Document for GILLENWATER, GRANT R vs. LUGO, JOAQUIN

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                                Filing # 176539655 E-Filed 06/30/2023 12:49:48 PM


                     IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
                             IN AND FOR OSCEOLA COUNTY, FLORIDA

                                          CASE NO: 2023 CA 001158 AN

         PEGGYLYNN PATRICIA
         ALPHONSE,

                         Plaintiff,

         vs.

         JOAQUIN LUGO,

                         Defendant.
                                                        /

             PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, JOAQUIN LUGO


                Plaintiff, PEGGYLYNN PATRICIA ALPHONSE, by and through undersigned counsel,

        and pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant,

        JOAQUIN LUGO 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 06/15/2022.

        5.      Please admit that you were operating a motor vehicle on 06/15/2022, in Osceola County,
                Florida.

        6.      Please admit that the motor vehicle operated by you on 06/15/2022, was owned by you.

        7.      Please admit that the motor vehicle operated by you on 06/15/2022, was being operated by
                you with the knowledge, permission and consent of its owner.

        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.



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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/ Melissa Patterer
                                              Melissa Patterer, Esquire
                                              Florida Bar No: 112115
                                              Morgan & Morgan, P.A.
                                              2150 Goodlette-Frank Rd, Suite 750
                                              Naples, FL 34102
                                              Telephone: (239) 432-6664
                                              Primary email: MPpleadings@forthepeople.com
                                              Secondary email: Morganservice@forthepeople.com

                                              Attorneys for Plaintiff




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