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Filing # 145140864 E-Filed 03/06/2022 05:35:20 AM
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA
SCOTT AKIN, STACEY AKIN, and CASE NO.: 2021-CA-4553
ASHLEY AKIN , DIVISION: CV-D
Plaintiffs,
V.
STEVEN WEBSTER, GERAD
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, STEVEN WEBSTER’S, RESPONSES TO PLAINTIFF, ASHLEY
AKIN’S, REQUESTS FOR ADMISSION
COMES NOW Defendants, STEVEN WEBSTER (hereinafter “Defendant”), by and
through his undersigned counsel, and pursuant to the Florida Rules of Civil Procedure
1.370, files his Responses to Plaintiffs Requests for Admissions and states as follows:
1. That you have no evidence that any act of Plaintiff, ASHLEY AKIN, caused or
contributed to the subject collision.
Response: Admit.
2. That you have no evidence that any omission of Plaintiff, ASHLEY AKIN,
caused orcontributed to subject collision.
Response: Denied.
3. That, at the time of the subject collision, Defendant, STEVEN WEBSTER, failed
to yield the right of way to the other vehicle involved in the collision.
Response: Denied.
COLE, SCOTT, KISSANE, P.A.
190 BELFORT ROAD, SUITE 3
JACKSONVILLE, FLOR IDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 03/06/2022 11:42:17 AM
CASE NO.: 2021-CA-4553
DIVISION: CV-D
That Defendant, STEVEN WEBSTER’s, actions contributed to causing the subject
collision.
Response: Admit.
That Defendant, STEVEN WEBSTER’s, actions caused the subject collision.
Response: Denied.
That Plaintiff, ASHLEY AKIN, suffered physical injury as a proximate result of the
subject collision.
Response: Objection. Defendant is not a medical doctor or other qualified
health care prover. As a result, he lacks the legal capacity to admit or deny
this request and further lacks personal knowledge from which to admit or
deny. Otherwise, denied.
That Defendant, STEVEN WEBSTER, was a professional driver and/or
professional rideshare operator on the date and time of the subject collision.
Response: Denied. Defendant admits that he was performing rideshare
services as an independent rideshare driver utilizing the Uber application.
That Defendant, STEVEN WEBSTER, was an employee, agent, and/or
independent contractor of RAISER-DC, LLC, at the time of the subject collision.
Response: Denied. Defendant admits that he was performing rideshare
services as an independent rideshare driver utilizing the Uber application.
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.
Response: Denied. Defendant admits that he was performing rideshare
services as an independent rideshare driver utilizing the Uber application.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 6th day of March, 2022, a true and correct copy
of the foregoing was filed with the Clerk of Duval County by using the Florida Courts e-
2
COLE, SCOTT, KISSANE, P.A.
4190 BELFORT ROAD, SUITE
JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX
CASE NO.: 2021-CA-4553
DIVISION: CV-D
Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: Justin S. Drach, Esq., Thoele Drach,
justin@thoeledrach.com;amanda@thoeledrach.com;courtney@thoeledrach.com, 7545
Centurion Parkway, Suite 303, Jacksonville, FL 32256, (904) 600-4384/(904) 306-1355
(F), Attorney for Plaintiffs, Ashley Akin, Scott A. Akin and Stacey Akin, Kathryn M.
Oughton, Esq., Boyd & Jenerette, P.A.,
efiling@boydjen.com;koughton@boydjen.com;adodd@boydjen.com;dhohmann@boydj
en.com;cmccaskill@boydjen.com, 201 North Hogan Street, Suite 400, Jacksonville, FL
32202, (904) 353-624 1/(904) 493-3739 (F), Attorney for Defendant, Rasier-DC, LLC a/k/a
Uber Technologies, Inc., Amanda Thoele, Esq., Thoele Drach,
justin@thoeledrach.com;amanda@thoeledrach.com;courtney@thoeldrach.com, 7545
Centurion Parkway, Suite 303, Jacksonville, FL 32256, (904) 233-1555/(604) 306-1355
(F), Attorney for Plaintiffs, Ashley Akin, Stacey Akin and Scott A. Akin.
COLE, SCOTT, KISSANE, P.A.
Counsel for Defendant STEVEN WEBSTER,
GERAD 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
Alternate e-mail:
hannah.emerson@csklegal.com;
kimberly.dodgen@csklegal.com;
tammy.lewis@csklegal.com
3
COLE, SCOTT, KISSANE, P.A.
4190 BELFORT ROAD, SUITE
JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX
CASE NO.: 2021-CA-4553
DIVISION: CV-D
By: _s/ Brea L. Dearing
TREVOR G. HAWES
Florida Bar No.: 521531
BREA L.DEARING
Florida Bar No.: 124341
0781.0525-00
4
COLE, SCOTT, KISSANE, P.A.
4190 BELFORT ROAD, SUITE
JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX
Preview
Filing # 145140864 E-Filed 03/06/2022 05:35:20 AM IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA SCOTT AKIN, STACEY AKIN, and CASE NO.: 2021-CA-4553 ASHLEY AKIN , DIVISION: CV-D Plaintiffs, V. STEVEN WEBSTER, GERAD 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, STEVEN WEBSTER’S, RESPONSES TO PLAINTIFF, ASHLEY AKIN’S, REQUESTS FOR ADMISSION COMES NOW Defendants, STEVEN WEBSTER (hereinafter “Defendant”), by and through his undersigned counsel, and pursuant to the Florida Rules of Civil Procedure 1.370, files his Responses to Plaintiffs Requests for Admissions and states as follows: 1. That you have no evidence that any act of Plaintiff, ASHLEY AKIN, caused or contributed to the subject collision. Response: Admit. 2. That you have no evidence that any omission of Plaintiff, ASHLEY AKIN, caused orcontributed to subject collision. Response: Denied. 3. That, at the time of the subject collision, Defendant, STEVEN WEBSTER, failed to yield the right of way to the other vehicle involved in the collision. Response: Denied. COLE, SCOTT, KISSANE, P.A. 190 BELFORT ROAD, SUITE 3 JACKSONVILLE, FLOR IDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 03/06/2022 11:42:17 AM CASE NO.: 2021-CA-4553 DIVISION: CV-D That Defendant, STEVEN WEBSTER’s, actions contributed to causing the subject collision. Response: Admit. That Defendant, STEVEN WEBSTER’s, actions caused the subject collision. Response: Denied. That Plaintiff, ASHLEY AKIN, suffered physical injury as a proximate result of the subject collision. Response: Objection. Defendant is not a medical doctor or other qualified health care prover. As a result, he lacks the legal capacity to admit or deny this request and further lacks personal knowledge from which to admit or deny. Otherwise, denied. That Defendant, STEVEN WEBSTER, was a professional driver and/or professional rideshare operator on the date and time of the subject collision. Response: Denied. Defendant admits that he was performing rideshare services as an independent rideshare driver utilizing the Uber application. That Defendant, STEVEN WEBSTER, was an employee, agent, and/or independent contractor of RAISER-DC, LLC, at the time of the subject collision. Response: Denied. Defendant admits that he was performing rideshare services as an independent rideshare driver utilizing the Uber application. 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. Response: Denied. Defendant admits that he was performing rideshare services as an independent rideshare driver utilizing the Uber application. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 6th day of March, 2022, a true and correct copy of the foregoing was filed with the Clerk of Duval County by using the Florida Courts e- 2 COLE, SCOTT, KISSANE, P.A. 4190 BELFORT ROAD, SUITE JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX CASE NO.: 2021-CA-4553 DIVISION: CV-D Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Justin S. Drach, Esq., Thoele Drach, justin@thoeledrach.com;amanda@thoeledrach.com;courtney@thoeledrach.com, 7545 Centurion Parkway, Suite 303, Jacksonville, FL 32256, (904) 600-4384/(904) 306-1355 (F), Attorney for Plaintiffs, Ashley Akin, Scott A. Akin and Stacey Akin, Kathryn M. Oughton, Esq., Boyd & Jenerette, P.A., efiling@boydjen.com;koughton@boydjen.com;adodd@boydjen.com;dhohmann@boydj en.com;cmccaskill@boydjen.com, 201 North Hogan Street, Suite 400, Jacksonville, FL 32202, (904) 353-624 1/(904) 493-3739 (F), Attorney for Defendant, Rasier-DC, LLC a/k/a Uber Technologies, Inc., Amanda Thoele, Esq., Thoele Drach, justin@thoeledrach.com;amanda@thoeledrach.com;courtney@thoeldrach.com, 7545 Centurion Parkway, Suite 303, Jacksonville, FL 32256, (904) 233-1555/(604) 306-1355 (F), Attorney for Plaintiffs, Ashley Akin, Stacey Akin and Scott A. Akin. COLE, SCOTT, KISSANE, P.A. Counsel for Defendant STEVEN WEBSTER, GERAD 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 Alternate e-mail: hannah.emerson@csklegal.com; kimberly.dodgen@csklegal.com; tammy.lewis@csklegal.com 3 COLE, SCOTT, KISSANE, P.A. 4190 BELFORT ROAD, SUITE JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX CASE NO.: 2021-CA-4553 DIVISION: CV-D By: _s/ Brea L. Dearing TREVOR G. HAWES Florida Bar No.: 521531 BREA L.DEARING Florida Bar No.: 124341 0781.0525-00 4 COLE, SCOTT, KISSANE, P.A. 4190 BELFORT ROAD, SUITE JACKSONVILLE, FLORIDA 32216-1461, - (904) 672-4100 (904) 672-4050 FAX