On February 28, 2024 a
Party Discovery
was filed
involving a dispute between
Context Medical Group Inc.,
Perez, Nairibel,
and
Progressive Express Insurance Company,
for Civil
in the District Court of Hillsborough County.
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Filing # 192938190 E-Filed 02/28/2024 02:30:26 PM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
SMALL CLAIMS DIVISION
CONTEXT MEDICAL GROUP, INC., as
assignee of Nairibel Perez,
Plaintiff,
CASE NO.:
v.
DIVISION:
PROGRESSIVE EXPRESS INSURANCE
COMPANY, a foreign corporation,
Defendant.
____________________________________
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW the Plaintiff and files this, its First Request for Admissions to Defendant, and
pursuant to Florida Rule of Civil Procedure 1.370 hereby requests that the Defendant admit or
deny the following matters within forty-five (45) of service:
1. Admit the policy of automobile insurance, which Plaintiff claims as affording coverage
under the claim number set forth in Plaintiff’s Complaint, contains medical payments
coverage.
2. Admit the Defendant issued a policy of automobile insurance that provided personal injury
protection benefits that provides coverage to the Plaintiff’s alleged assignor as plead in
Plaintiff’s Complaint.
3. Admit the Defendant has been properly named in the Complaint.
4. Admit the Defendant has been properly served with the Summons and Complaint.
5. Admit the Court has personal jurisdiction over the parties hereto in the above-styled matter.
6. Admit that Plaintiff’s assignor occupied a motor vehicle that was involved in the motor
vehicle crash as plead in Plaintiff’s Complaint.
2/28/2024 2:30 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
7. Admit that Plaintiff’s assignor sustained injuries as a result of the motor vehicle crash as
plead in Plaintiff’s Complaint.
8. Admit that Plaintiff’s assignor executed an assignment of PIP benefits in favor of Plaintiff.
9. Admit that Defendant is in possession of a document that purports to be an assignment of
Plaintiff’s assignor’s PIP benefits.
10. Admit that Defendant received a standard Disclosure and Acknowledgement form signed
by Plaintiff and Plaintiff’s assignor.
11. Admit that Defendant received an application for PIP benefits from Plaintiff’s assignor.
12. Admit that Defendant received notification of the automobile crash that is plead in
Plaintiff’s Complaint from its named insured.
13. Admit that Defendant’s named insured occupied a motor vehicle that was involved in the
motor vehicle crash as plead in Plaintiff’s Complaint.
14. Admit that an automobile, listed on a policy of insurance that Defendant issued, was
involved in the motor vehicle crash as plead in Plaintiff’s Complaint.
15. Admit that Defendant has issued a payment for property damage related to an automobile
that is listed on the policy of insurance under which Plaintiff seeks PIP benefits pursuant
to the claim number as plead in Plaintiff’s Complaint.
16. Admit that Defendant has cleared coverage for its named insured with regards to the
automobile crash that is plead in Plaintiff’s Complaint.
17. Admit that as a result of Defendant’s failure to pay Plaintiff’s under the policy of insurance
as plead in Plaintiff’s Complaint, Plaintiff has incurred attorney’s fees and costs in effort
to collect these sums due.
18. Admit that according to the Adjuster Code of Ethics, Defendant has been burdened to
2/28/2024 2:30 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
timely authenticate the claim.
19. Admit Plaintiff did lawfully render the services as plead in Plaintiff’s Complaint. To the
extent this admission is denied, kindly provide the documents upon which you will use to
factually support this denial.
Respectfully submitted by,
s/Marc J. Semago
MARC J. SEMAGO, ESQUIRE
Florida Bar#: 721441
MATTHEW D. BRUMLEY, ESQUIRE
Florida Bar #: 0480908
Semago & Associates, PLLC
d/b/a FL Legal Group
2700 W. Dr. Martin Luther King, Jr. Blvd, #400
Tampa, FL 33607
Phone: (813) 221-9500
Primary E-mail: filings@FLLegalAttorneys.com
Secondary E-mail:
MJSemago@FLLegalAttorneys.com
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I CERTIFY that a copy hereof has been e-filed and served along with the Summons and
Complaint, pursuant to Rule 2.516, using the Florida Courts E-Filing Portal’s Notice of Electronic Filing,
on February 28, 2024.
s/ Marc J. Semago
Attorney
2/28/2024 2:30 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
Document Filed Date
February 28, 2024
Case Filing Date
February 28, 2024
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Filing # 192938190 E-Filed 02/28/2024 02:30:26 PM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SMALL CLAIMS DIVISION CONTEXT MEDICAL GROUP, INC., as assignee of Nairibel Perez, Plaintiff, CASE NO.: v. DIVISION: PROGRESSIVE EXPRESS INSURANCE COMPANY, a foreign corporation, Defendant. ____________________________________ PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW the Plaintiff and files this, its First Request for Admissions to Defendant, and pursuant to Florida Rule of Civil Procedure 1.370 hereby requests that the Defendant admit or deny the following matters within forty-five (45) of service: 1. Admit the policy of automobile insurance, which Plaintiff claims as affording coverage under the claim number set forth in Plaintiff’s Complaint, contains medical payments coverage. 2. Admit the Defendant issued a policy of automobile insurance that provided personal injury protection benefits that provides coverage to the Plaintiff’s alleged assignor as plead in Plaintiff’s Complaint. 3. Admit the Defendant has been properly named in the Complaint. 4. Admit the Defendant has been properly served with the Summons and Complaint. 5. Admit the Court has personal jurisdiction over the parties hereto in the above-styled matter. 6. Admit that Plaintiff’s assignor occupied a motor vehicle that was involved in the motor vehicle crash as plead in Plaintiff’s Complaint. 2/28/2024 2:30 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 7. Admit that Plaintiff’s assignor sustained injuries as a result of the motor vehicle crash as plead in Plaintiff’s Complaint. 8. Admit that Plaintiff’s assignor executed an assignment of PIP benefits in favor of Plaintiff. 9. Admit that Defendant is in possession of a document that purports to be an assignment of Plaintiff’s assignor’s PIP benefits. 10. Admit that Defendant received a standard Disclosure and Acknowledgement form signed by Plaintiff and Plaintiff’s assignor. 11. Admit that Defendant received an application for PIP benefits from Plaintiff’s assignor. 12. Admit that Defendant received notification of the automobile crash that is plead in Plaintiff’s Complaint from its named insured. 13. Admit that Defendant’s named insured occupied a motor vehicle that was involved in the motor vehicle crash as plead in Plaintiff’s Complaint. 14. Admit that an automobile, listed on a policy of insurance that Defendant issued, was involved in the motor vehicle crash as plead in Plaintiff’s Complaint. 15. Admit that Defendant has issued a payment for property damage related to an automobile that is listed on the policy of insurance under which Plaintiff seeks PIP benefits pursuant to the claim number as plead in Plaintiff’s Complaint. 16. Admit that Defendant has cleared coverage for its named insured with regards to the automobile crash that is plead in Plaintiff’s Complaint. 17. Admit that as a result of Defendant’s failure to pay Plaintiff’s under the policy of insurance as plead in Plaintiff’s Complaint, Plaintiff has incurred attorney’s fees and costs in effort to collect these sums due. 18. Admit that according to the Adjuster Code of Ethics, Defendant has been burdened to 2/28/2024 2:30 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 timely authenticate the claim. 19. Admit Plaintiff did lawfully render the services as plead in Plaintiff’s Complaint. To the extent this admission is denied, kindly provide the documents upon which you will use to factually support this denial. Respectfully submitted by, s/Marc J. Semago MARC J. SEMAGO, ESQUIRE Florida Bar#: 721441 MATTHEW D. BRUMLEY, ESQUIRE Florida Bar #: 0480908 Semago & Associates, PLLC d/b/a FL Legal Group 2700 W. Dr. Martin Luther King, Jr. Blvd, #400 Tampa, FL 33607 Phone: (813) 221-9500 Primary E-mail: filings@FLLegalAttorneys.com Secondary E-mail: MJSemago@FLLegalAttorneys.com Attorneys for Plaintiff CERTIFICATE OF SERVICE I CERTIFY that a copy hereof has been e-filed and served along with the Summons and Complaint, pursuant to Rule 2.516, using the Florida Courts E-Filing Portal’s Notice of Electronic Filing, on February 28, 2024. s/ Marc J. Semago Attorney 2/28/2024 2:30 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3