On March 20, 2023 a
Party Discovery
was filed
involving a dispute between
Davila, Luis Antonio,
and
Home Depot Usa Inc,
Jacques, Ralph,
for CIRCUIT CIVIL
in the District Court of Osceola County.
Preview
Filing # 178952231 E-Filed 08/04/2023 12:30:15 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2023-CA-001120-AN
LUIS ANTONIO DAVILA,
Plaintiff,
-v-
RALPH JACQUES AND HOME
DEPOT USA, INC.,
Defendants.
_____________________________/
PLAINTIFF’S RESPONSE TO REQUEST FOR ADMISSIONS
Plaintiff, LUIS ANTONIO DAVILA by and through the undersigned attorney, responds to
the Request for Admissions of the Defendant, HOME DEPOT USA, INC., served on June 27. 2023,
as follows:
1. Plaintiff has not sustained an injury as a result of the subject accident.
RESPONSE: Denied.
2. Plaintiff has not sustained a permanent injury as a result of the subject accident.
RESPONSE: Denied.
3. Plaintiff has not sustained any lost wages as a result of the subject accident.
RESPONSE: Denied.
4. Plaintiff is not making a wage loss claim as a result of the subject accident.
RESPONSE: Denied.
5. Plaintiff is not making a claim for loss of future earning capacity as a result of the subject
accident.
RESPONSE: Denied.
6. The Defendant's insurer previously settled the property damage claim.
RESPONSE: Admitted.
7. Defendant satisfied Plaintiff's property damage claims.
RESPONSE: Admitted.
8. Plaintiff has not sustained any out-of-pocket medical expenses in connection with the subject
accident.
RESPONSE: Denied.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished,
by email, this 4th day of August, 2023 to: M i c h a e l A . K e r w i n , e s q u i r e , L u k s ,
Santaniello, Petrillo, Cohen & Peterfriend, 201 S. orange Avenue,
Suite 400, Orlando, FL 32801 (LUKSORL -Pleadings@LS-Law.com
s/ Manuel Stefan, Esq.
Manuel “Manny” Stefan, Esq.
Florida Bar No.: 0103389
MORGAN & MORGAN, P.A.
4495 South Semoran Blvd.
Orlando, FL 32822
Telephone No.: (407) 452-6982
Facsimile No.: (407) 572-0124
Primary email: MStefan@forthepeople.com
Secondary email: cvictor@forthepeople.com
Attorney for Plaintiff
Document Filed Date
August 04, 2023
Case Filing Date
March 20, 2023
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Filing # 178952231 E-Filed 08/04/2023 12:30:15 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2023-CA-001120-AN LUIS ANTONIO DAVILA, Plaintiff, -v- RALPH JACQUES AND HOME DEPOT USA, INC., Defendants. _____________________________/ PLAINTIFF’S RESPONSE TO REQUEST FOR ADMISSIONS Plaintiff, LUIS ANTONIO DAVILA by and through the undersigned attorney, responds to the Request for Admissions of the Defendant, HOME DEPOT USA, INC., served on June 27. 2023, as follows: 1. Plaintiff has not sustained an injury as a result of the subject accident. RESPONSE: Denied. 2. Plaintiff has not sustained a permanent injury as a result of the subject accident. RESPONSE: Denied. 3. Plaintiff has not sustained any lost wages as a result of the subject accident. RESPONSE: Denied. 4. Plaintiff is not making a wage loss claim as a result of the subject accident. RESPONSE: Denied. 5. Plaintiff is not making a claim for loss of future earning capacity as a result of the subject accident. RESPONSE: Denied. 6. The Defendant's insurer previously settled the property damage claim. RESPONSE: Admitted. 7. Defendant satisfied Plaintiff's property damage claims. RESPONSE: Admitted. 8. Plaintiff has not sustained any out-of-pocket medical expenses in connection with the subject accident. RESPONSE: Denied. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished, by email, this 4th day of August, 2023 to: M i c h a e l A . K e r w i n , e s q u i r e , L u k s , Santaniello, Petrillo, Cohen & Peterfriend, 201 S. orange Avenue, Suite 400, Orlando, FL 32801 (LUKSORL -Pleadings@LS-Law.com s/ Manuel Stefan, Esq. Manuel “Manny” Stefan, Esq. Florida Bar No.: 0103389 MORGAN & MORGAN, P.A. 4495 South Semoran Blvd. Orlando, FL 32822 Telephone No.: (407) 452-6982 Facsimile No.: (407) 572-0124 Primary email: MStefan@forthepeople.com Secondary email: cvictor@forthepeople.com Attorney for Plaintiff