Party Discovery: Gonzalez, Margarita Vs State Farm Mutual Automobile Insurance Company

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                                Filing # 143468857 E-Filed 02/08/2022 08:47:00 AM

IN THE COUNTY COURT, IN

THE TWENTIETH JUDICIAL CIRCUIT

IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL DIVISION

CASE NO: 11-2021-CC-002294-0001-XX

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY,
a/s/o MICHAEL AGNEW, and MICHAEL AGNEW individually
Plaintiff(s),

~vs-
MARGARITA GONZALEZ

Defendant(s).
/

PLAINTIFF’S REQUEST FOR ADMISSIONS

COMES NOW the Plaintiff, by and through the undersigned counsel, and directs this
Request for Admissions to the Defendant, MARGARITA GONZALEZ, who is requested to admit
the following in accordance with Rule 1.370 of the Florida Rules of Civil Procedure and Rule 7.020
of the Florida Rules of Summary Procedure, within thirty (30) days of the date of service hereof.

1. Do you admit that venue is proper in COLLIER County, Florida?

2. Do you admit that you were operating a motor vehicle that was involved in an
automobile accident on February 10, 2020 with a vehicle being operated by STATE
FARM MUTUAL AUTOMOBILE INSURANCE COMPANY’: insured, Michael
Agnew?

3. Do you admit that you were the driver of a 2006 Chevrolet that was involved in an
accident on February 10, 2020 with STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY’s insured Michael Agnew?

4. Do you admit that you had a duty to operate such vehicle in a safe, reasonable and
prudent fashion?

5. Do you admit that there were no visual obstructions that prevented you from
observing the Plaintiff's insured’s vehicle?

6. Do you admit that you could have observed Plaintiff's insured’s vehicle in time to
avoid the collision by the exercise of due care?

7. Do you admit that you failed to observe the Plaintiff's insured’s vehicle in time to
avoid the collision?

8. Do you admit that you breached the duty of the standard of care by driving in a
negligent manner?

9. Do you admit that your negligence was the sole proximate cause of the accident on
February 10, 2020?

10. Do you admit that at the time of the collision, the Plaintiff's insured, Michael Agnew,
was exercising due care in the operation of his/her motor vehicle?

11. Do you admit that as a result of the motor vehicle accident on February 10, 2020 the
Plaintiff's insured's vehicle sustained property damage?

12. Do you admit that STATE FARM MUTUAL AUTOMOBILE INSURANCE
COMPANY paid to Michael Agnew the sum of $8,755.24 under its liability

FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 02/08/2022 08:47:00 AMinsurance coverage for damages to Plaintiff's insured's motor vehicle as a direct result
of the aforementioned accident on February 10, 2020, and that the monies paid were
reasonable?

13. Do you admit that as a result of the motor vehicle accident on February 10, 2020, the
Plaintiff's insured, Michael Agnew, paid a deductible pursuant to the above policy in
the amount of $250.00?

14. Do you admit that as a result of the motor vehicle accident on February 10, 2020 the
Plaintiffs insured, Michael Agnew, sustained permanent injuries?

15. Do you admit that STATE FARM MUTUAL AUTOMOBILE INSURANCE
COMPANY paid to Michael Agnew the sum of $1,500.00 under its Uninsured and/or
Underinsured Motorist insurance coverage for the permanent injuries sustained as a
direct result of the motor vehicle accident on February 10, 2020, and that said
payments were reasonable?

16. Do you admit that as a result of the motor vehicle accident on February 10, 2020 the
Plaintiff's insured, Michael Agnew, sustained injuries?

17. Do you admit that STATE FARM MUTUAL AUTOMOBILE INSURANCE
COMPANY paid to Michael Agnew the sum of $4,711.12 under its Medical
Payments insurance coverage for the injuries sustained as a direct result of the motor
vehicle accident on February 10, 2020, and that said payments were reasonable?

18. Do you admit that this court has personal jurisdiction over you?

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished,
by U.S. Mail and/or by email, to Margarita Gonzalez at 3001 Tropicana Blvd Apt 8, Naples, FL
34116 this 8 day of February, 2022.

LOTANE & ASSOCIATES, P.A.

4s/Brady Johnson
BRADY JOHNSON, ESQUIRE

Florida Bar No: 1031673

1980 Michigan Avenue

Cocoa, Florida 32922

(321) 636-4861 / (800) 807-3334

Designated Service Email:
Service@Lotane.com

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