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Filing # 140910600 E-Filed 12/23/2021 04:04:29 PM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT, IN AND
FOR DUVAL COUNTY, FLORIDA
SCOTT AKIN, STACEY AKIN, AND CASE NO: 16-2021-CA-004553
ASHLEY AKIN, DIV: CV-D
Plaintiffs,
Vv.
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.
PLAINTIFF ASHLEY AKIN‘S REQUEST FOR ADMISSIONS TO DEFENDANT,
GERARD WEBSTER, JR
Plaintiff, ASHLEY AKIN, by and through the undersigned attorneys and pursuant to the
applicable rules, requests Defendant, GERARD WEBSTER, JR, to either admit or deny the
following:
Definitions: The term “subject collision” is defined to refer to the automobile crash that is the
subject of the Complaint.
1 That you have no evidence that any act of Plaintiff, ASHLEY AKIN, caused or contributed
to the subject collision.
2 That you have no evidence that any omission of Plaintiff, ASHLEY AKIN, caused or
contributed to subject collision.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/28/2021 11:09:41 AM
3 That, at the time of the subject collision, Defendant, STEVEN WEBSTER, failed to yield the
right of way to the other vehicle invovled in the collision.
4 That Defendant, STEVEN WEBSTER’s, actions contributed to causing the subject collision.
5 That Defendant, STEVEN WEBSTER’, actions caused the subject collision.
6 That Plaintiff, ASHLEY AKIN, suffered physical injury as a proximate result of the subject
collision.
7
That Defendant, STEVEN WEBSTER, was a professional driver and/or prefessional
reideshare operator on the date and time of the subject collision.
8. That Defendant, STEVEN WEBSTER, was an employee, agent, and/or independant
contractor of RAISER-DC, LLC, at the time of the subject collision.
9. That Defendant, STEVEN WEBSTER, was acting within the course and scope of his
employment or agency with RAISER-DC, LLC at the time of the subjection collision.
10. That at the time of the subject collision, Defendant, STEVEN WEBSTER, was operating a
vehicle owned by Defendant, GERARD WEBSTER, JR.
11. That at the time of the subject collision, Defendant, STEVEN WEBSTER, was operating the
vehicle owned by Defendant, GERARD WEBSTER, JR, with the knowledge of Defendant,
GERARD WEBSTER, JR.
12. That at the time of the subject collision, Defendant, STEVEN WEBSTER, was operating the
vehicle owned by Defendant, GERARD WEBSTER, JR, with the consent of Defendant,
GERARD WEBSTER, JR.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of this document was filed by Florida
Courts E-filing Portal and was electronically served pursuant Fla.R.Jud.Admin. 2.516 to the
parties/counsel on December 23, 2021.
THOELE | DRACH
BY/s/ Amanda Marie Thoele
Justin Seth Drach, Esq.
Florida Bar No. 103016
Email: justin@thoeledrach.com
Secondary email: pleadings@thoeledrach.com
Amanda Marie Thoele, Esq.
Florida Bar No. 75118
Email: amanda@thoeledrach.com
Secondary email: pleadings@thoeledrach.com
7545 Centurion Parkway, Suite 303
Jacksonville, FL 32256
Telephone: (904) 600-4384
Facsimile: (904) 306-1355
Attorneys for Plaintiffs
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Filing # 140910600 E-Filed 12/23/2021 04:04:29 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA SCOTT AKIN, STACEY AKIN, AND CASE NO: 16-2021-CA-004553 ASHLEY AKIN, DIV: CV-D Plaintiffs, Vv. 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. PLAINTIFF ASHLEY AKIN‘S REQUEST FOR ADMISSIONS TO DEFENDANT, GERARD WEBSTER, JR Plaintiff, ASHLEY AKIN, by and through the undersigned attorneys and pursuant to the applicable rules, requests Defendant, GERARD WEBSTER, JR, to either admit or deny the following: Definitions: The term “subject collision” is defined to refer to the automobile crash that is the subject of the Complaint. 1 That you have no evidence that any act of Plaintiff, ASHLEY AKIN, caused or contributed to the subject collision. 2 That you have no evidence that any omission of Plaintiff, ASHLEY AKIN, caused or contributed to subject collision. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/28/2021 11:09:41 AM 3 That, at the time of the subject collision, Defendant, STEVEN WEBSTER, failed to yield the right of way to the other vehicle invovled in the collision. 4 That Defendant, STEVEN WEBSTER’s, actions contributed to causing the subject collision. 5 That Defendant, STEVEN WEBSTER’, actions caused the subject collision. 6 That Plaintiff, ASHLEY AKIN, suffered physical injury as a proximate result of the subject collision. 7 That Defendant, STEVEN WEBSTER, was a professional driver and/or prefessional reideshare operator on the date and time of the subject collision. 8. That Defendant, STEVEN WEBSTER, was an employee, agent, and/or independant contractor of RAISER-DC, LLC, at the time of the subject collision. 9. That Defendant, STEVEN WEBSTER, was acting within the course and scope of his employment or agency with RAISER-DC, LLC at the time of the subjection collision. 10. That at the time of the subject collision, Defendant, STEVEN WEBSTER, was operating a vehicle owned by Defendant, GERARD WEBSTER, JR. 11. That at the time of the subject collision, Defendant, STEVEN WEBSTER, was operating the vehicle owned by Defendant, GERARD WEBSTER, JR, with the knowledge of Defendant, GERARD WEBSTER, JR. 12. That at the time of the subject collision, Defendant, STEVEN WEBSTER, was operating the vehicle owned by Defendant, GERARD WEBSTER, JR, with the consent of Defendant, GERARD WEBSTER, JR. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this document was filed by Florida Courts E-filing Portal and was electronically served pursuant Fla.R.Jud.Admin. 2.516 to the parties/counsel on December 23, 2021. THOELE | DRACH BY/s/ Amanda Marie Thoele Justin Seth Drach, Esq. Florida Bar No. 103016 Email: justin@thoeledrach.com Secondary email: pleadings@thoeledrach.com Amanda Marie Thoele, Esq. Florida Bar No. 75118 Email: amanda@thoeledrach.com Secondary email: pleadings@thoeledrach.com 7545 Centurion Parkway, Suite 303 Jacksonville, FL 32256 Telephone: (904) 600-4384 Facsimile: (904) 306-1355 Attorneys for Plaintiffs