Party Discovery: WATT, DORATTA vs PROGRESSIVE AMERICAN INSURANCE COMPANY

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                                Filing # 143297205 E-Filed 02/04/2022 10:25:32 AM

IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISON

DORATTA WATT and ALYSSA
WATT, a minor by and through her
parent and natural guardian, DORATTA
WATT,

Plaintiffs, CASE NO: 21-CA-513
-v-

PROGRESSIVE AMERICAN
INSUANCE COMPANY,

Defendant.
/

PLAINTIFF’S RESPONSE TO REQUEST FOR ADMISSIONS
Plaintiff, ALYSSA WATT, a minor by and through her parent and natural guardian,
DORATTA WATT, by and through the undersigned attorney, responds to the Request for admissions

of Defendant, WILLIAM BURT MACK, served the 5th day of October, 2021, as follows:

1. Admit.
2. Admit.
3. Deny.
4. Admit.
5. Admit.
6. Admit.
7. Admit.
8. Admit.
9. Admit.

10. Admit.11.

12.

13.

14,

15.

16.

17.

18.

19,

20.

21.

22.

23.

24.

25.

26.

27.

28.

29.

Admit.

Deny.

Admit.

Deny.

Admit.

Deny.

Plaintiff can neither admit nor deny this request. Improper predicate regarding
qualification of this witness to answer question as to whether the seatbelt/shoulder harness
was functional and operational. Subject to objection, Plaintiff was wearing a safety
restraint. Plaintiff has made a reasonable inquiry and the information known or readily
obtainable is insufficient to enable the Plaintiff to admit or deny the allegations in this

request.

Admitted that some issues in this litigation are applicable to the Florida Motor Vehicle
No-Fault Law, Florida Statute 627.730-627.7405.

Admit.
Admit.
Deny.
Admit.
Deny.
Deny.
Deny.
Deny.
Deny.
Deny.

Deny.CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished, by

email, this 4" day of February, 2022 to: Christopher M. Ballard, Esquire, Law Office of Terryl

Blackmon Walker, 600 North Westshore Blvd., Suite 300, Tampa, FL 33609

TampaHC@progressive.com and Christopher Ballard(@progressive.com.

/s/ Christopher Borzell

at

Christopher Borzell, Attorney

Morgan & Morgan Tampa, P.A.

One Tampa City Center

201 N. Franklin Street, 7th Floor

Tampa, FL 33602

Tele: (941) 271-6384

Fax: (941) 271-6484

Florida Bar #: 68277

Attorney for Plaintiff

Primary Email: CBorzell(@ForThePeople.com
Secondary: CT BPleadings@ForThePeople.com
Scheduling: RHoward@ForThePeople.com