On March 17, 2023 a
Party Discovery
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.
Preview
Filing # 178184540 E-Filed 07/25/2023 02:28:22 PM
IN THE CIRCUIT COURT OF THE
TWENTIETH JUDICIAL
CASE NO.: 23-CA-000551
STEPHANIE STABRYLLA,
Plaintiff,
vs.
ELIZABETH WHITKOPF and SAFECO INSURANCE
COMPANY OF ILLINOIS,
Defendants.
/
DEFENDANT, SAFECO INSURANCE COMPANY OF ILLINOIS’ RESPONSE TO
PLAINTIFF’S REQUEST FOR ADMISSIONS
SAFECO INSURANCE COMPANY OF ILLINOIS, by and through the
undersigned attorneys and in accordance with Florida Rule of Civil Procedure 1.370, hereby files
this Response to Request for Admissions and states as follows:
1. At all times material to the Complaint, Defendant was and is a corporation
licensed to do business in Charlotte County, State of Florida, and engaged in the business of
automobile insurance.
RESPONSE: Admit.
2. Defendant maintains agents
RESPONSE: Admit.
3. Defendant insured Plaintiff under an automobile insurance policy which provides
Uninsured/Underinsured Motorist Protection benefits for the motor vehicle crash which is the
subject of Plaintiffs complaint.
RESPONSE: Admit, subject to
the policy.
Case No.: 23-CA-000551
Stabrylla, Stephanie v. Whitkopf, Elizabeth, et al.
Defendant’s Response to Request for Admissions
Page of
4. The above-described automobile policy which Defendant issued was in full force
and effect for the subject crash and provides coverage for Uninsured/Underinsured Motorist
rsonal injuries Plaintiff sustained in the subject crash.
RESPONSE: Admit, subject to
the policy.
5. The above-styled Court, in and for Charlotte County, Florida, has jurisdiction
RESPONSE: Admit.
6. Defendant failed to pay Plaintiffs Un
payment.
RESPONSE: Deny.
7. Plaintiff’s policy with Defendant is
Sections 627.727, Florida Statutes.
RESPONSE: Admit, subject to
the policy.
8. Plaintiff’s policy with Defendant, even
in Sections 627.727 Florida Statutes, is deemed to provide
insurance for the payment of the interpreted to meet the other
requirements set forth in the Florida Statutes.
RESPONSE: Admit, subject to
the policy.
9. A multiplier of the Load Star for attorneys' fees would be appropriate if Plaintiff
has a contingent fee contract with the undersigned law firm.
RESPONSE: Deny.
10. Two Hundred Fifty Dollars ($250.00) per
milar services.
RESPONSE: Deny.
Case No.: 23-CA-000551
Stabrylla, Stephanie v. Whitkopf, Elizabeth, et al.
Defendant’s Response to Request for Admissions
Page of
11. Please admit that the Plaintiff was not
the motor vehicle crash which is the subject of Plaintiff's complaint.
RESPONSE: Defendant has made reasonable inquiry and the information known
or readily obtainable by this Defendant is insufficient to enable this Defendant to admit or
July, 2023 to Derrick Isaac, Esquire, Morgan & Morgan, derrickisaac@forthepeople.com,
acoffey@forthepeople.com.
LAW OFFICE OF IGNACIO M. SARMIENTO
PO Box 7217
London, KY 40742
Telephone: 305-670-9339
Attorney for Defendant, Safeco
Laura W. Johnson, Esq., FBN 113572
Primary E-mail (eservice only): FortMyersLegalMail@libertymutual.com
Secondary E-mail: Laura.Johnson02@Libertymutual.com
Case No.: 23-CA-000551
Stabrylla, Stephanie v. Whitkopf, Elizabeth, et al.
Defendant’s Response to Request for Admissions
Page of
Document Filed Date
July 25, 2023
Case Filing Date
March 17, 2023
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Filing # 178184540 E-Filed 07/25/2023 02:28:22 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CASE NO.: 23-CA-000551 STEPHANIE STABRYLLA, Plaintiff, vs. ELIZABETH WHITKOPF and SAFECO INSURANCE COMPANY OF ILLINOIS, Defendants. / DEFENDANT, SAFECO INSURANCE COMPANY OF ILLINOIS’ RESPONSE TO PLAINTIFF’S REQUEST FOR ADMISSIONS SAFECO INSURANCE COMPANY OF ILLINOIS, by and through the undersigned attorneys and in accordance with Florida Rule of Civil Procedure 1.370, hereby files this Response to Request for Admissions and states as follows: 1. At all times material to the Complaint, Defendant was and is a corporation licensed to do business in Charlotte County, State of Florida, and engaged in the business of automobile insurance. RESPONSE: Admit. 2. Defendant maintains agents RESPONSE: Admit. 3. Defendant insured Plaintiff under an automobile insurance policy which provides Uninsured/Underinsured Motorist Protection benefits for the motor vehicle crash which is the subject of Plaintiffs complaint. RESPONSE: Admit, subject to the policy. Case No.: 23-CA-000551 Stabrylla, Stephanie v. Whitkopf, Elizabeth, et al. Defendant’s Response to Request for Admissions Page of 4. The above-described automobile policy which Defendant issued was in full force and effect for the subject crash and provides coverage for Uninsured/Underinsured Motorist rsonal injuries Plaintiff sustained in the subject crash. RESPONSE: Admit, subject to the policy. 5. The above-styled Court, in and for Charlotte County, Florida, has jurisdiction RESPONSE: Admit. 6. Defendant failed to pay Plaintiffs Un payment. RESPONSE: Deny. 7. Plaintiff’s policy with Defendant is Sections 627.727, Florida Statutes. RESPONSE: Admit, subject to the policy. 8. Plaintiff’s policy with Defendant, even in Sections 627.727 Florida Statutes, is deemed to provide insurance for the payment of the interpreted to meet the other requirements set forth in the Florida Statutes. RESPONSE: Admit, subject to the policy. 9. A multiplier of the Load Star for attorneys' fees would be appropriate if Plaintiff has a contingent fee contract with the undersigned law firm. RESPONSE: Deny. 10. Two Hundred Fifty Dollars ($250.00) per milar services. RESPONSE: Deny. Case No.: 23-CA-000551 Stabrylla, Stephanie v. Whitkopf, Elizabeth, et al. Defendant’s Response to Request for Admissions Page of 11. Please admit that the Plaintiff was not the motor vehicle crash which is the subject of Plaintiff's complaint. RESPONSE: Defendant has made reasonable inquiry and the information known or readily obtainable by this Defendant is insufficient to enable this Defendant to admit or July, 2023 to Derrick Isaac, Esquire, Morgan & Morgan, derrickisaac@forthepeople.com, acoffey@forthepeople.com. LAW OFFICE OF IGNACIO M. SARMIENTO PO Box 7217 London, KY 40742 Telephone: 305-670-9339 Attorney for Defendant, Safeco Laura W. Johnson, Esq., FBN 113572 Primary E-mail (eservice only): FortMyersLegalMail@libertymutual.com Secondary E-mail: Laura.Johnson02@Libertymutual.com Case No.: 23-CA-000551 Stabrylla, Stephanie v. Whitkopf, Elizabeth, et al. Defendant’s Response to Request for Admissions Page of