Preview
Filing # 165124286 E-Filed 01/20/2023 11:52:15 AM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT, IN AND
FOR DUVAL COUNTY, FLORIDA
CASE NO. 16-2022-CA-006093
BRITTINIA VANE HUGHES, DIVISION: CV-A
Plaintiff,
v.
EAN HOLDINGS, LLC, a foreign
liability company, and
KATELAND WYATT,
Defendant.
_______________________________/
DEFENDANT, KATELAND WYATT’S,
RESPONSES TO PLAINTIFF’S REQUEST FOR ADMISSIONS
Defendant, Kateland Wyatt, by and through her undersigned attorneys, and
pursuant to the Florida Rule of Civil Procedure 1.370, hereby files this, their responses to
Plaintiff’s Request for Admissions to Defendant and states as follows:
1. The date of the incident, August 18, 2021, as alleged in the Complaint is correct.
RESPONSE: Admit
2. The place of the incident - Interstate Highway 10, Jacksonville, Duval County, Florida
- alleged in the Complaint is correct.
RESPONSE: Admit.
3. The name of the Defendant alleged to have owned the vehicle which you were driving
at the time alleged in the Complaint is correct.
RESPONSE: Following reasonable inquiry into information known or readily
obtainable, Defendant is unable to admit or deny.
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/20/2023 06:34:34 PM
CASE NO. 16-2022-CA-006093
4. You or someone on your behalf had photos taken of the scene of the alleged incident
at or near the time of the incident.
RESPONSE: Due to passage of time, Defendant is unable to recall. Following
reasonable inquiry into information known or readily obtainable, Defendant is
unable to admit or deny.
5. You or someone on your behalf had photos taken of the vehicles involved in the alleged
incident prior to any changes or repairs being made to the vehicle.
RESPONSE: Due to passage of time, Defendant is unable to recall. Following
reasonable inquiry into information known or readily obtainable, Defendant is
unable to admit or deny.
6. At the time of the collision you were driving the vehicle involved in this collision with the
permission of Defendant, EAN HOLDINGS, LLC.
RESPONSE: Following reasonable inquiry into information known or readily
obtainable, Defendant is unable to admit or deny.
7. At the time of the collision you were driving within the course and scope of your
employment with Defendant, EAN HOLDINGS, LLC.
RESPONSE: Deny.
8. At the time of the collision you were driving within the course and scope of your
employment with a third party who is not named as a party to this civil action.
RESPONSE: Deny.
9. On August 18, 2021, there was a collision between the 2021 Cadillac XTS, driven by
you, and another motor vehicle.
RESPONSE: Admit.
10. The 2021 Cadillac XTS was towed from the scene of the collision.
RESPONSE: Deny.
Page 2
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
11. At the time of the collision, the Plaintiff did not cause the collision between the 2021
Cadillac XTS, driven by you, and a vehicle occupied by Plaintiff.
RESPONSE: Deny.
12. On August 18, 2021, at the time of the collision between the left side of the 2021
Cadillac XTS and the right side of a vehicle occupied by Plaintiff.
RESPONSE: Objection; Defendant is unable to formulate a response to the request,
as drafted.
13. Plaintiff did not contribute to the collision between the 2021 Cadillac XTS, driven by
you, and a vehicle occupied by Plaintiff.
RESPONSE: Deny.
14. You were negligent in causing the crash.
RESPONSE: Deny.
15. You were solely negligent in causing the crash.
RESPONSE: Deny.
16. EAN HOLDINGS, LLC, or someone on behalf of EAN HOLDINGS, LLC, negligently
entrusted its vehicle to you.
RESPONSE: Deny.
17. As a consequence of EAN HOLDINGS, LLC's negligent entrusted of its vehicle to
you, Plaintiff sustained serious and permanent injuries.
RESPONSE: Deny.
18. Plaintiff suffered damages in excess of Two Hundred and Fifty Thousand Dollars
($250,000.00).
RESPONSE: Deny.
Page 3
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20th day of January, 2023, a true and correct
copy of the foregoing was filed with the Clerk of Court using the Florida Courts e-Filing
Portal, which will send an automatic e-mail message to counsel and parties of record.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant Kateland Hughes
4190 Belfort Road #300
Jacksonville, FL 32216
Telephone (904) 672-4100
Facsimile (904) 672-4050
Patrick.Snyder@csklegal.com
Alexandra.Dabek@csklegal.com
Justine.Shields@csklegal.com
Melody.Drew@csklegal.com
By: /s/ Alexandra A. Dabek
Patrick J. Snyder, Esq.
Florida Bar No. 669962
Alexandra A. Dabek, Esq.
Florida Bar No. 1025105
Page 4
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
Preview
Filing # 165124286 E-Filed 01/20/2023 11:52:15 AM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO. 16-2022-CA-006093 BRITTINIA VANE HUGHES, DIVISION: CV-A Plaintiff, v. EAN HOLDINGS, LLC, a foreign liability company, and KATELAND WYATT, Defendant. _______________________________/ DEFENDANT, KATELAND WYATT’S, RESPONSES TO PLAINTIFF’S REQUEST FOR ADMISSIONS Defendant, Kateland Wyatt, by and through her undersigned attorneys, and pursuant to the Florida Rule of Civil Procedure 1.370, hereby files this, their responses to Plaintiff’s Request for Admissions to Defendant and states as follows: 1. The date of the incident, August 18, 2021, as alleged in the Complaint is correct. RESPONSE: Admit 2. The place of the incident - Interstate Highway 10, Jacksonville, Duval County, Florida - alleged in the Complaint is correct. RESPONSE: Admit. 3. The name of the Defendant alleged to have owned the vehicle which you were driving at the time alleged in the Complaint is correct. RESPONSE: Following reasonable inquiry into information known or readily obtainable, Defendant is unable to admit or deny. COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/20/2023 06:34:34 PM CASE NO. 16-2022-CA-006093 4. You or someone on your behalf had photos taken of the scene of the alleged incident at or near the time of the incident. RESPONSE: Due to passage of time, Defendant is unable to recall. Following reasonable inquiry into information known or readily obtainable, Defendant is unable to admit or deny. 5. You or someone on your behalf had photos taken of the vehicles involved in the alleged incident prior to any changes or repairs being made to the vehicle. RESPONSE: Due to passage of time, Defendant is unable to recall. Following reasonable inquiry into information known or readily obtainable, Defendant is unable to admit or deny. 6. At the time of the collision you were driving the vehicle involved in this collision with the permission of Defendant, EAN HOLDINGS, LLC. RESPONSE: Following reasonable inquiry into information known or readily obtainable, Defendant is unable to admit or deny. 7. At the time of the collision you were driving within the course and scope of your employment with Defendant, EAN HOLDINGS, LLC. RESPONSE: Deny. 8. At the time of the collision you were driving within the course and scope of your employment with a third party who is not named as a party to this civil action. RESPONSE: Deny. 9. On August 18, 2021, there was a collision between the 2021 Cadillac XTS, driven by you, and another motor vehicle. RESPONSE: Admit. 10. The 2021 Cadillac XTS was towed from the scene of the collision. RESPONSE: Deny. Page 2 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 11. At the time of the collision, the Plaintiff did not cause the collision between the 2021 Cadillac XTS, driven by you, and a vehicle occupied by Plaintiff. RESPONSE: Deny. 12. On August 18, 2021, at the time of the collision between the left side of the 2021 Cadillac XTS and the right side of a vehicle occupied by Plaintiff. RESPONSE: Objection; Defendant is unable to formulate a response to the request, as drafted. 13. Plaintiff did not contribute to the collision between the 2021 Cadillac XTS, driven by you, and a vehicle occupied by Plaintiff. RESPONSE: Deny. 14. You were negligent in causing the crash. RESPONSE: Deny. 15. You were solely negligent in causing the crash. RESPONSE: Deny. 16. EAN HOLDINGS, LLC, or someone on behalf of EAN HOLDINGS, LLC, negligently entrusted its vehicle to you. RESPONSE: Deny. 17. As a consequence of EAN HOLDINGS, LLC's negligent entrusted of its vehicle to you, Plaintiff sustained serious and permanent injuries. RESPONSE: Deny. 18. Plaintiff suffered damages in excess of Two Hundred and Fifty Thousand Dollars ($250,000.00). RESPONSE: Deny. Page 3 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 20th day of January, 2023, a true and correct copy of the foregoing was filed with the Clerk of Court using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to counsel and parties of record. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant Kateland Hughes 4190 Belfort Road #300 Jacksonville, FL 32216 Telephone (904) 672-4100 Facsimile (904) 672-4050 Patrick.Snyder@csklegal.com Alexandra.Dabek@csklegal.com Justine.Shields@csklegal.com Melody.Drew@csklegal.com By: /s/ Alexandra A. Dabek Patrick J. Snyder, Esq. Florida Bar No. 669962 Alexandra A. Dabek, Esq. Florida Bar No. 1025105 Page 4 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX