On September 24, 2021 a
Party Discovery
was filed
involving a dispute between
Mobile Auto Glass Repair Llc,
Patton, Mary,
and
Farmers Casualty Insurance Company, A Foreign Corporation,
for Civil
in the District Court of Hillsborough County.
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Filing # 135998502 E-Filed 10/06/2021 10:07:38 AM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
SMALL CLAIMS DIVISION
MOBILE AUTO GLASS REPAIR LLC,
a/a/o Mary Patton
Plaintiff,
CASE NO.: 21-CC-098843
v.
DIVISION: J
FARMERS CASUALTY INSURANCE
COMPANY, a foreign corporation
Defendant.
____________________________________/
PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW, the Plaintiff by and through undersigned counsel, and hereby requests
the Defendant, admit that the following statements are true:
1. Please admit the Defendant's name as it appears on the complaint/statement of claim is
accurate.
2. Please admit the Plaintiff is a competent auto glass repair facility shop.
3. Please admit Plaintiff is conveniently located to the insured and/or the situs of the
accident.
4. Please admit the Plaintiff charged the "Prevailing Competitive Price."
5. Please admit the invoice amount charged by the Plaintiff is a price that the Defendant
can secure.
6. Please admit that the Defendant failed to pay the invoice price submitted by the
Plaintiff in full.
7. Please admit that the Defendant could have secured the same price that the insured
secured for the glass replacement services at issue in this case.
10/6/2021 10:07 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
8. Defendant did not secure a quote from any other repair facility when the claim was
reported to Defendant.
9. Defendant did not possess any estimate from any other repair facility when it
determined the prevailing competitive price to pay the Plaintiff.
10. At the time of the loss in the instant action, the Defendant already knew the price it
would limit reimbursement for the glass replacement services provided.
11. Defendant did not determine the "Prevailing Competitive Price" on the date of the
damage to the insured's vehicle.
CERTIFICATE OF SERVICE
I CERTIFY a true and correct copy of the above document was served on the Defendant
with the service of the complaint.
Respectfully submitted by,
s/ James R. Collins
JAMES R. COLLINS, ESQUIRE
Florida Bar #: 507431
Philip A. Friedman, Esquire
Florida Bar #: 0635243
FL Legal Group
2700 W. MLK Jr. Blvd., Suite 400
Tampa, FL 33607
Phone: (813) 221-9500
Primary E-mail: JRCollins@FLLegalGroup.com
Secondary E-mail: filings@FLLegalGroup.com
Attorneys for Plaintiff
Page 2 of 2
10/6/2021 10:07 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Document Filed Date
October 06, 2021
Case Filing Date
September 24, 2021
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Filing # 135998502 E-Filed 10/06/2021 10:07:38 AM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SMALL CLAIMS DIVISION MOBILE AUTO GLASS REPAIR LLC, a/a/o Mary Patton Plaintiff, CASE NO.: 21-CC-098843 v. DIVISION: J FARMERS CASUALTY INSURANCE COMPANY, a foreign corporation Defendant. ____________________________________/ PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW, the Plaintiff by and through undersigned counsel, and hereby requests the Defendant, admit that the following statements are true: 1. Please admit the Defendant's name as it appears on the complaint/statement of claim is accurate. 2. Please admit the Plaintiff is a competent auto glass repair facility shop. 3. Please admit Plaintiff is conveniently located to the insured and/or the situs of the accident. 4. Please admit the Plaintiff charged the "Prevailing Competitive Price." 5. Please admit the invoice amount charged by the Plaintiff is a price that the Defendant can secure. 6. Please admit that the Defendant failed to pay the invoice price submitted by the Plaintiff in full. 7. Please admit that the Defendant could have secured the same price that the insured secured for the glass replacement services at issue in this case. 10/6/2021 10:07 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 8. Defendant did not secure a quote from any other repair facility when the claim was reported to Defendant. 9. Defendant did not possess any estimate from any other repair facility when it determined the prevailing competitive price to pay the Plaintiff. 10. At the time of the loss in the instant action, the Defendant already knew the price it would limit reimbursement for the glass replacement services provided. 11. Defendant did not determine the "Prevailing Competitive Price" on the date of the damage to the insured's vehicle. CERTIFICATE OF SERVICE I CERTIFY a true and correct copy of the above document was served on the Defendant with the service of the complaint. Respectfully submitted by, s/ James R. Collins JAMES R. COLLINS, ESQUIRE Florida Bar #: 507431 Philip A. Friedman, Esquire Florida Bar #: 0635243 FL Legal Group 2700 W. MLK Jr. Blvd., Suite 400 Tampa, FL 33607 Phone: (813) 221-9500 Primary E-mail: JRCollins@FLLegalGroup.com Secondary E-mail: filings@FLLegalGroup.com Attorneys for Plaintiff Page 2 of 2 10/6/2021 10:07 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2