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Filing # 197779035 E-Filed 05/07/2024 12:40:18 PM
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
IN AND FOR BREVARD COUNTY, FLORIDA
ANDREA C, JOHNSON,
Plaintiff,
CASE NO:
-vs-
OWEN J. THOMAS, HAPPY
HOOKERZ TOWING, LLC., AND
USAA CASUALTY INSURANCE
COMPANY,
Defendants.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT,
OWEN J. THOMAS
Plaintiff, ANDREA C. JOHNSON, by and through the undersigned counsel and pursuant to
Rule 1.370, Florida Rules of Civil Procedure, hereby request(s) that Defendant, OWEN J.
THOMAS, admit the following within forty-five (45) days from the date of service hereof:
1 Please admit that jurisdiction for the Complaint filed by Plaintiff is properly
brought before the Circuit Court in Brevard County, Florida.
2. Please admit that the service of process against the Defendants was proper.
3 Please admit there is an excess insurance policy providing insurance coverage to
the defendant for the motor vehicle crash that occurred on November 13, 2023, which is the subject
matter of this lawsuit.
4 Please admit there is an umbrella insurance policy providing insurance coverage to
the defendant for the motor vehicle crash that occurred on November 13, 2023, which is the subject
matter of this lawsuit.
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Filing 197779035 Johnson, Andrea v Owen Thomas and Happy 05-2024-CA-027989-XXCA-BC.
Hookerz Towing LLC
5 On November 13, 2023, Defendant, OWEN J. THOMAS, was the operator of a
motor vehicle that collided with Plaintiff, ANDREA C. JOHNSON.
6 That the motor vehicle operated by Defendant, OWEN J. THOMAS, was owned
by Defendant, HAPPY HOOKERZ TOWING, LLC.
7 That on November 13, 2023, Defendant, OWEN J. THOMAS, negligently
operated its vehicle and collided with the vehicle containing Plaintiff, ANDREA C. JOHNSON.
8 The collision described in request number 1 above was not caused by any other
person or entity other than Defendant, OWEN J. THOMAS.
9 The collision described in request number 1 above was caused by the negligence of
Defendant, OWEN J. THOMAS.
10. Plaintiff was not negligent in any way and her actions did not contribute to causing
the accident described in request number 1 above.
11. That the Plaintiff, ANDREA C. JOHNSON, suffered a permanent injury as a result
of the accident of November 13, 2023.
12. Plaintiff, ANDREA C. JOHNSON, has received medical care and treatment as a
result of the bodily injury sustained in the collision described in request number 1.
13. Plaintiff, ANDREA C. JOHNSON sustained permanent injury within a reasonable
degree of medical probability under the terms of Florida Stat. §627.727(2)(b), and/or a significant
and permanent loss of an important bodily function under Fla. Stat. §627.737(2)(a) as a result of
the accident more fully described in request number 1.
14. Plaintiff's medical bills were reasonable, necessary and related to the accident.
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Filing 197779035 Johnson, Andrea v Owen Thomas and Happy 05-2024-CA-027989-XXCA-BC.
Hookerz Towing LLC
SUPPLEMENTAL INTERROGATORY
13. If any above Request for Admissions have been denied please explain the facts or
reasons for said denial.
DEFENDANT, OWN J. THOMAS,
SWORN TO and subscribed before me this day of. , 2024.
Notary Public
My commission expires:
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Filing 197779035 Johnson, Andrea v Owen Thomas and Happy 05-2024-CA-027989-XXCA-BC.
Hookerz Towing LLC
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true copy of the foregoing has been furnished to the Defendant
together with the Summons and Complaint.
<
gee
3" oe
Erick M. Salazar E squire
Morgan & Morgan Orlando P.A.
20 N Orange Ave, Suite 1600
Orlando, FL 321101
Tele: (6119) 219-2506
Fax: (6119) 219-24511
Primary Email: esalazar@forthepeople.com
Secondary Email: palston@forthepeople.com
kaitlyngarner@forthepeople.com
Florida Bar #: 1005939
Attorney for Plaintiff
4
Filing 197779035 Johnson, Andrea v Owen Thomas and Happy 05-2024-CA-027989-XXCA-BC.
Hookerz Towing LLC
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Filing # 197779035 E-Filed 05/07/2024 12:40:18 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA ANDREA C, JOHNSON, Plaintiff, CASE NO: -vs- OWEN J. THOMAS, HAPPY HOOKERZ TOWING, LLC., AND USAA CASUALTY INSURANCE COMPANY, Defendants. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, OWEN J. THOMAS Plaintiff, ANDREA C. JOHNSON, by and through the undersigned counsel and pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby request(s) that Defendant, OWEN J. THOMAS, admit the following within forty-five (45) days from the date of service hereof: 1 Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought before the Circuit Court in Brevard County, Florida. 2. Please admit that the service of process against the Defendants was proper. 3 Please admit there is an excess insurance policy providing insurance coverage to the defendant for the motor vehicle crash that occurred on November 13, 2023, which is the subject matter of this lawsuit. 4 Please admit there is an umbrella insurance policy providing insurance coverage to the defendant for the motor vehicle crash that occurred on November 13, 2023, which is the subject matter of this lawsuit. 1 Filing 197779035 Johnson, Andrea v Owen Thomas and Happy 05-2024-CA-027989-XXCA-BC. Hookerz Towing LLC 5 On November 13, 2023, Defendant, OWEN J. THOMAS, was the operator of a motor vehicle that collided with Plaintiff, ANDREA C. JOHNSON. 6 That the motor vehicle operated by Defendant, OWEN J. THOMAS, was owned by Defendant, HAPPY HOOKERZ TOWING, LLC. 7 That on November 13, 2023, Defendant, OWEN J. THOMAS, negligently operated its vehicle and collided with the vehicle containing Plaintiff, ANDREA C. JOHNSON. 8 The collision described in request number 1 above was not caused by any other person or entity other than Defendant, OWEN J. THOMAS. 9 The collision described in request number 1 above was caused by the negligence of Defendant, OWEN J. THOMAS. 10. Plaintiff was not negligent in any way and her actions did not contribute to causing the accident described in request number 1 above. 11. That the Plaintiff, ANDREA C. JOHNSON, suffered a permanent injury as a result of the accident of November 13, 2023. 12. Plaintiff, ANDREA C. JOHNSON, has received medical care and treatment as a result of the bodily injury sustained in the collision described in request number 1. 13. Plaintiff, ANDREA C. JOHNSON sustained permanent injury within a reasonable degree of medical probability under the terms of Florida Stat. §627.727(2)(b), and/or a significant and permanent loss of an important bodily function under Fla. Stat. §627.737(2)(a) as a result of the accident more fully described in request number 1. 14. Plaintiff's medical bills were reasonable, necessary and related to the accident. 2 Filing 197779035 Johnson, Andrea v Owen Thomas and Happy 05-2024-CA-027989-XXCA-BC. Hookerz Towing LLC SUPPLEMENTAL INTERROGATORY 13. If any above Request for Admissions have been denied please explain the facts or reasons for said denial. DEFENDANT, OWN J. THOMAS, SWORN TO and subscribed before me this day of. , 2024. Notary Public My commission expires: 3 Filing 197779035 Johnson, Andrea v Owen Thomas and Happy 05-2024-CA-027989-XXCA-BC. Hookerz Towing LLC CERTIFICATE OF SERVICE THEREBY CERTIFY that a true copy of the foregoing has been furnished to the Defendant together with the Summons and Complaint. < gee 3" oe Erick M. Salazar E squire Morgan & Morgan Orlando P.A. 20 N Orange Ave, Suite 1600 Orlando, FL 321101 Tele: (6119) 219-2506 Fax: (6119) 219-24511 Primary Email: esalazar@forthepeople.com Secondary Email: palston@forthepeople.com kaitlyngarner@forthepeople.com Florida Bar #: 1005939 Attorney for Plaintiff 4 Filing 197779035 Johnson, Andrea v Owen Thomas and Happy 05-2024-CA-027989-XXCA-BC. Hookerz Towing LLC