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Filing # E-Filed 04/04/2024 02:01:26 PM
IN THE CIRCUIT COURT, SEVENTH
JUDICIAL CIRCUIT, IN AND FOR
VOLUSIA COUNTY, FLORIDA
CASE NO.:
DIVISION:
IAN GRAHAM,
Plaintiff,
vs.
JON HALL CHEVROLET, INC.,
Defendant.
REQUEST FOR ADMISSIONS
Plaintiff, Ian Graham, pursuant to FL R. Civ. Pro. 1.370(a) requests Defendant, Jon Hall
Chevrolet, Inc., within 45 days after service of this request, to make the following admissions, under
oath, for the purpose of this action only; that each of the following statements is true:
1. That on October 10, 2020, you were the owner of the Chevrolet dealership located at 551
N. Nova Road, Daytona Beach, Florida.
2. That on October 10, 2020, Jon Hall Chevrolet was insured by the Zurich American
Insurance Company with one million dollars in premises liability coverage.
3. That on October 10, 2020, the Plaintiff, IAN GRAHAM, sustained a permanent injury in
the fall which forms the basis of this case.
4. That Zurich American Insurance Company is handling this matter for the Defendant, and
has coverage under claim number
5. That on October 10, 2020, it rained during the day in Daytona Beach.
6. That on October 10, 2020, agents and/or employees of Jon Hall Chevrolet had a duty to
2024 11189 CICI
warn customers of the slippery wet tile floors after a rain event.
7. That on October 10, 2020, Jon Hall Chevrolet owned several yellow "wet floor" signs for
use in its business premises at Jon Hall Chevrolet.
8. That on October 10, 2020, at the time of the Plaintiff s fall which forms the basis of this
claim, there were no "WET FLOOR" signs or warnings of any kind placed in the customer area of
Jon Hall Chevrolet's service department.
9. That on October 10, 2020, at the time of the Plaintiff s fall which forms the basis of this
claim, there were no "WET FLOOR" signs or warnings of any kind placed in the service bay of Jon
Hall Chevrolet.
10. That on October 10, 2020, Ian Graham entered the premises at Jon Hall Chevrolet as a
business invitee.
11. That on October 10, 2020, Ian Graham slipped and fell in the Service department of Jon
Hall Chevrolet while visiting as a business invitee.
12. That on October 10, 2020, Ian Graham was injured while visiting Jon Hall Chevrolet as
a business invitee.
13. That the fall which forms the basis of this complaint was witnessed by Jon Hall
Chevrolet service department employee, Lori Clark.
14. That on October 10, 2020, agents or employees of Jon Hall Chevrolet knew or should
have known that the floors were slippery when wet.
15. That on October 10, 2020, employees of Jon Hall Chevrolet's Service department were
aware of the fact that it was raining during at least part of that day.
16. That on October 10, 2020, before Ian Graham's fall, no agents or employees of Jon Hall
Chevrolet put out any warning signs of slippery, wet floors for the benefit of their customers.
17. That Ian Graham's medical bills related to the injuries which form the basis of this
claim which have been received by Zurich American Insurance Company total over $200,000.
18. That Ian Graham's medical bills which have been received by Zurich American
Insurance Company totaling over $200,000, were reasonable, necessary, and related to his fall or
falls on the premises of Jon Hall Chevrolet on 10/10/20.
Respectfully presented with the Complaint,
BRIAN R. TOUNG, P.A.
/s/Brian R. Toung
BRIAN R. TOUNG, ESQUIRE
FL BAR #373958
947 Beville Road, Suite 14
South Daytona, FL 32119
brtoung@gmail.com
breannajohnsonx@gmail.com
(386) 255-3425
Attorney for Plaintiff
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Filing # E-Filed 04/04/2024 02:01:26 PM IN THE CIRCUIT COURT, SEVENTH JUDICIAL CIRCUIT, IN AND FOR VOLUSIA COUNTY, FLORIDA CASE NO.: DIVISION: IAN GRAHAM, Plaintiff, vs. JON HALL CHEVROLET, INC., Defendant. REQUEST FOR ADMISSIONS Plaintiff, Ian Graham, pursuant to FL R. Civ. Pro. 1.370(a) requests Defendant, Jon Hall Chevrolet, Inc., within 45 days after service of this request, to make the following admissions, under oath, for the purpose of this action only; that each of the following statements is true: 1. That on October 10, 2020, you were the owner of the Chevrolet dealership located at 551 N. Nova Road, Daytona Beach, Florida. 2. That on October 10, 2020, Jon Hall Chevrolet was insured by the Zurich American Insurance Company with one million dollars in premises liability coverage. 3. That on October 10, 2020, the Plaintiff, IAN GRAHAM, sustained a permanent injury in the fall which forms the basis of this case. 4. That Zurich American Insurance Company is handling this matter for the Defendant, and has coverage under claim number 5. That on October 10, 2020, it rained during the day in Daytona Beach. 6. That on October 10, 2020, agents and/or employees of Jon Hall Chevrolet had a duty to 2024 11189 CICI warn customers of the slippery wet tile floors after a rain event. 7. That on October 10, 2020, Jon Hall Chevrolet owned several yellow "wet floor" signs for use in its business premises at Jon Hall Chevrolet. 8. That on October 10, 2020, at the time of the Plaintiff s fall which forms the basis of this claim, there were no "WET FLOOR" signs or warnings of any kind placed in the customer area of Jon Hall Chevrolet's service department. 9. That on October 10, 2020, at the time of the Plaintiff s fall which forms the basis of this claim, there were no "WET FLOOR" signs or warnings of any kind placed in the service bay of Jon Hall Chevrolet. 10. That on October 10, 2020, Ian Graham entered the premises at Jon Hall Chevrolet as a business invitee. 11. That on October 10, 2020, Ian Graham slipped and fell in the Service department of Jon Hall Chevrolet while visiting as a business invitee. 12. That on October 10, 2020, Ian Graham was injured while visiting Jon Hall Chevrolet as a business invitee. 13. That the fall which forms the basis of this complaint was witnessed by Jon Hall Chevrolet service department employee, Lori Clark. 14. That on October 10, 2020, agents or employees of Jon Hall Chevrolet knew or should have known that the floors were slippery when wet. 15. That on October 10, 2020, employees of Jon Hall Chevrolet's Service department were aware of the fact that it was raining during at least part of that day. 16. That on October 10, 2020, before Ian Graham's fall, no agents or employees of Jon Hall Chevrolet put out any warning signs of slippery, wet floors for the benefit of their customers. 17. That Ian Graham's medical bills related to the injuries which form the basis of this claim which have been received by Zurich American Insurance Company total over $200,000. 18. That Ian Graham's medical bills which have been received by Zurich American Insurance Company totaling over $200,000, were reasonable, necessary, and related to his fall or falls on the premises of Jon Hall Chevrolet on 10/10/20. Respectfully presented with the Complaint, BRIAN R. TOUNG, P.A. /s/Brian R. Toung BRIAN R. TOUNG, ESQUIRE FL BAR #373958 947 Beville Road, Suite 14 South Daytona, FL 32119 brtoung@gmail.com breannajohnsonx@gmail.com (386) 255-3425 Attorney for Plaintiff