On November 30, 2020 a
Party Discovery
was filed
involving a dispute between
Leisa Jones,
Mia Graham,
and
C&K Trucking, Llc,
John Morrisey,
Progressive Select Insurance Company,
for AUTO NEGLIGENCE CASE Division: CV-F
in the District Court of Duval County.
Preview
16-2020-CA-006698-XXXX-MA Div: CV-F
Filing # 117385800 E-Filed 11/30/2020 04:20:04 PM
LEISA JONES; and MIA GRAHAM, IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR,
Plaintiffs, DUVAL COUNTY, FLORIDA
vs. CASE NO.:
DIVISION:
JOHN MORRISEY; C&K TRUCKING, LLC;
and PROGRESSIVE SELECT INSURANCE
COMPANY,
Defendants.
/
PLAINTIFFS’ REQUEST FOR ADMISSIONS TO
DEFENDANT, C&K TRUCKING, LLC
Plaintiffs, LEISA JONES and MIA GRAHAM, by and through undersigned counsel and
pursuant to Rules 1.370, Florida Rules of Civil Procedure, requests the Defendant, C&K
TRUCKING, LLC, to admit the following:
1 The date of the incident as alleged in the Complaint is correct.
2. The place of the incident alleged in the Complaint is correct.
3. That you owned the vehicle as alleged in the Complaint, on the date of the incident
that is the basis of the instant litigation.
4 You or someone on your behalf had photos taken of the scene of the alleged incident
at or near the time of the incident.
5 You or someone on your behalf had photos taken of the vehicle involved in the
alleged incident prior to any changes or repairs being made to the vehicle.
6 At the time of the collision JOHN MORRISEY was operating the vehicle involved
in this collision with your permission.
7. At the time of the collision, JOHN MORRISEY was in the course and scope of his
employment with C&K TRUCKING, LLC.
ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 12/01/2020 09:20:27 AM.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing PLAINTIFFS’ REQUEST FOR
ADMISSIONS has been served on Defendant, C&K TRUCKING, LLC, together with Plaintiffs’
Summons and Complaint through service of process.
FARAH & FARAH, P.A.
/s/ Jeffrey L. Gadd
Jeffrey L. Gadd, Esquire
Florida Bar No.: 0027786
1534 Kingsley Avenue
Orange Park, Florida 32073
(904) 396-5555 (Telephone)
(904) 420-7746 (Facsimile)
Attorney for Plaintiff
jgadd@farahandfarah.com
myanko@farahandfarah.com
Document Filed Date
November 30, 2020
Case Filing Date
November 30, 2020
Category
AUTO NEGLIGENCE CASE Division: CV-F
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16-2020-CA-006698-XXXX-MA Div: CV-F Filing # 117385800 E-Filed 11/30/2020 04:20:04 PM LEISA JONES; and MIA GRAHAM, IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR, Plaintiffs, DUVAL COUNTY, FLORIDA vs. CASE NO.: DIVISION: JOHN MORRISEY; C&K TRUCKING, LLC; and PROGRESSIVE SELECT INSURANCE COMPANY, Defendants. / PLAINTIFFS’ REQUEST FOR ADMISSIONS TO DEFENDANT, C&K TRUCKING, LLC Plaintiffs, LEISA JONES and MIA GRAHAM, by and through undersigned counsel and pursuant to Rules 1.370, Florida Rules of Civil Procedure, requests the Defendant, C&K TRUCKING, LLC, to admit the following: 1 The date of the incident as alleged in the Complaint is correct. 2. The place of the incident alleged in the Complaint is correct. 3. That you owned the vehicle as alleged in the Complaint, on the date of the incident that is the basis of the instant litigation. 4 You or someone on your behalf had photos taken of the scene of the alleged incident at or near the time of the incident. 5 You or someone on your behalf had photos taken of the vehicle involved in the alleged incident prior to any changes or repairs being made to the vehicle. 6 At the time of the collision JOHN MORRISEY was operating the vehicle involved in this collision with your permission. 7. At the time of the collision, JOHN MORRISEY was in the course and scope of his employment with C&K TRUCKING, LLC. ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 12/01/2020 09:20:27 AM. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing PLAINTIFFS’ REQUEST FOR ADMISSIONS has been served on Defendant, C&K TRUCKING, LLC, together with Plaintiffs’ Summons and Complaint through service of process. FARAH & FARAH, P.A. /s/ Jeffrey L. Gadd Jeffrey L. Gadd, Esquire Florida Bar No.: 0027786 1534 Kingsley Avenue Orange Park, Florida 32073 (904) 396-5555 (Telephone) (904) 420-7746 (Facsimile) Attorney for Plaintiff jgadd@farahandfarah.com myanko@farahandfarah.com