Preview
we" CASE NUMBER: 502021CA001896XXXXMB Div: AK ****
Filing # 121226136 E-Filed 02/11/2021 11:36:45 AM
19449.1
IN THE CIRCUIT COURT, OF THE
15 JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO:
DIVISION:
MARC HARRIS and NADIA JOSEPH-HARRIS,
Plaintiff,
vs.
ALAN DENSEN
Defendant,
/
PLAINTIFFS’ REQUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW the Plaintiffs, MARC HARRIS and NADIA JOSEPH-HARRIS, by and
through their undersigned counsel, and requests the Defendant, ALAN DENSEN, to admit or deny
the following:
1. That on November 20, 2019, and at all times thereafter, you have been a resident of
Palm Beach County, Florida.
2. That on November 20, 2019, you were the owner and driver of a motor vehicle,
which on that date was involved in an accident at or near W Atlantic Ave in Palm Beach County,
Florida.
3. ‘That your negligence was a cause of the accident on November 20, 2019.
4. ‘That as a result of this motor vehicle accident Plaintiff MARC HARRIS, sustained
permanent injuries within a reasonable degree of medical probability.
5. That as a result of this motor vehicle accident Plaintiff NADIA JOSEPH-HARRIS,
sustained permanent injuries within a reasonable degree of medical probability.
6. ‘That Plaintiff, MARC HARRIS’ conduct did not in any way contribute to the cause
of the automobile accident described above.
CHEN. DAIAARCACUAAIINTY CL INCEDU ARDIIV7ZN FLED N9M141NNNA 44.9045 ANA
HILLY. PAL DLA VUUINE TT, FL, VUOL IE mDnueey, ULLIAN, ver eue! 1 .ou.ty mi7. That Plaintiff, NADIA JOSEPH-HARRIS’ conduct did not in any way contribute
to the cause of the automobile accident described above
8. That the automobile accident described above was not caused by the negligence
and careless actions, or occurrences of third parties and conditions, which were beyond your
control.
9. That Plaintiff, MARC HARRIS, incurred medical expenses for treatment for his
injuries from the accident within a reasonable degree of medical certainty.
10. That Plaintiff, NADIA JOSEPH-HARRIS, incurred medical expenses for
treatment for her injuries from the accident within a reasonable degree of medical certainty
11. That Plaintiff, MARC HARRIS, will continue to incur future medical expenses
for treatment for his injuries from the accident within a reasonable degree of medical certainty.
12. That Plaintiff, NADIA JOSEPH-HARRIS, will continue to incur future medical
expenses for treatment for her injuries from the accident within a reasonable degree of medical
certainty.
13. That as a result of this motor vehicle accident Plaintiff MARC HARRIS sustained
injuries which were caused by the accident within a reasonable degree of medical probability.
14. That as a result of this motor vehicle accident Plaintiff NADIA JOSEPH-HARRIS
sustained injuries which were caused by the accident within a reasonable degree of medical
probability.WE HEREBY CERTIFY that a true and correct copy of the foregoing was served with
Summons, Complaint, Interrogatories and Request to Produce.
SCHULER, HALVORSON, WEISSER,
ZOELLER & OVERBECK, P.A.
Attorneys for Plaintiff
1615 Forum Place, Suite 4-D
Barristers Building
West Palm Beach, FL 33401
Telephone (561) 689-8180
By: /s/ Eric Hayden
WILLIAM D. ZOELLER
Fla, Bar Ne: 155233
wzoeller@shw-law.com
tcoffey@shw-law.com
Eric Hayden
Florida Bar No: 100923
ehayden@shw-law.com
acoates@shw-law.com
Preview
we" CASE NUMBER: 502021CA001896XXXXMB Div: AK **** Filing # 121226136 E-Filed 02/11/2021 11:36:45 AM 19449.1 IN THE CIRCUIT COURT, OF THE 15 JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: DIVISION: MARC HARRIS and NADIA JOSEPH-HARRIS, Plaintiff, vs. ALAN DENSEN Defendant, / PLAINTIFFS’ REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW the Plaintiffs, MARC HARRIS and NADIA JOSEPH-HARRIS, by and through their undersigned counsel, and requests the Defendant, ALAN DENSEN, to admit or deny the following: 1. That on November 20, 2019, and at all times thereafter, you have been a resident of Palm Beach County, Florida. 2. That on November 20, 2019, you were the owner and driver of a motor vehicle, which on that date was involved in an accident at or near W Atlantic Ave in Palm Beach County, Florida. 3. ‘That your negligence was a cause of the accident on November 20, 2019. 4. ‘That as a result of this motor vehicle accident Plaintiff MARC HARRIS, sustained permanent injuries within a reasonable degree of medical probability. 5. That as a result of this motor vehicle accident Plaintiff NADIA JOSEPH-HARRIS, sustained permanent injuries within a reasonable degree of medical probability. 6. ‘That Plaintiff, MARC HARRIS’ conduct did not in any way contribute to the cause of the automobile accident described above. CHEN. DAIAARCACUAAIINTY CL INCEDU ARDIIV7ZN FLED N9M141NNNA 44.9045 ANA HILLY. PAL DLA VUUINE TT, FL, VUOL IE mDnueey, ULLIAN, ver eue! 1 .ou.ty mi7. That Plaintiff, NADIA JOSEPH-HARRIS’ conduct did not in any way contribute to the cause of the automobile accident described above 8. That the automobile accident described above was not caused by the negligence and careless actions, or occurrences of third parties and conditions, which were beyond your control. 9. That Plaintiff, MARC HARRIS, incurred medical expenses for treatment for his injuries from the accident within a reasonable degree of medical certainty. 10. That Plaintiff, NADIA JOSEPH-HARRIS, incurred medical expenses for treatment for her injuries from the accident within a reasonable degree of medical certainty 11. That Plaintiff, MARC HARRIS, will continue to incur future medical expenses for treatment for his injuries from the accident within a reasonable degree of medical certainty. 12. That Plaintiff, NADIA JOSEPH-HARRIS, will continue to incur future medical expenses for treatment for her injuries from the accident within a reasonable degree of medical certainty. 13. That as a result of this motor vehicle accident Plaintiff MARC HARRIS sustained injuries which were caused by the accident within a reasonable degree of medical probability. 14. That as a result of this motor vehicle accident Plaintiff NADIA JOSEPH-HARRIS sustained injuries which were caused by the accident within a reasonable degree of medical probability.WE HEREBY CERTIFY that a true and correct copy of the foregoing was served with Summons, Complaint, Interrogatories and Request to Produce. SCHULER, HALVORSON, WEISSER, ZOELLER & OVERBECK, P.A. Attorneys for Plaintiff 1615 Forum Place, Suite 4-D Barristers Building West Palm Beach, FL 33401 Telephone (561) 689-8180 By: /s/ Eric Hayden WILLIAM D. ZOELLER Fla, Bar Ne: 155233 wzoeller@shw-law.com tcoffey@shw-law.com Eric Hayden Florida Bar No: 100923 ehayden@shw-law.com acoates@shw-law.com