Party Discovery: RICHARD C SENKER TRUSTEEE OF THE RICHARD C SENKER vs SNAVELY SIESTA ASSOCIATES LLC

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                                IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA

RICHARD C. SENKER, Trustee of the Richard
C. Senker and Patricia A. Senker Land Trust,
a Florida Land Trust,

Plaintiff,

vs. CASE NO. 2007 CA 008509 NC

SNAVELY SIESTA ASSOCIATES, LLC,
an Ohio Limited Liability Company,

Defendant.

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REQUEST FOR ADMISSIONS Tot on 3
2OF- _
TO: Snavely Siesta Associates, LLC SSecr 22 os
by serving Scott K. Petersen, Esquire aOR oS o
50 Central Avenue Suite 700 TS on OD
— CS O

Sarasota, Florida 34236

Plaintiff, RICHARD C. SENKER, Trustee, by and through his
undersigned attorneys, requests that Defendant, SNAVELY SIESTA
ASSOCIATES, LLC, admit the truth of the following matters:

1. Admit that the changes made to the Declaration of
Condominium in the First Amendment to Declaration of Condominium
for Summer Cove Condominum (“the First Amendment”) were material.

2. Admit that in the First Amendment, a change was made that
narrowed the driveway into parking garage D.

3. Admit that in the First Amendment, a change was made that
narrowed the walkway near the mailboxes in parking garage D.

4. Admit that in the First Amendment, a change was made
that increased the number of parking spaces on the First Floor of

WTAparking garage D from 21 to 22.

5. Admit that in the First Amendment, a change was made that
relocates the mailboxes in parking garage D.

6. Admit that in the First Amendment, a change was made that
the Condominium Property with a new and undisclosed utility
easement.

7. Admit that on July 16, 2007, Defendant had not executed
and delivered to the Closing Agent a Special Warranty Deed for Unit
602C at Summer Cove Condominium.

8. Admit that on July 16, 2007, Defendant had not executed
and delivered to the Closing Agent a Closing Statement for the sale
of Unit 602C at Summer Cove Condominium.

9. Admit that on July 16, 2007, Defendant had not executed
and delivered to the Closing Agent an affidavit as to liens,
possession and other certifications to provide to Plaintiff
marketable title to Unit 602C at Summer Cove Condominium.

10. Admit that on July 16, 2007, Defendant had not executed
and delivered to the Closing Agent a Notice of Termination for Unit
602C at Summer Cove Condominium.

11. Admit that on July 16, 2007, Defendant had not obtained
a Final Contractor’s Affidavit from its General Contractor for Unit
602C at Summer Cove Condominium.

12. Admit that on August 10, 2007, Defendant had not executed

and delivered to the Closing Agent a Special Warranty Deed for Unit602C at Summer Cove Condominium.

13. Admit that on August 10, 2007, Defendant had not executed
and delivered to the Closing Agent a Closing Statement for the sale
of Unit 602C at Summer Cove Condominium.

14. Admit that on August 10, 2007, Defendant had not executed
and delivered to the Closing Agent an affidavit as to liens,
possession and other certifications to provide to Plaintiff
marketable title to Unit 602C at Summer Cove Condominium.

15. Admit that on August 10, 2007, Defendant had not executed
and delivered to the Closing Agent a Notice of Termination for Unit
602C at Summer Cove Condominium.

16. Admit that on August 10, 2007, Defendant had not obtained
a Final Contractor’s Affidavit from its General Contractor for Unit
602C at Summer Cove Condominium.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing has been

furnished by facsimile and U.S. Mail to the above-named addressee,

attorney on January 22, 2008.

THE EDWARDS LAW FIRM, PL
1901 Morrill Street
Sarasota, Florida 34236

Florida