Party Discovery: Carroll, Paige Plaintiff vs Foos, Annabelle Defendant

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                                Filing # 189204713 E-Filed 01/05/2024 04:56:45 PM



          IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
                       IN AND FOR LEE COUNTY, FLORIDA
                                 CIVIL DIVISION

          PAIGE CARROLL,

                Plaintiff,

          vs.                                       CASE NO.:

          ANNABELLE FOOS,

                Defendant.
                                                /

                      PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS
                            TO DEFENDANT ANNABELLE FOOS

                Plaintiff, by and through undersigned counsel, pursuant to Rule

          1.370, Fla. R. Civ. P., files this Request for Admissions to Defendant,

          ANNABELLE          FOOS.   Failure to respond within the time period set

          forth in Florida Rule of Civil Procedure 1.370 may result in such

          matters to be admitted.      The Defendant is directed to admit or deny

          with specificity the following matters:
                1
                        Admit that you were the sole owner of the motor vehicle

          you were operating at the time of the subject incident.

                2       Admit that you were not operating the motor vehicle in the

          course and scope of any employment at the time of the subject

          incident,
3     Admit that at the time of the subject motor vehicle

collision with Plaintiff, PAIGE CARROLL, that the motor vehicle

operated by Defendant, ANNABELLE        FOOS,   impacted the motor

vehicle operated by Plaintiff, PAIGE CARROLL.

      4     Admit that at the time of the subject motor vehicle

collision, the motor vehicle operated by Plaintiff, PAIGE CARROLL,

had the right of way.

      5.    Admit that at the time of the subject motor vehicle crash,

you violated the right of way of the motor vehicle operated by Plaintiff,

PAIGE CARROLL.

      6     Admit that you are 100% at fault for causing the motor

vehicle collision with the motor vehicle operated by Plaintiff, PAIGE

CARROLL.

      7     Admit that as a result of the subject motor vehicle collision

with the motor vehicle operated by Plaintiff, PAIGE CARROLL, you

caused injury to Plaintiff, PAIGE CARROLL.

                        CERTIFICATE OF SERVICE

      | HEREBY CERTIFY that a true and correct copy of the

foregoing has been furnished to Defendant, via service of process

with the Summons and Complaint and has been electronically filed
with the Clerk of the Court through the Florida Courts E-Filing Portal,

which will send notice of electronic filing to all counsel of record on

this 5 cday of January 2024.




                                     Benj    in D. Lusk,    BSq.
                                     Floriga Bar No,     8789
                                     Lusk,   rasites & Tolisano, P.A.
                                     202 Del Prado Blvd. S.
                                     Cape Coral, Florida 33990
                                     Telephone: (239) 574-7442
                                     Email: BLusk@LDTlaw.com
                                     Email:.Rose@LDTlaw.com
                                     Email: Gillan@LDTlaw.com