IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT,

ST. LUCIE COUNTY, FLORIDA

Case No. 00-CA-001074-(OC)

FIGG BRIDGE ENGINEERS, INC.,

Plaintiff,

v.

CHARLES GRANDE, EDWARD

McKAY, ROGER SHARP and

KEVIN STINNETTE,

Defendants.

/

DEFENDANTS’ THIRD REQUEST FOR ADMISSIONS

The defendants, CHARLES GRANDE, EDWARD McKAY, ROGER SHARP and KEVIN STINNETTE, pursuant to Fla. R. Civ. P. 1.370(a), request that the plaintiff admit the truth of the following:

    1. The document attached hereto as Exhibit A is a substantially accurate partial transcript of the August 17, 2000 meeting (referenced in paragraph 66 of the Complaint) (the "Meeting") of the St. Lucie County Expressway and Bridge Authority.
    2. Exhibit A sets forth the only part of the Meeting at which a defendant allegedly made an allegedly defamatory statement
    3. Exhibit A contains the allegedly defamatory statement in its entirety.
  1. Exhibit A fully and fairly reflects the allegedly defamatory statement.
  2. To the extent that Exhibit A is not precisely accurate, or the statements made at the Meeting might arguably have been transcribed differently, any such inaccuracies or differences are immaterial to the issues raised in this action.
  3. Any of the statements identified as "unintelligible" in Exhibit A were immaterial to the issues raised in this action.
  4. Exhibit A is admissible in this action as substantive evidence of the allegedly defamatory statements made at the Meeting.
  5. All of Exhibit A is admissible in order to show the allegedly defamatory statements in their full context, as required by the substantive law.
  6. Harold G. Melville attended the Meeting.
  7. Harold G. Melville attended the Meeting in his capacity as counsel to Figg Bridge Engineers, Inc.
  8. Linda Figg McAllister attended the Meeting.
  9. Linda Figg McAllister attended the meeting as an agent of Figg, and made a presentation on Figg’s behalf.
  10. Harold G. Melville did not address the Meeting to refute or deny the allegedly defamatory statements.
  11. Linda Figg McAllister did not address the Meeting to refute or deny the

allegedly defamatory statements.

I HEREBY CERTIFY that a copy of this Defendants’ Third Request for Admissions was served by fax and by U.S. Mail on October 31, 2000 upon counsel for

the plaintiff: Harold G. Melville, Melville & Sowerby, P.L., 2940 S. 25th St., Fort Pierce, FL 34981-5605.

Respectfully submitted,

 

 

Robert Rivas

The Rivas Law Firm

311 S. Calhoun St., Suite 206

Tallahassee, FL 32301-1802

Tel: (850) 412-0306

Fax: (850) 412-0909

Florida Bar No 896969

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