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Case Number: CACE-19-024724 Division: 04
Filing # 99652090 E-Filed 12/02/2019 03:35:46 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
EMMATINE WALLACE,
Plaintiff, CASE NO.
-~vs-
ARC ELECTRIC, INC.,
a Florida Profit Corporation and
YOSBEL P. ALONSO,
Defendants.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, YOSBEL P. ALONSO
Plaintiff, EMMATINE WALLACE, by and through the undersigned counsel and
pursuant to Fla. R. Civ. P. 1.370, requests that Defendant, YOSBEL P. ALONSO, to admit
or deny the truth of the following statement(s), considering that these requests are intended
to limit the issues at trial and should the Plaintiff prove any statement stated below not
admitted by the Defendant, that the Plaintiff shall seek attorneys fees and costs incurred
in proving the statement, and further recognizing that a response is due within forty five
(45) days of the propounding of these requests as certified in the certificate of service as
indicated below and the failure of Defendant to make a response within forty five (45) days
of the propounding of these requests shall entitle the Plaintiff to deem the statements
admitted as against that Defendant. The definition of "subject incident" is the incident that
is described in the current complaint file by the Plaintiff. "You" means the specific
Defendant responding to these Requests for Admissions and not every party to whom they
were served. Each Defendant shall serve its own response. THEREUPON, do you ADMIT
or DENY:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/02/2019 03:35:44 PM.****1. You were properly named in the Complaint.
2. Venue is appropriate.
3. The Court has jurisdiction over the parties.
4. You are the appropriate party to the case based on the allegations contained
in the Complaint.
5. There was a Collision at the time and location set forth the Complaint
involving you, your vehicle or a vehicle that if negligently operated or maintained could lead
to your liability for resulting damages.
6. No act or omission of the Plaintiff herein contributed to causing the collision
that is the subject of this lawsuit.
7. As a result of the crash which is the subject of this lawsuit, the Plaintiff
suffered 1) a permanent injury within a reasonable degree of medical probability other than
scarring or disfigurement; 2) significant and permanent scarring; and/or 3) the loss of an
important bodily function.
8. Plaintiff was injured in the crash which is the subject of this lawsuit.
9, Plaintiff incurred medical expenses as a result of the crash which is the
subject of this lawsuit.
10. Plaintiff was wearing a seatbelt at the time of the subject incident.
11. Defendant, ARC ELECTRIC, INC., owned the vehicle involved in the crash
set forth in the Complaint.
12. Atthe time of the incident set forth in the Complaint, Defendant, YOSBEL P.
ALONSO, was neither acting as the agent, apparent agent, employee and/or servant of
any person or entity nor acting within the course and scope of any agency, apparentagency, employment and/or servitude or in furtherance of the business pursuits of any
person or entity.
13. You are not being defended in this case pursuant to a reservation of rights.
14. YOSBEL P. ALONSO was at fault for causing the crash set forth in the
Complaint.
15. The crash set forth in the Complaint happened solely as a result of the acts
and/or omissions of the Defendant, YOSBEL P. ALONSO.
16. The vehicle driven by Defendant, YOSBEL P. ALONSO, collided with
Plaintiff's vehicle.
17. At the time of the crash set forth in the Complaint, Defendant, YOSBEL P.
ALONSO, was using a cellular, PCS, similar telephone, iPod, portable electronic device,
computer, electronic organizer or PDA.
18. The vehicle alleged in the Complaint and driven by Defendant, YOSBEL P.
ALONSO, was subject to the Federal Motor Carrier Safety Regulations of the U.S.
Department of Transportation.
| HEREBY CERTIFY that a copy of the foregoing has been served on the above
Defendant, YOSBEL P. ALONSO, with the Complaint.
STEINGER, GREENE & FEINER, P.A.
2727 NW 62 St.
Fort Lauderdale, FL 33309
Telephone: (954) 491-7701
Facsimile: (954) 634-8313
chan@injurylawyers.com
Attorneys for Plaintiff
/ol Yeemee Chan, Caguine
Yeemee Chan, Esquire
Florida Bar No.: 58355
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Case Number: CACE-19-024724 Division: 04 Filing # 99652090 E-Filed 12/02/2019 03:35:46 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA EMMATINE WALLACE, Plaintiff, CASE NO. -~vs- ARC ELECTRIC, INC., a Florida Profit Corporation and YOSBEL P. ALONSO, Defendants. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, YOSBEL P. ALONSO Plaintiff, EMMATINE WALLACE, by and through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.370, requests that Defendant, YOSBEL P. ALONSO, to admit or deny the truth of the following statement(s), considering that these requests are intended to limit the issues at trial and should the Plaintiff prove any statement stated below not admitted by the Defendant, that the Plaintiff shall seek attorneys fees and costs incurred in proving the statement, and further recognizing that a response is due within forty five (45) days of the propounding of these requests as certified in the certificate of service as indicated below and the failure of Defendant to make a response within forty five (45) days of the propounding of these requests shall entitle the Plaintiff to deem the statements admitted as against that Defendant. The definition of "subject incident" is the incident that is described in the current complaint file by the Plaintiff. "You" means the specific Defendant responding to these Requests for Admissions and not every party to whom they were served. Each Defendant shall serve its own response. THEREUPON, do you ADMIT or DENY: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/02/2019 03:35:44 PM.****1. You were properly named in the Complaint. 2. Venue is appropriate. 3. The Court has jurisdiction over the parties. 4. You are the appropriate party to the case based on the allegations contained in the Complaint. 5. There was a Collision at the time and location set forth the Complaint involving you, your vehicle or a vehicle that if negligently operated or maintained could lead to your liability for resulting damages. 6. No act or omission of the Plaintiff herein contributed to causing the collision that is the subject of this lawsuit. 7. As a result of the crash which is the subject of this lawsuit, the Plaintiff suffered 1) a permanent injury within a reasonable degree of medical probability other than scarring or disfigurement; 2) significant and permanent scarring; and/or 3) the loss of an important bodily function. 8. Plaintiff was injured in the crash which is the subject of this lawsuit. 9, Plaintiff incurred medical expenses as a result of the crash which is the subject of this lawsuit. 10. Plaintiff was wearing a seatbelt at the time of the subject incident. 11. Defendant, ARC ELECTRIC, INC., owned the vehicle involved in the crash set forth in the Complaint. 12. Atthe time of the incident set forth in the Complaint, Defendant, YOSBEL P. ALONSO, was neither acting as the agent, apparent agent, employee and/or servant of any person or entity nor acting within the course and scope of any agency, apparentagency, employment and/or servitude or in furtherance of the business pursuits of any person or entity. 13. You are not being defended in this case pursuant to a reservation of rights. 14. YOSBEL P. ALONSO was at fault for causing the crash set forth in the Complaint. 15. The crash set forth in the Complaint happened solely as a result of the acts and/or omissions of the Defendant, YOSBEL P. ALONSO. 16. The vehicle driven by Defendant, YOSBEL P. ALONSO, collided with Plaintiff's vehicle. 17. At the time of the crash set forth in the Complaint, Defendant, YOSBEL P. ALONSO, was using a cellular, PCS, similar telephone, iPod, portable electronic device, computer, electronic organizer or PDA. 18. The vehicle alleged in the Complaint and driven by Defendant, YOSBEL P. ALONSO, was subject to the Federal Motor Carrier Safety Regulations of the U.S. Department of Transportation. | HEREBY CERTIFY that a copy of the foregoing has been served on the above Defendant, YOSBEL P. ALONSO, with the Complaint. STEINGER, GREENE & FEINER, P.A. 2727 NW 62 St. Fort Lauderdale, FL 33309 Telephone: (954) 491-7701 Facsimile: (954) 634-8313 chan@injurylawyers.com Attorneys for Plaintiff /ol Yeemee Chan, Caguine Yeemee Chan, Esquire Florida Bar No.: 58355