Free Response to Discovery - District Court of Delaware - Delaware

Case 1:04-cv-00419-JJF

Document 101

Filed 08/23/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CATHY D. BROOKS-MCCOLLUM, et al. ) Plaintiff, ) ) v. ) ) STATE FARM INSURANCE COMPANY, ) ) Defendant. ) ) Civil Action No. 04-419 JJF

ANSWER OF DEFENDANT STATE FARM INSURANCE COMPANY TO PLAINTIFF'S REQUEST FOR ADMISSIONS DIRECTED TO ED B. RUST The defendant State Farm objects to the Request for Admission directed to Edward B. Rust on the ground that he is not a party to this litigation and State Farm was not properly served with the Request for Admissions. Insofar as the requests can be considered a Request for Admissions directed to State Farm, it answers as follows. 1. 2. 3. Denied. Denied. Rust is unable to admit or deny the request. Affirmative defenses were determined by

counsel. 4. 5. 5. 6. 7. 8. 9. Denied. Denied. [sic there are two number 5's] Denied. Denied. Rust is unable to admit or deny the request as stated. Denied. Denied.

Case 1:04-cv-00419-JJF

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10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32.

Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied.

Case 1:04-cv-00419-JJF

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Filed 08/23/2007

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33. 34. 35. 36. 37. 38. 39. 40. 41. 42. 43. 44. 45. 46. 47. 48. 49. 50. 51. 52. 53.

Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. It is admitted that State Farm issued a policy to Emerald Ridge Service Corporation.

Insureds under the policy are defined by the policy.

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54. 55. 56. 57. 58. 59. 60. 61. 62. 63. 64. 65. 66. 67. 68. 69. 70.

Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Denied. Rust has insufficient information in which to admit or deny this averment. Denied. Denied. Denied. Denied. Denied. Rust cannot admit or deny this averment because it does not seek an admission. CASARINO, CHRISTMAN & SHALK, P.A.

/s/ Stephen P. Casarino STEPHEN P. CASARINO, ESQUIRE BAR I.D. NO. 174 800 North King Street, Suite 200 Wilmington, DE 19801 Attorney for Defendant

Case 1:04-cv-00419-JJF

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Filed 08/23/2007

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CERTIFICATE OF SERVICE I, Stephen P. Casarino, Esq., hereby certify that I have caused to be deposited in the mailbox at 800 North King Street, Suite 200, Wilmington, DE 19801, on this 23rd day of August 2007, a true and correct copy of the attached Objection to Request for Admission to: Cathy D. Brooks-McCollum 115 Emerald Ridge Drive Bear, DE 19701

CASARINO, CHRISTMAN & SHALK, P.A. /S/ Stephen P. Casarino Stephen P. Casarino, Esq. I.D. No. 174 800 N. King Street, Suite 200 P.O. Box 1276 Wilmington, DE 19899-1276 Attorney for the Defendant