Request for Admissions - Due Date: Complete Date:

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                          Filing # 70259496 E-Filed 04/04/2018 05:40:30 PM

17-3651 TN THE COUNTY COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA

CIVIL DIVISION
CASE NUMBER:
MEJLAS MEDICAL CENTER, INC.,
a/a/o PEDRO OLIVARES,

Plaintiff,
vs.

GEICO INDEMNITY COMPANY,

Defendant.
i

PLAINTIFY’S FIRST REQUEST FOR ADMISSIONS TO

COMES NOW, Plaintiff, MEHAS MEDICAL CENTER, INC., as assignee of PEDRO
OLIVARES by and through undersigned counsel and pursuant to rule 1.370, Florida Rules of
Civil Procedure, requests that Defendant, GEICO INDEMNITY COMPANY, hereby to admit
the truth of the matters hereinafter set forth on or by the thirty (0th) day after service hereof by
answering in writing.

1. The above-described automobile policy issued by the Defendant was in full force
and affect at the time of the subject accident and provided coverage for PIP benefits for bodily
injuries sustained by the Plaintiff's assignor in the subject accident.

2. Defendant never denied Plaintiff's and/or Plaintiff's assignor’s claim based u…