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IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 082021CA000968XXXXXX
Plaintiff,
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
DEFENDANT,HHS ENVIRONMENTAL SERVICES, LLC’S, SUPPLEMENTAL AND
AMENDED RESPONSES TO PLAINTIFF’S REQUESTS FOR ADMISSIONS
Defendant, HHS ENVIRONMENTAL SERVICES, LLC (hereinafter “Defendant”), by
and through undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby
files its Supplemental and Amended Responses to Plaintiff’s Request for Admission, and states
as follows:
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all
counsel of the attached Service List this 16 day of January, 2023.
KUBICKI DRAPER
9100 South Dadeland Blvd.
Suite 1800
Miami, FL 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
Pleadings:
By: /s/ Francesca Ippolito-Craven
FRANCESCA IPPOLITO-CRAVEN
Florida Bar Number: 0145361
STEPHANIE B. GLICKMAN
Florida Bar Number: 117734
SERVICE LIST
Co-counsel for Plaintiff:
Michael J. Rossi, Esq.
MICHAEL J. ROSSI, P.A.
Tampa, FL 33606
michael@michaelrossilaw.com
STRATIGAKOS LAW, P.A.
Tampa, FL 33602
Primary: Helen@stratigakoslaw.com
Secondary: admin@stratigakoslaw.com
DEFENDANT’S SUPPLEMENTAL AND AMENDED
RESPONSES TO REQUESTS FOR ADMISSIONS
1. Please admit that Defendant, HHS ENVIRONMENTAL SERVICES, LLC (hereinafter
HHS) was, at the time of the incident which forms the basis of this lawsuit, the employer of
Defendant, MICHAEL G. EDWARDS (hereinafter EDWARDS).
agrees to withdraw its objection.]
RESPONSE: Admitted that Michael Edwards was employed by HHS on July 7, 2020.
2. Please admit that in 2020 HHS was not an employee of Bayfront Health Port Charlotte
Hospital.
agrees to withdraw its objection.]
RESPONSE: Denied.
3. Please admit that in 2020 HHS was a “vendor” of Bayfront Health Port Charlotte
Hospital.
agrees to withdraw its objection.]
RESPONSE: Admitted.
4. Please admit that in 2020 HHS had a valid indemnification agreement in place as part of the
contract maintained with Bayfront Health Port Charlotte Hospital.
[Per agreement with counsel, Plaintiff agrees to withdraw this Request.]
8. Please admit that HHS conducted a pre-employment screening of EDWARDS in the Fall
of 2019, prior to employing EDWARDS.
agrees to withdraw its objection.]
RESPONSE: Admitted.
12. Please admit that prior to his hiring, HHS did not provide EDWARDS with any formal
training in the operation of electric golf carts.
[Per agreement with counsel, Plaintiff agrees to withdraw this Request.]
13. Please admit that subsequent to his hiring, HHS did not provide EDWARDS with any
formal training in the operation of electric golf carts.
[Per agreement with counsel, Plaintiff agrees to withdraw this Request.]
15. Please admit that the HHS office located at Bayfront Health Port Charlotte Hospital was
agrees to withdraw its objection.]
RESPONSE: Denied.
16. Please admit that HHS maintained an office at Bayfront Health Port Charlotte Hospital
on the date of loss described in the Complaint.
agrees to withdraw its objection.]
RESPONSE: Denied.
17. Please admit that the HHS office at Bayfront Health Port Charlotte Hospital was staffed
exclusively by employees of HHS.
agrees to withdraw its objection.]
RESPONSE: Denied.
18. Please admit that the HHS office at Bayfront Health Port Charlotte Hospital was the
location where employees of HHS would “cl
agrees to withdraw its objection.]
RESPONSE: Denied.
19. Please admit that HHS is responsible for the actions of its employees while working at
Bayfront Health Port Charlotte Hospital.
[Per agreement with counsel, Defendant agrees to amend its objection.]
ambiguous as to what is meant by “respons
conclusion. Without waiving said objections, denied as phrased.
20. Please admit that HHS is responsible for the work-related actions of its employees while
working at Bayfront Health Port Charlotte Hospital.
[Per agreement with counsel, Defendant agrees to amend its objection.]
ambiguous as to what is meant by “responsible for the work-related actions;” and calls for
a legal conclusion. Without waiving said objections, denied as phrased.
21. Please admit that HHS is responsible for the job-related performance of its
employees while working at Bayfront Health Port Charlotte Hospital.
[Per agreement with counsel, Defendant agrees to amend its objection.]
ambiguous as to what is meant by “responsible for job related performance;” and calls for
a legal conclusion. Without waiving said objections, denied as phrased.
22. Please admit that HHS is responsible for training its employees working at Bayfront
Health Port Charlotte Hospital to perform the tasks they were hired to perform.
[Per agreement with counsel, Defendant agrees to amend its objection.]
ambiguous as to what is meant by “respons
conclusion. Without waiving said objections, denied as phrased.
[Per agreement with counsel, Defendant agrees to respond to Plaintiff’s additional Requests for
Admissions beyond #30.]
31. Please admit that prior to July 2020, HHS employees were aware that the backup buzzer
for the white 2007 Club Car Golf Cart that was operated by EDWARDS on the date of loss as
described in the Complaint had been disconnected.
RESPONSE: Denied.
32. Please admit that prior to July 2020, HHS employees were aware that the backup buzzer
for the white 2007 Club Car Golf Cart that was operated by EDWARDS on the date of loss as
described in the Complaint was not functioning.
RESPONSE: Denied.
33. Please admit that prior to July 2020, HHS employees notified the Hospital’s maintenance
department that the backup buzzer the white 2007 Club Car Golf Cart that was operated by
EDWARDS on the date of loss as described in the Complaint was not functioning.
RESPONSE: Denied.
34. Please admit that in July 2020, HHS had possession of a key used to operate the white
2007 Club Car Golf Cart that was driven by EDWARDS on the date of loss described in the
Complaint in the HHS office at the hospital.
RESPONSE: Without sufficient knowledge to admit or deny, therefore, denied.
35. Please admit that in July 2020, HHS provided the key used to operate the white 2007
Club Car Golf Cart to EDWARDS on the date of loss described in the Complaint to perform his
work-related duties, to wit: removal of garbage from garbage cans located on the exterior of
Bayfront Health Port Charlotte Hospital.
RESPONSE: Without sufficient knowledge to admit or deny, therefore, denied.
36. Please admit that in July 2020, HHS provided the key used to operate the white 2007
Club Car Golf Cart that was driven by EDWARDS on the date of loss described in the
Complaint to other HHS employees to perform work-related duties, to wit: removal of garbage
from garbage cans located on the exterior of Bayfront Health Port Charlotte Hospital.
RESPONSE: Without sufficient knowledge to admit or deny, therefore, denied.
37. Please admit that HHS is also known by the initials “EVS” to the staff at Bayfront Health
Port Charlotte.
RESPONSE: Admitted.
38. Please admit that HHS is also known as “Environmental Services” to the staff at Bayfront
Health Port Charlotte.
RESPONSE: Admitted.
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IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 082021CA000968XXXXXX Plaintiff, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. DEFENDANT,HHS ENVIRONMENTAL SERVICES, LLC’S, SUPPLEMENTAL AND AMENDED RESPONSES TO PLAINTIFF’S REQUESTS FOR ADMISSIONS Defendant, HHS ENVIRONMENTAL SERVICES, LLC (hereinafter “Defendant”), by and through undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby files its Supplemental and Amended Responses to Plaintiff’s Request for Admission, and states as follows: CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all counsel of the attached Service List this 16 day of January, 2023. KUBICKI DRAPER 9100 South Dadeland Blvd. Suite 1800 Miami, FL 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 Pleadings: By: /s/ Francesca Ippolito-Craven FRANCESCA IPPOLITO-CRAVEN Florida Bar Number: 0145361 STEPHANIE B. GLICKMAN Florida Bar Number: 117734 SERVICE LIST Co-counsel for Plaintiff: Michael J. Rossi, Esq. MICHAEL J. ROSSI, P.A. Tampa, FL 33606 michael@michaelrossilaw.com STRATIGAKOS LAW, P.A. Tampa, FL 33602 Primary: Helen@stratigakoslaw.com Secondary: admin@stratigakoslaw.com DEFENDANT’S SUPPLEMENTAL AND AMENDED RESPONSES TO REQUESTS FOR ADMISSIONS 1. Please admit that Defendant, HHS ENVIRONMENTAL SERVICES, LLC (hereinafter HHS) was, at the time of the incident which forms the basis of this lawsuit, the employer of Defendant, MICHAEL G. EDWARDS (hereinafter EDWARDS). agrees to withdraw its objection.] RESPONSE: Admitted that Michael Edwards was employed by HHS on July 7, 2020. 2. Please admit that in 2020 HHS was not an employee of Bayfront Health Port Charlotte Hospital. agrees to withdraw its objection.] RESPONSE: Denied. 3. Please admit that in 2020 HHS was a “vendor” of Bayfront Health Port Charlotte Hospital. agrees to withdraw its objection.] RESPONSE: Admitted. 4. Please admit that in 2020 HHS had a valid indemnification agreement in place as part of the contract maintained with Bayfront Health Port Charlotte Hospital. [Per agreement with counsel, Plaintiff agrees to withdraw this Request.] 8. Please admit that HHS conducted a pre-employment screening of EDWARDS in the Fall of 2019, prior to employing EDWARDS. agrees to withdraw its objection.] RESPONSE: Admitted. 12. Please admit that prior to his hiring, HHS did not provide EDWARDS with any formal training in the operation of electric golf carts. [Per agreement with counsel, Plaintiff agrees to withdraw this Request.] 13. Please admit that subsequent to his hiring, HHS did not provide EDWARDS with any formal training in the operation of electric golf carts. [Per agreement with counsel, Plaintiff agrees to withdraw this Request.] 15. Please admit that the HHS office located at Bayfront Health Port Charlotte Hospital was agrees to withdraw its objection.] RESPONSE: Denied. 16. Please admit that HHS maintained an office at Bayfront Health Port Charlotte Hospital on the date of loss described in the Complaint. agrees to withdraw its objection.] RESPONSE: Denied. 17. Please admit that the HHS office at Bayfront Health Port Charlotte Hospital was staffed exclusively by employees of HHS. agrees to withdraw its objection.] RESPONSE: Denied. 18. Please admit that the HHS office at Bayfront Health Port Charlotte Hospital was the location where employees of HHS would “cl agrees to withdraw its objection.] RESPONSE: Denied. 19. Please admit that HHS is responsible for the actions of its employees while working at Bayfront Health Port Charlotte Hospital. [Per agreement with counsel, Defendant agrees to amend its objection.] ambiguous as to what is meant by “respons conclusion. Without waiving said objections, denied as phrased. 20. Please admit that HHS is responsible for the work-related actions of its employees while working at Bayfront Health Port Charlotte Hospital. [Per agreement with counsel, Defendant agrees to amend its objection.] ambiguous as to what is meant by “responsible for the work-related actions;” and calls for a legal conclusion. Without waiving said objections, denied as phrased. 21. Please admit that HHS is responsible for the job-related performance of its employees while working at Bayfront Health Port Charlotte Hospital. [Per agreement with counsel, Defendant agrees to amend its objection.] ambiguous as to what is meant by “responsible for job related performance;” and calls for a legal conclusion. Without waiving said objections, denied as phrased. 22. Please admit that HHS is responsible for training its employees working at Bayfront Health Port Charlotte Hospital to perform the tasks they were hired to perform. [Per agreement with counsel, Defendant agrees to amend its objection.] ambiguous as to what is meant by “respons conclusion. Without waiving said objections, denied as phrased. [Per agreement with counsel, Defendant agrees to respond to Plaintiff’s additional Requests for Admissions beyond #30.] 31. Please admit that prior to July 2020, HHS employees were aware that the backup buzzer for the white 2007 Club Car Golf Cart that was operated by EDWARDS on the date of loss as described in the Complaint had been disconnected. RESPONSE: Denied. 32. Please admit that prior to July 2020, HHS employees were aware that the backup buzzer for the white 2007 Club Car Golf Cart that was operated by EDWARDS on the date of loss as described in the Complaint was not functioning. RESPONSE: Denied. 33. Please admit that prior to July 2020, HHS employees notified the Hospital’s maintenance department that the backup buzzer the white 2007 Club Car Golf Cart that was operated by EDWARDS on the date of loss as described in the Complaint was not functioning. RESPONSE: Denied. 34. Please admit that in July 2020, HHS had possession of a key used to operate the white 2007 Club Car Golf Cart that was driven by EDWARDS on the date of loss described in the Complaint in the HHS office at the hospital. RESPONSE: Without sufficient knowledge to admit or deny, therefore, denied. 35. Please admit that in July 2020, HHS provided the key used to operate the white 2007 Club Car Golf Cart to EDWARDS on the date of loss described in the Complaint to perform his work-related duties, to wit: removal of garbage from garbage cans located on the exterior of Bayfront Health Port Charlotte Hospital. RESPONSE: Without sufficient knowledge to admit or deny, therefore, denied. 36. Please admit that in July 2020, HHS provided the key used to operate the white 2007 Club Car Golf Cart that was driven by EDWARDS on the date of loss described in the Complaint to other HHS employees to perform work-related duties, to wit: removal of garbage from garbage cans located on the exterior of Bayfront Health Port Charlotte Hospital. RESPONSE: Without sufficient knowledge to admit or deny, therefore, denied. 37. Please admit that HHS is also known by the initials “EVS” to the staff at Bayfront Health Port Charlotte. RESPONSE: Admitted. 38. Please admit that HHS is also known as “Environmental Services” to the staff at Bayfront Health Port Charlotte. RESPONSE: Admitted.