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Filing # 140283466 E-Filed 12/13/2021 04:33:08 PM
ARLENI RIVERO HERNANDEZ, IN THE 11TH JUDICIAL CIRCUIT COURT
ERNESTO PUPO HERNANDEZ AND IN AND FOR MIAMI DADE COUNTY,
ANISLEYDIS PUPO RIVERO FLORIDA
PLAINTIFFS,
CASE NO2021-023121-CA-01
V.
FABRICIO RUBIO ALMEIDA &
EDUARDO R. ALMEIDA
DEFENDANTS
______________________________________/
PLAINTIFF, ANISLEYDIS PUPO RIVERO’S RESPONSE TO DEFENDANT’S
REQUEST FOR ADMISSIONS/INTERROGATORIES
COMES NOW, the Plaintiff, Anisleydis Pupo Rivero, by and through the undersigned
counsel, pursuant to Florida Rule of Civil Procedure 1.350, and hereby files responses to
Defendant’s Request for Admissions and states:
1. Please admit that the Plaintiff or Plaintiffs have not subrogated any portion of their
claim for hospital, medical or other expenses to any entity, including any insurance
company or companies under any insurance policy, in connection with the injuries
allegedly sustained as a result of the incident alleged in the Complaint.
RESPONSE: Admit.
2. Please admit that there are no liens of any kind (including, but not limited to, Workers’
Compensation liens, attorney liens, judgment liens, Federal liens, including Medicare
and Internal Revenue Service) that may or will attach to any monetary proceeds
received by the Plaintiff or Plaintiffs in this case as a result of any judgment rendered
in this cause or any settlement of this cause between the parties as a result of the
incident alleged herein.
RESPONSE: Admit.
3. Please admit that all lost wages incurred by you in connection with the injuries you
allegedly sustained as a result of the incident alleged herein, have been paid by collateral
sources.
RESPONSE: Denied.
4. Please admit that all medical expenses incurred by you in connection with the injuries
you allegedly sustained as a result of the incident alleged herein, have been paid by
Pacin Levine, P.A.
1150 NW 72nd Avenue, Suite 600, Miami, FL 33126 ï‚– Telephone: (305) 760-9085 ï‚– Facsimile: (786) 800-3611
collateral sources.
RESPONSE: Denied.
INTERROGATORIES
A. If you deny the Request for Admission #1, please set forth, with particularity, the
following information:
(1) The name and address of the entity having the subrogated interest.
(2) The nature of the claim, or that portion of the claim, which was paid by such entity.
(3) Itemize the amounts for which such entity has, or may have, a subrogation claim.
RESPONSE: None.
B. If you deny the Request for Admission #2, please set forth, with particularity, all
liens of any kind that you are claiming may or will attach to any monetary proceeds
received by the Plaintiff or Plaintiffs in this case as a result of any judgment rendered
in this cause or any settlement of this cause between the parties, as a result of the
incident alleged herein (include the amount of the lien and the name and address of
the lienholder).
RESPONSE: None.
C. If you deny the Request for Admission #3, please set forth, with particularity, all lost
wages you are claiming have not been paid by collateral sources, including the dates
for which you are claiming the wages were not paid.
RESPONSE: None.
D. If you deny the Request for Admission #4, please set forth, with particularity, each
and every medical bill you are claiming has not been paid by collateral sources.
RESPONSE: Please see all medical bills, billing ledgers, and PIP log attached in response
to Defendant’s request for production.
E. If you admit the Request for Admission #4, please set forth, with particularity, each
and every medical bill you are claiming has been paid by collateral sources.
RESPONSE: Please see all medical bills, billing ledgers, and PIP log attached in response
to Defendant’s request for production.
[Certificate of service to follow]
Pacin Levine, P.A.
1150 NW 72nd Avenue, Suite 600, Miami, FL 33126 ï‚– Telephone: (305) 760-9085 ï‚– Facsimile: (786) 800-3611
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was emailed to:
Alexandra M. De Maio, The Law Office of Robert P. Kelly, P.O. Box 7217, London, KY 40742,
PLGMail@libertymutual.com; alexandra.demaio@libertymutual.com, on December 13, 2021.
Attorneys for Plaintiff
1150 NW 72nd Avenue, Suite 600
Miami, FL 33126
(305) 760-9085- Telephone
(786) 800-3611- Facsimile
By: Signed electronically to avoid delay
Frances A. Faccidomo, Esq.
Florida Bar No. 0653659
Pleadings Email: bipleadings@pl-law.com
Pacin Levine, P.A.
1150 NW 72nd Avenue, Suite 600, Miami, FL 33126 ï‚– Telephone: (305) 760-9085 ï‚– Facsimile: (786) 800-3611
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Filing # 140283466 E-Filed 12/13/2021 04:33:08 PM ARLENI RIVERO HERNANDEZ, IN THE 11TH JUDICIAL CIRCUIT COURT ERNESTO PUPO HERNANDEZ AND IN AND FOR MIAMI DADE COUNTY, ANISLEYDIS PUPO RIVERO FLORIDA PLAINTIFFS, CASE NO2021-023121-CA-01 V. FABRICIO RUBIO ALMEIDA & EDUARDO R. ALMEIDA DEFENDANTS ______________________________________/ PLAINTIFF, ANISLEYDIS PUPO RIVERO’S RESPONSE TO DEFENDANT’S REQUEST FOR ADMISSIONS/INTERROGATORIES COMES NOW, the Plaintiff, Anisleydis Pupo Rivero, by and through the undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.350, and hereby files responses to Defendant’s Request for Admissions and states: 1. Please admit that the Plaintiff or Plaintiffs have not subrogated any portion of their claim for hospital, medical or other expenses to any entity, including any insurance company or companies under any insurance policy, in connection with the injuries allegedly sustained as a result of the incident alleged in the Complaint. RESPONSE: Admit. 2. Please admit that there are no liens of any kind (including, but not limited to, Workers’ Compensation liens, attorney liens, judgment liens, Federal liens, including Medicare and Internal Revenue Service) that may or will attach to any monetary proceeds received by the Plaintiff or Plaintiffs in this case as a result of any judgment rendered in this cause or any settlement of this cause between the parties as a result of the incident alleged herein. RESPONSE: Admit. 3. Please admit that all lost wages incurred by you in connection with the injuries you allegedly sustained as a result of the incident alleged herein, have been paid by collateral sources. RESPONSE: Denied. 4. Please admit that all medical expenses incurred by you in connection with the injuries you allegedly sustained as a result of the incident alleged herein, have been paid by Pacin Levine, P.A. 1150 NW 72nd Avenue, Suite 600, Miami, FL 33126  Telephone: (305) 760-9085  Facsimile: (786) 800-3611 collateral sources. RESPONSE: Denied. INTERROGATORIES A. If you deny the Request for Admission #1, please set forth, with particularity, the following information: (1) The name and address of the entity having the subrogated interest. (2) The nature of the claim, or that portion of the claim, which was paid by such entity. (3) Itemize the amounts for which such entity has, or may have, a subrogation claim. RESPONSE: None. B. If you deny the Request for Admission #2, please set forth, with particularity, all liens of any kind that you are claiming may or will attach to any monetary proceeds received by the Plaintiff or Plaintiffs in this case as a result of any judgment rendered in this cause or any settlement of this cause between the parties, as a result of the incident alleged herein (include the amount of the lien and the name and address of the lienholder). RESPONSE: None. C. If you deny the Request for Admission #3, please set forth, with particularity, all lost wages you are claiming have not been paid by collateral sources, including the dates for which you are claiming the wages were not paid. RESPONSE: None. D. If you deny the Request for Admission #4, please set forth, with particularity, each and every medical bill you are claiming has not been paid by collateral sources. RESPONSE: Please see all medical bills, billing ledgers, and PIP log attached in response to Defendant’s request for production. E. If you admit the Request for Admission #4, please set forth, with particularity, each and every medical bill you are claiming has been paid by collateral sources. RESPONSE: Please see all medical bills, billing ledgers, and PIP log attached in response to Defendant’s request for production. [Certificate of service to follow] Pacin Levine, P.A. 1150 NW 72nd Avenue, Suite 600, Miami, FL 33126  Telephone: (305) 760-9085  Facsimile: (786) 800-3611 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was emailed to: Alexandra M. De Maio, The Law Office of Robert P. Kelly, P.O. Box 7217, London, KY 40742, PLGMail@libertymutual.com; alexandra.demaio@libertymutual.com, on December 13, 2021. Attorneys for Plaintiff 1150 NW 72nd Avenue, Suite 600 Miami, FL 33126 (305) 760-9085- Telephone (786) 800-3611- Facsimile By: Signed electronically to avoid delay Frances A. Faccidomo, Esq. Florida Bar No. 0653659 Pleadings Email: bipleadings@pl-law.com Pacin Levine, P.A. 1150 NW 72nd Avenue, Suite 600, Miami, FL 33126  Telephone: (305) 760-9085  Facsimile: (786) 800-3611