Party Discovery: RIDGE TOP EXTERIORS LLC Vs. MATT S TURPIN, ELISABETH PARKER

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                                Filing #     121100638 E-Filed 02/09/2021                04:08:59 PM

                                 IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
                                IN AND FOR PINELLAS COUNTY, FLORIDA                            -

                                                                                                  CIVIL DIVISION

                RIDGE TOP EXTERIORS, LLC,                                                        Case No.:         2020-006863-SC
                a Florida limited liability company,                                             Division:
                         Plaintiff
                V



                MATT     S. TURPIN, and
                ELISABETH PARKER,
                         Defendants.                         i


                                         PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS
                                                    TO DEFENDANT, MATT S. TURPIN


                         Plaintiff,  RIDGE TOP        EXTERIORS,        LLC,    by  and   through   the  undersigned     counsel, and

                Pursuant to    Rule   1.370 of the   Florida Rules of Civil      Procedure,    hereby serves its First Request for

                Admissions to Defendant MATT S. TURPIN.




                                                         CERTIFICATE OF SERVICE


                         I HEREBY CERTIFY that a true and correct copy ofthe                   foregoing has been furnished by e-
                designation on this 2Z day of February 2021            to:                                            and Counsel for
                Defendants, Law Office ofWM Newt Hudson, Wm Newt Hudson, Esq., 23                           W.  Tarpon Ave. Tarpon
                Springs, FL 34689 @

                                                                                        Cox    Law, PLLC

                                                                                        BY-/S/nwv  R.P111-
                                                                                                   R
                                                                                                   nwv
                                                                                        Sean P. Cox, Esq.
                                                                                        Florida Bar Number 706760
                                                                                        156 E. Bloomindale Ave.
                                                                                        Brandon, FL 33511-8179
                                                                                        Tel: 813-685-8600
                                                                                        Fax:  813-685-8699
                                                                                        Attorney for Defendant
                SPC/vag                                                                 sean@coxlawplc.com
                Cc: Client




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    ***ELECTRONICALLYFILED 02/09/2021              04:08:59 PM:   KEN  BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
                                                                     Definitions

                             A.   The  term   "Subject Property" rgers the property         owned by    Defendants    Matt  Turpin   and
                Elisabeth parker located at 119 S. Sprinlts Blvd., Tarpon Sprinlts, FL 34689.


                 PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT MATT S. TURPIN


                          1.      Admit    or
                                              deny   that the  Defendants, MATT         S. TURPIN and ELISABETH PARKER
                have been    properly   served with the Summons and          Complaint.
                         RESPONSE:

                         2.       Admit    or deny   that the  Court has jurisdiction over the       parties hereto    and the  subject
                matter hereof.

                         RESPONSE:

                         3.       Admit    or  deny that the    Contract attached to the       Complaint, which is       also  attached
                hereto as Exhibit "A.001-A.004," bears the signature of Defendant MATT S.                     TURPIN.

                         RESPONSE:

                         4.       Admit or deny that Contract attached to the          Complaint, which is also attached hereto
                as Exhibit "A.001-A.004," is a true and correct copy ofthe original underlying contract

                         RESPONSE:

                         5.       Admit    or
                                               deny   that  Defendants, MATT          S. TURPIN      and   ELISABETH PARKER
                                                                                                                            ,,
                received the services delineated in the Contract attached hereto as Exhibit "A.001-A.004.

                         RESPONSE:

                         6.       Admit or deny that DefendantsMATT              S. TURPIN and ELISABETH PARKER have
                only paid   one  dollar  and  zero  cents-($1.00)   for the  services  delineated in the Contract attached hereto
                                                ,,
                as Exhibit "A.001-A.004.


                         RESPONSE:

                         7.       Admit or deny that PlaintiffRIDGE TOP EXTERIORS, LLC has provided a benefit(s)
                to DefendantsMATT S. TURPIN and ELISABETH PARKER.

                         RESPONSE:

                         8.       Admit or deny that DefendantsMATT S. TURPIN and ELISABETH PARKER knew
                of the benefit(s) provided to them.

                         RESPONSE:

                         9.       Admit    or
                                              deny that DefendantsMATT            S. TURPIN and ELISABETH PARKER have
                accepted the    benefit(s)provided by      Plaintiff  RIDGE     TOP   EXTERIORS, LLC.
                         RESPONSE:

                          10.     Admit     or deny    Plaintiff  RIDGE      TOP    EXTERIORS,         LLC    is  a  licensed   Florida
                contractor.

                         RESPONSE:

                         11.      Admit or deny that Plaintiff RIDGE TOP EXTERIORS, LLC                       did not need a     permit
                for the work performed to the subject propertyby Plaintiff RIDGE TOP EXTERIORS, LLC.

                         RESPONSE:

                          12.     Admit    or  deny   that Plaintiff did   need   a  permit   for  work   performed     to  the subject
                property by    Plaintiff RIDGE     TOP    EXTERIORS,        LLC.

                         RESPONSE:

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