On September 07, 2021 a
Party Discovery
was filed
involving a dispute between
Montes, Yajaira,
and
Douglas, Dennis,
Douglas, Donna,
Geico General Insurance Company,
for AUTO NEGLIGENCE - CIRCUIT
in the District Court of Pinellas County.
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_/
Case Number:21-004236-CI
Filing # 134086976 E-Filed 09/07/2021 10:14:16 AM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR THE COUNTY OF PINELLAS, STATE OF FLORIDA
CIVIL DIVISION
YAJAIRA MONTES,
Plaintiff,
vs. CASE NO.:
DIVISION:
DONNA DOUGLAS; DENNIS
DOUGLAS; and GEICO GENERAL
INSURANCE COMPANY,
Defendants.
REQUEST FOR ADMISSIONS, REQUEST TO PRODUCE AND INTERROGATORIES
TO DEFENDANT, GEICO GENERAL INSURANCE COMPANY
COMES NOW, the Plaintiff, YAJAIRA MONTES, by and through her undersigned
counsel, pursuant to Rule 1.370 Florida Rules of Civil Procedure, and files this Request for
Admissions, Request to Produce and Interrogatories and requests Defendant, GEICO GENERAL
INSURANCE COMPANY, to admit, in this action, that each of the following statements are
true:
1. Plaintiff has complied with all conditions precedent to the filing of this action.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to the
Defendant via service of process.
CATANIA & CATANIA, P
MARC B. PARISH, ESQUIRE
FBN: 0056714
efiling@cataniaandcatania.com
Bank of America Plaza, Suite 2400
101 E. Kennedy Boulevard
Tampa, FL 33602
813/222-8545
Attorney for Plaintiff
***ELECTRONICALLY FILED 09/07/2021 10:14:13 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
_5
INTERROGATORIES
1. If admission #1 isdenied, please state the factual basis of the denial.
On behalf of GEICO GENERAL INSURANCE
COMPANY
Printed name
STATE OF FLORIDA
of,
COUNTY OF
SWORN TO AND SUBSCRIBED before me, personally appeared
, who, after being first duly sworn, deposes and says
that he/she/it executed the foregoing Interrogatories on this the day
2021.
NOTARY PUBLIC
My Commission Expires:
REQUEST FOR
REQUEST FOR PRODUCTION
PRODUCTION
1.
1. If
If admission
admission #1
#1 is
is denied,
denied, please
please produce
produce any
any and
and all
all documents
documents that
that substantiate
substantiate
Defendant’s
Defendant’s denial.
denial.
Document Filed Date
September 07, 2021
Case Filing Date
September 07, 2021
Category
AUTO NEGLIGENCE - CIRCUIT
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_/ Case Number:21-004236-CI Filing # 134086976 E-Filed 09/07/2021 10:14:16 AM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR THE COUNTY OF PINELLAS, STATE OF FLORIDA CIVIL DIVISION YAJAIRA MONTES, Plaintiff, vs. CASE NO.: DIVISION: DONNA DOUGLAS; DENNIS DOUGLAS; and GEICO GENERAL INSURANCE COMPANY, Defendants. REQUEST FOR ADMISSIONS, REQUEST TO PRODUCE AND INTERROGATORIES TO DEFENDANT, GEICO GENERAL INSURANCE COMPANY COMES NOW, the Plaintiff, YAJAIRA MONTES, by and through her undersigned counsel, pursuant to Rule 1.370 Florida Rules of Civil Procedure, and files this Request for Admissions, Request to Produce and Interrogatories and requests Defendant, GEICO GENERAL INSURANCE COMPANY, to admit, in this action, that each of the following statements are true: 1. Plaintiff has complied with all conditions precedent to the filing of this action. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to the Defendant via service of process. CATANIA & CATANIA, P MARC B. PARISH, ESQUIRE FBN: 0056714 efiling@cataniaandcatania.com Bank of America Plaza, Suite 2400 101 E. Kennedy Boulevard Tampa, FL 33602 813/222-8545 Attorney for Plaintiff ***ELECTRONICALLY FILED 09/07/2021 10:14:13 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** _5 INTERROGATORIES 1. If admission #1 isdenied, please state the factual basis of the denial. On behalf of GEICO GENERAL INSURANCE COMPANY Printed name STATE OF FLORIDA of, COUNTY OF SWORN TO AND SUBSCRIBED before me, personally appeared , who, after being first duly sworn, deposes and says that he/she/it executed the foregoing Interrogatories on this the day 2021. NOTARY PUBLIC My Commission Expires: REQUEST FOR REQUEST FOR PRODUCTION PRODUCTION 1. 1. If If admission admission #1 #1 is is denied, denied, please please produce produce any any and and all all documents documents that that substantiate substantiate Defendant’s Defendant’s denial. denial.