Party Discovery: Agave Glass Florida Llc A/A/O Michael Gaus vs Geico General Insurance Company

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                                Filing # 176054798 E-Filed 06/24/2023 01:11:44 AM


                     IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
                             IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

             AGAVE GLASS FLORIDA LLC a/a/o
             MICHAEL GAUS,
                                                             CASE NUMBER: 2023-______________
                     Plaintiff,
             vs.

             GEICO GENERAL INSURANCE COMPANY,

                   Defendant.
             ______________________________________/

                                              REQUEST FOR ADMISSIONS


                     COMES NOW, Plaintiff, AGAVE GLASS FLORIDA LLC, a/a/o MICHAEL GAUS, by

              and through undersigned counsel and pursuant to F.R.C.P. 1.370, requests Defendant, GEICO

              GENERAL INSURANCE COMPANY, admit or deny each of the following:

                     1.      Admit Defendant paid the Plaintiff the sum due under MICHAEL GAUS’s contract

             of insurance based upon Defendant’s interpretation of the insurance contract’s limitation of

             liability provision.

                     2.      Admit Defendant owes Plaintiff the difference between Plaintiff’s invoice for

             services rendered to MICHAEL GAUS and the amount paid by Defendant for the Plaintiffs invoice

             for services rendered to MICHAEL GAUS.

                     3.      Admit that Defendant did not send Plaintiff any communication that specifically

             itemized the amount it paid for MICHAEL GAUS’s windshield glass, molding (if applicable),

             labor rate and hours, urethane, sales tax, and fees if applicable.

                     4.      Admit Defendant did not pay for Plaintiff’s Fee(s) charged for the repair of

             MICHAEL GAUS’s vehicle.

                     I HEREBY CERTIFY that a true and correct copy of the foregoing Request for




6/24/2023 1:11 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
             Admissions was served in conjunction with Plaintiff’s Complaint.



                                                                       /s/ Jack W. Vasilaros
                                                                       Jack W. Vasilaros, Esquire
                                                                       Florida Bar Number: 0125152
                                                                       United Law Group of Florida
                                                                       1920 West Bay Drive, Suite 1
                                                                       Largo, Florida 33770
                                                                       Phone: (727) 455-9400
                                                                       Email: Jack@unitedlawfla.com
                                                                       Email: Madi@unitedlawfla.com
                                                                       Attorney for Plaintiff




6/24/2023 1:11 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2