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 # 172051514 E-Filed 04/28/2023 03:18:17 PM
IN THE CIRCUIT COURT,
FOURTH JUDIICAL CIRCUIT,
IN AND FOR DUVAL COUNTY, FLORIDA
CASE NO: 16-2022-CA-7116
VICKI MEEKS,
Plaintiff,
-v-
RAEQWON BROWN, AN
INDIVIDUAL, AND TURNER PEST
CONTROL, LLC, A FLORIDA
LIMITED LIABILITY COMPANY,
Defendants.
_____________________________/
PLAINTIFF’S RESPONSE FOR REQUEST FOR ADMISSIONS
Plaintiff, VICKI MEEKS, by and through the undersigned attorney, responds to the Request
for Admissions of the Defendant, TURNER PEST CONTROL, served on January 18, 2023, as
follows:
1. Admit that you have no visible scars as a result of the incident alleged in your Complaint.
RESPONSE: Deny.
2. Admit that you are not disfigured as a result of the incident alleged in your Complaint.
RESPONSE: Deny.
3. Admit that you have not lost the capacity to enjoy life as a result of the incident alleged in
your Complaint.
RESPONSE: Deny.
4. Admit that you were not hospitalized as a result of the incident alleged in your Complaint.
RESPONSE: Deny.
5. Admit that you did not lose wages as a result of the incident alleged in your Complaint.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 04/28/2023 09:48:42 PM
RESPONSE: Admit.
6. Admit that you have not suffered a loss of future earning capacity as a result of the incident
alleged in your Complaint.
RESPONSE: Admit.
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: Deny.
8. Admit that you drove away from the scene of the alleged incident without issue.
RESPONSE: Deny.
9. Admit that you refused medical attention from Emergency Medical Services immediately
following the alleged incident.
RESPONSE: Deny.
10. Admit that the damages to your vehicle were minimal.
RESPONSE: Deny.
11. Amit that your vehicle was operational after the alleged incident.
RESPONSE: Deny.
12. Admit that you did not aggravate a pre-existing condition as a result of the incident alleged in
your Complaint.
RESPONSE: Admit.
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: Deny.
14. Admit that you have had prior accidents, such as accidents at work and others, which resulted
in physical injuries.
RESPONSE: Deny.
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: Deny.
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: Deny.
17. Admit that you have had prior injuries in those prior motor vehicle accidents.
RESPONSE: Deny.
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: Deny.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 28, 2023, I forwarded the foregoing Response to
Request for Admissions via email to: Blake H. Cole, Saalfield Shad, PA, 245 Riverside Ave.,
Suite 400, Jacksonville, FL 32202, bcole@saalfieldlaw.com, rblake@saalfieldlaw.com,
brett.cole@saalfieldlaw.com.
/s/ Michael D. Marrese
Michael D. Marrese, Esquire
FBN: 0544299
Morgan & Morgan, P.A.
501 Riverside Ave, Suite 1200
Jacksonville, FL 32202
Telephone: (904) 361-0052
Facsimile: (904) 361-4384
E-Mail: mmarrese@forthepeople.com
jlow@forthepeople.com
stempletom@forthepeople.com
scopeland@forthepeople.com
Attorneys for Plaintiff
Preview
Filing # 172051514 E-Filed 04/28/2023 03:18:17 PM IN THE CIRCUIT COURT, FOURTH JUDIICAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO: 16-2022-CA-7116 VICKI MEEKS, Plaintiff, -v- RAEQWON BROWN, AN INDIVIDUAL, AND TURNER PEST CONTROL, LLC, A FLORIDA LIMITED LIABILITY COMPANY, Defendants. _____________________________/ PLAINTIFF’S RESPONSE FOR REQUEST FOR ADMISSIONS Plaintiff, VICKI MEEKS, by and through the undersigned attorney, responds to the Request for Admissions of the Defendant, TURNER PEST CONTROL, served on January 18, 2023, as follows: 1. Admit that you have no visible scars as a result of the incident alleged in your Complaint. RESPONSE: Deny. 2. Admit that you are not disfigured as a result of the incident alleged in your Complaint. RESPONSE: Deny. 3. Admit that you have not lost the capacity to enjoy life as a result of the incident alleged in your Complaint. RESPONSE: Deny. 4. Admit that you were not hospitalized as a result of the incident alleged in your Complaint. RESPONSE: Deny. 5. Admit that you did not lose wages as a result of the incident alleged in your Complaint. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 04/28/2023 09:48:42 PM RESPONSE: Admit. 6. Admit that you have not suffered a loss of future earning capacity as a result of the incident alleged in your Complaint. RESPONSE: Admit. 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: Deny. 8. Admit that you drove away from the scene of the alleged incident without issue. RESPONSE: Deny. 9. Admit that you refused medical attention from Emergency Medical Services immediately following the alleged incident. RESPONSE: Deny. 10. Admit that the damages to your vehicle were minimal. RESPONSE: Deny. 11. Amit that your vehicle was operational after the alleged incident. RESPONSE: Deny. 12. Admit that you did not aggravate a pre-existing condition as a result of the incident alleged in your Complaint. RESPONSE: Admit. 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: Deny. 14. Admit that you have had prior accidents, such as accidents at work and others, which resulted in physical injuries. RESPONSE: Deny. 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: Deny. 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: Deny. 17. Admit that you have had prior injuries in those prior motor vehicle accidents. RESPONSE: Deny. 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: Deny. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 28, 2023, I forwarded the foregoing Response to Request for Admissions via email to: Blake H. Cole, Saalfield Shad, PA, 245 Riverside Ave., Suite 400, Jacksonville, FL 32202, bcole@saalfieldlaw.com, rblake@saalfieldlaw.com, brett.cole@saalfieldlaw.com. /s/ Michael D. Marrese Michael D. Marrese, Esquire FBN: 0544299 Morgan & Morgan, P.A. 501 Riverside Ave, Suite 1200 Jacksonville, FL 32202 Telephone: (904) 361-0052 Facsimile: (904) 361-4384 E-Mail: mmarrese@forthepeople.com jlow@forthepeople.com stempletom@forthepeople.com scopeland@forthepeople.com Attorneys for Plaintiff