On January 25, 2008 a
Party Discovery
was filed
involving a dispute between
Daniel J Shepherd,
John Farina,
and
Mark Skeffington,
for LANDLORD/TENANT
in the District Court of Palm Beach County.
Preview
CIRCUIT COURT, FIFTEENTH JUDICIAL
CIRCUIT, PALM BEACH COUNTY, FLORIDA.
SORQORLA 0 0.22 3 6 XXXXNB
DANIEL J. SHEPHERD and JOHN FARINA,
TRUSTEES,
Plaintiffs, AD
ve
ot Ss
MARK SKEFFINGTON, Sc S
or =
Defendant./ s € ay
Qe
ag OF
REQUEST FOR ADMISSIONS om >?
xO
Plaintiffs, DANIEL J. SHEPHERD and JOHN FARINA, TRUSTEES, by and through their
undersigned attorneys, and pursuant to Rule 1.370, Fla.R.Civ.P., requests Defendant, MARK
SKEFFINGTON, within 45 days from the date of this request, to make the following admissions for
the purposes of this action only:
1. Each document attached to Plaintiffs’ Complaint is a true and correct copy of a
genuine original document.
2. You signed the original of each document of which a copy is attached to Plaintiffs’
Complaint and which bears your name.
3. You received everything you expected to receive in consideration of, or in exchange
for, your signature upon each document of which a copy is attached to Plaintiffs’ Complaint.
4. You have never notified or informed anyone of any reason why you are not
obligated to pay to Plaintiffs the amounts sued for.
5. You have never notified Plaintiffs of any reason why you are not obligated to pay
Plaintiffs the amounts sued for.
6. The computations as to amount of interest sued for in Plaintiffs’ Complaint and
attachments thereto are correct.
7. None of the agreements set forth in Plaintiffs’ Complaint and attachments thereto
have been subsequently modified or superseded.8. Plaintiffs are the lawful owners and holders of each document of which a copy is
attached to Plaintiffs’ Complaint.
9. The computation by which the principal balance claimed by Plaintiffs was computed
is accurate.
10. The balance herein sued for is due and owing by defendant to Plaintiffs.
11. Written demand has been made by Plaintiffs upon defendant for payment of the
claim herein sued upon prior to date hereof.
12. Except as may be shown in Plaintiffs’ Complaint or attachments thereto, Defendant
is not entitled to any credits, offsets or deductions.
13. | There are no documents, writings, letters, records or papers of any sort upon which
defendant intend to utilize as evidence of or a basis for any defense in this action.
14. Interest on the claim asserted herein by Plaintiffs is due in the amounts of
established by applicable law and by the charges shown in the attachments to Plaintiffs’ Complaint.
15. Every statement or allegation contained in Plaintiffs’ Complaint is true and correct.
I HEREBY CERTIFY that a true and correct copy of the foregoing was provided to a process
server on January 22, 2008, for service upon the above named Defendant together with copies of
the Summons and Complaint.
Dated: January 22, 2008.
LAW OFFICES OF RICHARD S. COHEN, LLC
By:
RICHARD S. COHEN
Attorney for Plaintiffs
FL Bar No.: 329983
1806 Old Okeechobee Road
West Palm Beach, Florida 33409
Phone: 561-684-7701; Fax: 561-615-6265
Document Filed Date
January 25, 2008
Case Filing Date
January 25, 2008
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
CIRCUIT COURT, FIFTEENTH JUDICIAL CIRCUIT, PALM BEACH COUNTY, FLORIDA. SORQORLA 0 0.22 3 6 XXXXNB DANIEL J. SHEPHERD and JOHN FARINA, TRUSTEES, Plaintiffs, AD ve ot Ss MARK SKEFFINGTON, Sc S or = Defendant./ s € ay Qe ag OF REQUEST FOR ADMISSIONS om >? xO Plaintiffs, DANIEL J. SHEPHERD and JOHN FARINA, TRUSTEES, by and through their undersigned attorneys, and pursuant to Rule 1.370, Fla.R.Civ.P., requests Defendant, MARK SKEFFINGTON, within 45 days from the date of this request, to make the following admissions for the purposes of this action only: 1. Each document attached to Plaintiffs’ Complaint is a true and correct copy of a genuine original document. 2. You signed the original of each document of which a copy is attached to Plaintiffs’ Complaint and which bears your name. 3. You received everything you expected to receive in consideration of, or in exchange for, your signature upon each document of which a copy is attached to Plaintiffs’ Complaint. 4. You have never notified or informed anyone of any reason why you are not obligated to pay to Plaintiffs the amounts sued for. 5. You have never notified Plaintiffs of any reason why you are not obligated to pay Plaintiffs the amounts sued for. 6. The computations as to amount of interest sued for in Plaintiffs’ Complaint and attachments thereto are correct. 7. None of the agreements set forth in Plaintiffs’ Complaint and attachments thereto have been subsequently modified or superseded.8. Plaintiffs are the lawful owners and holders of each document of which a copy is attached to Plaintiffs’ Complaint. 9. The computation by which the principal balance claimed by Plaintiffs was computed is accurate. 10. The balance herein sued for is due and owing by defendant to Plaintiffs. 11. Written demand has been made by Plaintiffs upon defendant for payment of the claim herein sued upon prior to date hereof. 12. Except as may be shown in Plaintiffs’ Complaint or attachments thereto, Defendant is not entitled to any credits, offsets or deductions. 13. | There are no documents, writings, letters, records or papers of any sort upon which defendant intend to utilize as evidence of or a basis for any defense in this action. 14. Interest on the claim asserted herein by Plaintiffs is due in the amounts of established by applicable law and by the charges shown in the attachments to Plaintiffs’ Complaint. 15. Every statement or allegation contained in Plaintiffs’ Complaint is true and correct. I HEREBY CERTIFY that a true and correct copy of the foregoing was provided to a process server on January 22, 2008, for service upon the above named Defendant together with copies of the Summons and Complaint. Dated: January 22, 2008. LAW OFFICES OF RICHARD S. COHEN, LLC By: RICHARD S. COHEN Attorney for Plaintiffs FL Bar No.: 329983 1806 Old Okeechobee Road West Palm Beach, Florida 33409 Phone: 561-684-7701; Fax: 561-615-6265