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Filing # 198190041 E-Filed 05/13/2024 03:19:47 PM
073047 1778.3 LTP
Total Pages: 4
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR MANATEE COUNTY, FLORIDA
CIVIL DIVISION
JANTZEN ADAMS, CASE NO.
2024-CA-579
PLAINTIFF,
VS.
TONIA LYNN WHITTEN AND
ALLSTATE FIRE & CASUALTY
INSURANCE COMPANY,
DEFENDANTS.
DEFENDANT, ALLSTATE FIRE & CASUALTY
INSURANCE COMPANY’S, REQUEST FOR ADMISSIONS
Defendant, ALLSTATE FIRE & CASUALTY INSURANCE COMPANY, by and
through the undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.370, requests
Plaintiff, JANTZEN ADAMS, to admit, in this action, that each of the following statements are
true:
1 Plaintiff received benefits from a collateral source, as defined by Florida
Statute 768.76, for medical bills alleged to have been incurred as a result of the incident
described in the Complaint.
2. Plaintiff is entitled to reecive benefits from a collateral source, as defined by Florida
Statute 768.76, for medical bills alleged to have been incurred as a result of the incident
described in the Complaint.
3. Plaintiff received benefits from a collateral source, as defined by Florida
Statute 768.76, for loss of wages or income alleged to have been sustained as a result of the
incident described in the Complaint.
4. Plaintiff is entitled to reccive benefits from a collateral source, as defined by Florida
Statute 768.76, for loss of wages or income alleged to have been sustained as a result of the
incident described in the Complaint.
5. Plaintiff received benefits under the Personal Injury Protection portion of an
automobile policy for medical bills alleged to have been incurred as a result of the incident
described in the Complaint.
"2024CA000579AX" 198190041 Filed at Manatee County Clerk 05/13/2024 03:19:47 PM EDT
CASE NO, 2024-CA-579
6, Plaintiff is entitled to receive benefits under the Personal Injury Protection portion
of an automobile policy for medical bills alleged to have been incurred as a result of the incident
described in the Complaint.
7. Plaintiff received benefits under the Personal Injury Protection portion of an
automobile insurance policy for loss of wages or income alleged to have been sustained as a
result of the incident described in the Complaint.
8. Plaintiff is entitled to receive benefits under the Personal Injury Protection portion
of an automobile insurance policy for loss of wages or income alleged to have been sustained as
a result of the incident described in the Complaint.
9. Plaintiff received benefits under the medical payments provisions of an automobile
insurance policy for medical bills alleged to have been incurred as a result of the incident
described in the Complaint.
10. Plaintiff is entitled to receive benefits under the medical payments provisions of an
automobile insurance policy for medical bills alleged to have been incurred as a result of the
incident described in the Complaint.
11. Plaintiff is subjcct to a deductible under the Personal Injury Protection portion of an
automobile insurance policy.
12. Plaintiff received benefits pursuant to personal or group health insurance policy, for
medical bills alleged to have been incurred as a result of the incident described in the Complaint.
13. Plaintiff is entitled to receive benefits pursuant to personal or group health insurance
policy, for medical bills alleged to have been incurred as a result of the incident described in the
Complaint.
14. Plaintiff received benefits pursuant to a personal or group wage continuation plan or
policy, for loss of wages or income alleged to have been sustained as a result of the incident
described in the Complaint.
15. Plaintiff is entitled to receive benefits pursuant to a personal or group wage
continuation plan or policy, for loss of wages or income alleged to have been sustained as a
result of the incident described in the Complaint.
16. Plaintiff received benefits pursuant to Medicaid for medical bills alleged to have
been incurred as a result of the incident described in the Complaint.
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"2024CA000579AX" 198190041 Filed at Manatee County Clerk 05/13/2024 03:19:47 PM EDT
CASE NO, 2024-CA-579
17. Plaintiff is eligible to receive benefits pursuant to Medicaid for medical bills alleged
to have been incurred as a result of the incident described in the Complaint.
18. Plaintiff received benefits pursuant to Medicare for medical bills alleged to have
been incurred as a result of the incident described in the Complaint.
19. Plaintiff is eligible to receive benefits pursuant to Medicare for medical bills alleged
to have been incurred as a result of the incident described in the Complaint.
20. Plaintiff received benefits pursuant to a Medicare Advantage Plan for medical bills
alleged to have been incurred as a result of the incident described in the Complaint.
21. Plaintiff is eligible to receive benefits pursuant to a Medicare Advantage Plan for
medical bills alleged to have been incurred as a result of the incident described in the Complaint.
22. Plaintiff, at the time and place of the incident described in the Complaint, had
available a functional and operational seat belt/shoulder harness restraint system.
23. Plaintiff, at the time and place of the incident described in the Complaint, failed to
use the available functional and operational seat belt/shoulder harness restraint system.
24. Plaintiff use of the available functional and operational seat belt/shoulder harness
restraint system, at the time and place of the incident deseribed in the Complaint, would have
prevented or lessened the injury and damage alleged by Plaintiff.
25. This action is subject to the Florida Motor Vehicle No-Fault Law, Florida Statute
Sections 627.730 et seq.
26. Plaintiff is an insured person under the Personal Injury Protection portion of an
automobile insurance policy which was in force on the date of the incident described in the
Complaint which provides payment of benefits of eighty (80%) percent of all reasonable and
necessary medical expenses incurred and sixty (60%) percent of loss of income or earning
capacity from inability to work as a result of injury sustained from the incident described in the
Complaint to a maximum of Ten Thousand ($10,000.00) Dollars.
3
"2024CA000579AX" 198190041 Filed at Manatee County Clerk 05/13/2024 03:19:47 PM EDT
CASE NO, 2024-CA-579
THEREBY CERTIFY that on the 13th day of May , 2024,
pursuant to Administrative Order No. AOSC 13-49, a copy of the foregoing Defendant’s Request
for Admissions has been electronically filed and served using the Florida Courts E-Filing Portal
to:
Christopher Borzell, Esq.
Florida Bar #: 68277
MORGAN & MORGAN TAMPA, P.A.
One Tampa City Center
201 N. Franklin Street, 7th Floor
Tampa, FL 33602
Tele: (941) 271-6384
Fax: (941) 271-6484
Primary Email: CBorzell@ForThePeople.com
Secondary: CTBPleadings@ForThePeople.com
Paralegal: RHoward@ForThePeople.com
Attorney for Plaintiff
LAW OFFICES OF DOLINA LORDEUS LASCAZE
Mailing Address Only:
4443 Lyons Road, Suite 206
Coconut Creck, FL 33073
Attorney Direct: (813) 260-0127
Fax: (877) 838-0840
By: Keikrica Baker
KEIERICA BAKER
FL Bar No. 1002676
Attorncy for Defendant
ALLSTATE FIRE & CASUALTY INSURANCE
COMPANY
PRINCIPAL E-MAIL ADDRESS:
TAMPALEGAL@ALLSTATE.COM
Personal E-mail Address
{NOT for Service of Pleadings and Documents):
KeiErica. Baker@allstate.com
4
"2024CA000579AX" 198190041 Filed at Manatee County Clerk 05/13/2024 03:19:47 PM EDT
Preview
Filing # 198190041 E-Filed 05/13/2024 03:19:47 PM 073047 1778.3 LTP Total Pages: 4 IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA CIVIL DIVISION JANTZEN ADAMS, CASE NO. 2024-CA-579 PLAINTIFF, VS. TONIA LYNN WHITTEN AND ALLSTATE FIRE & CASUALTY INSURANCE COMPANY, DEFENDANTS. DEFENDANT, ALLSTATE FIRE & CASUALTY INSURANCE COMPANY’S, REQUEST FOR ADMISSIONS Defendant, ALLSTATE FIRE & CASUALTY INSURANCE COMPANY, by and through the undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.370, requests Plaintiff, JANTZEN ADAMS, to admit, in this action, that each of the following statements are true: 1 Plaintiff received benefits from a collateral source, as defined by Florida Statute 768.76, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 2. Plaintiff is entitled to reecive benefits from a collateral source, as defined by Florida Statute 768.76, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 3. Plaintiff received benefits from a collateral source, as defined by Florida Statute 768.76, for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 4. Plaintiff is entitled to reccive benefits from a collateral source, as defined by Florida Statute 768.76, for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 5. Plaintiff received benefits under the Personal Injury Protection portion of an automobile policy for medical bills alleged to have been incurred as a result of the incident described in the Complaint. "2024CA000579AX" 198190041 Filed at Manatee County Clerk 05/13/2024 03:19:47 PM EDT CASE NO, 2024-CA-579 6, Plaintiff is entitled to receive benefits under the Personal Injury Protection portion of an automobile policy for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 7. Plaintiff received benefits under the Personal Injury Protection portion of an automobile insurance policy for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 8. Plaintiff is entitled to receive benefits under the Personal Injury Protection portion of an automobile insurance policy for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 9. Plaintiff received benefits under the medical payments provisions of an automobile insurance policy for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 10. Plaintiff is entitled to receive benefits under the medical payments provisions of an automobile insurance policy for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 11. Plaintiff is subjcct to a deductible under the Personal Injury Protection portion of an automobile insurance policy. 12. Plaintiff received benefits pursuant to personal or group health insurance policy, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 13. Plaintiff is entitled to receive benefits pursuant to personal or group health insurance policy, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 14. Plaintiff received benefits pursuant to a personal or group wage continuation plan or policy, for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 15. Plaintiff is entitled to receive benefits pursuant to a personal or group wage continuation plan or policy, for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 16. Plaintiff received benefits pursuant to Medicaid for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 2 "2024CA000579AX" 198190041 Filed at Manatee County Clerk 05/13/2024 03:19:47 PM EDT CASE NO, 2024-CA-579 17. Plaintiff is eligible to receive benefits pursuant to Medicaid for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 18. Plaintiff received benefits pursuant to Medicare for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 19. Plaintiff is eligible to receive benefits pursuant to Medicare for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 20. Plaintiff received benefits pursuant to a Medicare Advantage Plan for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 21. Plaintiff is eligible to receive benefits pursuant to a Medicare Advantage Plan for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 22. Plaintiff, at the time and place of the incident described in the Complaint, had available a functional and operational seat belt/shoulder harness restraint system. 23. Plaintiff, at the time and place of the incident described in the Complaint, failed to use the available functional and operational seat belt/shoulder harness restraint system. 24. Plaintiff use of the available functional and operational seat belt/shoulder harness restraint system, at the time and place of the incident deseribed in the Complaint, would have prevented or lessened the injury and damage alleged by Plaintiff. 25. This action is subject to the Florida Motor Vehicle No-Fault Law, Florida Statute Sections 627.730 et seq. 26. Plaintiff is an insured person under the Personal Injury Protection portion of an automobile insurance policy which was in force on the date of the incident described in the Complaint which provides payment of benefits of eighty (80%) percent of all reasonable and necessary medical expenses incurred and sixty (60%) percent of loss of income or earning capacity from inability to work as a result of injury sustained from the incident described in the Complaint to a maximum of Ten Thousand ($10,000.00) Dollars. 3 "2024CA000579AX" 198190041 Filed at Manatee County Clerk 05/13/2024 03:19:47 PM EDT CASE NO, 2024-CA-579 THEREBY CERTIFY that on the 13th day of May , 2024, pursuant to Administrative Order No. AOSC 13-49, a copy of the foregoing Defendant’s Request for Admissions has been electronically filed and served using the Florida Courts E-Filing Portal to: Christopher Borzell, Esq. Florida Bar #: 68277 MORGAN & MORGAN TAMPA, P.A. One Tampa City Center 201 N. Franklin Street, 7th Floor Tampa, FL 33602 Tele: (941) 271-6384 Fax: (941) 271-6484 Primary Email: CBorzell@ForThePeople.com Secondary: CTBPleadings@ForThePeople.com Paralegal: RHoward@ForThePeople.com Attorney for Plaintiff LAW OFFICES OF DOLINA LORDEUS LASCAZE Mailing Address Only: 4443 Lyons Road, Suite 206 Coconut Creck, FL 33073 Attorney Direct: (813) 260-0127 Fax: (877) 838-0840 By: Keikrica Baker KEIERICA BAKER FL Bar No. 1002676 Attorncy for Defendant ALLSTATE FIRE & CASUALTY INSURANCE COMPANY PRINCIPAL E-MAIL ADDRESS: TAMPALEGAL@ALLSTATE.COM Personal E-mail Address {NOT for Service of Pleadings and Documents): KeiErica. Baker@allstate.com 4 "2024CA000579AX" 198190041 Filed at Manatee County Clerk 05/13/2024 03:19:47 PM EDT