On September 21, 2021 a
Party Discovery
was filed
involving a dispute between
Rivera, Maylen,
Tampa Bay Imaging, Llc,
and
State Farm Mutual Automobile Insurance Company,
for Civil
in the District Court of Hillsborough County.
Preview
Filing # 135028066 E-Filed 09/21/2021 04:14:16 PM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
SMALL CLAIMS DIVISION
TAMPA BAY IMAGING, LLC., as
assignee of Maylen Rivera
Plaintiff,
v. CASE NO.:
DIVISION:
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY, a foreign
corporation
Defendant.
____________________________________/
NOTICE OF SERVICE OF PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO
DEFENDANT
COMES NOW the Plaintiff, by and through its undersigned counsel, and files this, its
Notice of Service of Plaintiff's First Request for Admissions to Defendant. Pursuant to Florida
Rule of Civil Procedure 1.370, Defendant's Responses are due within forty-five (45) days of
service.
DATED September 21, 2021.
Respectfully submitted by,
s/ Philip A. Friedman
PHILIP A. FRIEDMAN, ESQUIRE
Florida Bar #: 0635243
FL Legal Group
2700 W. Dr. Martin Luther King, Jr. Blvd. Suite 400
Tampa, FL 33607
Phone: (813) 221-9500
Primary E-mail: PAFriedman@FLLegalGroup.com
Secondary E-mail:Filings@FLLegalGroup.com
Attorneys for Plaintiff
9/21/2021 4:14 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
SMALL CLAIMS DIVISION
TAMPA BAY IMAGING, LLC., as
assignee of Maylen Rivera
Plaintiff,
v. CASE NO.:
DIVISION:
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY, a foreign
corporation
Defendant.
____________________________________/
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW the Plaintiff and files this, its First Request for Admissions to Defendant, and
pursuant to Florida Rule of Civil Procedure 1.370 hereby requests that the Defendant admit or
deny the following matters within forty-five (45) of service:
1. Admit the policy of automobile insurance, which Plaintiff claims as affording coverage
under the claim number set forth in Plaintiff’s Complaint, contains medical payments
coverage.
2. Admit the Defendant issued a policy of automobile insurance that provided personal injury
protection benefits that provides coverage to the Plaintiff’s alleged assignor as plead in
Plaintiff’s Complaint.
3. Admit the Defendant has been properly named in the Complaint.
4. Admit the Defendant has been properly served with the Summons and Complaint.
5. Admit the Court has personal jurisdiction over the parties hereto in the above-styled matter.
6. Admit that Plaintiff’s assignor occupied a motor vehicle that was involved in the motor
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9/21/2021 4:14 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
vehicle crash as plead in Plaintiff’s Complaint.
7. Admit that Plaintiff’s assignor sustained injuries as a result of the motor vehicle crash as
plead in Plaintiff’s Complaint.
8. Admit that Plaintiff’s assignor executed an assignment of PIP benefits in favor of Plaintiff.
9. Admit that Defendant is in possession of a document that purports to be an assignment of
Plaintiff’s assignor’s PIP benefits.
10. Admit that Defendant received a standard Disclosure and Acknowledgement form signed
by Plaintiff and Plaintiff’s assignor.
11. Admit that Defendant received an application for PIP benefits from Plaintiff’s assignor.
12. Admit that Defendant received notification of the automobile crash that is plead in
Plaintiff’s Complaint from its named insured.
13. Admit that Defendant’s named insured occupied a motor vehicle that was involved in the
motor vehicle crash as plead in Plaintiff’s Complaint.
14. Admit that an automobile, listed on a policy of insurance that Defendant issued, was
involved in the motor vehicle crash as plead in Plaintiff’s Complaint.
15. Admit that Defendant has issued a payment for property damage related to an automobile
that is listed on the policy of insurance under which Plaintiff seeks PIP benefits pursuant
to the claim number as plead in Plaintiff’s Complaint.
16. Admit that Defendant has cleared coverage for its named insured with regards to the
automobile crash that is plead in Plaintiff’s Complaint.
17. Admit that as a result of Defendant’s failure to pay Plaintiff’s under the policy of insurance
as plead in Plaintiff’s Complaint, Plaintiff has incurred attorney’s fees and costs in effort
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9/21/2021 4:14 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
to collect these sums due.
18. Admit that according to the Adjuster Code of Ethics, Defendant has been burdened to
timely authenticate the claim.
19. Admit Plaintiff did lawfully render the services as plead in Plaintiff’s Complaint. To the
extent this admission is denied, kindly provide the documents upon which you will use to
factually support this denial.
Respectfully submitted by,
s/ Philip A. Friedman
PHILIP A. FRIEDMAN, ESQUIRE
Florida Bar #: 0635243
FL Legal Group
2700 W. Dr. Martin Luther King, Jr. Blvd. Suite 400
Tampa, FL 33607
Phone: (813) 221-9500
Primary E-mail: PAFriedman@FLLegalGroup.com
Secondary E-mail:Filings@FLLegalGroup.com
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I CERTIFY that a copy hereof has been furnished with the summons and complaint.
s/ Philip A. Friedman
Attorney
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9/21/2021 4:14 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4
Preview
Filing # 135028066 E-Filed 09/21/2021 04:14:16 PM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SMALL CLAIMS DIVISION TAMPA BAY IMAGING, LLC., as assignee of Maylen Rivera Plaintiff, v. CASE NO.: DIVISION: STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, a foreign corporation Defendant. ____________________________________/ NOTICE OF SERVICE OF PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW the Plaintiff, by and through its undersigned counsel, and files this, its Notice of Service of Plaintiff's First Request for Admissions to Defendant. Pursuant to Florida Rule of Civil Procedure 1.370, Defendant's Responses are due within forty-five (45) days of service. DATED September 21, 2021. Respectfully submitted by, s/ Philip A. Friedman PHILIP A. FRIEDMAN, ESQUIRE Florida Bar #: 0635243 FL Legal Group 2700 W. Dr. Martin Luther King, Jr. Blvd. Suite 400 Tampa, FL 33607 Phone: (813) 221-9500 Primary E-mail: PAFriedman@FLLegalGroup.com Secondary E-mail:Filings@FLLegalGroup.com Attorneys for Plaintiff 9/21/2021 4:14 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SMALL CLAIMS DIVISION TAMPA BAY IMAGING, LLC., as assignee of Maylen Rivera Plaintiff, v. CASE NO.: DIVISION: STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, a foreign corporation Defendant. ____________________________________/ PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW the Plaintiff and files this, its First Request for Admissions to Defendant, and pursuant to Florida Rule of Civil Procedure 1.370 hereby requests that the Defendant admit or deny the following matters within forty-five (45) of service: 1. Admit the policy of automobile insurance, which Plaintiff claims as affording coverage under the claim number set forth in Plaintiff’s Complaint, contains medical payments coverage. 2. Admit the Defendant issued a policy of automobile insurance that provided personal injury protection benefits that provides coverage to the Plaintiff’s alleged assignor as plead in Plaintiff’s Complaint. 3. Admit the Defendant has been properly named in the Complaint. 4. Admit the Defendant has been properly served with the Summons and Complaint. 5. Admit the Court has personal jurisdiction over the parties hereto in the above-styled matter. 6. Admit that Plaintiff’s assignor occupied a motor vehicle that was involved in the motor 2 of 2 9/21/2021 4:14 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 vehicle crash as plead in Plaintiff’s Complaint. 7. Admit that Plaintiff’s assignor sustained injuries as a result of the motor vehicle crash as plead in Plaintiff’s Complaint. 8. Admit that Plaintiff’s assignor executed an assignment of PIP benefits in favor of Plaintiff. 9. Admit that Defendant is in possession of a document that purports to be an assignment of Plaintiff’s assignor’s PIP benefits. 10. Admit that Defendant received a standard Disclosure and Acknowledgement form signed by Plaintiff and Plaintiff’s assignor. 11. Admit that Defendant received an application for PIP benefits from Plaintiff’s assignor. 12. Admit that Defendant received notification of the automobile crash that is plead in Plaintiff’s Complaint from its named insured. 13. Admit that Defendant’s named insured occupied a motor vehicle that was involved in the motor vehicle crash as plead in Plaintiff’s Complaint. 14. Admit that an automobile, listed on a policy of insurance that Defendant issued, was involved in the motor vehicle crash as plead in Plaintiff’s Complaint. 15. Admit that Defendant has issued a payment for property damage related to an automobile that is listed on the policy of insurance under which Plaintiff seeks PIP benefits pursuant to the claim number as plead in Plaintiff’s Complaint. 16. Admit that Defendant has cleared coverage for its named insured with regards to the automobile crash that is plead in Plaintiff’s Complaint. 17. Admit that as a result of Defendant’s failure to pay Plaintiff’s under the policy of insurance as plead in Plaintiff’s Complaint, Plaintiff has incurred attorney’s fees and costs in effort 2 of 3 9/21/2021 4:14 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 to collect these sums due. 18. Admit that according to the Adjuster Code of Ethics, Defendant has been burdened to timely authenticate the claim. 19. Admit Plaintiff did lawfully render the services as plead in Plaintiff’s Complaint. To the extent this admission is denied, kindly provide the documents upon which you will use to factually support this denial. Respectfully submitted by, s/ Philip A. Friedman PHILIP A. FRIEDMAN, ESQUIRE Florida Bar #: 0635243 FL Legal Group 2700 W. Dr. Martin Luther King, Jr. Blvd. Suite 400 Tampa, FL 33607 Phone: (813) 221-9500 Primary E-mail: PAFriedman@FLLegalGroup.com Secondary E-mail:Filings@FLLegalGroup.com Attorneys for Plaintiff CERTIFICATE OF SERVICE I CERTIFY that a copy hereof has been furnished with the summons and complaint. s/ Philip A. Friedman Attorney 3 of 3 9/21/2021 4:14 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4