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Filing # 131193967 E-Filed 07/22/2021 11:29:02 AM
'TH
J
IN THE CIRCUIT COURT OF THE 17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE 21-008882
DARREN J HILL SR,
Plaintiff,
VS.
CLEVELAND CLINIC WESTON HOSPITAL
NON-PROFIT CORPORATION, a Florida
corporation
Defendant.
RESPONSE TO PLAINTIFF'S REQUEST FOR ADMISSIONSTO DEFENDANT,
CLEVELAND CLINIC WESTON HOSPITAL NON-PROFIT CORPORATION
Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON-PROFIT
CORPORATION, by and through the undersigned counsel, pursuant to Florida Rules of Civil
Procedure 1.370(a), provides its Response to Plaintiff's Request for Admissions served with the
Complaint as set forth below.
1 Admit or deny that Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON-
PROFIT CORPORATION, was properly named herein.
RESPONSE: Admit.
2. Admit or
deny that Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON-
PROFIT CORPORATION, was properly served.
RESPONSE: Admit.
1
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/22/2021 11:29:02 AM.****
3. Admit or deny that Plaintiff, DARREN J HILL SR., was in the premises of the
Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON-PROFIT
CORPORATION, located at 2930 Cleveland Clinic Blvd, Weston, FL 33331, in Broward
County, Florida.
RESPONSE: Deny.1
4. Admit or deny that Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON-
PROFIT CORPORATION, had entire or partial control of the premises mentioned above.
RESPONSE: Deny.
5. Admit or deny that Defendant, CLEVELAND CLIN1 C WESTON HOSPITAL NON-
PROFIT CORPORATION, owed a duty to Plaintiff, DARREN J HILL SR., and to the
general public using the aforementioned premises, to keep said premises in a
reasonably
safe condition for people lawfully on said premises.
RESPONSE: Deny.
6. Admit or
deny that the above incident occurred in or about February 18, 2018, at
Defendant's premises located at 2930 Cleveland Clinic Blvd, Weston, FL 33331, in
Broward County, Florida was the result of the negligence of Defendant, CLEVELAND
CLINIC WESTON HOSPITALNON PROFIT CORPORATION.
RESPONSE: Deny.
12930 Cleveland Clinic Blvd., Weston, FL 33331 is an incorrect address. No such address exists.
2
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this ,Rlay of July, 2021, a copy of the foregoing
was filed and served via the Florida Courts E-Filing Portal to Vincent T. Brown, Esq., The
Brown Law Group, P.A., 1195 N.W. 11gth Street, Suite 202, Miami, Florida, 33168,
STEARNS WEAVER MILLER
WEISSLER ALHADEFF & SITTERSON, P.A.
Attorneys for Defendant
200 East Las Olas Blvd., Suite 2100
Fort Lauderdale, FL 33301
Telephone: (954) 462-9500
Facsimile:
(95* 462-9567
By: IVA-1---
THNMASG. ALJIN, GKQUIRE
FBN: 008060
1,
MATTHEW S. PODOLNICK, ESQUIRE
FBN: 112126
AMANADA L. SPENCER, ESQUIRE
FBN: 1010874
asn@ncer@stearnsweaver.com
3
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Filing # 131193967 E-Filed 07/22/2021 11:29:02 AM 'TH J IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 21-008882 DARREN J HILL SR, Plaintiff, VS. CLEVELAND CLINIC WESTON HOSPITAL NON-PROFIT CORPORATION, a Florida corporation Defendant. RESPONSE TO PLAINTIFF'S REQUEST FOR ADMISSIONSTO DEFENDANT, CLEVELAND CLINIC WESTON HOSPITAL NON-PROFIT CORPORATION Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON-PROFIT CORPORATION, by and through the undersigned counsel, pursuant to Florida Rules of Civil Procedure 1.370(a), provides its Response to Plaintiff's Request for Admissions served with the Complaint as set forth below. 1 Admit or deny that Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON- PROFIT CORPORATION, was properly named herein. RESPONSE: Admit. 2. Admit or deny that Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON- PROFIT CORPORATION, was properly served. RESPONSE: Admit. 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/22/2021 11:29:02 AM.**** 3. Admit or deny that Plaintiff, DARREN J HILL SR., was in the premises of the Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON-PROFIT CORPORATION, located at 2930 Cleveland Clinic Blvd, Weston, FL 33331, in Broward County, Florida. RESPONSE: Deny.1 4. Admit or deny that Defendant, CLEVELAND CLINIC WESTON HOSPITAL NON- PROFIT CORPORATION, had entire or partial control of the premises mentioned above. RESPONSE: Deny. 5. Admit or deny that Defendant, CLEVELAND CLIN1 C WESTON HOSPITAL NON- PROFIT CORPORATION, owed a duty to Plaintiff, DARREN J HILL SR., and to the general public using the aforementioned premises, to keep said premises in a reasonably safe condition for people lawfully on said premises. RESPONSE: Deny. 6. Admit or deny that the above incident occurred in or about February 18, 2018, at Defendant's premises located at 2930 Cleveland Clinic Blvd, Weston, FL 33331, in Broward County, Florida was the result of the negligence of Defendant, CLEVELAND CLINIC WESTON HOSPITALNON PROFIT CORPORATION. RESPONSE: Deny. 12930 Cleveland Clinic Blvd., Weston, FL 33331 is an incorrect address. No such address exists. 2 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this ,Rlay of July, 2021, a copy of the foregoing was filed and served via the Florida Courts E-Filing Portal to Vincent T. Brown, Esq., The Brown Law Group, P.A., 1195 N.W. 11gth Street, Suite 202, Miami, Florida, 33168, STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A. Attorneys for Defendant 200 East Las Olas Blvd., Suite 2100 Fort Lauderdale, FL 33301 Telephone: (954) 462-9500 Facsimile: (95* 462-9567 By: IVA-1--- THNMASG. ALJIN, GKQUIRE FBN: 008060 1, MATTHEW S. PODOLNICK, ESQUIRE FBN: 112126 AMANADA L. SPENCER, ESQUIRE FBN: 1010874 asn@ncer@stearnsweaver.com 3