On May 13, 2021 a
Party Discovery
was filed
involving a dispute between
Grant, Heather,
Vadillo, Francisco Gabriel,
and
Grant, Heather,
Lyft Florida Inc,
Lyft, Inc.,
Vadillo, David,
Vadillo, Franciso Gabriel,
for Auto Negligence
in the District Court of Broward County.
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Filing # 129136528 E-Filed 06/21/2021 11:18:39 AM
,th
IN THE CIRCUIT COURT OF THE 17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-009583
HEATHER GRANT,
Plaintiff.
VS.
FRANCISCO GABRIEL
VADILLO, DAVID VADILLO and
LYFT, INC.,
Defendants.
i
REQUEST FOR ADMISSIONS TO DEFENDANT, FRANCISCO VADILLO
Plaintiff, HEATHER GRANT, by and through her undersigned counsel, requests
the Defendant, FRANCISCO GABRIEL VADILLO to admit or deny the truth of the
following matters within the time and manner set forth by law:
1. Admit that at the time of the subject incident that is the subject matter of this
lawsuit, you were logged into the "LYFT" rideshare app.
2. Admit that at the time o f the incident, you were in the course of performing a
transportation ride for the Defendant, "LYFT".
3. Admit that at the time of the subject incident, you were
engaged in an active
ride on behalf of the Defendant, "LYFT".
4. Admit that at the time of the subject incident, you were in the process of
transportinga passenger to his/her destination.
5. Admit that at the time ofthe subject incident, you were an "in service" Lyft.
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/21/2021 11:18:39 AM.****
6. Admit that immediatelyprior to the subject incident, you attempted to make a
left turn onto Broward Boulevard.
7. Admit that in the process of making your left turn, you struck the vehicle
driven by the Plaintiff, HEATHER GRANT who was driving southbound on
NE 3rd Ave. at the intersection with Broward Boulevard, Fort Lauderdale,
Florida.
8. Admit that immediatelyprior to the subject incident, you had a clear view of
ird
oncoming traffic travelling southbound on NE 3 Ave. at the intersection with
Broward Boulevard.
9. Admit that prior to the subject incident, the Plaintiff, HEATHER GRANT had
the right of way.
10. Admit that you did not yield the right of way to the Plaintiff's, HEATHER
GRANT'S vehicle.
11. Admit that prior to completing your left turn onto Broward Boulevard, you
ird
did not allow all vehicles travelling southbound on NE 3 Ave. to drive
through the intersection.
12. Admit that your actions contributed substantially to the subject incident that is
the subject matter of this lawsuit.
13. Admit that the Plaintiff's, HEATHER GRANT'S actions did not contribute to
the subject incident.
14. Admit that the Plaintiff's, HEATHER GRANT'S vehicle flipped over
immediately after the impact with your vehicle.
15. Admit that the Plaintiff, HEATHER GRANT was taken to Broward General
Medical Center following this incident.
16. Admit that the Plaintiff, HEATHER GRANT has been diagnosed with a
permanent injury resulting from the subject incident that is the subject matter
of this lawsuit.
17. Admit that the Plaintiff's, HEATHER GRANT'S medical care and treatment
in connection to the subject incident were reasonable and necessary.
18. Admit that you are not aware of any third parties who may have contributed to
the subject incident.
19. Admit that the Plaintiff's, HEATHER GRANT'S medical expenses incurred
in connection with the subject incident were reasonable and necessary;
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing has been served along with the
Summons and Amended Complaint.
is/Jon A.Zmck.Esq.
Jon A. Zepnick, Esq.
Florida Bar No.. 586951
ANSEL & MILLER, LLC
Counsel for the Plaintiff
1939 Tyler Street
Hollywood, Florida 33020
Phone: (954) 922-9100
Fax: (954) 922-9176
eansel@anselmiller. com
Document Filed Date
June 21, 2021
Case Filing Date
May 13, 2021
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Filing # 129136528 E-Filed 06/21/2021 11:18:39 AM ,th IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-009583 HEATHER GRANT, Plaintiff. VS. FRANCISCO GABRIEL VADILLO, DAVID VADILLO and LYFT, INC., Defendants. i REQUEST FOR ADMISSIONS TO DEFENDANT, FRANCISCO VADILLO Plaintiff, HEATHER GRANT, by and through her undersigned counsel, requests the Defendant, FRANCISCO GABRIEL VADILLO to admit or deny the truth of the following matters within the time and manner set forth by law: 1. Admit that at the time of the subject incident that is the subject matter of this lawsuit, you were logged into the "LYFT" rideshare app. 2. Admit that at the time o f the incident, you were in the course of performing a transportation ride for the Defendant, "LYFT". 3. Admit that at the time of the subject incident, you were engaged in an active ride on behalf of the Defendant, "LYFT". 4. Admit that at the time of the subject incident, you were in the process of transportinga passenger to his/her destination. 5. Admit that at the time ofthe subject incident, you were an "in service" Lyft. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/21/2021 11:18:39 AM.**** 6. Admit that immediatelyprior to the subject incident, you attempted to make a left turn onto Broward Boulevard. 7. Admit that in the process of making your left turn, you struck the vehicle driven by the Plaintiff, HEATHER GRANT who was driving southbound on NE 3rd Ave. at the intersection with Broward Boulevard, Fort Lauderdale, Florida. 8. Admit that immediatelyprior to the subject incident, you had a clear view of ird oncoming traffic travelling southbound on NE 3 Ave. at the intersection with Broward Boulevard. 9. Admit that prior to the subject incident, the Plaintiff, HEATHER GRANT had the right of way. 10. Admit that you did not yield the right of way to the Plaintiff's, HEATHER GRANT'S vehicle. 11. Admit that prior to completing your left turn onto Broward Boulevard, you ird did not allow all vehicles travelling southbound on NE 3 Ave. to drive through the intersection. 12. Admit that your actions contributed substantially to the subject incident that is the subject matter of this lawsuit. 13. Admit that the Plaintiff's, HEATHER GRANT'S actions did not contribute to the subject incident. 14. Admit that the Plaintiff's, HEATHER GRANT'S vehicle flipped over immediately after the impact with your vehicle. 15. Admit that the Plaintiff, HEATHER GRANT was taken to Broward General Medical Center following this incident. 16. Admit that the Plaintiff, HEATHER GRANT has been diagnosed with a permanent injury resulting from the subject incident that is the subject matter of this lawsuit. 17. Admit that the Plaintiff's, HEATHER GRANT'S medical care and treatment in connection to the subject incident were reasonable and necessary. 18. Admit that you are not aware of any third parties who may have contributed to the subject incident. 19. Admit that the Plaintiff's, HEATHER GRANT'S medical expenses incurred in connection with the subject incident were reasonable and necessary; CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing has been served along with the Summons and Amended Complaint. is/Jon A.Zmck.Esq. Jon A. Zepnick, Esq. Florida Bar No.. 586951 ANSEL & MILLER, LLC Counsel for the Plaintiff 1939 Tyler Street Hollywood, Florida 33020 Phone: (954) 922-9100 Fax: (954) 922-9176 eansel@anselmiller. com