On May 31, 2022 a
RESPONSE TO REQUEST FOR ADMISSIONS
was filed
involving a dispute between
Frankos, Kyle,
and
Maries, Catalin,
Tenka Sol Llc,
for Circuit Civil
in the District Court of Lake County.
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Filing # 155435552 E-Filed 08/16/2022 02:29:34 PM
IN THE CIRCUIT COURT OF THE
FIFTH JUDICIAL CIRCUIT IN AND FOR
LAKE COUNTY, FLORIDA
KYLE FRANKOS,
Plaintiff,
-v-
TENKA SOL LLC,
CASE NO: 2022-CA-000959
Defendant.
/
PLAINTIFF’S RESPONSE TO REQUEST FOR ADMISSIONS
Plaintiff, KYLE FRANKOS, by and through the undersigned attorney, responds to the
Request for admissions of Defendant, TENKA SOL LLC, served the 16th day of August, 2022, as
follows:
1 At the time of the accident that is the subject of this lawsuit, the vehicle in which you were
riding had a fully operational seat belt that was available for your use. RESPONSE: Admitted.
2, At the time of the accident that is the subject of this lawsuit, the vehicle in which you were
riding had a fully operational shoulder harness that was available for your use. RESPONSE:
Admitted.
3. ‘You were not wearing the available and fully operational seat belt at the time of the accident.
RESPONSE: Denied.
4 ‘You were not wearing the available and fully operational harness at the time of the accident.
RESPONSE: Denied.
5 Your failure to use the seat belt or hamess produced or contributed substantially to at least a
portion of your claimed damages. RESPONSE: Denied.
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 08/16/2022 02:32:13 PM
6 Your failure to use the seat belt as set forth above was unreasonable under the circumstances.
RESPONSE: Denied.
7
Your failure to use this shoulder harness as set forth above was unreasonable under the
circumstances. RESPONSE: Denied.
8 The claims of the Plaintiff are subject to the provisions of the "Florida Vehicle No-Fault Law."
RESPONSE: Admitted.
9 Please admit that all lost wages incurred by you in connection with the injuries you allegedly
sustained as a result of the incident alleged herein, have been paid by collateral sources. RESPONSE:
Denied.
10. Please admit that all medical expenses incurred by you in connection with the injuries you
allegedly sustained as a result of the incident alleged herein, have been paid by collateral sources.
RESPONSE: Admitted.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished, by
email, this 16th day of August, 2022 to: Gregory D. Jones, Esquire, [ gjones@rywantalvarez.com;
service@rywantalvarez.com; mkeni@rywantalvarez.com ] Rywant, Alvarez, Jones, Russo &
Guyton, P.A. 302 Knights Run Avenue, Suite 1000 Tampa, FL 33602..
/s/ W. Colby Roof.
W. COLBY ROOF, ESQUIRE
Florida Bar Number: 118888
Morgan & Morgan, P.A.
20 N. Orange Avenue
Suite 1600
Orlando, FL 32801
Telephone: (407) 420-1414
Facsimile: (407) 245-3485
Primary email: croof@forthepeople.com
Secondary email: kristiajohnson@forthepeople.com
Attorneys for Plaintiff
Document Filed Date
August 16, 2022
Case Filing Date
May 31, 2022
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Filing # 155435552 E-Filed 08/16/2022 02:29:34 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA KYLE FRANKOS, Plaintiff, -v- TENKA SOL LLC, CASE NO: 2022-CA-000959 Defendant. / PLAINTIFF’S RESPONSE TO REQUEST FOR ADMISSIONS Plaintiff, KYLE FRANKOS, by and through the undersigned attorney, responds to the Request for admissions of Defendant, TENKA SOL LLC, served the 16th day of August, 2022, as follows: 1 At the time of the accident that is the subject of this lawsuit, the vehicle in which you were riding had a fully operational seat belt that was available for your use. RESPONSE: Admitted. 2, At the time of the accident that is the subject of this lawsuit, the vehicle in which you were riding had a fully operational shoulder harness that was available for your use. RESPONSE: Admitted. 3. ‘You were not wearing the available and fully operational seat belt at the time of the accident. RESPONSE: Denied. 4 ‘You were not wearing the available and fully operational harness at the time of the accident. RESPONSE: Denied. 5 Your failure to use the seat belt or hamess produced or contributed substantially to at least a portion of your claimed damages. RESPONSE: Denied. FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 08/16/2022 02:32:13 PM 6 Your failure to use the seat belt as set forth above was unreasonable under the circumstances. RESPONSE: Denied. 7 Your failure to use this shoulder harness as set forth above was unreasonable under the circumstances. RESPONSE: Denied. 8 The claims of the Plaintiff are subject to the provisions of the "Florida Vehicle No-Fault Law." RESPONSE: Admitted. 9 Please admit that all lost wages incurred by you in connection with the injuries you allegedly sustained as a result of the incident alleged herein, have been paid by collateral sources. RESPONSE: Denied. 10. Please admit that all medical expenses incurred by you in connection with the injuries you allegedly sustained as a result of the incident alleged herein, have been paid by collateral sources. RESPONSE: Admitted. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished, by email, this 16th day of August, 2022 to: Gregory D. Jones, Esquire, [ gjones@rywantalvarez.com; service@rywantalvarez.com; mkeni@rywantalvarez.com ] Rywant, Alvarez, Jones, Russo & Guyton, P.A. 302 Knights Run Avenue, Suite 1000 Tampa, FL 33602.. /s/ W. Colby Roof. W. COLBY ROOF, ESQUIRE Florida Bar Number: 118888 Morgan & Morgan, P.A. 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 Telephone: (407) 420-1414 Facsimile: (407) 245-3485 Primary email: croof@forthepeople.com Secondary email: kristiajohnson@forthepeople.com Attorneys for Plaintiff