Preview
Filing # 195725473 E-Filed 04/08/2024 04:38:41 PM
IN THE CIRCUIT COURT FOR THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
SASHA TOPEY,
Plaintiff,
Case No.:
VS.
Div.:
KYLENE BYRNE and
TODD BYRNE,
Defendants.
/
Plaintiff, SASHA TOPEY’s First Set of Requests for Admission to Defendant, TODD
BYRNE
Under authority of Rule 1.370, Florida Rules of Civil Procedure, you are hereby requested
to admit or deny, within forty-five (45) days from the receipt hereof, the following Requests for
Admission.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been provided to
the above along with the Summons and Complaint.
DATED April 8, 2024.
/s/ Imani Waters, Esq.
Imani Waters, Esq.
FBN: 1028051
Kemp Law Group
Offices FL & GA (Mail) 11567 Trinity Boulevard
Trinity, FL 34655
Phone: 727-847-4878
Fax: 727-375-7300
service@kemplaw.com
iwaters@kemplaw.com
ATTORNEY FOR PLAINTIFF
4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
Plaintiff, SASHA TOPEY’s First Set of Requests for Admission to Defendant, TODD
BYRNE
Admit Defendant, KYLENE BYRNE, was negligent in causing the incident described in
Plaintiff, SASHA TOPEY’s complaint.
Answer:
Admit Defendant, KYLENE BYRNE, was using a cell phone at the time of the incident
described in Plaintiff, SASHA TOPEY’s complaint.
Answer:
Admit Plaintiff, SASHA TOPEY, was not negligent in causing the incident described in
Plaintiff, SASHA TOPEY’s complaint.
Answer:
Admit Defendant, KYLENE BYRNE’s negligence was the sole cause of the incident
described in Plaintiff, SASHA TOPEY’s complaint.
Answer:
Admit Defendant, KYLENE BYRNE’s negligence was a legal cause of loss, injury or
damage to Plaintiff, SASHA TOPEY.
Answer:
Admit Defendant, KYLENE BYRNE’s negligence was the sole legal cause of loss, injury
or damage to Plaintiff, SASHA TOPEY.
Answer:
Admit that as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint,
Plaintiff, SASHA TOPEY, sustained bodily injuries.
Answer:
4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Admit that as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint,
Plaintiff, SASHA TOPEY, sustained bodily injuries that resulted in an aggravation of an
existing disease or physical defect.
Answer:
Admit that Plaintiff, SASHA TOPEY, has received medical care and treatment as a result
of the bodily injuries sustained from the incident described in Plaintiff, SASHA TOPEY’s
complaint.
Answer:
10. Admit that it was reasonable for Plaintiff, SASHA TOPEY, to receive medical care and
treatment as a result of the bodily injuries sustained from the incident described in Plaintiff,
SASHA TOPEY’s complaint.
Answer:
11 Admit that it was reasonable for Plaintiff, SASHA TOPEY, to follow the medical
recommendations Plaintiff, SASHA TOPEY’s medical providers made for the medical
care and treatment received for the bodily injuries sustained from the incident described in
Plaintiff, SASHA TOPEY’s complaint.
Answer:
12 Admit that it was reasonable for Plaintiff, SASHA TOPEY, to undergo the medical care
and treatment recommended and performed by Plaintiff, SASHA TOPEY’s medical
providers following the incident described in Plaintiff, SASHA TOPEY’s complaint.
Answer:
13 Admit Plaintiff, SASHA TOPEY, will require additional medical care and treatment in the
future as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint.
Answer:
4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
14. Admit that it is reasonable for Plaintiff, SASHA TOPEY, to undergo the future medical
care and treatment recommended by Plaintiff, SASHA TOPEY’s medical providers for the
bodily injuries sustained as a result of the incident described in Plaintiff, SASHA TOPEY’s
complaint.
Answer:
15 Admit the medical bills incurred from the treatment Plaintiff, SASHA TOPEY, has
received as a result of the bodily injuries sustained from the incident described in Plaintiff,
SASHA TOPEY’s complaint were necessary and related to this incident.
Answer:
16. Admit the medical bills incurred from the treatment Plaintiff, SASHA TOPEY, has
received as a result of the bodily injuries sustained from the incident described in Plaintiff,
SASHA TOPEY’s complaint were reasonable.
Answer:
17 Admit the estimates for the medical treatment recommended by Plaintiff, SASHA
TOPEY’s medical providers for the bodily injuries sustained as a result of the incident
described in Plaintiff, SASHA TOPEY’s complaint are necessary and related.
Answer:
18 Admit the estimates for the medical treatment recommended by Plaintiff, SASHA
TOPEY’s medical providers for the bodily injuries sustained as a result of the incident
described in Plaintiff, SASHA TOPEY’s complaint are reasonable.
Answer:
19 Admit Plaintiff, SASHA TOPEY, sustained a permanent injury within a reasonable degree
of medical probability under the terms of Florida Stat. §627.727(2)(b) as a result of the
incident described in Plaintiff, SASHA TOPEY’s complaint.
Answer:
4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4
20. Admit Plaintiff, SASHA TOPEY, sustained a significant and permanent loss of an
important bodily function within a reasonable degree of medical probability under the
terms of Fla. Stat. §627.737(2)(a) as a result of the incident described in Plaintiff, SASHA
TOPEY’s complaint.
Answer:
4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5
Preview
Filing # 195725473 E-Filed 04/08/2024 04:38:41 PM IN THE CIRCUIT COURT FOR THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION SASHA TOPEY, Plaintiff, Case No.: VS. Div.: KYLENE BYRNE and TODD BYRNE, Defendants. / Plaintiff, SASHA TOPEY’s First Set of Requests for Admission to Defendant, TODD BYRNE Under authority of Rule 1.370, Florida Rules of Civil Procedure, you are hereby requested to admit or deny, within forty-five (45) days from the receipt hereof, the following Requests for Admission. I HEREBY CERTIFY that a true and correct copy of the foregoing has been provided to the above along with the Summons and Complaint. DATED April 8, 2024. /s/ Imani Waters, Esq. Imani Waters, Esq. FBN: 1028051 Kemp Law Group Offices FL & GA (Mail) 11567 Trinity Boulevard Trinity, FL 34655 Phone: 727-847-4878 Fax: 727-375-7300 service@kemplaw.com iwaters@kemplaw.com ATTORNEY FOR PLAINTIFF 4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 Plaintiff, SASHA TOPEY’s First Set of Requests for Admission to Defendant, TODD BYRNE Admit Defendant, KYLENE BYRNE, was negligent in causing the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: Admit Defendant, KYLENE BYRNE, was using a cell phone at the time of the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: Admit Plaintiff, SASHA TOPEY, was not negligent in causing the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: Admit Defendant, KYLENE BYRNE’s negligence was the sole cause of the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: Admit Defendant, KYLENE BYRNE’s negligence was a legal cause of loss, injury or damage to Plaintiff, SASHA TOPEY. Answer: Admit Defendant, KYLENE BYRNE’s negligence was the sole legal cause of loss, injury or damage to Plaintiff, SASHA TOPEY. Answer: Admit that as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint, Plaintiff, SASHA TOPEY, sustained bodily injuries. Answer: 4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 Admit that as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint, Plaintiff, SASHA TOPEY, sustained bodily injuries that resulted in an aggravation of an existing disease or physical defect. Answer: Admit that Plaintiff, SASHA TOPEY, has received medical care and treatment as a result of the bodily injuries sustained from the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: 10. Admit that it was reasonable for Plaintiff, SASHA TOPEY, to receive medical care and treatment as a result of the bodily injuries sustained from the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: 11 Admit that it was reasonable for Plaintiff, SASHA TOPEY, to follow the medical recommendations Plaintiff, SASHA TOPEY’s medical providers made for the medical care and treatment received for the bodily injuries sustained from the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: 12 Admit that it was reasonable for Plaintiff, SASHA TOPEY, to undergo the medical care and treatment recommended and performed by Plaintiff, SASHA TOPEY’s medical providers following the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: 13 Admit Plaintiff, SASHA TOPEY, will require additional medical care and treatment in the future as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: 4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 14. Admit that it is reasonable for Plaintiff, SASHA TOPEY, to undergo the future medical care and treatment recommended by Plaintiff, SASHA TOPEY’s medical providers for the bodily injuries sustained as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: 15 Admit the medical bills incurred from the treatment Plaintiff, SASHA TOPEY, has received as a result of the bodily injuries sustained from the incident described in Plaintiff, SASHA TOPEY’s complaint were necessary and related to this incident. Answer: 16. Admit the medical bills incurred from the treatment Plaintiff, SASHA TOPEY, has received as a result of the bodily injuries sustained from the incident described in Plaintiff, SASHA TOPEY’s complaint were reasonable. Answer: 17 Admit the estimates for the medical treatment recommended by Plaintiff, SASHA TOPEY’s medical providers for the bodily injuries sustained as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint are necessary and related. Answer: 18 Admit the estimates for the medical treatment recommended by Plaintiff, SASHA TOPEY’s medical providers for the bodily injuries sustained as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint are reasonable. Answer: 19 Admit Plaintiff, SASHA TOPEY, sustained a permanent injury within a reasonable degree of medical probability under the terms of Florida Stat. §627.727(2)(b) as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: 4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4 20. Admit Plaintiff, SASHA TOPEY, sustained a significant and permanent loss of an important bodily function within a reasonable degree of medical probability under the terms of Fla. Stat. §627.737(2)(a) as a result of the incident described in Plaintiff, SASHA TOPEY’s complaint. Answer: 4/8/2024 4:38 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5