On December 14, 2022 a
Party Discovery
was filed
involving a dispute between
Vicki Meeks,
and
Raeqwon Brown,
Turner Pest Control, Llc,
in the District Court of Duval County.
Preview
Filing # 164950432 E-Filed 01/18/2023 01:06:31 PM
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR DUVAL
COUNTY FLORIDA
CASE NO.: 16-2022-CA-007116
DIVISION: CV-A
VICKI MEEKS,
Plaintiff,
v.
RAEQWON BROWN, an individual, and
TURNER PEST CONTROL, LLC, a Florida
Limited Liability Company,
Defendants.
___________________________________/
DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF
COMES NOW Defendant, TURNER PEST CONTROL LLC, by and through its
undersigned counsel and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure,
requests that the Plaintiff, VICKI MEEKS, admit the truth or genuineness of each of the
following within thirty (30) days after receipt of service:
1. Admit that you have no visible scars as a result of the incident alleged in your
Complaint.
RESPONSE:
2. Admit that you are not disfigured as a result of the incident alleged in your
Complaint.
RESPONSE:
3. Admit that you have not lost the capacity to enjoy life as a result of the incident
alleged in your Complaint.
RESPONSE:
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/19/2023 02:04:04 PM
4. Admit that you were not hospitalized as a result of the incident alleged in your
Complaint.
RESPONSE:
5. Admit that you did not lose wages as a result of the incident alleged in your
Complaint.
RESPONSE:
6. Admit that you have not suffered a loss of future earning capacity as a result of
the incident alleged in your Complaint.
RESPONSE:
7. Admit that at the time of the alleged incident, you told one or more individuals
present that you were fine and suffered no injuries.
RESPONSE:
8. Admit that you drove away from the scene of the alleged incident without issue.
RESPONSE:
9. Admit that you refused medical attention from Emergency Medical Services
immediately following the alleged incident.
RESPONSE:
10. Admit that the damages to your vehicle were minimal.
RESPONSE:
11. Amit that your vehicle was operational after the alleged incident.
RESPONSE:
12. Admit that you did not aggravate a pre-existing condition as a result of the incident
alleged in your Complaint.
RESPONSE:
13. Admit that the injuries that you claim are a result of the accident referenced in
your Complaint pre-date and pre-exist the date of the accident.
RESPONSE:
2
14. Admit that you have had prior accidents, such as accidents at work and others,
which resulted in physical injuries.
RESPONSE:
15. Admit that before the accident, which is referenced in your Complaint, you
sustained an injury to the same body part(s) as the body part(s) you are alleging
injury(ies) to in this lawsuit.
RESPONSE:
16. Admit that you have been involved in an automobile accident which predates the
incident referenced in your Complaint either as a driver, passenger or pedestrian.
RESPONSE:
17. Admit that you have had prior injuries in those prior motor vehicle accidents.
RESPONSE:
18. Admit that one (1) or more of your prior treating physicians opined that you
sustained significant and permanent injuries in said prior motor vehicle accident.
RESPONSE:
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing document has been
filed electronically with the Clerk of the Court using the Florida Court’s E-Filing Portal
system and furnished to the following named addressees via email on this 18th day of
January, 2023: to Michael D. Marrese, Esq., Morgan & Morgan Jacksonville, PLLC 501
Riverside Avenue, Suite 1200, Jacksonville, Florida 32202;
Mmarrese@forthepeople.com; Jlow@forthepeople.com; tlthomas@forthepeople.com.
SAALFIELD SHAD, P.A.
3
/s/ Brett A. Cole
BLAKE H. COLE, ESQUIRE
Florida Bar Number: 75031
BRETT A. COLE, ESQUIRE
Florida Bar Number: 1039195
245 Riverside Avenue, Suite 400
Jacksonville, Florida 32202
Phone: (904) 355-4401
Facsimile: (904) 355-3503
Primary: bcole@saalfieldlaw.com
rblake@saalfieldlaw.com
Secondary: brett.cole@saalfieldlaw.com
Attorneys for Defendant TURNER PEST
CONTROL LLC
4
Preview
Filing # 164950432 E-Filed 01/18/2023 01:06:31 PM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY FLORIDA CASE NO.: 16-2022-CA-007116 DIVISION: CV-A VICKI MEEKS, Plaintiff, v. RAEQWON BROWN, an individual, and TURNER PEST CONTROL, LLC, a Florida Limited Liability Company, Defendants. ___________________________________/ DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF COMES NOW Defendant, TURNER PEST CONTROL LLC, by and through its undersigned counsel and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, requests that the Plaintiff, VICKI MEEKS, admit the truth or genuineness of each of the following within thirty (30) days after receipt of service: 1. Admit that you have no visible scars as a result of the incident alleged in your Complaint. RESPONSE: 2. Admit that you are not disfigured as a result of the incident alleged in your Complaint. RESPONSE: 3. Admit that you have not lost the capacity to enjoy life as a result of the incident alleged in your Complaint. RESPONSE: ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/19/2023 02:04:04 PM 4. Admit that you were not hospitalized as a result of the incident alleged in your Complaint. RESPONSE: 5. Admit that you did not lose wages as a result of the incident alleged in your Complaint. RESPONSE: 6. Admit that you have not suffered a loss of future earning capacity as a result of the incident alleged in your Complaint. RESPONSE: 7. Admit that at the time of the alleged incident, you told one or more individuals present that you were fine and suffered no injuries. RESPONSE: 8. Admit that you drove away from the scene of the alleged incident without issue. RESPONSE: 9. Admit that you refused medical attention from Emergency Medical Services immediately following the alleged incident. RESPONSE: 10. Admit that the damages to your vehicle were minimal. RESPONSE: 11. Amit that your vehicle was operational after the alleged incident. RESPONSE: 12. Admit that you did not aggravate a pre-existing condition as a result of the incident alleged in your Complaint. RESPONSE: 13. Admit that the injuries that you claim are a result of the accident referenced in your Complaint pre-date and pre-exist the date of the accident. RESPONSE: 2 14. Admit that you have had prior accidents, such as accidents at work and others, which resulted in physical injuries. RESPONSE: 15. Admit that before the accident, which is referenced in your Complaint, you sustained an injury to the same body part(s) as the body part(s) you are alleging injury(ies) to in this lawsuit. RESPONSE: 16. Admit that you have been involved in an automobile accident which predates the incident referenced in your Complaint either as a driver, passenger or pedestrian. RESPONSE: 17. Admit that you have had prior injuries in those prior motor vehicle accidents. RESPONSE: 18. Admit that one (1) or more of your prior treating physicians opined that you sustained significant and permanent injuries in said prior motor vehicle accident. RESPONSE: CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing document has been filed electronically with the Clerk of the Court using the Florida Court’s E-Filing Portal system and furnished to the following named addressees via email on this 18th day of January, 2023: to Michael D. Marrese, Esq., Morgan & Morgan Jacksonville, PLLC 501 Riverside Avenue, Suite 1200, Jacksonville, Florida 32202; Mmarrese@forthepeople.com; Jlow@forthepeople.com; tlthomas@forthepeople.com. SAALFIELD SHAD, P.A. 3 /s/ Brett A. Cole BLAKE H. COLE, ESQUIRE Florida Bar Number: 75031 BRETT A. COLE, ESQUIRE Florida Bar Number: 1039195 245 Riverside Avenue, Suite 400 Jacksonville, Florida 32202 Phone: (904) 355-4401 Facsimile: (904) 355-3503 Primary: bcole@saalfieldlaw.com rblake@saalfieldlaw.com Secondary: brett.cole@saalfieldlaw.com Attorneys for Defendant TURNER PEST CONTROL LLC 4