Preview
Filing # 68171199 E-Filed 02/20/2018 09:53:40 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE 2018-001322 (12)
KARMEL RUNCIE,
Plaintiff,
Vv.
INTERNATIONAL VILLAGE
ASSOCIATION, INC. and DOREEN
SYRLIK
Defendants.
ee eee Se Sa Seer
DEFENDANT, DOREEN SYRLIK’S, FIRST REQUEST FOR ADMISSIONS TO
PLAINTIFF
COMES NOW Defendant, DOREEN SYRLIK, (hereinafter “Defendant’), by and
through its undersigned counsel, and pursuant to Rule 1.370 of the Florida Rules of
Civil Procedure, hereby propounds to the Plaintiff, KARMEL RUNCIE, (hereinafter
referred to as “Plaintiff’), Request for Admissions requiring that said Requests for
Admissions be answered within thirty (30) days from the date of the Certificate of
Service, as follows:
1. Your earning capacity was not reduced as a result of the Defendants,
DOREEN SYRLIK’S and INTERNATIONAL VILLAGE ASSOCIATION’S,
alleged actions as set forth in the Complaint.
2. Your earning capacity was not impaired as a result of the Defendants,
DOREEN SYRLIK’S and INTERNATIONAL VILLAGE ASSOCIATION'S,
alleged actions as set forth in the Complaint.
3. You did not lose any wages or income as a result of the Defendants,
DOREEN SYRLIK’S and INTERNATIONAL VILLAGE ASSOCIATION'S,
alleged actions as set forth in the Complaint.
COLE, SCOTT & KISSANE, P.A.
COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O, BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-6300 - (305) 373-2294 FAX
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/20/2018 9:53:40 AM.****CASE NO: CACE 2018-001322 (12)
4. Your ability to enjoy life has not been reduced as a result of the
Defendants, DOREEN SYRLIK’S and INTERNATIONAL VILLAGE
ASSOCIATION'S, alleged actions as set forth in the Complaint.
5. Admit that DOREEN SYRLIK knew that the alleged defamatory statement
was true when it was declared.
6. Admit that DOREEN SYRLIK’s alleged defamatory statement did not
lower the Plaintiff in the estimation of the community or deter third persons
from associating with the Plaintiff.
7. Admit that DOREEN SYRLIK’s alleged defamatory statement was not
about and/or concerned the Plaintiff.
8. Admit that you have a criminal record.
9. Admit that you do not currently have gainful employment.
-2-
COLE, SCOTT & KISSANE, P.A.
COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O, BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-6300 - (305) 373-2294 FAXCASE NO: CACE 2018-001322 (12)
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 20‘ day of February 2018, a true and correct
copy of the foregoing was filed with the Clerk of Broward County by using the Florida
Courts e-Filing Portal, which will send an automatic e-mail message to the following
parties registered with the e-Filing Portal system: chelsalewispa.@gmail.com;
lewislawpleadings@gmail.com; Chelsea Lewis, Esquire, Lewis Law LLC,,151 N. Nob
Hill Road, Suite 348, Plantation, FL 33324, Attorneys for Plaintiff.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendants,
International Village Association, Inc. and Doreen
Syrlik
Cole, Scott & Kissane Building
9150 South Dadeland Boulevard, Suite 1400
P.O. Box 569015
Miami, Florida 33256
Telephone (305) 350-5361
Facsimile (305) 373-2294
Primary e-mail: Daniel. Klein@csklegal.com
Secondary e-mail: Tania.Cabrera@csklegal.com
Primary e-mail: Samuel. Falk@csklegal.com
Secondary e-mail: Linda. Vitti@csklegal.com
By: _s/ Daniel J. Klein
DANIEL J. KLEIN
Florida Bar No.: 16126
SAMUEL J. FALK
Florida Bar No.: 123539
-3-
COLE, SCOTT & KISSANE, P.A.
COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O, BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-6300 - (305) 373-2294 FAX
Preview
Filing # 68171199 E-Filed 02/20/2018 09:53:40 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE 2018-001322 (12) KARMEL RUNCIE, Plaintiff, Vv. INTERNATIONAL VILLAGE ASSOCIATION, INC. and DOREEN SYRLIK Defendants. ee eee Se Sa Seer DEFENDANT, DOREEN SYRLIK’S, FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF COMES NOW Defendant, DOREEN SYRLIK, (hereinafter “Defendant’), by and through its undersigned counsel, and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, hereby propounds to the Plaintiff, KARMEL RUNCIE, (hereinafter referred to as “Plaintiff’), Request for Admissions requiring that said Requests for Admissions be answered within thirty (30) days from the date of the Certificate of Service, as follows: 1. Your earning capacity was not reduced as a result of the Defendants, DOREEN SYRLIK’S and INTERNATIONAL VILLAGE ASSOCIATION’S, alleged actions as set forth in the Complaint. 2. Your earning capacity was not impaired as a result of the Defendants, DOREEN SYRLIK’S and INTERNATIONAL VILLAGE ASSOCIATION'S, alleged actions as set forth in the Complaint. 3. You did not lose any wages or income as a result of the Defendants, DOREEN SYRLIK’S and INTERNATIONAL VILLAGE ASSOCIATION'S, alleged actions as set forth in the Complaint. COLE, SCOTT & KISSANE, P.A. COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O, BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-6300 - (305) 373-2294 FAX *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/20/2018 9:53:40 AM.****CASE NO: CACE 2018-001322 (12) 4. Your ability to enjoy life has not been reduced as a result of the Defendants, DOREEN SYRLIK’S and INTERNATIONAL VILLAGE ASSOCIATION'S, alleged actions as set forth in the Complaint. 5. Admit that DOREEN SYRLIK knew that the alleged defamatory statement was true when it was declared. 6. Admit that DOREEN SYRLIK’s alleged defamatory statement did not lower the Plaintiff in the estimation of the community or deter third persons from associating with the Plaintiff. 7. Admit that DOREEN SYRLIK’s alleged defamatory statement was not about and/or concerned the Plaintiff. 8. Admit that you have a criminal record. 9. Admit that you do not currently have gainful employment. -2- COLE, SCOTT & KISSANE, P.A. COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O, BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-6300 - (305) 373-2294 FAXCASE NO: CACE 2018-001322 (12) CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 20‘ day of February 2018, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: chelsalewispa.@gmail.com; lewislawpleadings@gmail.com; Chelsea Lewis, Esquire, Lewis Law LLC,,151 N. Nob Hill Road, Suite 348, Plantation, FL 33324, Attorneys for Plaintiff. COLE, SCOTT & KISSANE, P.A. Counsel for Defendants, International Village Association, Inc. and Doreen Syrlik Cole, Scott & Kissane Building 9150 South Dadeland Boulevard, Suite 1400 P.O. Box 569015 Miami, Florida 33256 Telephone (305) 350-5361 Facsimile (305) 373-2294 Primary e-mail: Daniel. Klein@csklegal.com Secondary e-mail: Tania.Cabrera@csklegal.com Primary e-mail: Samuel. Falk@csklegal.com Secondary e-mail: Linda. Vitti@csklegal.com By: _s/ Daniel J. Klein DANIEL J. KLEIN Florida Bar No.: 16126 SAMUEL J. FALK Florida Bar No.: 123539 -3- COLE, SCOTT & KISSANE, P.A. COLE, SCOTT & KISSANE BUILDING - 9150 SOUTH DADELAND BOULEVARD - SUITE 1400 - P.O, BOX 569015 - MIAMI, FLORIDA 33256 - (305) 350-6300 - (305) 373-2294 FAX