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Filing # 172887807 E-Filed 05/10/2023 04:50:32 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN AND FOR
OSCEOLA COUNTY, FLORIDA
ADRIANA MULET, CASE NO: 2023-CA-001300AN
Plaintiff,
vs.
RICHARD CORREA and
LUZ ELENIA CORREA,
Defendants.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT
RICHARD CORREA
COMES NOW the Plaintiff, ADRIANA MULET, by and through the undersigned
counsel and pursuant to Rule 1.370, Florida Rules Of Civil Procedure, hereby request that
Defendant, RICHARD CORREA, admit the following within forty-five (45) days from the date
of service hereof:
1) 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 Osceola County, Florida.
3) Please admit that the service of process against the Defendant, RICHARD
CORREA, was proper.
4) Please admit that this is an action for damages in excess of Fifty Thousand
Dollars ($50,000) arising in Osceola County, Florida.
5) Please admit that the Defendant, RICHARD CORREA, was operating a motor
vehicle, owned by Defendant, on July 20, 2022, at or near the intersection of Interstate Highway
4 and County Road 532 in Osceola County, Florida, as described in the Complaint.
6) Please admit that the motor vehicle operated by Defendant, RICHARD CORREA,
was owned by Defendant, RICHARD CORREA.
7) Please admit that the motor vehicle operated by Defendant, RICHARD CORREA,
was owned by Defendant, LUZ ELENIA CORREA.
8) Please admit that there are no other individuals or entities that owned the vehicle
operated by Defendant, RICHARD CORREA.
9) Please admit that the motor vehicle operated by Defendant, RICHARD
CORREA, was being operated by Defendant with the knowledge, permission and consent of its
owner(s).
10) Please admit that Defendant, RICHARD CORREA, was employed with
Defendant, LUZ ELENIA CORREA, at the time of the subject motor vehicle accident.
11) Please admit that Defendant, RICHARD CORREA, was operating the subject
vehicle during the course and scope of his employment with Defendant, LUZ ELENIA
CORREA.
12) Please admit that Defendant, RICHARD CORREA, was performing a task for the
purposes of his employment when the subject accident occurred.
13) Please admit that Defendant, RICHARD CORREA, was negligent in the
operation of a motor vehicle which resulted in the subject collision with Plaintiff’s vehicle.
14) Please admit that Defendant, RICHARD CORREA, received a citation issued by
the investigating law enforcement agency arising out of the subject accident.
15) Please admit that Defendant, RICHARD CORREA, pled guilty to the citation in
connection with the subject accident.
16) Please admit that ADRIANA MULET, was injured in the subject accident.
17) Please admit that ADRIANA MULET, suffered a permanent injury within a
reasonable degree of medical probability resulting from the subject accident.
18) Please admit that ADRIANA MULET, was not guilty of negligence which caused
or contributed to the subject accident.
19) Please admit that ADRIANA MULET, incurred medical expenses for treatment
of injuries resulting from the subject accident.
20) Please admit that ADRIANA MULET's 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/ Ashley M. Nelson
Ashley M. Nelson, Esquire
FBN: 1018349
Morgan & Morgan, P.A.
20 N. Orange Avenue
Suite 1600
Orlando, FL 32801
Telephone: (407) 867-4823
Facsimile: (407) 452-1632
Primary email: ANelson@forthepeople.com
Secondary email: EManzueta@forthepeople.com;
EstefanyPonce@forthepeople.com
Attorneys for Plaintiff
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Filing # 172887807 E-Filed 05/10/2023 04:50:32 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA ADRIANA MULET, CASE NO: 2023-CA-001300AN Plaintiff, vs. RICHARD CORREA and LUZ ELENIA CORREA, Defendants. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT RICHARD CORREA COMES NOW the Plaintiff, ADRIANA MULET, by and through the undersigned counsel and pursuant to Rule 1.370, Florida Rules Of Civil Procedure, hereby request that Defendant, RICHARD CORREA, admit the following within forty-five (45) days from the date of service hereof: 1) 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 Osceola County, Florida. 3) Please admit that the service of process against the Defendant, RICHARD CORREA, was proper. 4) Please admit that this is an action for damages in excess of Fifty Thousand Dollars ($50,000) arising in Osceola County, Florida. 5) Please admit that the Defendant, RICHARD CORREA, was operating a motor vehicle, owned by Defendant, on July 20, 2022, at or near the intersection of Interstate Highway 4 and County Road 532 in Osceola County, Florida, as described in the Complaint. 6) Please admit that the motor vehicle operated by Defendant, RICHARD CORREA, was owned by Defendant, RICHARD CORREA. 7) Please admit that the motor vehicle operated by Defendant, RICHARD CORREA, was owned by Defendant, LUZ ELENIA CORREA. 8) Please admit that there are no other individuals or entities that owned the vehicle operated by Defendant, RICHARD CORREA. 9) Please admit that the motor vehicle operated by Defendant, RICHARD CORREA, was being operated by Defendant with the knowledge, permission and consent of its owner(s). 10) Please admit that Defendant, RICHARD CORREA, was employed with Defendant, LUZ ELENIA CORREA, at the time of the subject motor vehicle accident. 11) Please admit that Defendant, RICHARD CORREA, was operating the subject vehicle during the course and scope of his employment with Defendant, LUZ ELENIA CORREA. 12) Please admit that Defendant, RICHARD CORREA, was performing a task for the purposes of his employment when the subject accident occurred. 13) Please admit that Defendant, RICHARD CORREA, was negligent in the operation of a motor vehicle which resulted in the subject collision with Plaintiff’s vehicle. 14) Please admit that Defendant, RICHARD CORREA, received a citation issued by the investigating law enforcement agency arising out of the subject accident. 15) Please admit that Defendant, RICHARD CORREA, pled guilty to the citation in connection with the subject accident. 16) Please admit that ADRIANA MULET, was injured in the subject accident. 17) Please admit that ADRIANA MULET, suffered a permanent injury within a reasonable degree of medical probability resulting from the subject accident. 18) Please admit that ADRIANA MULET, was not guilty of negligence which caused or contributed to the subject accident. 19) Please admit that ADRIANA MULET, incurred medical expenses for treatment of injuries resulting from the subject accident. 20) Please admit that ADRIANA MULET's 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/ Ashley M. Nelson Ashley M. Nelson, Esquire FBN: 1018349 Morgan & Morgan, P.A. 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 Telephone: (407) 867-4823 Facsimile: (407) 452-1632 Primary email: ANelson@forthepeople.com Secondary email: EManzueta@forthepeople.com; EstefanyPonce@forthepeople.com Attorneys for Plaintiff