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Filing # 136065861 E-Filed 10/06/2021 06:30:14 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT IN AND FOR
CITRUS COUNTY, FLORIDA
DORATTA WATT and ALYSSA WATT, a
minor by and through her Parent and Natural
Guardian, DORATTA WATT,
Plaintiffs, CASE NO: 21-CA-513
CIVIL DIVISION
v.
PROGRESSIVE AMERICAN
INSURANCE COMPANY,
Defendant.
/
DEFENDANT'S RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS
Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, by and through the
undersigned attorney, files Defendant's Responses to Plaintiffs’ Request for Admissions dated July
29, 2021, and would state as follows:
1. Admit.
2. Admit that Defendant transacts its customary business in Citrus County, Florida.
Remaining allegations, deny.
3. Admit that Plaintiffs had an insurance policy, at the time of the subject motor
vehicle accident, with Progressive American Insurance Company that provided for
Underinsured/Uninsured Motorist coverage subject to the terms and limitations of the policy;
however, deny that Plaintiffs are entitled to recover.
4. Admit that Plaintiffs had an insurance policy, at the time of the subject motor
vehicle accident, with Progressive American Insurance Company that provided for
Underinsured/Uninsured Motorist coverage subject to the terms and limitations of the policy;
however, deny that Plaintiffs are entitled to recover.Case No: 21-CA-513
5. Insufficient information at this time; therefore, can neither admit nor deny.
Defendant reserves the right to amend this response.
6. Deny.
7. Objection; vague and ambiguous; irrelevant and not reasonably calculated to lead
to admissible evidence. Without waiving said objection, admit that Plaintiffs had an insurance
policy, at the time of the subject motor vehicle accident, with Progressive American Insurance
Company that provided for Underinsured/Uninsured Motorist coverage subject to the terms and
limitations of the policy; however, deny that Plaintiffs are entitled to recover.
8. Objection; vague and ambiguous; irrelevant and not reasonably calculated to lead
to admissible evidence. Without waiving said objection, admit that Plaintiffs had an insurance
policy, at the time of the subject motor vehicle accident, with Progressive American Insurance
Company that provided for Underinsured/Uninsured Motorist coverage subject to the terms and
limitations of the policy; however, deny that Plaintiffs are entitled to recover.
9. Objection; vague and ambiguous; irrelevant and not reasonably calculated to lead
to admissible evidence.
SUPPLEMENTAL INTERROGATORY
10. Discovery, investigation, and depositions remain incomplete at this date. The
above responses have been formulated as completely as possible based upon reasonable inquiry,
investigation, and review of the documentation and information available at this time. The issues
of fault, damages, causation, and permanency, among others, constitute ultimate issues whose
determination lies within the province of the finder of fact.Case No: 21-CA-513
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished via E-Mail on October 6, 2021 to Christopher Borzell, Esquire, Morgan & Morgan,
Tampa, P.A., Attorney for Plaintiffs, Doratta Watt and Alyssa Watt, a minor by and through her
Parent and Natural Guardian, Doratta Watt, CTBPleadings@forthepeople.com;
chorzeli@forthepeoplecom, ssssS—S
Law Office of Terryl Blackmon Walker
Attorneys for Defendant
600 North Westshore Blvd., Suite 300
Tampa, FL 33609
(813) 371-4024 (Asst.)/(813) 371-3945 (Direct)
Fax: (866) 516-8617
SERVICE DESIGNATIONS:
Primary: TampaHC@progressive.com
Secondary: Christopher_Ballard@progressive.com
By:
CHRISTOPHER M. BALLARD, ESQUIRE
Florida Bar No. 10274
"Salaried Employees of Progressive Casualty Insurance Company”
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Filing # 136065861 E-Filed 10/06/2021 06:30:14 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA DORATTA WATT and ALYSSA WATT, a minor by and through her Parent and Natural Guardian, DORATTA WATT, Plaintiffs, CASE NO: 21-CA-513 CIVIL DIVISION v. PROGRESSIVE AMERICAN INSURANCE COMPANY, Defendant. / DEFENDANT'S RESPONSES TO PLAINTIFFS' REQUEST FOR ADMISSIONS Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, by and through the undersigned attorney, files Defendant's Responses to Plaintiffs’ Request for Admissions dated July 29, 2021, and would state as follows: 1. Admit. 2. Admit that Defendant transacts its customary business in Citrus County, Florida. Remaining allegations, deny. 3. Admit that Plaintiffs had an insurance policy, at the time of the subject motor vehicle accident, with Progressive American Insurance Company that provided for Underinsured/Uninsured Motorist coverage subject to the terms and limitations of the policy; however, deny that Plaintiffs are entitled to recover. 4. Admit that Plaintiffs had an insurance policy, at the time of the subject motor vehicle accident, with Progressive American Insurance Company that provided for Underinsured/Uninsured Motorist coverage subject to the terms and limitations of the policy; however, deny that Plaintiffs are entitled to recover.Case No: 21-CA-513 5. Insufficient information at this time; therefore, can neither admit nor deny. Defendant reserves the right to amend this response. 6. Deny. 7. Objection; vague and ambiguous; irrelevant and not reasonably calculated to lead to admissible evidence. Without waiving said objection, admit that Plaintiffs had an insurance policy, at the time of the subject motor vehicle accident, with Progressive American Insurance Company that provided for Underinsured/Uninsured Motorist coverage subject to the terms and limitations of the policy; however, deny that Plaintiffs are entitled to recover. 8. Objection; vague and ambiguous; irrelevant and not reasonably calculated to lead to admissible evidence. Without waiving said objection, admit that Plaintiffs had an insurance policy, at the time of the subject motor vehicle accident, with Progressive American Insurance Company that provided for Underinsured/Uninsured Motorist coverage subject to the terms and limitations of the policy; however, deny that Plaintiffs are entitled to recover. 9. Objection; vague and ambiguous; irrelevant and not reasonably calculated to lead to admissible evidence. SUPPLEMENTAL INTERROGATORY 10. Discovery, investigation, and depositions remain incomplete at this date. The above responses have been formulated as completely as possible based upon reasonable inquiry, investigation, and review of the documentation and information available at this time. The issues of fault, damages, causation, and permanency, among others, constitute ultimate issues whose determination lies within the province of the finder of fact.Case No: 21-CA-513 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via E-Mail on October 6, 2021 to Christopher Borzell, Esquire, Morgan & Morgan, Tampa, P.A., Attorney for Plaintiffs, Doratta Watt and Alyssa Watt, a minor by and through her Parent and Natural Guardian, Doratta Watt, CTBPleadings@forthepeople.com; chorzeli@forthepeoplecom, ssssS—S Law Office of Terryl Blackmon Walker Attorneys for Defendant 600 North Westshore Blvd., Suite 300 Tampa, FL 33609 (813) 371-4024 (Asst.)/(813) 371-3945 (Direct) Fax: (866) 516-8617 SERVICE DESIGNATIONS: Primary: TampaHC@progressive.com Secondary: Christopher_Ballard@progressive.com By: CHRISTOPHER M. BALLARD, ESQUIRE Florida Bar No. 10274 "Salaried Employees of Progressive Casualty Insurance Company”