Document for SMITH, MELISSA J vs. GUSS, ROBYN M

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                                Filing # 184311572 E-Filed 10/19/2023 09:51:12 AM


           IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
           CHARLOTTE COUNTY, FLORIDA                             CIVIL ACTION

           MELISSA J. SMITH,

                         Plaintiff,

          vs.                                                CASE NO. 23-CA-000712

          ROBYN M. GUSS and
          STATE FARM MUTUAL
          AUTOMOBILE INSURANCE COMPANY,

                         Defendants.



                      DEFENDANT’S RESPONSE TO REQUEST FOR ADMISSION


                 COMES       NOW       the   Defendant,   STATE    FARM    MUTUAL      AUTOMOBILE

          INSURANCE COMPANY,             by and through its undersigned attorneys, and in response to

          the Plaintiff's Request for Admissions, dated September 26, 2023, states as follows:

                 1     Admit.

                2      Admit.

                 3     Defendant has made         reasonable inquiry and that the information known

          or readily obtainable by Defendant is insufficient to enable Defendant to admit or deny.

                4      Admit.

                5      Admit for jurisdictional purposes only.

                6      Admit for jurisdictional purposes only.

                7      Defendant has made reasonable inquiry and that the information known

          or readily obtainable by Defendant is insufficient to enable Defendant to admit or deny.

                8      Deny.
9.      Defendant has made reasonable inquiry and that the information known

or readily obtainable by Defendant is insufficient to enable Defendant to admit or deny.

       | HEREBY CERTIFY that a true and correct copy of the above and foregoing has

been furnished by electronic mail delivery to CHRISTOPHER        HALLETT, ESQUIRE and

DAMIAN      B. MALLARD,   ESQUIRE,    889 N. Washington      Boulevard,    Sarasota,   Florida

34236;       damian@mallardperez.com;                  ange!l@mallardperez.com;

regena@mallardperez.com;     and ANDREW       RIORDAN,      ESQUIRE,      4443   Lyons Road,

Suite 206, Coconut Creek, Florida    33073; ftmyerslegal@allstate.com; on this         _ / qtt

day of October, 2023.

                                                VERNIS & BOWLING OF
                                                SOUTHWEST FLORIDA, P.A
                                                Attorneys for State Farm
                                                2369 West First Street
                                                Fort Myers, Florida 33901
                                                (239) 334-3035
                                                                 L
                                                Bi
                                                     EVER     B. SUNDOOK
                                                     Florida Bar No. 352470
                                                     ssundook@florida-law.com