On September 13, 2021 a
Party Discovery
was filed
involving a dispute between
Miranda, Ana L,
and
Geico General Insurance Company,
Moore, John,
Ward, Travis N,
for Circuit Civil
in the District Court of Lake County.
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Filing # 136860938 E-Filed 10/19/2021 04:01:08 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR LAKE
COUNTY, FLORIDA
ANA L. MIRANDA,
Plaintiff,
VS.
CASE NO: 2021-CA-1576
TRAVIS N. WARD and GEICO CIVIL DIVISION
GENERAL INSURANCE COMPANY,
Defendants
/
DEFENDANT'S RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS
Defendant, TRAVIS N. WARD, by and through the undersigned attorney, files
Defendant's Responses to Plaintiff's Request for Admissions and would state as follows:
1 Admitted that name is spelled correctly.
2. Admitted.
Admitted.
Admitted for jurisdictional purposes only.
Denied.
Admitted that vehicle was owned by Defendant.
Denied.
Denied.
Denied.
10. Denied.
11 Denied.
12. As discovery has just begun, Defendant cannot admit or deny.
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 10/19/2021 04:22:09 PM.
Case No: 2021-CA-1576
13. Denied.
14. Denied.
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 19, 2021 to Eloisa Pino, Esquire, Morgan & Morgan, Pa, Attorney
for Plaintiff, Ana L. Miranda, epino@forthepeople.com;amichel@forthepeople.com, (689) 219-
2080/(689) 219-2180 (F).
Law Office of Terry] Blackmon Walker
Attorneys for Defendant
901 N. Lake Destiny Rd., Suite 105
Maitland, FL 32751
(407) 949-3418 (Asst.)/(407) 949-3800 (Direct)
Fax: (866) 516-8617
SERVICE DESIGNATIONS:
Primary: OrlandoHC@Progressive.com
Secondary: Joshua_M_Parks@progressive.com
Le , JOSHUA M. PARKS, ESQUIRE
Florida Bar No. 16866
“Salaried Employees of Progressive Casualty Insurance Company”
Document Filed Date
October 19, 2021
Case Filing Date
September 13, 2021
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Filing # 136860938 E-Filed 10/19/2021 04:01:08 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR LAKE COUNTY, FLORIDA ANA L. MIRANDA, Plaintiff, VS. CASE NO: 2021-CA-1576 TRAVIS N. WARD and GEICO CIVIL DIVISION GENERAL INSURANCE COMPANY, Defendants / DEFENDANT'S RESPONSES TO PLAINTIFF'S REQUEST FOR ADMISSIONS Defendant, TRAVIS N. WARD, by and through the undersigned attorney, files Defendant's Responses to Plaintiff's Request for Admissions and would state as follows: 1 Admitted that name is spelled correctly. 2. Admitted. Admitted. Admitted for jurisdictional purposes only. Denied. Admitted that vehicle was owned by Defendant. Denied. Denied. Denied. 10. Denied. 11 Denied. 12. As discovery has just begun, Defendant cannot admit or deny. FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 10/19/2021 04:22:09 PM. Case No: 2021-CA-1576 13. Denied. 14. Denied. 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 19, 2021 to Eloisa Pino, Esquire, Morgan & Morgan, Pa, Attorney for Plaintiff, Ana L. Miranda, epino@forthepeople.com;amichel@forthepeople.com, (689) 219- 2080/(689) 219-2180 (F). Law Office of Terry] Blackmon Walker Attorneys for Defendant 901 N. Lake Destiny Rd., Suite 105 Maitland, FL 32751 (407) 949-3418 (Asst.)/(407) 949-3800 (Direct) Fax: (866) 516-8617 SERVICE DESIGNATIONS: Primary: OrlandoHC@Progressive.com Secondary: Joshua_M_Parks@progressive.com Le , JOSHUA M. PARKS, ESQUIRE Florida Bar No. 16866 “Salaried Employees of Progressive Casualty Insurance Company”