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Filing # 169365691 E-Filed 03/22/2023 12:50:43 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND FOR
OSCEOLA COUNTY, FLORIDA
ASBEL ALEXANDER LLERENA, CASE NO.: 2020-CA-002872
Plaintiff,
v.
ADRIAN RODRIGUEZ CHAVEZ AND
GRANNY'S GARDEN II, INC.,
Defendants.
_______________________________/
DEFENDANT, GRANNY’S GARDEN II, INC.S,
FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF
Defendant, ADRIAN RODRIGUEZ CHAVEZ, (“Defendant”), by and through the
undersigned counsel, hereby serves Plaintiff, ASBEL ALEXANDER LLERENA,
(“Plaintiff”), to respond to the following Request for Admissions pursuant to Florida Rule
of Civil Procedure 1.370:
1. Admit you were the sole cause of the motor vehicle accident alleged in your
Complaint.
2. Admit you did not use reasonable care on the roadways to avoid the motor
vehicle accident alleged in your Complaint.
3. Admit that your actions contributed to the damages you allegedly suffered
as a result of the motor vehicle accident alleged in your Complaint.
4. Admit you did not sustain a permanent injury within a reasonable degree of
medical probability as a result of the motor vehicle accident alleged in your Complaint.
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2020-CA-002872
5. Admit that the motor vehicle accident alleged in your Complaint did not
negatively impact the performance of your job.
6. Admit that you have not lost the capacity to enjoy life as a result of the motor
vehicle accident alleged in your Complaint.
7. Admit that you did not lose wages as a result of the motor vehicle accident
alleged in your Complaint.
8. Admit that you have not suffered a loss of future earning capacity as a result
of the motor vehicle accident alleged in your Complaint.
9. Admit you have not treated with a medical provider within the last three
months as a result of the motor vehicle accident alleged in your Complaint.
[Certificate of Service on Following Page]
-2-
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2020-CA-002872
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd day of March, 2023, a true and correct copy
of the foregoing was filed with the Clerk of Osceola County by using the Florida Courts e-
Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: Melissa Alzate, Esq., Morgan & Morgan, P.A.,
malzate@forthepeople.com;imerlos@forthepeople.com, 198 Broadway Avenue,
Kissimmee, FL 34741, (407) 452-1597/(407) 452-1623 (F), Attorney for Plaintiff, Asbel
Alexander Llerena.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant ADRIAN RODRIGUEZ
CHAVEZ AND GRANNY'S GARDEN II, INC.
Tower Place, Suite 400
1900 Summit Tower Boulevard
Orlando, Florida 32810
Telephone (321) 972-0094
Facsimile (321) 972-0099
Primary e-mail: melissa.crowley@csklegal.com
Secondary e-mail: harley.clement@csklegal.com
Alternate e-mail:
gabrielle.porcaro@csklegal.com
By: /s/ Harley C. Clement
MELISSA D. CROWLEY
Florida Bar No.: 90984
HARLEY C. CLEMENT
Florida Bar No.: 1019181
0487.2384-00
-3-
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
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Filing # 169365691 E-Filed 03/22/2023 12:50:43 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA ASBEL ALEXANDER LLERENA, CASE NO.: 2020-CA-002872 Plaintiff, v. ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC., Defendants. _______________________________/ DEFENDANT, GRANNY’S GARDEN II, INC.S, FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF Defendant, ADRIAN RODRIGUEZ CHAVEZ, (“Defendant”), by and through the undersigned counsel, hereby serves Plaintiff, ASBEL ALEXANDER LLERENA, (“Plaintiff”), to respond to the following Request for Admissions pursuant to Florida Rule of Civil Procedure 1.370: 1. Admit you were the sole cause of the motor vehicle accident alleged in your Complaint. 2. Admit you did not use reasonable care on the roadways to avoid the motor vehicle accident alleged in your Complaint. 3. Admit that your actions contributed to the damages you allegedly suffered as a result of the motor vehicle accident alleged in your Complaint. 4. Admit you did not sustain a permanent injury within a reasonable degree of medical probability as a result of the motor vehicle accident alleged in your Complaint. COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2020-CA-002872 5. Admit that the motor vehicle accident alleged in your Complaint did not negatively impact the performance of your job. 6. Admit that you have not lost the capacity to enjoy life as a result of the motor vehicle accident alleged in your Complaint. 7. Admit that you did not lose wages as a result of the motor vehicle accident alleged in your Complaint. 8. Admit that you have not suffered a loss of future earning capacity as a result of the motor vehicle accident alleged in your Complaint. 9. Admit you have not treated with a medical provider within the last three months as a result of the motor vehicle accident alleged in your Complaint. [Certificate of Service on Following Page] -2- COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2020-CA-002872 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 22nd day of March, 2023, a true and correct copy of the foregoing was filed with the Clerk of Osceola County by using the Florida Courts e- Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Melissa Alzate, Esq., Morgan & Morgan, P.A., malzate@forthepeople.com;imerlos@forthepeople.com, 198 Broadway Avenue, Kissimmee, FL 34741, (407) 452-1597/(407) 452-1623 (F), Attorney for Plaintiff, Asbel Alexander Llerena. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC. Tower Place, Suite 400 1900 Summit Tower Boulevard Orlando, Florida 32810 Telephone (321) 972-0094 Facsimile (321) 972-0099 Primary e-mail: melissa.crowley@csklegal.com Secondary e-mail: harley.clement@csklegal.com Alternate e-mail: gabrielle.porcaro@csklegal.com By: /s/ Harley C. Clement MELISSA D. CROWLEY Florida Bar No.: 90984 HARLEY C. CLEMENT Florida Bar No.: 1019181 0487.2384-00 -3- COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX