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35-2022-CA-000754-AXXX-XX
Filing # 148510658 E-Filed 04/27/2022 03:30:46 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT IN AND FOR LAKE
COUNTY, FLORIDA
CASE NO:
ERLENE FEDRICK,
Plaintiff,
Vv.
PATRICK DONALD HENES and ARCH
INSURANCE COMPANY, a Foreign Profit
Corporation,
Defendants.
/
PLAINTIFFS’ REQUEST FOR ADMISSIONS TO
DEFENDANT, PATRICK DONALD HENES
COMES NOW the Plaintiffs, ERLENE FEDRICK, by and through the undersigned
counsel and pursuant to Rule 1.370, Florida Rules Of Civil Procedure, hereby requests that
Defendant, PATRICK DONALD HENES, admit the following within forty-five (45) days from
the date of service hereof:
) Please admit that this action brought against the Defendants properly and correctly
name the parties to be sued in this cause.
2) Please admit that jurisdiction for the Complaint filed by Plaintiff is properly
brought before the Circuit Court in LAKE County, Florida.
3) Please admit that the service of process against the Defendant, PATRICK
DONALD HENES, was proper.
4) Please admit that this is an action for damages in excess of Thirty Thousand Dollars
($30,000) arising in LAKE County, Florida.
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 04/27/2022 04:41:01 PM.
5) Please admit that the Defendant, PATRICK DONALD HENES, was operating a
motor vehicle owned by Defendant, PATRICK DONALD HENES, on OCTOBER 23, 2020 at or
near CR-455 AND CAVALLO DR IN MONTVERDE , LAKE County, Florida, as described in
the Complaint.
6) Please admit that the motor vehicle operated by Defendant, PATRICK DONALD
HENES, was owned by Defendant.
2 Please admit that the motor vehicle operated by Defendant, PATRICK DONALD
HENES, was owned by Defendant, PATRICK DONALD HENES.
8) Please admit that there are no other individuals or entities that owned the vehicle
operated by Defendant, PATRICK DONALD HENES.
9) Please admit that the motor vehicle operated by Defendant, PATRICK DONALD
HENES, was being operated by Defendant with the knowledge, permission and consent of its
owner.
10) Please admit that the Defendant, PATRICK DONALD HENES, was operating the
vehicle during the course and scope of his employment when the subject accident occurred.
11) Please admit that the Defendant, PATRICK DONALD HENES, was performing a
task for the purposes of his employment when the subject accident occurred.
12) Please admit that Defendant, PATRICK DONALD HENES, was negligent in the
operation of a motor vehicle which resulted in the subject collision with Plaintiffs vehicle.
13) Please admit that Defendant, PATRICK DONALD HENES, received a citation
issued by the investigating law enforcement agency arising out of the subject accident.
14) Please admit that Defendant, PATRICK DONALD HENES, pled guilty to the
citation in connection with the subject accident.
15) Please admit that Plaintiff, ERLENE FEDRICK, was injured in the subject
accident.
16) Please admit that Plaintiff, ERLENE FEDRICK, suffered a permanent injury within
a reasonable degree of medical probability resulting from the subject accident.
17) Please admit that Plaintiff, ERLENE FEDRICK, was not guilty of negligence
which caused or contributed to the subject accident.
18) Please admit that Plaintiff, ERLENE FEDRICK, incurred medical expenses for
treatment of injuries resulting from the subject accident.
19) Please admit that Plaintiff's, ERLENE FEDRICK, medical expenses were
reasonable and necessary for the care and treatment of the injuries sustained in the subject accident.
I HEREBY CERTIFY THAT a copy of the foregoing has been served upon the above-
named Defendant along with the Summons and Complaint.
s/ Devry R. Kelley
Devry R. Kelley, Esquire
Florida Bar No.: 0567302
Dan Newlin Injury Attorneys
7335 W. Sand Lake Road, Suite 300
Orlando, FL 32819
Direct: (321) 234-3859
Fax: (863) 225-9853
Attorneys for Plaintiff
Devry.Kelley@newlinlaw.com
Patricia.Croc@newlinlaw.com
devry.pleadings@newlinlaw.com
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35-2022-CA-000754-AXXX-XX Filing # 148510658 E-Filed 04/27/2022 03:30:46 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA CASE NO: ERLENE FEDRICK, Plaintiff, Vv. PATRICK DONALD HENES and ARCH INSURANCE COMPANY, a Foreign Profit Corporation, Defendants. / PLAINTIFFS’ REQUEST FOR ADMISSIONS TO DEFENDANT, PATRICK DONALD HENES COMES NOW the Plaintiffs, ERLENE FEDRICK, by and through the undersigned counsel and pursuant to Rule 1.370, Florida Rules Of Civil Procedure, hereby requests that Defendant, PATRICK DONALD HENES, admit the following within forty-five (45) days from the date of service hereof: ) Please admit that this action brought against the Defendants properly and correctly name the parties to be sued in this cause. 2) Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought before the Circuit Court in LAKE County, Florida. 3) Please admit that the service of process against the Defendant, PATRICK DONALD HENES, was proper. 4) Please admit that this is an action for damages in excess of Thirty Thousand Dollars ($30,000) arising in LAKE County, Florida. FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 04/27/2022 04:41:01 PM. 5) Please admit that the Defendant, PATRICK DONALD HENES, was operating a motor vehicle owned by Defendant, PATRICK DONALD HENES, on OCTOBER 23, 2020 at or near CR-455 AND CAVALLO DR IN MONTVERDE , LAKE County, Florida, as described in the Complaint. 6) Please admit that the motor vehicle operated by Defendant, PATRICK DONALD HENES, was owned by Defendant. 2 Please admit that the motor vehicle operated by Defendant, PATRICK DONALD HENES, was owned by Defendant, PATRICK DONALD HENES. 8) Please admit that there are no other individuals or entities that owned the vehicle operated by Defendant, PATRICK DONALD HENES. 9) Please admit that the motor vehicle operated by Defendant, PATRICK DONALD HENES, was being operated by Defendant with the knowledge, permission and consent of its owner. 10) Please admit that the Defendant, PATRICK DONALD HENES, was operating the vehicle during the course and scope of his employment when the subject accident occurred. 11) Please admit that the Defendant, PATRICK DONALD HENES, was performing a task for the purposes of his employment when the subject accident occurred. 12) Please admit that Defendant, PATRICK DONALD HENES, was negligent in the operation of a motor vehicle which resulted in the subject collision with Plaintiffs vehicle. 13) Please admit that Defendant, PATRICK DONALD HENES, received a citation issued by the investigating law enforcement agency arising out of the subject accident. 14) Please admit that Defendant, PATRICK DONALD HENES, pled guilty to the citation in connection with the subject accident. 15) Please admit that Plaintiff, ERLENE FEDRICK, was injured in the subject accident. 16) Please admit that Plaintiff, ERLENE FEDRICK, suffered a permanent injury within a reasonable degree of medical probability resulting from the subject accident. 17) Please admit that Plaintiff, ERLENE FEDRICK, was not guilty of negligence which caused or contributed to the subject accident. 18) Please admit that Plaintiff, ERLENE FEDRICK, incurred medical expenses for treatment of injuries resulting from the subject accident. 19) Please admit that Plaintiff's, ERLENE FEDRICK, medical expenses were reasonable and necessary for the care and treatment of the injuries sustained in the subject accident. I HEREBY CERTIFY THAT a copy of the foregoing has been served upon the above- named Defendant along with the Summons and Complaint. s/ Devry R. Kelley Devry R. Kelley, Esquire Florida Bar No.: 0567302 Dan Newlin Injury Attorneys 7335 W. Sand Lake Road, Suite 300 Orlando, FL 32819 Direct: (321) 234-3859 Fax: (863) 225-9853 Attorneys for Plaintiff Devry.Kelley@newlinlaw.com Patricia.Croc@newlinlaw.com devry.pleadings@newlinlaw.com