On April 06, 2020 a
Party Discovery
was filed
involving a dispute between
John Valis,
and
Christine Hitchcock,
Usaa Casualty Insurance Company,
for AUTO NEGLIGENCE CASE Division: CV-C
in the District Court of Duval County.
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Filing # 106576807 E-Filed 04/22/2020 03:34:38 PM
IN THE CIRCUIT COURT,
FOURTH JUDICIAL CIRCUIT,
IN AND FOR DUVAL COUNTY,
FLORIDA
CASE NO: 2020-CA-002067
JOHN VALIS,
Plaintiff,
vs.
CHRISTINE HITCHCOCK and
USAA CASUALTY INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S FIRST REQUEST FOR
ADMISSIONS TO DEFENDANT, CHRISTINE HITCHCOCK
COMES NOW the Plaintiff, JOHN VALIS pursuant to Rule 1.370 of the Florida Rules of
Civil Procedure, and request the Defendant, CHRISTINE HITCHCOCK, to admit or deny the
following within forty-five (45) days from the date of the certificate of service hereof.
1 That at the time of the subject accident, Defendant, CHRISTINE HITCHCOCK, operated
the motor vehicle in St. Johns County, Florida.
2. That Defendant, CHRISTINE HITCHCOCK, was negligent in the operation of said
motor vehicle which resulted in a collision with Plaintiff on or about August 16, 2017.
3 That Plaintiff, JOHN VALIS, was injured in the subject accident.
4 That Plaintiff, JOHN VALIS, suffered a permanent injury within a reasonable degree of
medical probability resultant of the subject accident.
5 That Plaintiff, JOHN VALIS, was not guilty of negligence which caused or contributed to
the subject accident.
ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 04/24/2020 10:04:44 AM.
6 That Plaintiff, JOHN VALIS, incurred medical expenses for treatment of injuries resulting
from the subject accident.
7
That Plaintiff, JOHN VALIS’, medical expenses were reasonable and necessary for the
care and treatment of the injuries sustained in the subject accident.
I HEREBY CERTIFY that a true copy of the foregoing has been provided to the Defendant along
with service of the Complaint and Summons in this action.
MORGAN & MORGAN, P.A.
/s/ Michael D. Marrese
Michael D. Marrese, Esquire
FBN: 0544299
Morgan & Morgan, P.A
2601 North Ponce de Leon Blvd.
St. Augustine, FL 32084
Email: Mmarrese@forthepeople.com
Telephone: (904) 417-4170
Facsimile: (904) 417-4171
Attorneys for Plaintiff
Document Filed Date
April 22, 2020
Case Filing Date
April 06, 2020
Category
AUTO NEGLIGENCE CASE Division: CV-C
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Filing # 106576807 E-Filed 04/22/2020 03:34:38 PM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO: 2020-CA-002067 JOHN VALIS, Plaintiff, vs. CHRISTINE HITCHCOCK and USAA CASUALTY INSURANCE COMPANY, Defendant. / PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT, CHRISTINE HITCHCOCK COMES NOW the Plaintiff, JOHN VALIS pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, and request the Defendant, CHRISTINE HITCHCOCK, to admit or deny the following within forty-five (45) days from the date of the certificate of service hereof. 1 That at the time of the subject accident, Defendant, CHRISTINE HITCHCOCK, operated the motor vehicle in St. Johns County, Florida. 2. That Defendant, CHRISTINE HITCHCOCK, was negligent in the operation of said motor vehicle which resulted in a collision with Plaintiff on or about August 16, 2017. 3 That Plaintiff, JOHN VALIS, was injured in the subject accident. 4 That Plaintiff, JOHN VALIS, suffered a permanent injury within a reasonable degree of medical probability resultant of the subject accident. 5 That Plaintiff, JOHN VALIS, was not guilty of negligence which caused or contributed to the subject accident. ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 04/24/2020 10:04:44 AM. 6 That Plaintiff, JOHN VALIS, incurred medical expenses for treatment of injuries resulting from the subject accident. 7 That Plaintiff, JOHN VALIS’, medical expenses were reasonable and necessary for the care and treatment of the injuries sustained in the subject accident. I HEREBY CERTIFY that a true copy of the foregoing has been provided to the Defendant along with service of the Complaint and Summons in this action. MORGAN & MORGAN, P.A. /s/ Michael D. Marrese Michael D. Marrese, Esquire FBN: 0544299 Morgan & Morgan, P.A 2601 North Ponce de Leon Blvd. St. Augustine, FL 32084 Email: Mmarrese@forthepeople.com Telephone: (904) 417-4170 Facsimile: (904) 417-4171 Attorneys for Plaintiff