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  • RAPOSA, DONNA vs. POWELL, KAREN Auto Negligence document preview
  • RAPOSA, DONNA vs. POWELL, KAREN Auto Negligence document preview
  • RAPOSA, DONNA vs. POWELL, KAREN Auto Negligence document preview
  • RAPOSA, DONNA vs. POWELL, KAREN Auto Negligence document preview
						
                                

Preview

Filing # 191057797 E-Filed 02/01/2024 03:00:32 PM IN THE CIRCUIT COURT FOR THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO.2024 CA 000070 DIVISION: 49 DONNA RAPOSA, Plaintiff, VS. KAREN MILDRED POWELL, Defendant. a PLAINTIFF’S REQUESTS FOR ADMISSION TO THE DEFENDANT, KAREN MILDRED POWELL COMES NOW the Plaintiff, DONNA RAPOSA, by and through the undersigned attorney, and pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that the Defendant, KAREN MILDRED POWELL, admit the following within thirty (30) days from this date: 1. Admit that you were negligent in the operation of the motor vehicle you were operating on April 2, 2023, which is the subject matter of this lawsuit. 2. Admit that your negligence in the operation of your motor vehicle on April 2, 2023, caused or contributed to the cause of the accident which is the subject matter of this lawsuit. 3. Admit that your negligence was a legal cause of loss, injury, or damage to Plaintiff, DONNA RAPOSA. A. Admit that Plaintiff, DONNA RAPOSA incurred medical treatment as a result of the accident which is the subject matter of this lawsuit. 5. Admit that Plaintiff, DONNA RAPOSA sustained a permanent injury within a reasonable degree of medical probability as a result of the accident which is the subject matter of this lawsuit. 6. Admit that Plaintiff, DONNA RAPOSA suffered either a permanent injury or a permanent aggravation of a pre-existing condition as a result of the accident which is the subject matter of this lawsuit. Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 02/02/2024 11:28 AM - DIN: 9 7. Admit that Plaintiff DONNA RAPOSA is not comparatively negligent for the cause of this subject accident. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished together with the Complaint herein. RUE & ZIFFRA fox BZ JAA ff fi (4 \ Le oY oe Allan L. Ziffra, Esquire 632 Dunlawton Avenue Port Orange, FL 32127 Phone: (386) 788-7700 FBN: 0749265 Email: Attorney for the Plaintiff