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Filing# 180379971 E-Filed 08/23/2023 05:43:20 PM
INTHE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. CACE 21-010715 Division 13
JUSTIN BLEVINS,
Plaintiff,
V
ORVILL WEIR, CAMBRIDGE SECURITY
SERVICES CORP., a Fla. Corp.,and
WESTON APARTMENTS CORP. d/b/a
WESTON PLACE APARTMENTS, a
Fla. Corp.,
Defendants.
i
DEFENDANT'S, WESTON APARTMENTS CORP.,
REQUEST FOR ADMISSIONS TO DEFENDANT, ORVILL WEIR
COMES NOW the Defendant, WESTON APARTMENTS CORP. d/b/a WESTON
PLACE APARTMENTS ("WESTON"), by and through its undersigned counsel and pursuant to
Fla. R. Civ. P. 1.370, and hereby requests that the Defendant, ORVILL WEIR, admit or deny the
truth of the followingstatements within thirty(30)days from the date hereof.
1. Admit that the photographs included in your Amended Response to Plaintiff's
Request for Production #5 filed and served on August 31, 2022, which Amended Response is
attached hereto as Exhibit A, depictthe scene of the accident which is the subjectofthis lawsuit.
2. Admit that Photo #1, the first photo on page 4 of Exhibit A, shows two yellow
on the roadway depictedin the photograph.
stripes
3. Admit that Photo #2, as identified on page 4 of Exhibit A, shows two yellow stripes
on the roadway depictedin the photograph.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/23/2023 05:43:20 PM.****
4. Admit that Photo #3, as identified on page 4 ofExhibit A, shows two yellow stripes
on the roadway depictedin the photograph.
5. Admit that Photo #4, as identified on page 4 ofExhibit A, shows two yellow stripes
on the roadway depictedin the photograph.
6. Admit that Photo #6, as identified on page 5 ofExhibit A, shows two yellow stripes
on the roadway depictedin the photograph.
7. Admit that Photo #1, the first photo on page 4 ofExhibit A, shows that the roadway
around the motorcycle is illuminated by a lightsource.
8. Admit that Photo #2, as identified on page 4 of Exhibit A, shows that the roadway
around the motorcycle is illuminated by a lightsource.
9. Admit that Photo #3, as identified on page 4 of Exhibit A, shows that the roadway
around the motorcycle is illuminated by a lightsource.
10. Admit that Photo #4, as identified on page 4 of Exhibit A, shows that the roadway
behind the motorcycle is illuminated by a lightsource.
11. Admit that Photo #6, as identified on page 5 of Exhibit A, shows that the roadway
behind the motorcycle is illuminated by a lightsource.
12. Admit that the Florida Traffic Crash Report for the accident that is the subjectof
this lawsuit,which is attached hereto as Exhibit B, states that you "FAILED TO YIELD RIGHT-
OF-WAY" as it relates to "Drivers Actions at Time of Crash (First)."
13. Admit that the Florida Traffic Crash Report states that you "FAILED TO KEEP IN
PROPER LANE" as it relates to "Drivers Actions at Time of Crash (Second).
..
14. Admit that the Florida Traffic Crash Report states that "VISION NOT
OBSCURED" as it relates to "Vision Obstruction.
..
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15. Admit that the Florida Traffic Crash Report states that you were "drivingin the
west bound lane travelingeast bound" when you collided with the motorcycle.
16. Admit that you were drivingin the west bound lane travelingeast bound when you
collided with the motorcycle.
17. Admit that the Florida Traffic Crash Report found you to be at fault for this crash,
along with the other driver.
18. Admit that you were wholly or partially
at fault for the accident which is the subject
of this lawsuit.
19. Admit that the golf cart was operationalat the time of the accident which is the
subjectofthis lawsuit.
20. Admit that you were not experiencingany mechanical issue with the golf cart at the
time ofthe accident which is the subjectofthis lawsuit.
21. Admit that the golf cart headlightwas operationalat the time of the accident which
is the subjectofthis lawsuit.
22. Admit that you did not have the golf cart headlightturned On at the time of the
accident which is the subjectofthis lawsuit.
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy o f the foregoinghas been furnished via
electronic mail, through the Court's E-Portal System, to William McAfee, Esq., LAW OFFICES
OF ANIDJAR & LEVINE, P.A., Attorneys for Plaintiff,
300 Southeast 17 Street,Fort Lauderdale,
Florida 33316, pleadings@anl-law.com;and to Daniel J. Santaniello,Esq. and James T. Sparkman,
Esq., LUKS, SANTANIELLO, PETRILLO, COHEN & PETERFRIEND, Attorneys for
Cambridge and Weir, 301 Yamato Road, Suite 4150, Boca Raton, Florida 33431, luksboca-
pleadings@LS-law.com; jsparkman@insurancedefense.net;jmonteiro@insurancedefense.net,
this 23rd day o f August, 2023.
SACHS SAX CAPLAN
Attorneys for Defendant, Weston Apartments Corp.
6111 Broken Sound Parkway NW, Suite 200
Boca Raton, FL 33487
Telephone: (561) 994-4499
Facsimile: (561) 994-4985
Email: ssax@ssclawfirm.com
ltrumbower@ssclawfirm.com
By: IwkaaUN.WWA.MOWM
Spencer M. Sax, Esq.
Florida Bar No. 312241
Katherine A. Moum, Esq.
Florida Bar No. 92913
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Filing# 180379971 E-Filed 08/23/2023 05:43:20 PM INTHE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE 21-010715 Division 13 JUSTIN BLEVINS, Plaintiff, V ORVILL WEIR, CAMBRIDGE SECURITY SERVICES CORP., a Fla. Corp.,and WESTON APARTMENTS CORP. d/b/a WESTON PLACE APARTMENTS, a Fla. Corp., Defendants. i DEFENDANT'S, WESTON APARTMENTS CORP., REQUEST FOR ADMISSIONS TO DEFENDANT, ORVILL WEIR COMES NOW the Defendant, WESTON APARTMENTS CORP. d/b/a WESTON PLACE APARTMENTS ("WESTON"), by and through its undersigned counsel and pursuant to Fla. R. Civ. P. 1.370, and hereby requests that the Defendant, ORVILL WEIR, admit or deny the truth of the followingstatements within thirty(30)days from the date hereof. 1. Admit that the photographs included in your Amended Response to Plaintiff's Request for Production #5 filed and served on August 31, 2022, which Amended Response is attached hereto as Exhibit A, depictthe scene of the accident which is the subjectofthis lawsuit. 2. Admit that Photo #1, the first photo on page 4 of Exhibit A, shows two yellow on the roadway depictedin the photograph. stripes 3. Admit that Photo #2, as identified on page 4 of Exhibit A, shows two yellow stripes on the roadway depictedin the photograph. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/23/2023 05:43:20 PM.**** 4. Admit that Photo #3, as identified on page 4 ofExhibit A, shows two yellow stripes on the roadway depictedin the photograph. 5. Admit that Photo #4, as identified on page 4 ofExhibit A, shows two yellow stripes on the roadway depictedin the photograph. 6. Admit that Photo #6, as identified on page 5 ofExhibit A, shows two yellow stripes on the roadway depictedin the photograph. 7. Admit that Photo #1, the first photo on page 4 ofExhibit A, shows that the roadway around the motorcycle is illuminated by a lightsource. 8. Admit that Photo #2, as identified on page 4 of Exhibit A, shows that the roadway around the motorcycle is illuminated by a lightsource. 9. Admit that Photo #3, as identified on page 4 of Exhibit A, shows that the roadway around the motorcycle is illuminated by a lightsource. 10. Admit that Photo #4, as identified on page 4 of Exhibit A, shows that the roadway behind the motorcycle is illuminated by a lightsource. 11. Admit that Photo #6, as identified on page 5 of Exhibit A, shows that the roadway behind the motorcycle is illuminated by a lightsource. 12. Admit that the Florida Traffic Crash Report for the accident that is the subjectof this lawsuit,which is attached hereto as Exhibit B, states that you "FAILED TO YIELD RIGHT- OF-WAY" as it relates to "Drivers Actions at Time of Crash (First)." 13. Admit that the Florida Traffic Crash Report states that you "FAILED TO KEEP IN PROPER LANE" as it relates to "Drivers Actions at Time of Crash (Second). .. 14. Admit that the Florida Traffic Crash Report states that "VISION NOT OBSCURED" as it relates to "Vision Obstruction. .. 2 15. Admit that the Florida Traffic Crash Report states that you were "drivingin the west bound lane travelingeast bound" when you collided with the motorcycle. 16. Admit that you were drivingin the west bound lane travelingeast bound when you collided with the motorcycle. 17. Admit that the Florida Traffic Crash Report found you to be at fault for this crash, along with the other driver. 18. Admit that you were wholly or partially at fault for the accident which is the subject of this lawsuit. 19. Admit that the golf cart was operationalat the time of the accident which is the subjectofthis lawsuit. 20. Admit that you were not experiencingany mechanical issue with the golf cart at the time ofthe accident which is the subjectofthis lawsuit. 21. Admit that the golf cart headlightwas operationalat the time of the accident which is the subjectofthis lawsuit. 22. Admit that you did not have the golf cart headlightturned On at the time of the accident which is the subjectofthis lawsuit. 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy o f the foregoinghas been furnished via electronic mail, through the Court's E-Portal System, to William McAfee, Esq., LAW OFFICES OF ANIDJAR & LEVINE, P.A., Attorneys for Plaintiff, 300 Southeast 17 Street,Fort Lauderdale, Florida 33316, pleadings@anl-law.com;and to Daniel J. Santaniello,Esq. and James T. Sparkman, Esq., LUKS, SANTANIELLO, PETRILLO, COHEN & PETERFRIEND, Attorneys for Cambridge and Weir, 301 Yamato Road, Suite 4150, Boca Raton, Florida 33431, luksboca- pleadings@LS-law.com; jsparkman@insurancedefense.net;jmonteiro@insurancedefense.net, this 23rd day o f August, 2023. SACHS SAX CAPLAN Attorneys for Defendant, Weston Apartments Corp. 6111 Broken Sound Parkway NW, Suite 200 Boca Raton, FL 33487 Telephone: (561) 994-4499 Facsimile: (561) 994-4985 Email: ssax@ssclawfirm.com ltrumbower@ssclawfirm.com By: IwkaaUN.WWA.MOWM Spencer M. Sax, Esq. Florida Bar No. 312241 Katherine A. Moum, Esq. Florida Bar No. 92913 4