On July 17, 2015 a
Party Discovery
was filed
involving a dispute between
Collura, Brandon,
and
State Farm Mutual Automobile Insurance Company,
for Auto Negligence
in the District Court of Broward County.
Preview
Filing # 32608903 E-Filed 09/29/2015 12:35:05 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL
CIRCUIT, IN AND FOR BROWARD COUNTY,
FLORIDA
CASE NO: 15-012665 (08)
BRANDON COLLURA,
vs.
Plaintiff,
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY, a foreign profit corporation.
Defendant.
PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST FOR ADMISSIONS
COMES NOW The Plaintiff, BRANDON COLLURA, by and through his
undersigned counsel, files this response to the Defendant, STATE FARM MUTUAL
AUTOMOBILE INSURANCE COMPANY, Request for Admissions propounded to
Plaintiff under certificate date of September 3, 2015, as follows:
1.
Admit as to Plaintiff received benefits from his automobile personal injury
protection for medical bills that he incurred as a result of the incident
described in the complaint, otherwise denied.
Objection, as phrased “entitled to receive” would require counsel to reach
a legal conclusion in order to prepare a response, unable to admit or deny.
Denied
Objection, as phrased “entitled to receive” would require counsel to reach
a legal conclusion in order to prepare a response, unable to admit or deny.
. Admit
** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/29/2015 12:35:05 PM.****11.
12.
13.
14.
15.
16.
Objection, as phrased “entitled to receive” would require counsel to reach
a legal conclusion in order to prepare a response, unable to admit or deny.
Denied
Objection, as phrased “entitled to receive” would require counsel to reach
a legal conclusion in order to prepare a response, unable to admit or deny.
Admit.
. Objection, as phrased “entitled to receive” would require counsel to reach
a legal conclusion in order to prepare a response, unable to admit or deny.
Denied
Denied
Objection, as phrased “entitled to receive” would require counsel to reach
a legal conclusion in order to prepare a response, unable to admit or deny.
Denied
Objection, as phrased “entitled to receive” would require counsel to reach
a legal conclusion in order to prepare a response, unable to admit or deny.
Admit
. Denied
. Denied
. Denied
. Objection; as phrased this request is overly broad, vague and unduly
burdensome. The Plaintiff cannot admit or deny this Request as it employs
imprecise specifications of the information sought as vague andambiguous and/or fails to provide relevant and specific sub-sections or
paragraphs of the “Florida Statute Sections 627.7405,” as stated.
21. Denied
22. Objection; as phrased this request is overly broad, vague and unduly
burdensome. The Plaintiff cannot admit or deny this Request as it employs
imprecise specifications of the information sought as vague and
ambiguous and/or fails to provide relevant and specific sub-sections or
paragraphs of the “Florida Statute Sections 627.733,” as stated.
23. Admit
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via eservice to: LISA J. BALIGIAN, Esq, Nicholas J. Ryan & Associates, 110 S.E. 6" Street
0¢
Suite 2100 Fort Laudedale FI 33301, flor.law-lisabaligian.294019@statefarm.com, on this 4 }
day of SCY) , 2015.
CARNER, NEWMARK & COHEN, LLP
Attorneys for Plaintiff
600 S. Andrews Avenue Suite: 301
Fort Lauderdale, FL 33301
Telephone: 954-779-7479
By:
SCOTT NEWM.
Florida Bar No: 59
Document Filed Date
September 29, 2015
Case Filing Date
July 17, 2015
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Filing # 32608903 E-Filed 09/29/2015 12:35:05 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: 15-012665 (08) BRANDON COLLURA, vs. Plaintiff, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, a foreign profit corporation. Defendant. PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST FOR ADMISSIONS COMES NOW The Plaintiff, BRANDON COLLURA, by and through his undersigned counsel, files this response to the Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Request for Admissions propounded to Plaintiff under certificate date of September 3, 2015, as follows: 1. Admit as to Plaintiff received benefits from his automobile personal injury protection for medical bills that he incurred as a result of the incident described in the complaint, otherwise denied. Objection, as phrased “entitled to receive” would require counsel to reach a legal conclusion in order to prepare a response, unable to admit or deny. Denied Objection, as phrased “entitled to receive” would require counsel to reach a legal conclusion in order to prepare a response, unable to admit or deny. . Admit ** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/29/2015 12:35:05 PM.****11. 12. 13. 14. 15. 16. Objection, as phrased “entitled to receive” would require counsel to reach a legal conclusion in order to prepare a response, unable to admit or deny. Denied Objection, as phrased “entitled to receive” would require counsel to reach a legal conclusion in order to prepare a response, unable to admit or deny. Admit. . Objection, as phrased “entitled to receive” would require counsel to reach a legal conclusion in order to prepare a response, unable to admit or deny. Denied Denied Objection, as phrased “entitled to receive” would require counsel to reach a legal conclusion in order to prepare a response, unable to admit or deny. Denied Objection, as phrased “entitled to receive” would require counsel to reach a legal conclusion in order to prepare a response, unable to admit or deny. Admit . Denied . Denied . Denied . Objection; as phrased this request is overly broad, vague and unduly burdensome. The Plaintiff cannot admit or deny this Request as it employs imprecise specifications of the information sought as vague andambiguous and/or fails to provide relevant and specific sub-sections or paragraphs of the “Florida Statute Sections 627.7405,” as stated. 21. Denied 22. Objection; as phrased this request is overly broad, vague and unduly burdensome. The Plaintiff cannot admit or deny this Request as it employs imprecise specifications of the information sought as vague and ambiguous and/or fails to provide relevant and specific sub-sections or paragraphs of the “Florida Statute Sections 627.733,” as stated. 23. Admit CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via eservice to: LISA J. BALIGIAN, Esq, Nicholas J. Ryan & Associates, 110 S.E. 6" Street 0¢ Suite 2100 Fort Laudedale FI 33301, flor.law-lisabaligian.294019@statefarm.com, on this 4 } day of SCY) , 2015. CARNER, NEWMARK & COHEN, LLP Attorneys for Plaintiff 600 S. Andrews Avenue Suite: 301 Fort Lauderdale, FL 33301 Telephone: 954-779-7479 By: SCOTT NEWM. Florida Bar No: 59