1.

[CIVIL] CASE NO.: 2016-123

ACTION: MOTION TO COMPEL ADMISSIONS

OF STATEMENTS OF FACT

4
5VENUE: AT THE COUNTY COURT OF CANTERBURY
6THE CANTERBURY COMBINED COURT CENTRE
7THE LAW COURTS
8CHAUCER ROAD
9CANTERBURY
10KENT CT1 1ZA
11
12

BEFORE:

13

JUDGE BARRY BENCHWORTH

14

_____________________________/

15

BETWEEN:

16

MR DANNY KILMER

17

256 OLD DOVER ROAD

18

CANTERBURY

19

KENT CT1 3JQ

COMPLAINANT

20

AND

21
22

MASTER JULIAN JEREMIAH

23
c/o:

24

THE ACCUSED

314 BROAD OAK ROAD at: CANTERBURY

25

SOUTH-EAST GREAT BRITAIN

26

_____________________________/

27
28//////////
29//////////
30//////////
31//////////
32//////////
33//////////
2
3

Page 1 of 2

MOTION TO COMPEL ADMISSIONS OF STATEMENTS OF FACT

1.
1

MOTION TO COMPEL ADMISSIONS OF STATEMENTS OF FACT

2
3THE ACCUSED Master Julian Jeremiah, pursuant to Rule 1.380 Florida Rules of Civil
4Procedure, moves this Honorable Court for an Order compelling Mr. Danny Kilmer to make
5admissions to the statements of fact previously requested by the accused and states:
6
71. On the 18th day of September 2016, the accused served complainant with a Notice to
8

Admit Facts, a copy of which attached Exhibit is included and integrated by reference as

though completely stated and visible herein.

102. Complainant failed and refused to respond to the accuseds request for admissions as
11

required by Order 20, Part I, Rule 2(1), or Order 17, Rule 2 of The County Court Rules

12

1981, No. 1687 (L. 20).

133. Pursuant to Order 20, Part I, Rule 2(2) of The County Court Rules 1981, No. 1687 (L. 20),
14

complainant had 7 days to respond to the accuseds request.

154. More than 7 days elapsed.

165. The accused is entitled to entry of an Order compelling the requested admissions as a
17

matter of law even if the admissions previously requested are inadmissible, so long as the

18

resulting outcome of the admissions can reasonably be calculated to lead to the discovery

19

of admissible evidence.

20
21WHEREFORE Master Julian Jeremiah moves the Court to enter an Order compelling
22complainant to make admissions to the previously requested statements of fact;
23
24RESPECTFULLY SUBMITTED this 31st day of October 2016.
25
26
27

_______________________________________

28

Master Julian Jeremiah, The Accused

29
30
31

Attached Certificate of Service Exhibit is included and integrated

by reference as though completely stated and visible herein.

32
33//////////
2
3

Page 2 of 2

MOTION TO COMPEL ADMISSIONS OF STATEMENTS OF FACT