Party Discovery: CITIBANK SOUTH DAKOTA NA vs BARCAN, ELLEN

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IN THE CIRCUIT COURT, CIVIL DIVISION, SARASOTA COUNTY, FLORIDA

CITIBANK (SOUTH DAKOTA), N.A.

Plaintiff CASE NO.: 2007CA7974SC
VS.
BLLEN BARCAN
Defendant /
REQUEST FOR ADMISSIONS TO DEFENDANT oO ns
“i
COMES NOW THE Plaintiff, by and through undersignédmcourige1 =
and pursuant to Fl. R. Civ. P. 1.370 requests that otemane (5
ry;
admit the following facts, and serve the answers at theSofsica, of

the undersigned attorney no later than 30 days from tBEdate of
the Certificate of Service below. Failure to to submit 3a anges
or objection addressed to the matter within 30 days fropghe mate
of the Certificate of Service below can result in admission.

1. Admit that Defendant(s) applied to Plaintiff for the
establishment of a credit card account.

2. Admit that Plaintiff established a credit card account for
Defendant(s).

3

3. Admit that Defendant (s) made purchases of goods and/or
services using the account established by Plaintiff.

4. Admit that the Defendant(s) failed to fully pay for said
purchases.

5. Admit that the Defendant(s) were given a copy of the
agreement relating to the use of the account.

6. Admit that the exhibits attached to the Complaint relating
to the financial records of the Plaintiff are true and correct.

7. Admit that Defendant(s) owe Plaintiff the amount sought in
Plaintiff's Complaint.

REQUEST FOR PRODUCTION OF DOCUMENTS

COMES NOW THE Plaintiff, by and through undersigned counsel,
and pursuant to Fl. R. Civ. P. 1.350 requests that Defendant(s)
admit the following facts, and serve the answers at the office of
the undersigned attorney no later than 30 days from the date of
the Certificate of Service below. Failure to to submit an answer
or objection addressed to the matter within 30 days from the date

of the Certificate of Service below can result in unanswered¥
Ss

requests for admissions being deemed admitted.

1. All correspondence sent from Defendant(s) to Plaintiff
Since the date of Defendant(s) last zero balance on the account.

2. All payments made by Defendant(s) to Plaintiff since the
date of Defendant(s) last zero balance on the account.

3. All sales receipts for purchases made by Defendant(s),
utilizing the open account established by Plaintiff since the date
of Defendant(s) last zero balance on the account.

4. All statements sent to Defendant(s) from Plaintiff since
the date of Defendant(s) last zero balance on the account.

5. Any and all documentation that Defendant(s) will rely on
in their defense to Plaintiff's claim.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the
foregoing was furnished to ELLEN BARCAN 321 PEDRO STREET VENICE
FL 34285-2325 by U.S. Mail Delivery on 07/27/07. This is a
communication from a debt collector.

PATRICK A. CAREY, P.A.

Patrick A. Carey, ESquire FBN 558184
Aaron Scicchitano, Esquire FBN 0598569
P.O. Box 574226

Orlando, Fl. 32857-4226

(407) 380-1333