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Filing # 176562953 E-Filed 06/30/2023 03:22:14 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR
OSCEOLA COUNTY, FLORIDA
CASE NO.: 2020-CA-002872
ASBEL ALEXANDER LLERENA,
Plaintiff,
v.
ADRIAN RODRIGUEZ CHAVEZ AND
GRANNY'S GARDEN II, INC.,
Defendants.
_______________________________/
DEFENDANT, ADRIAN RODRIGUEZ CHAVEZ’S RESPONSE TO PLAINTIFF’S
REQUEST FOR ADMISSIONS
Defendant, ADRIAN RODRIGUEZ CHAVEZ, by and through the undersigned
attorney and pursuant to the Florida Rule of Civil Procedure 1.370, hereby files this, their
responses to Plaintiff’s Request for Admissions to Defendant and states as follows:
1. Please admit that this action brought against the Defendant(s) properly and correctly
name the parties to be sued in this cause.
RESPONSE: Admitted that Adrian Rodriguez Chavez is spelled correctly.
2. Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought
before the Circuit Court in Osceola County, Florida.
RESPONSE: Admitted.
Page 1
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
3. Please admit that the service of process against the Defendant, ADRIAN
RODRIGUEZ CHAVEZ, was proper.
RESPONSE: Admitted.
4. Please admit that this is an action for damages in excess of Thirty Thousand Dollars
($30,000) arising in Osceola County, Florida.
RESPONSE: Admitted as phrased. Denied that Plaintiff suffered damages
equivalent to the threshold amount.
5. Please admit that the Defendant, ADRIAN RODRIGUEZ CHAVEZ, was operating a
motor vehicle on or about December 3, 2019 on West Neptune Road at or near its
intersection with Hand Street in Kissimmee, Osceola County, Florida.
RESPONSE: Admitted.
6. Please admit that the motor vehicle operated by Defendant, ADRIAN RODRIGUEZ
CHAVES, was owned by Defendant, GRANNY'S GARDEN II, INC.
RESPONSE: Admitted.
7. Please admit the vehicle was being operated by Defendant, ADRIAN RODRIGUEZ
CHAVEZ, with the knowledge, permission and consent of its owner.
RESPONSE: Admitted.
8. Please admit that Defendant, ADRIAN RODRIGUEZ CHAVEZ, was negligent in the
operation of a motor vehicle which resulted in the subject collision with Plaintiffs
-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
vehicle.
RESPONSE: Denied.
9. Please admit that Defendant, ADRIAN RODRIGUEZ CHAVEZ, received a citation
issued by the investigating law enforcement agency arising out of the subject accident.
RESPONSE: Denied.
10. Please admit that Defendant. ADRIAN RODRIGUEZ CHAVEZ, pled guilty to said
citation in connection with the subject accident.
RESPONSE: Denied.
11. Please admit that Plaintiff was injured in the subject accident.
RESPONSE: Denied.
12. Please admit that Plaintiff suffered a permanent injury within a reasonable degree of
medical probability resulting from the subject accident.
RESPONSE: Denied.
13. Please admit that Plaintiff was not guilty of negligence which caused or contributed
to the subject accident.
RESPONSE: Denied.
14. Please admit that Plaintiff incurred medical expenses for treatment of injuries
resulting from the subject accident.
RESPONSE: Denied.
-3-
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
15. Please admit that Plaintiffs medical expenses were reasonable and necessary for the
care and treatment of the injuries sustained in the subject accident.
RESPONSE: Denied.
[Certificate of Service on Following Page]
-4-
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 30th day of June, 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 Defendants ADRIAN RODRIGUEZ
CHAVEZ AND GRANNY'S GARDEN II, INC.
Tower Place, Suite 400
1900 Summit Tower Boulevard
Orlando, Florida 32810
Telephone (321) 972-0011
Facsimile (321) 972-0099
Primary e-mail: scott.shelton@csklegal.com
Secondary e-mail: gary.lewis@csklegal.com
Alternate e-mail: sandra.mcintosh@csklegal.com
By: /s/ Gary L. Lewis
SCOTT A. SHELTON
Florida Bar No.: 36486
GARY L. LEWIS
Florida Bar No.: 158887
0487.2384-00
-5-
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 # 176562953 E-Filed 06/30/2023 03:22:14 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2020-CA-002872 ASBEL ALEXANDER LLERENA, Plaintiff, v. ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC., Defendants. _______________________________/ DEFENDANT, ADRIAN RODRIGUEZ CHAVEZ’S RESPONSE TO PLAINTIFF’S REQUEST FOR ADMISSIONS Defendant, ADRIAN RODRIGUEZ CHAVEZ, by and through the undersigned attorney and pursuant to the Florida Rule of Civil Procedure 1.370, hereby files this, their responses to Plaintiff’s Request for Admissions to Defendant and states as follows: 1. Please admit that this action brought against the Defendant(s) properly and correctly name the parties to be sued in this cause. RESPONSE: Admitted that Adrian Rodriguez Chavez is spelled correctly. 2. Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought before the Circuit Court in Osceola County, Florida. RESPONSE: Admitted. Page 1 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 3. Please admit that the service of process against the Defendant, ADRIAN RODRIGUEZ CHAVEZ, was proper. RESPONSE: Admitted. 4. Please admit that this is an action for damages in excess of Thirty Thousand Dollars ($30,000) arising in Osceola County, Florida. RESPONSE: Admitted as phrased. Denied that Plaintiff suffered damages equivalent to the threshold amount. 5. Please admit that the Defendant, ADRIAN RODRIGUEZ CHAVEZ, was operating a motor vehicle on or about December 3, 2019 on West Neptune Road at or near its intersection with Hand Street in Kissimmee, Osceola County, Florida. RESPONSE: Admitted. 6. Please admit that the motor vehicle operated by Defendant, ADRIAN RODRIGUEZ CHAVES, was owned by Defendant, GRANNY'S GARDEN II, INC. RESPONSE: Admitted. 7. Please admit the vehicle was being operated by Defendant, ADRIAN RODRIGUEZ CHAVEZ, with the knowledge, permission and consent of its owner. RESPONSE: Admitted. 8. Please admit that Defendant, ADRIAN RODRIGUEZ CHAVEZ, was negligent in the operation of a motor vehicle which resulted in the subject collision with Plaintiffs -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 vehicle. RESPONSE: Denied. 9. Please admit that Defendant, ADRIAN RODRIGUEZ CHAVEZ, received a citation issued by the investigating law enforcement agency arising out of the subject accident. RESPONSE: Denied. 10. Please admit that Defendant. ADRIAN RODRIGUEZ CHAVEZ, pled guilty to said citation in connection with the subject accident. RESPONSE: Denied. 11. Please admit that Plaintiff was injured in the subject accident. RESPONSE: Denied. 12. Please admit that Plaintiff suffered a permanent injury within a reasonable degree of medical probability resulting from the subject accident. RESPONSE: Denied. 13. Please admit that Plaintiff was not guilty of negligence which caused or contributed to the subject accident. RESPONSE: Denied. 14. Please admit that Plaintiff incurred medical expenses for treatment of injuries resulting from the subject accident. RESPONSE: Denied. -3- 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 15. Please admit that Plaintiffs medical expenses were reasonable and necessary for the care and treatment of the injuries sustained in the subject accident. RESPONSE: Denied. [Certificate of Service on Following Page] -4- 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 30th day of June, 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 Defendants ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC. Tower Place, Suite 400 1900 Summit Tower Boulevard Orlando, Florida 32810 Telephone (321) 972-0011 Facsimile (321) 972-0099 Primary e-mail: scott.shelton@csklegal.com Secondary e-mail: gary.lewis@csklegal.com Alternate e-mail: sandra.mcintosh@csklegal.com By: /s/ Gary L. Lewis SCOTT A. SHELTON Florida Bar No.: 36486 GARY L. LEWIS Florida Bar No.: 158887 0487.2384-00 -5- COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX