On May 11, 115 a
Party Discovery
was filed
involving a dispute between
Llerena, Ashel Alexander,
and
Granny'S Garden Ii Inc,
Rodriguez Chavez, Adrian,
for CIRCUIT CIVIL
in the District Court of Osceola County.
Preview
Filing # 116862892 E-Filed 11/18/2020 10:28:08 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL
CIRCUIT IN AND FOR OSCEOLA COUNTY,
FLORIDA
CASE NO:
ASBEL ALEXANDER LLERENA,
Plaintiff,
vs.
ADRIAN RODRIGUEZ CHAVEZ
AND GRANNY'S GARDEN II, INC.,
Defendants.
—
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PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT
ADRIAN RODRIGUEZ CHAVEZ
COME(S) NOW the Plaintiff, ASBEL ALEXANDER LLERENA, by and through the
undersigned counsel and pursuant to Rule 1.370, Florida Rules Of Civil Procedure, hereby
request(s) that Defendants, ADRIAN RODRIGUEZ CHAVEZ, admit the following within forty-
five (45) days from the date of service hereof:
1. Please admit that this action brought against the Defendant(s) properly and correctly name
the parties to be sued in this cause.
2. Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought before
the Circuit Court in Osceola County, Florida.
3. Please admit that the service of process against the Defendant, ADRIAN RODDRIGUEZ
CHAVEZ, was proper.
4. Please admit that this is an action for damages in excess of Thirty Thousand Dollars
($30,000) arising in Osceola County, Florida.
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.
6. Please admit that the motor vehicle operated by Defendant, ADRIAN RODRIGUEZ
CHAVES, was owned by Defendant, GRANNY’S GARDEN II, INC.
1
7. Please admit the vehicle was being operated by Defendant, ADRIAN RODRIGUEZ
CHAVEZ, with the knowledge, permission and consent of its owner.
8. Please admit that Defendant, ADRIAN RODRIGUEZ CHAVEZ, was negligent in the
operation of a motor vehicle which resulted in the subject collision with Plaintiff's vehicle.
9. Please admit that Defendant, ADRIAN RODRIGUEZ CHAVEZ, received a citation issued
by the investigating law enforcement agency arising out of the subject accident.
10. Please admit that Defendant. ADRIAN RODRIGUEZ CHAVEZ, pled guilty to said citation
in connection with the subject accident.
11. Please admit that Plaintiff was injured in the subject accident.
12. Please admit that Plaintiff suffered a permanent injury within a reasonable degree of medical
probability resulting from the subject accident.
13. Please admit that Plaintiff was not guilty of negligence which caused or contributed to the
subject accident.
14. —_ Please admit that Plaintiff incurred medical expenses for treatment of injuries resulting from
the subject accident.
15. Please admit that Plaintiff's medical expenses were reasonable and necessary for the care
and treatment of the injuries sustained in the subject accident.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the above-named Defendant(s), along with the summons and complaint.
/s/Louts A. DeFreitas, Jr.
Louis A. DeFreitas, Jr., Esquire
FBN 0080292
Morgan & Morgan, P.A.
198 Broadway Ave.
Kissimmee, FL 34741
Telephone: (407) 452-6990
Facsimile: (407) 452-6989
Primary email: L.DeFreitas@forthepeople.com
Secondary email: KMargolis@forthepeople.com
Tertiary email: AJoaguin@forthepeople.com
Attorneys for Plaintiff
2
Document Filed Date
November 18, 2020
Case Filing Date
May 11, 115
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Filing # 116862892 E-Filed 11/18/2020 10:28:08 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: ASBEL ALEXANDER LLERENA, Plaintiff, vs. ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC., Defendants. — eaeeaiaiaiaia(‘_ié_C PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT ADRIAN RODRIGUEZ CHAVEZ COME(S) NOW the Plaintiff, ASBEL ALEXANDER LLERENA, by and through the undersigned counsel and pursuant to Rule 1.370, Florida Rules Of Civil Procedure, hereby request(s) that Defendants, ADRIAN RODRIGUEZ CHAVEZ, admit the following within forty- five (45) days from the date of service hereof: 1. Please admit that this action brought against the Defendant(s) properly and correctly name the parties to be sued in this cause. 2. Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought before the Circuit Court in Osceola County, Florida. 3. Please admit that the service of process against the Defendant, ADRIAN RODDRIGUEZ CHAVEZ, was proper. 4. Please admit that this is an action for damages in excess of Thirty Thousand Dollars ($30,000) arising in Osceola County, Florida. 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. 6. Please admit that the motor vehicle operated by Defendant, ADRIAN RODRIGUEZ CHAVES, was owned by Defendant, GRANNY’S GARDEN II, INC. 1 7. Please admit the vehicle was being operated by Defendant, ADRIAN RODRIGUEZ CHAVEZ, with the knowledge, permission and consent of its owner. 8. Please admit that Defendant, ADRIAN RODRIGUEZ CHAVEZ, was negligent in the operation of a motor vehicle which resulted in the subject collision with Plaintiff's vehicle. 9. Please admit that Defendant, ADRIAN RODRIGUEZ CHAVEZ, received a citation issued by the investigating law enforcement agency arising out of the subject accident. 10. Please admit that Defendant. ADRIAN RODRIGUEZ CHAVEZ, pled guilty to said citation in connection with the subject accident. 11. Please admit that Plaintiff was injured in the subject accident. 12. Please admit that Plaintiff suffered a permanent injury within a reasonable degree of medical probability resulting from the subject accident. 13. Please admit that Plaintiff was not guilty of negligence which caused or contributed to the subject accident. 14. —_ Please admit that Plaintiff incurred medical expenses for treatment of injuries resulting from the subject accident. 15. Please admit that Plaintiff's medical expenses were reasonable and necessary for the care and treatment of the injuries sustained in the subject accident. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the above-named Defendant(s), along with the summons and complaint. /s/Louts A. DeFreitas, Jr. Louis A. DeFreitas, Jr., Esquire FBN 0080292 Morgan & Morgan, P.A. 198 Broadway Ave. Kissimmee, FL 34741 Telephone: (407) 452-6990 Facsimile: (407) 452-6989 Primary email: L.DeFreitas@forthepeople.com Secondary email: KMargolis@forthepeople.com Tertiary email: AJoaguin@forthepeople.com Attorneys for Plaintiff 2