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Filing # 137164710 E-Filed 10/25/2021 10:10:24 AM
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, INAND FOR DUVAL
COUNTY, FLORIDA
CASE NO.: 2021-CA-4553
DIVISION: CV-D
SCOTT AKIN, STACEY AKIN, and ASHLEY
AKIN,
Plaintiffs,
V.
STEVEN WEBSTER, GERARD
WEBSTER,JR., UBER TECHNOLOGIES,
INC., RASIER, LLC, RASIER-CA,LLC,
RASIER-DC,LLC, RASIER,-PA,LLC,
RASIER-MT,LLC, and HINTER-NM,LLC,
Defendants.
/
DEFENDANT’S, STEVEN WEBSTER, FIRST REQUEST FOR ADMISSIONS TO
PLAINTIFF, ASHLEY AKIN
COMES NOW Defendant, STEVEN WEBSTER, (hereinafter “Defendant”), by and
through his undersigned counsel and pursuant to Rule 1.370 of the Florida Rules of Civil
Procedure, requests that Plaintiff, ASHLEY AKIN , admit the truth or genuineness of each
of the following within thirty (30) days after receipt of service:
1 You did not sustain any permanent injuries as a result of the incident set forth in
the operative Complaint.
You did not sustain any permanent scarring as a result of the incident set forth in
the operative Complaint.
You did not lose any wages or income as a result of the Defendant's alleged
negligence as set forth in the operative Complaint.
Your earning capacity was not reduced as a result of the Defendant’s alleged
negligence as set forth in the operative Complaint.
COLE, SCOTT, KISSANE, P.A.
4190 BELFORT ROAD, SUITE 300
JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 10/25/2021 03:48:51 PM
CASE NO.: 2021-CA-4553
DIVISION: CV-D
No medical provider has expressed a medical opinion that you have sustained a
permanent injury as a result of the Defendant's alleged negligence as set forth in
the operative Complaint.
No medical provider has expressed a medical opinion that you have sustained a
permanent scar or scarring as a result of the Defendant's alleged negligence as
set forth in the operative Complaint.
The injuries you are claiming as damages as a result of the incident referred to in
the complaint pre-existed the date of the alleged incident.
Any injuries allegedly sustained by you following the incident set forth in the
operative Complaint have completely healed.
You no longer experience any pain as a result of any alleged injury sustained by
you in the incident set forth in the operative Complaint.
10 Your ability to enjoy life has not been reduced as a result of any alleged injury
sustained by you in the incident set forth in the operative Complaint.
11 Any and all pain and suffering you alleged to have incurred as a result of the
incident set forth in the operative Complaint pre-existed the date of the alleged
incident.
12 You were involved in an auto accident prior to the incident set forth in the operative
Complaint.
13 You were involved in an auto accident after the incident set forth in the operative
Complaint.
14. You were involved in a fall prior to the incident set forth in the operative Complaint.
15 You were involved in a fall after the incident set forth in the operative Complaint.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 25th day of October, 2021, a true and correct
copy of the foregoing was filed with the Clerk of Duval County by using the Florida Courts
e-Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: Amanda Thoele, Esq. Thoele & Drach, Attorney
for Plaintiff via amanda@thoeledrach.com, pleadings@thoeledrach.com.
-2-
COLE, SCOTT, KISSANE, P.A.
BELFORT ROAD, SUITE 3(
JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX
CASE NO.: 2021-CA-4553
DIVISION: CV-D
COLE, SCOTT, KISSANE, P.A.
Counsel for Defendants STEVEN WEBSTER,
GERARD WEBSTER,JR.
4190 Belfort Road, Suite 300
Jacksonville, Florida 32216-1461
Telephone (904) 672-4099
Facsimile (904) 672-4050
Primary e-mail: trevor.hawes@csklegal.com;
brandi.stevens@csklegal.com
Secondary e-mail:
hannah.emerson@csklegal.com;
kimberly.dodgen@csklegal.com;
tammy.lewis@csklegal.com
By s/ Brandi N. Stevens
TREVOR G. HAWES
Florida Bar No.: 521531
BRANDI N. STEVENS
Florida Bar No.: 1010443
0781.0525-00
-3-
COLE, SCOTT, KISSANE, P.A.
BELFORT ROAD, SUITE 3(
JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX
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Filing # 137164710 E-Filed 10/25/2021 10:10:24 AM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, INAND FOR DUVAL COUNTY, FLORIDA CASE NO.: 2021-CA-4553 DIVISION: CV-D SCOTT AKIN, STACEY AKIN, and ASHLEY AKIN, Plaintiffs, V. STEVEN WEBSTER, GERARD WEBSTER,JR., UBER TECHNOLOGIES, INC., RASIER, LLC, RASIER-CA,LLC, RASIER-DC,LLC, RASIER,-PA,LLC, RASIER-MT,LLC, and HINTER-NM,LLC, Defendants. / DEFENDANT’S, STEVEN WEBSTER, FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF, ASHLEY AKIN COMES NOW Defendant, STEVEN WEBSTER, (hereinafter “Defendant”), by and through his undersigned counsel and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, requests that Plaintiff, ASHLEY AKIN , admit the truth or genuineness of each of the following within thirty (30) days after receipt of service: 1 You did not sustain any permanent injuries as a result of the incident set forth in the operative Complaint. You did not sustain any permanent scarring as a result of the incident set forth in the operative Complaint. You did not lose any wages or income as a result of the Defendant's alleged negligence as set forth in the operative Complaint. Your earning capacity was not reduced as a result of the Defendant’s alleged negligence as set forth in the operative Complaint. COLE, SCOTT, KISSANE, P.A. 4190 BELFORT ROAD, SUITE 300 JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 10/25/2021 03:48:51 PM CASE NO.: 2021-CA-4553 DIVISION: CV-D No medical provider has expressed a medical opinion that you have sustained a permanent injury as a result of the Defendant's alleged negligence as set forth in the operative Complaint. No medical provider has expressed a medical opinion that you have sustained a permanent scar or scarring as a result of the Defendant's alleged negligence as set forth in the operative Complaint. The injuries you are claiming as damages as a result of the incident referred to in the complaint pre-existed the date of the alleged incident. Any injuries allegedly sustained by you following the incident set forth in the operative Complaint have completely healed. You no longer experience any pain as a result of any alleged injury sustained by you in the incident set forth in the operative Complaint. 10 Your ability to enjoy life has not been reduced as a result of any alleged injury sustained by you in the incident set forth in the operative Complaint. 11 Any and all pain and suffering you alleged to have incurred as a result of the incident set forth in the operative Complaint pre-existed the date of the alleged incident. 12 You were involved in an auto accident prior to the incident set forth in the operative Complaint. 13 You were involved in an auto accident after the incident set forth in the operative Complaint. 14. You were involved in a fall prior to the incident set forth in the operative Complaint. 15 You were involved in a fall after the incident set forth in the operative Complaint. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 25th day of October, 2021, a true and correct copy of the foregoing was filed with the Clerk of Duval County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Amanda Thoele, Esq. Thoele & Drach, Attorney for Plaintiff via amanda@thoeledrach.com, pleadings@thoeledrach.com. -2- COLE, SCOTT, KISSANE, P.A. BELFORT ROAD, SUITE 3( JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX CASE NO.: 2021-CA-4553 DIVISION: CV-D COLE, SCOTT, KISSANE, P.A. Counsel for Defendants STEVEN WEBSTER, GERARD WEBSTER,JR. 4190 Belfort Road, Suite 300 Jacksonville, Florida 32216-1461 Telephone (904) 672-4099 Facsimile (904) 672-4050 Primary e-mail: trevor.hawes@csklegal.com; brandi.stevens@csklegal.com Secondary e-mail: hannah.emerson@csklegal.com; kimberly.dodgen@csklegal.com; tammy.lewis@csklegal.com By s/ Brandi N. Stevens TREVOR G. HAWES Florida Bar No.: 521531 BRANDI N. STEVENS Florida Bar No.: 1010443 0781.0525-00 -3- COLE, SCOTT, KISSANE, P.A. BELFORT ROAD, SUITE 3( JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX