On March 21, 2023 a
Party Discovery
was filed
involving a dispute between
Gray, Ursula,
and
Alsharif, Fadi,
Insurance Company, Progressiv,
for Circuit Civil 3-C
in the District Court of Wakulla County.
Preview
Filing # 172577128 E-Filed 05/05/2023 06:45:12 PM
IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT,
IN AND FOR WAKULLA COUNTY, FLORIDA
CASE NO: 23000127CAAXMX
URSULA GRAY,
Plaintiff,
vs.
FADI ALSHARIF, AND
PROGRESSIVE INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT,
PROGRESSIVE INSURANCE COMPANY
Plaintiff, URSULA GRAY, by and through undersigned counsel, and pursuant to Rule
1.370, Florida Rules of Civil Procedure, hereby requests that Defendant, PROGRESSIVE
INSURANCE COMPANY, admit the following within forty-five (45) days from the date of service
hereof:
1 Please admit that this action properly and correctly names the parties to be sued in this
cause,
2. Please admit that at all times material to the Complaint, Defendant, PROGRESSIVE
INSURANCE COMPANY, was and is a corporation licensed to do business in the State of Florida
and engaged in the business of automobile insurance.
3 Please admit that jurisdiction for this action is properly brought before the Circuit
Court in Wakulla County, Florida.
4 Please admit that Defendant insured Plaintiff under an automobile insurance policy
which provides Uninsured/Underinsured Motorist Protection benefits for the subject accident.
13724. i
Rkesteqniqally Filed Wakulla Case # 23000127CAAXMX 05/05/2023 06:45:12 PM
5 Please admit that the above-described automobile policy which Defendant issued was
in full force and effect on 01/18/2023, and provides coverage for Uninsured/Underinsured Motorist
Protection benefits for the personal injuries Plaintiff sustained in the subject accident.
6. Please admit that Defendant failed to pay Plaintiff's Uninsured/Underinsured Motorist
Protection claim without “reasonable proof to establish” that Defendant was not responsible for the
payment.
7 Please admit that pursuant to Plaintiff's policy with Defendant, PROGRESSIVE
INSURANCE COMPANY, is required to conform to all requirements of Sections 627.727, Florida
Statutes.
8 Please admit that Plaintiff's policy with Defendant, even if it does not by its own terms
comply with the requirements set forth in Sections 627.727 Florida Statutes, is deemed to provide
insurance for the payment of the required benefits and should be interpreted to meet the other
requirements set forth in the Florida Statutes.
9 Please admit that the Plaintiff was not negligent in any way which contributed to
the motor vehicle crash which is the subject of Plaintiff's Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the above-named Defendant, along with the summons and complaint.
/s/ Kelsey Saalmann
Kelsey Saalmann, Esquire
Florida Bar No: 1038962
Morgan & Morgan, P.A.
501 Riverside Ave., Suite 1200
Jacksonville, Florida 32202
Telephone: (904) 944-8347
Primary email: ksaalmann@forthepeople.com
Secondary email: Morganservice@forthepeople.com
Attorneys for Plaintiff
13724426
RFACOO1
Document Filed Date
May 05, 2023
Case Filing Date
March 21, 2023
Category
Circuit Civil 3-C
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Filing # 172577128 E-Filed 05/05/2023 06:45:12 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT, IN AND FOR WAKULLA COUNTY, FLORIDA CASE NO: 23000127CAAXMX URSULA GRAY, Plaintiff, vs. FADI ALSHARIF, AND PROGRESSIVE INSURANCE COMPANY, Defendant. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, PROGRESSIVE INSURANCE COMPANY Plaintiff, URSULA GRAY, by and through undersigned counsel, and pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant, PROGRESSIVE INSURANCE COMPANY, admit the following within forty-five (45) days from the date of service hereof: 1 Please admit that this action properly and correctly names the parties to be sued in this cause, 2. Please admit that at all times material to the Complaint, Defendant, PROGRESSIVE INSURANCE COMPANY, was and is a corporation licensed to do business in the State of Florida and engaged in the business of automobile insurance. 3 Please admit that jurisdiction for this action is properly brought before the Circuit Court in Wakulla County, Florida. 4 Please admit that Defendant insured Plaintiff under an automobile insurance policy which provides Uninsured/Underinsured Motorist Protection benefits for the subject accident. 13724. i Rkesteqniqally Filed Wakulla Case # 23000127CAAXMX 05/05/2023 06:45:12 PM 5 Please admit that the above-described automobile policy which Defendant issued was in full force and effect on 01/18/2023, and provides coverage for Uninsured/Underinsured Motorist Protection benefits for the personal injuries Plaintiff sustained in the subject accident. 6. Please admit that Defendant failed to pay Plaintiff's Uninsured/Underinsured Motorist Protection claim without “reasonable proof to establish” that Defendant was not responsible for the payment. 7 Please admit that pursuant to Plaintiff's policy with Defendant, PROGRESSIVE INSURANCE COMPANY, is required to conform to all requirements of Sections 627.727, Florida Statutes. 8 Please admit that Plaintiff's policy with Defendant, even if it does not by its own terms comply with the requirements set forth in Sections 627.727 Florida Statutes, is deemed to provide insurance for the payment of the required benefits and should be interpreted to meet the other requirements set forth in the Florida Statutes. 9 Please admit that the Plaintiff was not negligent in any way which contributed to the motor vehicle crash which is the subject of Plaintiff's Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the above-named Defendant, along with the summons and complaint. /s/ Kelsey Saalmann Kelsey Saalmann, Esquire Florida Bar No: 1038962 Morgan & Morgan, P.A. 501 Riverside Ave., Suite 1200 Jacksonville, Florida 32202 Telephone: (904) 944-8347 Primary email: ksaalmann@forthepeople.com Secondary email: Morganservice@forthepeople.com Attorneys for Plaintiff 13724426 RFACOO1