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Runyon's answer to Thomas A Mix 3rd Request for Admssions .pdf



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IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR INDIAN RIVER COUNTY FLORIDA

THOMAS MIX,
Plaintiff,

Case No.: 312015CA000961XXXXXX
DEFENDANT, JEANETTE RUNYON'S
RESPONSE TO PLAINTIFF’S THIRD
REQUEST FOR ADMISSIONS

vs

JEANETTE TYE RUNYON,
Defendant,

_________________________/

COMES NOW the Defendant, Jeanette Tye Runyon, acting Pro Se, answering
Plaintiff Thomas Mix’s Third Request For Admissions.
1. Objection to Plaintiff’s question on the grounds that Plaintiff is seeking
Defendant’s work product in preparing for litigation. Code of Civil
Procedures states that legal research in not discoverable under any
circumstances.
2. Denied



-1DEFENDANT, JEANETTE RUNYON'S RESPONSE TO PLAINTIFF’S THIRD REQUEST FOR ADMISSIONS

3. Objection to Plaintiff’s request on the grounds that this question has been
asked and answered in previous admissions and in depositions. Continuous
demands into the same subject matter constitute abuse and harassment.
4. Objection to Plaintiff’s request on the grounds that this question has been
asked and answered in previous admissions and in depositions. Continuous
demands into the same subject matter constitute abuse and harassment.
5. Objection to Plaintiff’s question on the grounds that Plaintiff is seeking
Defendant’s work product in preparing for litigation. Code of Civil
Procedures states that legal research in not discoverable under any
circumstances.
6. Objection to Plaintiff’s question on the grounds that Plaintiff’s question is
too vague, overly broad not relevant to the subject matter of Plaintiff’s
lawsuit and not likely to lead to the discovery of admissible evidence.
7. Objection to Plaintiff’s question on the grounds that Plaintiff’s question is
too vague, overly broad not relevant to the subject matter of Plaintiff’s
lawsuit and not likely to lead to the discovery of admissible evidence.
8. Objection to Plaintiff’s question as it is redundant to question number 2.
Further the Plaintiff’s question is too vague and seeks information not
relevant to the subject matter of Plaintiff’s lawsuit.
9. Objection to Plaintiff’s question on the grounds that the question is too
vague and seeks information not relevant to the subject matter of Plaintiff’s
lawsuit.
10. Objection to Plaintiff’s question as it asking for an opinion about the
Plaintiff’s state of mind. Defendant is not a mind reader. Subject to that
objection, denied.


-2DEFENDANT, JEANETTE RUNYON'S RESPONSE TO PLAINTIFF’S THIRD REQUEST FOR ADMISSIONS

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the forgoing answers to Plaintiff’s
Third Request For Admissions has been sent, electronically and by United States Post
Office, First Class Mail, postage prepaid to, Rooney & Rooney, P.A., Attention, Matthew
Randall Groom FBN: 106373, 1517 20th Street, Vero Beach, Florida 32960 on this 13 day of
July, 2017.

Jeanette Tye Runyon



-3DEFENDANT, JEANETTE RUNYON'S RESPONSE TO PLAINTIFF’S THIRD REQUEST FOR ADMISSIONS


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