On August 23, 2021 a
Party Discovery
was filed
involving a dispute between
Ashley Akin,
Scott Akin,
Stacey Akin,
and
Gerald Webster Jr,
Hinter-Nm, Llc,
Rasier-Ca, Llc,
Rasier-Dc, Llc,
Rasier, Llc,
Rasier-Mt, Llc,
Rasier-Pa, Llc,
Steven Webster,
Uber Technologies, Inc.,
for AUTO NEGLIGENCE CASE Division: CV-D
in the District Court of Duval County.
Preview
Filing # 140916558 E-Filed 12/23/2021 07:29:26 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, STACEY AKIN’S RESPONSE TO DEFENDANT’S, STEVEN WEBSTER,
FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF, STACEY AKIN
Plaintiff, STACEY AKIN, by and through the undersigned attorneys and pursuant to the
applicable Rules of Civil Procedure, hereby responds to the following Requests for Admissions to
Plaintiff, Stacey Akin.
1 You did not sustain any permanent injuries as a result of the incident set forth in the
operative Complaint.
RESPONSE: Denied.
2 You did not sustain any permanent scarring as a result of the incident set forth in the
operative Complaint.
RESPONSE: Denied.
3 You did not lose any wages or income as a result of the Defendant’s alleged negligence as
set forth in the operative Complaint.
RESPONSE: Admitted.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/28/2021 11:59:29 AM
Your earning capacity was not reduced as a result of the Defendant’s alleged negligence as
set forth in the operative Complaint.
RESPONSE: Admitted.
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.
RESPONSE: Denied.
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.
RESPONSE: Denied.
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.
RESPONSE: Denied.
Any injuries allegedly sustained by you following the incident set forth in the operative
Complaint have completely healed.
RESPONSE: Denied.
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.
RESPONSE: Denied.
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.
RESPONSE: Denied.
1 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.
RESPONSE: Denied.
12. You were involved in an auto accident prior to the incident set forth in the operative
Complaint.
RESPONSE: Denied.
13. You were involved in an auto accident after the incident set forth in the operative
Complaint.
RESPONSE: Admitted.
14. You were involved in a fall prior to the incident set forth in the operative Complaint.
RESPONSE: Denied.
15. You were involved in a fall after the incident set forth in the operative Complaint.
RESPONSE: Denied.
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
Document Filed Date
December 23, 2021
Case Filing Date
August 23, 2021
Category
AUTO NEGLIGENCE CASE Division: CV-D
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 140916558 E-Filed 12/23/2021 07:29:26 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, STACEY AKIN’S RESPONSE TO DEFENDANT’S, STEVEN WEBSTER, FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF, STACEY AKIN Plaintiff, STACEY AKIN, by and through the undersigned attorneys and pursuant to the applicable Rules of Civil Procedure, hereby responds to the following Requests for Admissions to Plaintiff, Stacey Akin. 1 You did not sustain any permanent injuries as a result of the incident set forth in the operative Complaint. RESPONSE: Denied. 2 You did not sustain any permanent scarring as a result of the incident set forth in the operative Complaint. RESPONSE: Denied. 3 You did not lose any wages or income as a result of the Defendant’s alleged negligence as set forth in the operative Complaint. RESPONSE: Admitted. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/28/2021 11:59:29 AM Your earning capacity was not reduced as a result of the Defendant’s alleged negligence as set forth in the operative Complaint. RESPONSE: Admitted. 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. RESPONSE: Denied. 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. RESPONSE: Denied. 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. RESPONSE: Denied. Any injuries allegedly sustained by you following the incident set forth in the operative Complaint have completely healed. RESPONSE: Denied. 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. RESPONSE: Denied. 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. RESPONSE: Denied. 1 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. RESPONSE: Denied. 12. You were involved in an auto accident prior to the incident set forth in the operative Complaint. RESPONSE: Denied. 13. You were involved in an auto accident after the incident set forth in the operative Complaint. RESPONSE: Admitted. 14. You were involved in a fall prior to the incident set forth in the operative Complaint. RESPONSE: Denied. 15. You were involved in a fall after the incident set forth in the operative Complaint. RESPONSE: Denied. 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