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Filing # 192915215 E-Filed 02/28/2024 12:00:27 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY FLORIDA,
CIVIL DIVISION
JESSICA KOWALSKI,
Plaintiff
CASE NO:
-vs-
JEREMY MICHAEL LUCAS and KNIGHT
TRANSPORTATION, LLC,
Defendants
/
REQUEST FOR ADMISSIONS
TO: KNIGHT TRANSPORTATION, LLC
PURSUANT TO Rule 1.370, Florida Rules of Civil Procedure, the Plaintiff, JESSICA
KOWALSKI, requests that Defendant, KNIGHT TRANSPORTATION, LLC, admit or deny the
following within forty-five (45) days from the date of service hereof.
1. On April 17, 2023, on Interstate 75 at or near Sun City Center Blvd, in Hillsborough
County, Florida, Defendant, JEREMY MICHAEL LUCAS, was the operator of a motor vehicle that
collided with Plaintiff, JESSICA KOWALSKI’s, vehicle.
2. That the motor vehicle operated by Defendant, JEREMY MICHAEL LUCAS, was
owned by Defendant, KNIGHT TRANSPORTATION, LLC.
3. That the Defendant, KNIGHT TRANSPORTATION, LLC, gave permission to the
Defendant, JEREMY MICHAEL LUCAS, to use and operate the motor vehicle involved in the
subject accident.
4. That on April 17, 2023, Defendant, JEREMY MICHAEL LUCAS, negligently
operated said vehicle and collided with the vehicle containing Plaintiff, JESSICA KOWALSKI.
2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
5. That the Plaintiff, JESSICA KOWALSKI, suffered a permanent injury as a result of
the accident of April 17, 2023.
6. Plaintiff, JESSICA KOWALSKI, has received medical care and treatment as a result
of the bodily injury sustained in the collision described in request number 1.
7. Plaintiff, JESSICA KOWALSKI, sustained permanent injury within a reasonable
degree of medical probability under the terms of Florida Stat. §627.727(2)(b), and/or a significant and
permanent loss of an important bodily function under Fla. Stat. §627.737(2)(a) as a result of the
accident more fully described in request number 1.
8. Plaintiff’s medical bills were reasonable, necessary and related to the accident.
9. As a result of the collision described in request number 1, the vehicle driven by
Plaintiff was damaged.
SUPPLEMENTAL INTERROGATORY
10. If any above Request for Admissions have been denied please explain the facts or
reasons for said denial.
SWORN TO and subscribed before me this ____ day of _____________, 2024.
Notary Public
My commission expires:
2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
I HEREBY CERTIFY that a true copy of the foregoing, Request for Admissions to
KNIGHT TRANSPORTATION, LLC, has been furnished to the Defendant together with the
Summons and Complaint.
/s/ Amy Ferrera, Esquire
Amy Ferrera, Esquire
Florida Bar #: 15313
Morgan & Morgan Tampa P.A.
201 N. Franklin Street 7th Floor
Tampa, FL 33602
Tele: (813) 577-4738
Fax: (813) 559-4846
Primary email: AMFpleadings@forthepeople.com
Secondary email: sneal@forthepeople.com
Attorney for Plaintiff
2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
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Filing # 192915215 E-Filed 02/28/2024 12:00:27 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY FLORIDA, CIVIL DIVISION JESSICA KOWALSKI, Plaintiff CASE NO: -vs- JEREMY MICHAEL LUCAS and KNIGHT TRANSPORTATION, LLC, Defendants / REQUEST FOR ADMISSIONS TO: KNIGHT TRANSPORTATION, LLC PURSUANT TO Rule 1.370, Florida Rules of Civil Procedure, the Plaintiff, JESSICA KOWALSKI, requests that Defendant, KNIGHT TRANSPORTATION, LLC, admit or deny the following within forty-five (45) days from the date of service hereof. 1. On April 17, 2023, on Interstate 75 at or near Sun City Center Blvd, in Hillsborough County, Florida, Defendant, JEREMY MICHAEL LUCAS, was the operator of a motor vehicle that collided with Plaintiff, JESSICA KOWALSKI’s, vehicle. 2. That the motor vehicle operated by Defendant, JEREMY MICHAEL LUCAS, was owned by Defendant, KNIGHT TRANSPORTATION, LLC. 3. That the Defendant, KNIGHT TRANSPORTATION, LLC, gave permission to the Defendant, JEREMY MICHAEL LUCAS, to use and operate the motor vehicle involved in the subject accident. 4. That on April 17, 2023, Defendant, JEREMY MICHAEL LUCAS, negligently operated said vehicle and collided with the vehicle containing Plaintiff, JESSICA KOWALSKI. 2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 5. That the Plaintiff, JESSICA KOWALSKI, suffered a permanent injury as a result of the accident of April 17, 2023. 6. Plaintiff, JESSICA KOWALSKI, has received medical care and treatment as a result of the bodily injury sustained in the collision described in request number 1. 7. Plaintiff, JESSICA KOWALSKI, sustained permanent injury within a reasonable degree of medical probability under the terms of Florida Stat. §627.727(2)(b), and/or a significant and permanent loss of an important bodily function under Fla. Stat. §627.737(2)(a) as a result of the accident more fully described in request number 1. 8. Plaintiff’s medical bills were reasonable, necessary and related to the accident. 9. As a result of the collision described in request number 1, the vehicle driven by Plaintiff was damaged. SUPPLEMENTAL INTERROGATORY 10. If any above Request for Admissions have been denied please explain the facts or reasons for said denial. SWORN TO and subscribed before me this ____ day of _____________, 2024. Notary Public My commission expires: 2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 I HEREBY CERTIFY that a true copy of the foregoing, Request for Admissions to KNIGHT TRANSPORTATION, LLC, has been furnished to the Defendant together with the Summons and Complaint. /s/ Amy Ferrera, Esquire Amy Ferrera, Esquire Florida Bar #: 15313 Morgan & Morgan Tampa P.A. 201 N. Franklin Street 7th Floor Tampa, FL 33602 Tele: (813) 577-4738 Fax: (813) 559-4846 Primary email: AMFpleadings@forthepeople.com Secondary email: sneal@forthepeople.com Attorney for Plaintiff 2/28/2024 12:00 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3