On October 15, 2019 a
Request for Admissions - Party: Defendant Winn- Dixie Stores, Inc
was filed
involving a dispute between
Smith, Lueretta,
and
Winn- Dixie Stores, Inc,
for Neg - Premises Liability Commercial
in the District Court of Broward County.
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Filing # 98595429 E-Filed 11/08/2019 10:38:32 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
LUERETTA SMITH,
Plaintiff, CASE NO. CACE-19-021319 (13)
VS.
WINN-DIXIE STORES, INC.,
Defendant.
/
DEFENDANT'S REQUEST FOR ADMISSIONS TO PLAINTIFF
Defendant, WINN-DIXIE STORES, INC., by and through undersigned counsel, and
pursuant to Fla.R.Civ.P. 1.370, requests that Plaintiff, LUERETTA SMITH, admit or deny the
following within thirty (30) days of service:
1. Admit or deny that you are 65 years of age or older.
2. Admit or deny that you have received Social Security benefits for a period of 24
months or more.
3. Admit or deny that you may be eligible for Medicare benefits within the next
eighteen (18) months.
4. Admit or deny that you may be eligible for Medicare benefits within the next
three (3) years.
5. Admit or deny that you are suffering from end-stage renal disease.
6. Admit or deny that Medicare has a conditional lien on the medicals you are
claiming as a result of the alleged accident.
7. Admit or deny that Medicare has made payments on the medicals on the injuries
you are claiming as a result of the alleged incident.
1025563\304601328.v1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/08/2019 10:38:32 AM.****CASE NO. CACE-19-021319 (13)
8. Admit or deny that you have received a formal letter from Medicare outlining the
conditional lien amount.
9. Admit or deny that you will need future treatment for the injuries claimed are a
result of this accident.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8th day of November, 2019, a true and correct copy of
the foregoing was filed and served via Florida Courts eFiling Portal to the following counsel of
record: Justin G. Morgan, Esq., The Law Offices of Justin G. Morgan, P.A., 2500 Weston Road,
Suite 211, Weston, FL 33331; pleadings@justinmorganlaw.com.
HINSHAW & CULBERTSON LLP
/s/Paul J_Gamm
Paul J. Gamm
Florida Bar No. 0577146
One East Broward Boulevard
Suite 1010
Ft. Lauderdale, FL 33301
Telephone: 954-467-7900
Facsimile: 954-467-1024
Primary: pgamm@hinshawlaw.com
Secondary: kcardenas@hinshawlaw.com
Attorneys for Defendant WINN-DIXIE
1025563\304601328.v1
Document Filed Date
November 08, 2019
Case Filing Date
October 15, 2019
Category
Neg - Premises Liability Commercial
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Filing # 98595429 E-Filed 11/08/2019 10:38:32 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION LUERETTA SMITH, Plaintiff, CASE NO. CACE-19-021319 (13) VS. WINN-DIXIE STORES, INC., Defendant. / DEFENDANT'S REQUEST FOR ADMISSIONS TO PLAINTIFF Defendant, WINN-DIXIE STORES, INC., by and through undersigned counsel, and pursuant to Fla.R.Civ.P. 1.370, requests that Plaintiff, LUERETTA SMITH, admit or deny the following within thirty (30) days of service: 1. Admit or deny that you are 65 years of age or older. 2. Admit or deny that you have received Social Security benefits for a period of 24 months or more. 3. Admit or deny that you may be eligible for Medicare benefits within the next eighteen (18) months. 4. Admit or deny that you may be eligible for Medicare benefits within the next three (3) years. 5. Admit or deny that you are suffering from end-stage renal disease. 6. Admit or deny that Medicare has a conditional lien on the medicals you are claiming as a result of the alleged accident. 7. Admit or deny that Medicare has made payments on the medicals on the injuries you are claiming as a result of the alleged incident. 1025563\304601328.v1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/08/2019 10:38:32 AM.****CASE NO. CACE-19-021319 (13) 8. Admit or deny that you have received a formal letter from Medicare outlining the conditional lien amount. 9. Admit or deny that you will need future treatment for the injuries claimed are a result of this accident. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 8th day of November, 2019, a true and correct copy of the foregoing was filed and served via Florida Courts eFiling Portal to the following counsel of record: Justin G. Morgan, Esq., The Law Offices of Justin G. Morgan, P.A., 2500 Weston Road, Suite 211, Weston, FL 33331; pleadings@justinmorganlaw.com. HINSHAW & CULBERTSON LLP /s/Paul J_Gamm Paul J. Gamm Florida Bar No. 0577146 One East Broward Boulevard Suite 1010 Ft. Lauderdale, FL 33301 Telephone: 954-467-7900 Facsimile: 954-467-1024 Primary: pgamm@hinshawlaw.com Secondary: kcardenas@hinshawlaw.com Attorneys for Defendant WINN-DIXIE 1025563\304601328.v1