On March 22, 2023 a
Party Discovery
was filed
involving a dispute between
Kingsbury, Carla,
and
Arnett, Parker,
Ean Holdings Llc,
for CIRCUIT CIVIL
in the District Court of Osceola County.
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Filing # 172573474 E-Filed 05/05/2023 05:22:31 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2023 CA 002524 AN
CARLA T. KINGSBURY,
Plaintiff,
vs.
PARKER JAMES ARNETT, EAN
HOLDINGS LLC, AND LM
GENERAL INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, PARKER JAMES
ARNETT
Plaintiff, CARLA T. KINGSBURY, by and through undersigned counsel, and pursuant to
Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant, PARKER JAMES
ARNETT admit the following within forty-five (45) days from the date of service hereof:
1. Please admit that this action properly and correctly names the parties to be sued in this cause.
2. Please admit that jurisdiction for this action is properly brought before the Circuit Court in
Osceola County, Florida.
3. Please admit that the service of process against you was proper.
4. Please admit that you were operating a motor vehicle on 08/19/2022.
5. Please admit that you were operating a motor vehicle on 08/19/2022, in Osceola County,
Florida.
6. Please admit that the motor vehicle operated by you on 08/19/2022, was owned by you.
7. Please admit that the motor vehicle operated by you on 08/19/2022, was being operated by
you with the knowledge, permission and consent of its owner.
13149503 1
RFAD001
8. Please admit that you were negligent in the operation of a motor vehicle which resulted in the
subject collision with the vehicle in which Plaintiff was riding.
9. Please admit that you received a citation issued by the investigating law enforcement agency
arising out of the subject crash.
10. Please admit that you pled guilty to said citation in connection with the subject crash.
11. Please admit that Plaintiff was injured in the subject crash.
12. Please admit that Plaintiff suffered a permanent injury within a reasonable degree of medical
probability resulting from the subject crash.
13. Please admit that Plaintiff was not guilty of negligence which caused or contributed to the
subject crash.
14. Please admit that Plaintiff incurred medical expenses for treatment of injuries resulting from
the subject crash.
15. Please admit that Plaintiff’s medical expenses were reasonable and necessary for the care and
treatment of the injuries sustained in the subject crash.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the above-named Defendant, along with the summons and complaint.
/s/ James Davis
James Davis, Esquire
Florida Bar No: 334707
Morgan & Morgan, P.A.
20 N Orange Ave., Suite 1600
Orlando, Florida 32801
Telephone: (407) 849-4624
Primary email: jamesdavis@forthepeople.com
Secondary email: Morganservice@forthepeople.com
Attorneys for Plaintiff
13149503 2
RFAD001
Document Filed Date
May 05, 2023
Case Filing Date
March 22, 2023
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Filing # 172573474 E-Filed 05/05/2023 05:22:31 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2023 CA 002524 AN CARLA T. KINGSBURY, Plaintiff, vs. PARKER JAMES ARNETT, EAN HOLDINGS LLC, AND LM GENERAL INSURANCE COMPANY, Defendant. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, PARKER JAMES ARNETT Plaintiff, CARLA T. KINGSBURY, by and through undersigned counsel, and pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant, PARKER JAMES ARNETT admit the following within forty-five (45) days from the date of service hereof: 1. Please admit that this action properly and correctly names the parties to be sued in this cause. 2. Please admit that jurisdiction for this action is properly brought before the Circuit Court in Osceola County, Florida. 3. Please admit that the service of process against you was proper. 4. Please admit that you were operating a motor vehicle on 08/19/2022. 5. Please admit that you were operating a motor vehicle on 08/19/2022, in Osceola County, Florida. 6. Please admit that the motor vehicle operated by you on 08/19/2022, was owned by you. 7. Please admit that the motor vehicle operated by you on 08/19/2022, was being operated by you with the knowledge, permission and consent of its owner. 13149503 1 RFAD001 8. Please admit that you were negligent in the operation of a motor vehicle which resulted in the subject collision with the vehicle in which Plaintiff was riding. 9. Please admit that you received a citation issued by the investigating law enforcement agency arising out of the subject crash. 10. Please admit that you pled guilty to said citation in connection with the subject crash. 11. Please admit that Plaintiff was injured in the subject crash. 12. Please admit that Plaintiff suffered a permanent injury within a reasonable degree of medical probability resulting from the subject crash. 13. Please admit that Plaintiff was not guilty of negligence which caused or contributed to the subject crash. 14. Please admit that Plaintiff incurred medical expenses for treatment of injuries resulting from the subject crash. 15. Please admit that Plaintiff’s medical expenses were reasonable and necessary for the care and treatment of the injuries sustained in the subject crash. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the above-named Defendant, along with the summons and complaint. /s/ James Davis James Davis, Esquire Florida Bar No: 334707 Morgan & Morgan, P.A. 20 N Orange Ave., Suite 1600 Orlando, Florida 32801 Telephone: (407) 849-4624 Primary email: jamesdavis@forthepeople.com Secondary email: Morganservice@forthepeople.com Attorneys for Plaintiff 13149503 2 RFAD001