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Filing # 199043478 E-Filed 05/23/2024 11:54:33 AM DIN: 6
IN THE CIRCUIT COURT OF THE 6TH
JUDICIAL CIRCUIT IN AND FOR
PASCO COUNTY, FLORIDA
SARAH MARTINEZ,
Case No.:
Plaintiff,
Vv.
JULIA LINES and DOUGLAS LINES,
Defendants.
REQUEST FOR ADMISSIONS TO DEFENDANT, JULIA LINES
TO: JULIA LINES , described as "you" "your", or "Defendant" herein.
YOU ARE REQUIRED, pursuant to Florida Rules of Civil Procedure 1.280 and
1.370, to answer completely, in writing, the following requests for admissions, and to return
your answers to this request for admissions to Plaintiff at the mailing address of their
attorney within forty-five (45) days of the date of service of these requests for admissions.
Instructions for Request for Admission:
A These requests for admissions are directed toward all information known or
available to you, including information contained in the records and documents in your
custody or control or available to you, upon reasonable inquiry. Your answer to each
request for admission shall specifically admit or deny the matter, or set forth in detail the
reasons why you cannot truthfully admit or deny the matter. Where requests for
admissions cannot be answered, the non-answer shall be accompanied by a specification
of the reasons for the incompleteness of the answer and whatever actual knowledge is
possessed with respect to each unanswered or incompletely answered request for
admission.
B "You" or "Your" refers to the Defendant to whom this request is addressed,
including his/her/its employees, agents, servants, subsidiaries, parent company, affiliated
company, and other persons acting for or in concert with or purporting to act on the
Defendant's behalf, including your representatives, meaning all agents, employees,
servants, officers, directors, attorneys, or other persons acting or purporting to act on
behalf of you, including insurance company employees.
Electronically Filed Pasco Case # 2024CA001418CAAXWS 05/23/2024 11:54:33 AM
Cc Each request for an admission is to be deemed a continuing one. If, after
serving an answer to any request for an admission, you obtain or become aware of any
further information pertaining to that request for admission, you are requested to serve a
supplemental answer setting forth such information.
D References to the "subject accident" shall mean the motor vehicle collision
involving Plaintiff and Defendants, as described and alleged in the Complaint.
E References to the "subject vehicle" shall mean the 2020 Honda CRV
described in the Complaint.
F As to every request for an admission which you fail to answer in whole or in
part, the subject matter of that admissions will be deemed confessed and stipulated as fact
to the Court.
REQUESTS FOR ADMISSION
1
Admit that on November 5, 2023, you were operating the subject vehicle,
traveling northbound on Mitchell Boulevard, in Pasco County, Florida, when Defendant's
vehicle collided into the Plaintiffs vehicle.
2 Admit that this action has been filed in the proper venue.
3 Admit that the above-styled Court has jurisdiction over the claim of the
Plaintiff against Defendants.
4 Admit that you were at fault for the accident.
5 Admit that at the time of the subject accident, you were operating and in
exclusive control of the subject vehicle.
6 Admit that Plaintiff has suffered permanent injuries as a result of the subject
accident.
7 Admit that you did not suffer an "Act of God" that would absolve you of
responsibility for the subject accident.
8 Admit that you are liable for the subject accident.
9 Admit that at time and at the scene of the subject accident that you did not
claim that a sudden medical condition was responsible for the accident.
10. Admit that at the time of the subject accident, you failed to operate the
subject vehicle in a careful and prudent manner, giving due regard to the width, grade,
curves, corners, traffic, and all other attendant circumstances, so as not to endanger the
life, limb, or property of any person.
11. Admit that you had a duty to use reasonable care in the operation and control
of the subject vehicle.
12. Admit that Defendant, DOUGLAS LINES, was the owner of the subject
vehicle that you were operating at the time of the subject accident.
13. Admit that you had full permission and consent from the Defendant,
DOUGLAS LINES, to operate the subject vehicle at the time of the subject accident.
| HEREBY CERTIFY that a true and correct copy of the foregoing was served along
with the Summons and Complaint.
DATED this 23 day of May, 2024.
THE BERMAN LAW GROUP
Attorneys for Plaintiff
Post Office Box 272789
Boca Raton, Florida 33427
Telephone: (561) 826-5200
Facsimile: (561) 826-5201
By: /s/Adam Storm Chess
Adam Storm Chess, Esq.
Florida Bar No.: 109416
service@thebermanlawgroup.com
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Filing # 199043478 E-Filed 05/23/2024 11:54:33 AM DIN: 6 IN THE CIRCUIT COURT OF THE 6TH JUDICIAL CIRCUIT IN AND FOR PASCO COUNTY, FLORIDA SARAH MARTINEZ, Case No.: Plaintiff, Vv. JULIA LINES and DOUGLAS LINES, Defendants. REQUEST FOR ADMISSIONS TO DEFENDANT, JULIA LINES TO: JULIA LINES , described as "you" "your", or "Defendant" herein. YOU ARE REQUIRED, pursuant to Florida Rules of Civil Procedure 1.280 and 1.370, to answer completely, in writing, the following requests for admissions, and to return your answers to this request for admissions to Plaintiff at the mailing address of their attorney within forty-five (45) days of the date of service of these requests for admissions. Instructions for Request for Admission: A These requests for admissions are directed toward all information known or available to you, including information contained in the records and documents in your custody or control or available to you, upon reasonable inquiry. Your answer to each request for admission shall specifically admit or deny the matter, or set forth in detail the reasons why you cannot truthfully admit or deny the matter. Where requests for admissions cannot be answered, the non-answer shall be accompanied by a specification of the reasons for the incompleteness of the answer and whatever actual knowledge is possessed with respect to each unanswered or incompletely answered request for admission. B "You" or "Your" refers to the Defendant to whom this request is addressed, including his/her/its employees, agents, servants, subsidiaries, parent company, affiliated company, and other persons acting for or in concert with or purporting to act on the Defendant's behalf, including your representatives, meaning all agents, employees, servants, officers, directors, attorneys, or other persons acting or purporting to act on behalf of you, including insurance company employees. Electronically Filed Pasco Case # 2024CA001418CAAXWS 05/23/2024 11:54:33 AM Cc Each request for an admission is to be deemed a continuing one. If, after serving an answer to any request for an admission, you obtain or become aware of any further information pertaining to that request for admission, you are requested to serve a supplemental answer setting forth such information. D References to the "subject accident" shall mean the motor vehicle collision involving Plaintiff and Defendants, as described and alleged in the Complaint. E References to the "subject vehicle" shall mean the 2020 Honda CRV described in the Complaint. F As to every request for an admission which you fail to answer in whole or in part, the subject matter of that admissions will be deemed confessed and stipulated as fact to the Court. REQUESTS FOR ADMISSION 1 Admit that on November 5, 2023, you were operating the subject vehicle, traveling northbound on Mitchell Boulevard, in Pasco County, Florida, when Defendant's vehicle collided into the Plaintiffs vehicle. 2 Admit that this action has been filed in the proper venue. 3 Admit that the above-styled Court has jurisdiction over the claim of the Plaintiff against Defendants. 4 Admit that you were at fault for the accident. 5 Admit that at the time of the subject accident, you were operating and in exclusive control of the subject vehicle. 6 Admit that Plaintiff has suffered permanent injuries as a result of the subject accident. 7 Admit that you did not suffer an "Act of God" that would absolve you of responsibility for the subject accident. 8 Admit that you are liable for the subject accident. 9 Admit that at time and at the scene of the subject accident that you did not claim that a sudden medical condition was responsible for the accident. 10. Admit that at the time of the subject accident, you failed to operate the subject vehicle in a careful and prudent manner, giving due regard to the width, grade, curves, corners, traffic, and all other attendant circumstances, so as not to endanger the life, limb, or property of any person. 11. Admit that you had a duty to use reasonable care in the operation and control of the subject vehicle. 12. Admit that Defendant, DOUGLAS LINES, was the owner of the subject vehicle that you were operating at the time of the subject accident. 13. Admit that you had full permission and consent from the Defendant, DOUGLAS LINES, to operate the subject vehicle at the time of the subject accident. | HEREBY CERTIFY that a true and correct copy of the foregoing was served along with the Summons and Complaint. DATED this 23 day of May, 2024. THE BERMAN LAW GROUP Attorneys for Plaintiff Post Office Box 272789 Boca Raton, Florida 33427 Telephone: (561) 826-5200 Facsimile: (561) 826-5201 By: /s/Adam Storm Chess Adam Storm Chess, Esq. Florida Bar No.: 109416 service@thebermanlawgroup.com