On March 21, 2023 a
was filed
involving a dispute between
Gudino, Pedro,
and
Guzman, Fermin Santiago,
State Farm,
for CIRCUIT CIVIL
in the District Court of Osceola County.
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Filing # 177333190 E-Filed 07/13/2023 11:35:51 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2023 CA 001416 AN
PEDRO GUDINO,
Plaintiff,
vs.
FERMIN SANTIAGO GUZMAN,
AND STATE FARM MUTUAL
AUTOMOBILE INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT,
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
Plaintiff, PEDRO GUDINO, by and through undersigned counsel, and pursuant to Rule
1.370, Florida Rules of Civil Procedure, hereby requests that Defendant, STATE FARM MUTUAL
AUTOMOBILE 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, STATE FARM
MUTUAL AUTOMOBILE 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 Osceola 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.
13690703 1
RFAC001
5. Please admit that the above-described automobile policy which Defendant issued was
in full force and effect on 12/23/2022, 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, STATE FARM
MUTUAL AUTOMOBILE 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/ Andrew Rollins
Andrew Rollins, Esquire
Florida Bar No: 1026179
Morgan & Morgan, P.A.
20 N Orange Ave., Suite 1600
Orlando, Florida 32801
Telephone: (407) 849-4624
Primary email: arollins@forthepeople.com
Secondary email: Morganservice@forthepeople.com
Attorneys for Plaintiff
13690703 2
RFAC001
Document Filed Date
November 02, 2023
Case Filing Date
March 21, 2023
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Filing # 177333190 E-Filed 07/13/2023 11:35:51 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2023 CA 001416 AN PEDRO GUDINO, Plaintiff, vs. FERMIN SANTIAGO GUZMAN, AND STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY Plaintiff, PEDRO GUDINO, by and through undersigned counsel, and pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant, STATE FARM MUTUAL AUTOMOBILE 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, STATE FARM MUTUAL AUTOMOBILE 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 Osceola 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. 13690703 1 RFAC001 5. Please admit that the above-described automobile policy which Defendant issued was in full force and effect on 12/23/2022, 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, STATE FARM MUTUAL AUTOMOBILE 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/ Andrew Rollins Andrew Rollins, Esquire Florida Bar No: 1026179 Morgan & Morgan, P.A. 20 N Orange Ave., Suite 1600 Orlando, Florida 32801 Telephone: (407) 849-4624 Primary email: arollins@forthepeople.com Secondary email: Morganservice@forthepeople.com Attorneys for Plaintiff 13690703 2 RFAC001