On June 17, 1974 a
Party Discovery
was filed
involving a dispute between
Hanedi Bashjawish,
Mohammed Bashjawish,
Rihanna Bashjawish,
Sophia Bashjawish,
and
Agathe Civil,
Geico General Insurance Company,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
Preview
1/12/2021 04:26:53 PM
CASE NO.: 502020ca008464 AD
MOHAMMED BASHJAWISH, HANEDI BASHJAWISH,
SOPHIA BASHJAWISH, and RIHANNA BASHJAWISH, a
minor by and through her natural parent and guardian,
MOHAMMED BASHJAWISH,
Plaintiff,
vs.
AGATHE CIVIL and GEICO GENERAL INSURANCE
COMPANY, a foreign profit corporation,
Defendants.
PLAINTIFF’S RESPONSE TO DEFENDANT'S REQUEST FOR ADMISSIONS
COMES NOW, the Plaintiff, SOPHIA BASHJA WISH, by and through the undersigned counsel, and files
his Response to Defendant's Request for Admissions as follows:
1. Plaintiff received or is entitled to receive benefits from a collateral source, as
defined by Florida Statute 768.76, for medical bills alleged to have been incurred as a result of the
incident described in the Complaint.
Admit.
2. Plaintiff received or is entitled to receive benefits from a collateral source, as
defined by Florida Statute 768.76 for loss of wages or income alleged to have been sustained as a
result of the incident described in the Complaint.
Deny.
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 01/12/2021 04:26:53 PM ***3. Plaintiff received or is entitled to receive benefits under the Personal Injury
Protection portion of an automobile policy for medical bills alleged to have been incurred as a
result of the incident described in the Complaint.
Admit.
4. Plaintiff received or is entitled to receive benefits under the Personal Injury
Protection portion of an automobile insurance policy for loss of wage or income alleged to have
been sustained as a result of the incident described in the Complaint.
Deny.
5. Plaintiff received or is entitled to receive benefits under the medical payments
provisions of an automobile insurance policy for medical bills alleged to have been incurred as a
result of the incident described in the Complaint.
Deny.
6. Plaintiff is subject to a deductible under the Personal Injury Protection portion of
an automobile insurance policy.
Deny.
7. Plaintiff received or is entitled to receive benefits pursuant to personal or group
health insurance policy, for which no subrogation rights exist, for medical bills alleged to have
been incurred as a result of the incident described in the Complaint.
Deny.
8. Plaintiff received or is entitled to receive benefits pursuant to a personal or group
wage continuation plan or policy, for which no subrogation rights exist, for lost wages or income
alleged to have been incurred as a result of the incident described in the Complaint.
Deny.9. Plaintiff is an insured person under the Personal Injury Protection portion of an
automobile insurance policy which was in force on the date of the incident described in the
Complaint which provides payment of benefits of eighty (80%) percent of all reasonable and
necessary medical expenses incurred and sixty (60%) percent of loss of income or earning
capacity from inability to work as a result of injury sustained from the incident described in the
Complaint.
Admit.
10. This action is subject to the Florida Motor Vehicle No-Fault Law, Florida Statutes
Sections 627.730--627.7405.
Admit.
11. At all times material hereto, the Defendant complied with the provision and.
security requirements set forth in Florida Statute 627.737(1).
Admit.
12. The Defendant herein is entitled to a tort exemption under Florida Statute Section
627.737, and the Plaintiff must prove at least one of the following in order to prevail on Plaintiff's
personal injury claim:
. Significant and permanent loss of an important bodily function.
. Permanent injury within a reasonable degree of medical probability,
other than scarring or disfigurement.
. Significant and permanent scarring or disfigurement.
. Death.
Admit.
13. Plaintiff, SOPHIA BASHJAWISH, has not suffered any loss of wages as a resultof the accident described in the Complaint.
Admit.
14. Plaintiff, SOPHIA BASHJAWISH, has not suffered any loss of earning capacity
as a result of the accident described in the Complaint.
Admit.
15. Plaintiff, SOPHIA BASHJAWISH, has not incurred any medical expenses which
have not been reimbursed or paid for by the PIP carrier or other collateral source as a result of
the accident described in the Complaint.
Deny.
16. Plaintiff, SOPHIA BASHJAWISH, has not sustained a permanent injury as a
result of the accident described in the Complaint.
Deny.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was emailed on the
12" of January, 2021, to: Marni Adams, Esq, at wpbgeico@geico.com and David M. Drahos, Esq.
at DMD-KD@kubickidraper.com.
LEEDER LAW
Attorneys for Plaintiff
8551 West Sunrise Blvd. | Ste. 202
Plantation, FL 33322
Telephone (954) 734-2382
Pleadings@leederlaw.com
pyis) Colne § DebPereio
THOMAS H. LEEDER, ESQ.
FBN: 746401
COLLINS S. DELPERCIO, ESQ.
FBN: 1014971
Document Filed Date
January 12, 2021
Case Filing Date
June 17, 1974
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1/12/2021 04:26:53 PM CASE NO.: 502020ca008464 AD MOHAMMED BASHJAWISH, HANEDI BASHJAWISH, SOPHIA BASHJAWISH, and RIHANNA BASHJAWISH, a minor by and through her natural parent and guardian, MOHAMMED BASHJAWISH, Plaintiff, vs. AGATHE CIVIL and GEICO GENERAL INSURANCE COMPANY, a foreign profit corporation, Defendants. PLAINTIFF’S RESPONSE TO DEFENDANT'S REQUEST FOR ADMISSIONS COMES NOW, the Plaintiff, SOPHIA BASHJA WISH, by and through the undersigned counsel, and files his Response to Defendant's Request for Admissions as follows: 1. Plaintiff received or is entitled to receive benefits from a collateral source, as defined by Florida Statute 768.76, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. Admit. 2. Plaintiff received or is entitled to receive benefits from a collateral source, as defined by Florida Statute 768.76 for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. Deny. *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 01/12/2021 04:26:53 PM ***3. Plaintiff received or is entitled to receive benefits under the Personal Injury Protection portion of an automobile policy for medical bills alleged to have been incurred as a result of the incident described in the Complaint. Admit. 4. Plaintiff received or is entitled to receive benefits under the Personal Injury Protection portion of an automobile insurance policy for loss of wage or income alleged to have been sustained as a result of the incident described in the Complaint. Deny. 5. Plaintiff received or is entitled to receive benefits under the medical payments provisions of an automobile insurance policy for medical bills alleged to have been incurred as a result of the incident described in the Complaint. Deny. 6. Plaintiff is subject to a deductible under the Personal Injury Protection portion of an automobile insurance policy. Deny. 7. Plaintiff received or is entitled to receive benefits pursuant to personal or group health insurance policy, for which no subrogation rights exist, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. Deny. 8. Plaintiff received or is entitled to receive benefits pursuant to a personal or group wage continuation plan or policy, for which no subrogation rights exist, for lost wages or income alleged to have been incurred as a result of the incident described in the Complaint. Deny.9. Plaintiff is an insured person under the Personal Injury Protection portion of an automobile insurance policy which was in force on the date of the incident described in the Complaint which provides payment of benefits of eighty (80%) percent of all reasonable and necessary medical expenses incurred and sixty (60%) percent of loss of income or earning capacity from inability to work as a result of injury sustained from the incident described in the Complaint. Admit. 10. This action is subject to the Florida Motor Vehicle No-Fault Law, Florida Statutes Sections 627.730--627.7405. Admit. 11. At all times material hereto, the Defendant complied with the provision and. security requirements set forth in Florida Statute 627.737(1). Admit. 12. The Defendant herein is entitled to a tort exemption under Florida Statute Section 627.737, and the Plaintiff must prove at least one of the following in order to prevail on Plaintiff's personal injury claim: . Significant and permanent loss of an important bodily function. . Permanent injury within a reasonable degree of medical probability, other than scarring or disfigurement. . Significant and permanent scarring or disfigurement. . Death. Admit. 13. Plaintiff, SOPHIA BASHJAWISH, has not suffered any loss of wages as a resultof the accident described in the Complaint. Admit. 14. Plaintiff, SOPHIA BASHJAWISH, has not suffered any loss of earning capacity as a result of the accident described in the Complaint. Admit. 15. Plaintiff, SOPHIA BASHJAWISH, has not incurred any medical expenses which have not been reimbursed or paid for by the PIP carrier or other collateral source as a result of the accident described in the Complaint. Deny. 16. Plaintiff, SOPHIA BASHJAWISH, has not sustained a permanent injury as a result of the accident described in the Complaint. Deny.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was emailed on the 12" of January, 2021, to: Marni Adams, Esq, at wpbgeico@geico.com and David M. Drahos, Esq. at DMD-KD@kubickidraper.com. LEEDER LAW Attorneys for Plaintiff 8551 West Sunrise Blvd. | Ste. 202 Plantation, FL 33322 Telephone (954) 734-2382 Pleadings@leederlaw.com pyis) Colne § DebPereio THOMAS H. LEEDER, ESQ. FBN: 746401 COLLINS S. DELPERCIO, ESQ. FBN: 1014971