. to this action. CERTIFICATE OF SERVICE I HEREBY CERTIFY that'a true and correct.copy of the foregoing has been forwarded this June 06, 2019, to: Merli O Valle Soto, 7025: Sierra Club Circle, Apt. 6204, Naples, FL 34113. (94 faa, O8 THOMAS L. AVRUTIS, ESQUIRE Florida Bar #0369365 SCOTT D. FOELLER, ESQUIRE Florida Bar #0002143 Email Service: PEEADINGS@HODGESAVRUTIS.COM #44217