On April 11, 2024 a
Party Discovery
was filed
involving a dispute between
Jantzen Adams,
and
Allstate Fire And Causalty Insurance Company,
Tonia Lynn Whitten,
for Circuit Civil
in the District Court of Manatee County.
Preview
Filing # 195991977 E-Filed 04/11/2024 01:08:52 PM
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR MANATEE COUNTY, FLORIDA
CIVIL DIVISION
JANTZEN ADAMS,
Plaintiff,
vs. CASE NO.:
TONIA LYNN WHITTEN and
ALLSTATE FIRE & CASUALTY INSURANCE COMPANY,
Defendants.
REQUEST FOR ADMISSIONS TO DEFENDA)}
TO: ALLSTATE FIRE & CASUALTY INSURANCE COMPANY
PURSUANT to Rule 1.370, Florida Rules of Civil Procedure, Plaintiff, JANTZEN
ADAMS, requests Defendant, ALLSTATE FIRE & CASUALTY INSURANCE COMPANY, to
admit in writing the truth of the matters set forth below on or by the forty-fifth (45th) day after
service of this Request for Admissions.
1 At all times material to the Complaint, Defendant was and is a corporation licensed to do
business in Manatee County, State of Florida, and engaged in the business of automobil
insurance.
Defendant maintains agents in Manatee County, Florida, to transact its customary business
in Manatee County, Florida.
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 Plaintiff's complaint.
1
"2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT
The above-described automobile policy which Defendant issued was in full foree and effect
for the subject crash and provides coverage for Uninsured/Underinsured Motorist
Protection benefits for the personal injuries Plaintiff sustained in the subject crash.
The above-styled Court, in and for Manatee County, Florida, has jurisdiction over
Plaintiffs claim against Defendant.
Defendant failed to pay Plaintiff's Uninsured/Underinsured Motorist Protection claim
without "reasonable proofto establish" that Defendant was not responsible for the payment.
Plaintiff's policy with Defendant is required to conform to all requirements of Sections
627.727, Florida Statutes.
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.
A multiplicr of the Load Star for attorneys’ fecs would be appropriate if Plaintiff has a
contingent fee contract with the undersigned law firm.
10. Two Hundred Fifty Dollars ($250.00) per hour is a reasonable hourly rate for the
undersigned law firm to charge based on the charges customarily charged in this
community for the same or similar services.
11 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
IT HEREBY CERTIFY that a true copy of the foregoing has been furnished to the
Defendant, together with the Summons and Complaint.
2
"2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT
/s/ Christopher Borzell
Christopher Borzell, Attorncy
Morgan & Morgan Tampa, P.A.
One Tampa City Center
201 N. Franklin Street, 7th Floor
Tampa, FL 33602
Tele: (941) 271-6384
Fax: (941) 271-6484
Florida Bar #: 68277
Attorney for Plaintiff
Primary Email: CBorzell@ForThePecople.co:
Secondary: CT BPlcadines«ForThePeople.com
Paralegal: RHoward@ForThePeople.com
3
"2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT
Document Filed Date
April 11, 2024
Case Filing Date
April 11, 2024
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Filing # 195991977 E-Filed 04/11/2024 01:08:52 PM IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA CIVIL DIVISION JANTZEN ADAMS, Plaintiff, vs. CASE NO.: TONIA LYNN WHITTEN and ALLSTATE FIRE & CASUALTY INSURANCE COMPANY, Defendants. REQUEST FOR ADMISSIONS TO DEFENDA)} TO: ALLSTATE FIRE & CASUALTY INSURANCE COMPANY PURSUANT to Rule 1.370, Florida Rules of Civil Procedure, Plaintiff, JANTZEN ADAMS, requests Defendant, ALLSTATE FIRE & CASUALTY INSURANCE COMPANY, to admit in writing the truth of the matters set forth below on or by the forty-fifth (45th) day after service of this Request for Admissions. 1 At all times material to the Complaint, Defendant was and is a corporation licensed to do business in Manatee County, State of Florida, and engaged in the business of automobil insurance. Defendant maintains agents in Manatee County, Florida, to transact its customary business in Manatee County, Florida. 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 Plaintiff's complaint. 1 "2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT The above-described automobile policy which Defendant issued was in full foree and effect for the subject crash and provides coverage for Uninsured/Underinsured Motorist Protection benefits for the personal injuries Plaintiff sustained in the subject crash. The above-styled Court, in and for Manatee County, Florida, has jurisdiction over Plaintiffs claim against Defendant. Defendant failed to pay Plaintiff's Uninsured/Underinsured Motorist Protection claim without "reasonable proofto establish" that Defendant was not responsible for the payment. Plaintiff's policy with Defendant is required to conform to all requirements of Sections 627.727, Florida Statutes. 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. A multiplicr of the Load Star for attorneys’ fecs would be appropriate if Plaintiff has a contingent fee contract with the undersigned law firm. 10. Two Hundred Fifty Dollars ($250.00) per hour is a reasonable hourly rate for the undersigned law firm to charge based on the charges customarily charged in this community for the same or similar services. 11 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 IT HEREBY CERTIFY that a true copy of the foregoing has been furnished to the Defendant, together with the Summons and Complaint. 2 "2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT /s/ Christopher Borzell Christopher Borzell, Attorncy Morgan & Morgan Tampa, P.A. One Tampa City Center 201 N. Franklin Street, 7th Floor Tampa, FL 33602 Tele: (941) 271-6384 Fax: (941) 271-6484 Florida Bar #: 68277 Attorney for Plaintiff Primary Email: CBorzell@ForThePecople.co: Secondary: CT BPlcadines«ForThePeople.com Paralegal: RHoward@ForThePeople.com 3 "2024CA000579AX" 195991977 Filed at Manatee County Clerk 04/11/2024 01:08:51 PM EDT