Party Discovery: BUZZARD BEACH INC vs RICCIARDI, SUZANNE

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                                Filing # 136436970 E-Filed 10/13/2021 09:15:56 AM


                             IN THE CIRCUIT COURT, FIFTH JUDICIAL CIRCUIT,
                                    IN AND FOR LAKE COUNTY, FLORIDA

            BUZZARD BEACH INC                                          CASE NO.: 2021-001554-CA
            a Florida for-profit corporation, and                      DIVISION:
            JACK PROTZMAN,

                   Plaintiffs,

            Vv.


            SUZANNE RICCIARDI

                   Defendant.



                   REQUEST FOR ADMISSIONS TO DEFENDANT, SUZANNE RICCIARDI


                   COME(S)       NOW   the Plaintiff(s), BUZZARD     BEACH    INC. and JACK        PROTZMAN
            (hereinafter collectively as “Plaintiff(s)”, by and through the undersigned counsel and pursuant to
            Rule 1.370, Florida Rules of Civil Procedure, hereby request(s) that the Defendant, SUZANNE
            RICCIARD (hereinafter as the “you”, “your”, or “Defendant”), admit the following within forty-
            five (45) days from the date of service hereof:


                   Please admit that this action brought against the Defendant(s) properly and correctly
                   names the parties to be sued in this cause.

                   Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought
                   before the Circuit Court in Lake County, Florida.

                   Please admit that the service of process against the Defendant(s) was proper.

                   Please admit that this is an action for damages in excess of Thirty Thousand Dollars
                   ($30,000) arising in Lake County, Florida.

                   Please admit that you and the Plaintiff formed an oral agreement to enter into a joint
                   venture to purchase the property located at 12335 US Highway 441, Tavares, Florida,
                   (hereinafter as the “property”).

                   Please admit that you and the Plaintiff formed an oral agreement wherein the Plaintiff
                   would rehab, renovate, and rent out the property.




FILED: LAKE COUNTY, GARY J. COONEY, CLERK,               10/13/2021 09:39:41 AM
Please admit that you and the Plaintiff formed an oral agreement wherein when the
   property sold, you and the Plaintiff would split the net sale proceeds evenly in a 50/50
   split.

   Please admit that the property received a substantial capital upgrade from the rehab and
   renovations performed and paid for by the Plaintiff, and that the parcel is enhanced in
   value because of said upgrades.

   Please admit that the Plaintiff performed maintenance on and managed the property as
   needed since the date the property was purchased, until the summer of 2021.

10 Please admit that the Plaintiff provided you with funds to pay property taxes on the
   property on more than one occasion.

11 Please admit that the Plaintiff provided you with funds when you requested in the form
   of cash.

12 Please admit that you did not share in the cost of rehab and renovations for the property.

13 Please admit that you did not compensate the Plaintiff for the rehab and renovations he
   performed on the property, which included labor, supplies, equipment rentals, and
   materials.

14 Please admit that the Plaintiff was never denied access to the property up until the summer
   of 2021, when you ousted him by changing the locks on the property.




                
     
CERTIFICATE OF SERVICE


I HEREBY CERTIFY, that on this 12" day of October, 2021, a true and correct copy of the

foregoing document(s) has been sent via the Florida E-filing Portal System to all registered

participants, which includes electronic service to Defendant’s counsel of record: Michael G.

Moore, Esq. at michael@moorelex.com.




DAVID G HAMILTON PLLC


Siodle fpcs
David G. Hamilton, Esq.,
Florida Bar #1015311
501 N. Ridgewood Ave Suite B
Edgewater, FL 32132
Attorney: davidghamiltonpllc@gmail.com
Staff: dghparalegal@gmail.com
P (386) 689-5949
Attorney for the Plaintiffs