Party Discovery: MCCOTTER, NIKKI vs GIM, HAWK HEUNGSU et al

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                                Filing # 195328170 E-Filed 04/02/2024 04:39:24 PM



                              IN THE CIRCUIT OF THE FIRST JUDICIAL CIRCUIT
                         IN AND FOR WALTON COUNTY, FLORIDA, CIVIL DIVISION


        NIKKI MCCOTTER,

                Plaintiff,

        vs.
                                                                 CASE NO. 24000158CAAXMX
        RUSSELL WEHRLIN, and
        HAWK HEUNGSU GIM

                Defendants.

                              PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS
                                  ON DEFENDANT, HAWK HEUNGSU GIM



                Plaintiff, NIKKI MCCOTTER,         by and through the undersigned counsel and pursuant to

        Florida Rule of Civil Procedure 1.370(a), hereby requests that Defendant, HAWK HEUNGSU

        GIM, admit or deny the following within forty-five (45) days from the date of service:

                                                      Definitions

                As used herein, the terms      "Defendant",     "you' mom,
                                                                       > your", and “defendant driver" mean

        HAWK HIEUNGSU GIM, the party Defendant to this case.

                As used herein, the terms "the accident", "the subject accident", "this accident", "the

         incident" and "this incident" mean the accident described in the Complaint which occurred on

        July 21, 2023.

                As used herein, the term "the vehicle"        means the 2021   Hyundai   Sonata   motor vehicle

        which Defendant, RUSSELL        WEHRLIN, was driving at the time of this accident, as alleged in

        the Complaint.




        Electronically Filed Walton Case # 24000158CAAXMX 04/02/2024 03:39:24 PM.
                                                            1
REQUEST FOR ADMISSIONS
 1      Please admit that Defendant, HAWK HEUNGSU GIM, is properly and

correctly named in Plaintiff's Complaint.




2       Please admit that the Circuit Court in Walton County              has jurisdiction

over Plaintiff's Complaint.




 3      Please   admit   that   the   service   of   process    against   Defendant,    HAWK

HEUNGSU GIM, was proper.




4       Please admit that this is an action for damages in excess of Fifty Thousand

Dollars ($50,000) arising in Walton County, Florida.




 5      Please admit that the Defendant,        RUSSELL        WEHRLIN      was   operating the

2021   Hyundai   Sonata on or about July 21, 2023, on US Highway 98 in Walton

County, Florida.
6       Please admit that Defendant,         RUSSELL     WEHRLIN,     was   negligent   in   the

operation of the 2021        Hyundai    Sonata motor vehicle, which resulted in the subject

collision with Plaintiff.




7       Please admit that Defendant, HAWK          HEUNGSU     GIM,   is vicariously liable for

the negligent operation of the 2021 Hyundai Sonata motor vehicle, which resulted in

the subject collision with Plaintiff.




8       Please admit that Plaintiff was injured in the subject incident.




9       Please admit that Plaintiff suffered a permanent injury within a reasonable degree

of medical probability resulting from the subject incident.




10.     Please    admit     that Plaintiff was   not guilty of negligence   which   caused    or

contributed to the subject incident.




11.     Please admit that Plaintiff incurred medical expenses for treatment of injuries

resulting from the subject incident.
12.    Please admit that Plaintiff's medical expenses were reasonable and necessary for

the care and treatment of the injuries sustained in the subject incident.



                                 CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed with

this Court via the E-Filing Portal and will be served along with the Summons and Complaint.


                                               Respectfully submitted,

                                               /s/ Drew Bruner
                                               Drew Bruner, Esq.
                                               Florida Bar No.: 098458
                                               THE BRUNER LAW FIRM
                                                110 Eglin Pkwy SE
                                               Fort Walton Beach, FL 32548
                                               drew@pbrunerfirm.com
                                               jamie@brunerfirm.com
                                                neghan@brunerfirm.con
                                               Phone: (850) 243-2222
                                               Attorney for Plaintiff