Party Discovery: GOVERNMENT EMPLOYEES INSURANCE COMPANY AS SUBROGEE OF DAVID KENT,

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      Filing # 168680809 E-Filed 03/14/2023 12:38:54 PM




                                                                             IN THE CIRCUIT COURT FOR THE 5TH
                                                                             JUDICIAL CIRCUIT IN AND FOR.
                                                                             LAKE COUNTY, FLORIDA:
             GOVERNMENT EMPLOYEES INSURANCE
             COMPANY as subrogee.of DA VID KENT,

                        Plaintiff,                                           CASE NO.::2022-CA-002055-AXXX-XX
             -Vs-

             ANDREA WILSON EVANS
             a/k/a ANDREA WILSON CALLAWAY
             and RONALD ISAIAH TURNER,
                        Defendants.
             neneee.                           -/

                       PLAINTIFE’S RESPONSE TO THE DEFENDANTS                       REQUEST FOR ADMISSIONS

                     Plaintiff, by and:through its undersigned counsel, files this its Response to the Defendants’ Request
             for Admissions as follows:
                        1. Plaintiff cannot admit or deny and Plaintiff has taken every reasonable step to inquire.
                        2..Admit.
                        3. Plaintiff carinot admit or deny and Plaintiff has taken every reasonable:step to inquire
                        4. Admit.
                        5, Plaintiff cannot admit or deriy:and Plaintiff has taken every reasonable step to inquire.
                        6, Admit.
                        7. Plaintiff cannot admit or deny.and Plaintiff has taken every reasonable step to inquire
                        8. Admit.
                        9, Plaintiff cannot admit or deny and Plaintiff has taken every reasonable step to inquire.
                        10. Denied.
                        11. Denied.
                        12. Plaintiff cannot admit or deny and Plaintiff has taken every reasonable step to inquire.
                        13. Plaintiff cannot admit or deny and Plaintiff has taken every. feasonable step to ‘inquire.
                        14, Plaintiff cannot admit or deny and Plaintiff has taken every reasonable:step to inquire.
                        15. Plaintiff cannot admit.or deny and Plaintiff has taken every reasonable step to inquire.
                       16. Plaintiff. cannot admit or deny and Plaintiff has taken every reasonable step to inquire.
                        17.. Plaintiff: cannot admit.or deny and Plaintiff has taken every reasonable step to inquire.
                       18, Plaintiff cannot:admit or deny and Plaintiff has taken every reasonable step to inquire.
                       19.-Plaintiffcainiot-admit-or- déeny-and-Plaintiff has-taken-every-reasonable-step-to-inquire-




FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 03/14/2023 01:29:33 PM.
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               20. Plaintiff cannot admit or deny and Plaintiff has taken every reasonable step to inquire.
               21. Plaintiff cannot admit or deny and Plaintiff has taken every reasonable step to inquire.
               22. Admit.
            23. Denied.
            24, Objection, calls for a legal conclusion to be determined by the trier of fact
           25. Admit.
           26. Plaintiff cannot admit or deny and Plaintiff has taken every reasonable step to inquire.
           27. Admit.




                                 —fstoh”
           I HEREBY CERTIFY that              rug and correct copy of the foregoing was furnished via E-mail this
                   day of.                            , 2023 to: Barbi L. Feldman, Esq., bfeldman@vefjlaw.com,
    Civil@vefilaw.com, and bfeldman@ycfilaw.com,




                                                                 LAW OFFICES OF YATES & SCHILLER, P.A.
                                                                 Attorneys for Plaintiff
                                                                 7900 Glades Road, Suite 405
                                                                 Boca Raton, Florida 33434
                                                                 Designated email address for pleadings only:
                                                                 pleadings@yatesandschiller.com
                                                                 Telephone: 561-477-7729
                                                                 Facsimile: 561-477-7731


                                                                 By: s/ Samantha L. Hare, Esq.
                                                                     BRUCE H, SCHILLER, Esq.
                                                                     FBN: 982725
                                                                     SAMANTHA L. HARE, Esq.
                                                                      FBN: 110047
    Ys40649