On March 17, 2023 a
Request,Application
was filed
involving a dispute between
Stabrylla, Stephanie,
and
Safeco Insurance Company Of Illinois,
Whitkopf, Elizabeth,
for Auto Negligence
in the District Court of Charlotte County.
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Filing # 177082063 E-Filed 07/10/2023 06:27:17 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT,
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CASE NO: 23000551CA
STEPHANIE NICOLE STABRYLLA,
Plaintiff,
vs.
ELIZABETH WHITKOPF AND
SAFECO INSURANCE COMPANY
OF ILLINOIS,
Defendant.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT,
SAFECO INSURANCE COMPANY OF ILLINOIS
Plaintiff, STEPHANIE NICOLE STABRYLLA, by and through undersigned counsel
and pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant,
SAFECO INSURANCE COMPANY OF ILLINOIS, admit the following within forty-five (45)
days from the date of service hereof:
Please admit that this action properly and correctly names the parties to be sued in this
cause.
Please admit that at all times material to the Complaint, Defendant, SAFECO
INSURANCE COMPANY OF ILLINOIS, was and is a corporation licensed to do business in the
State of Florida and engaged in the business of automobile insurance.
Please admit that jurisdiction for this action is properly brought before the Circuit
Court in Charlotte County, Florida.
Please admit that Defendant insured Plaintiff under an automobile insurance policy
which provides Uninsured/Underinsured Motorist Protection benefits for the subject accident.
13323180
RFAC001
Please admit that the above-described automobile policy which Defendant issued was
in full force and effect on 09/29/2022 and provides coverage for Uninsured/Underinsured Motorist
Protection benefits for the personal injuries Plaintiff sustained in the subject accident.
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.
Please admit that pursuant to Plaintiff's policy with Defendant, SAFECO
INSURANCE COMPANY OF ILLINOIS, is required to conform to all requirements of Sections
627.727, Florida Statutes.
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.
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/ Ashley McMahan
Ashley McMahan, Esquire
Florida Bar No: 1003316
Morgan & Morgan, P.A.
2150 Goodlette-Frank Rd, Suite 750
Naples, FL 34102
Telephone: (239) 432-6664
Primary email: amcmahan@forthepeople.com
Secondary email: Morganservice@forthepeople.com
Attorneys for Plaintiff
13323180
RFAC001
Document Filed Date
July 10, 2023
Case Filing Date
March 17, 2023
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Filing # 177082063 E-Filed 07/10/2023 06:27:17 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT, IN AND FOR CHARLOTTE COUNTY, FLORIDA CASE NO: 23000551CA STEPHANIE NICOLE STABRYLLA, Plaintiff, vs. ELIZABETH WHITKOPF AND SAFECO INSURANCE COMPANY OF ILLINOIS, Defendant. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, SAFECO INSURANCE COMPANY OF ILLINOIS Plaintiff, STEPHANIE NICOLE STABRYLLA, by and through undersigned counsel and pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant, SAFECO INSURANCE COMPANY OF ILLINOIS, admit the following within forty-five (45) days from the date of service hereof: Please admit that this action properly and correctly names the parties to be sued in this cause. Please admit that at all times material to the Complaint, Defendant, SAFECO INSURANCE COMPANY OF ILLINOIS, was and is a corporation licensed to do business in the State of Florida and engaged in the business of automobile insurance. Please admit that jurisdiction for this action is properly brought before the Circuit Court in Charlotte County, Florida. Please admit that Defendant insured Plaintiff under an automobile insurance policy which provides Uninsured/Underinsured Motorist Protection benefits for the subject accident. 13323180 RFAC001 Please admit that the above-described automobile policy which Defendant issued was in full force and effect on 09/29/2022 and provides coverage for Uninsured/Underinsured Motorist Protection benefits for the personal injuries Plaintiff sustained in the subject accident. 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. Please admit that pursuant to Plaintiff's policy with Defendant, SAFECO INSURANCE COMPANY OF ILLINOIS, is required to conform to all requirements of Sections 627.727, Florida Statutes. 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. 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/ Ashley McMahan Ashley McMahan, Esquire Florida Bar No: 1003316 Morgan & Morgan, P.A. 2150 Goodlette-Frank Rd, Suite 750 Naples, FL 34102 Telephone: (239) 432-6664 Primary email: amcmahan@forthepeople.com Secondary email: Morganservice@forthepeople.com Attorneys for Plaintiff 13323180 RFAC001