On April 21, 2017 a
Request for Admissions - Party: Defendant Comcast Corporation
was filed
involving a dispute between
Vohs, Ronald,
and
Comcast Corporation,
Industrial Cable Communications Services Inc,
Josimars Cleaning Services Corp,
Usa Br General Services Corp,
for Neg - Premises Liability Residential
in the District Court of Broward County.
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Filing # 59666985 E-Filed 07/28/2017 02:32:51 PM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
RONALD VOHS, CASE NO.: 17-007673 CACE 05
Plaintiff,
Vv.
JOSIMAR’S CLEANING SERVICES
CORP., INDUSTRIAL CABLE
COMMUNICATIONS SERVICES, INC.,
AND COMCAST OF COLORADO/FLORIDA/
MICHIGAN/NEW MEXICO/PENNSYLVANIA
/WASHINGTON, LLC.,
Defendants.
/
DEFENDANT’S REQUEST FOR ADMISSIONS TO PLAINTIFF RONALD VOHS
The Defendant COMCAST OF COLORADO / FLORIDA / MICHIGAN / NEW MEXICO
/ PENNSYLVANIA / WASHINGTON, LLC., by and through the undersigned counsel, and in
accordance with Florida Rules of Civil Procedure, 1.310, within the time limits as provided by
said Rule, requests the Plaintiff, Ronald Vohs, to admit or deny the following:
1. You are entitled to receive medical payment coverage benefits as a result of the subject
incident.
2. You have received medical payments coverage benefits as a result of the subject incident.
3. You sustained no permanent injuries as a result of the subject incident.
4. No medical provider has expressed a medical opinion that you have sustained a permanent
injury as a result of the subject incident.
5. You were not gainfully employed at the time of the subject incident.
6. You did not lose any wages or income as a result of the subject incident.
7. Your earning capacity was not reduced or impaired as a result of the subject incident.
8. Your ability to enjoy life has not been reduced as a result of the subject incident.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/28/2017 2:32:50 PM.****9. You had been involved in one (1) or more motor vehicle accident(s) prior to the subject
incident.
10. You sustained significant and permanent injuries in said prior motor vehicle accident(s).
11. You have been in one (1) or more motor vehicle accidents(s) subsequent to the subject
incident.
12. You sustained significant and permanent injuries in said subsequent motor vehicle
accident(s).
13. You had been involved in one (1) or more slip and fall type or other non-motor vehicle
accidents prior to the subject incident.
14. You sustained significant and permanent injuries in the prior slip and fall type or other non-
motor vehicle accident(s).
15. You have been involved in one (1) or more slip and fall type or other non-motor vehicle
accidents subsequent to the subject incident.
16. You sustained significant and permanent injuries in the subsequent slip and fall type or
other non-vehicle accident(s).
17. Some or all of the injuries you are claiming damages for in this matter pre-existed the
subject incident.
18. You have a prior felony conviction.
19. You have a prior conviction involving dishonesty or false statement.
20. You have turned down work you were physically able to perform since the date of the
subject incident.
21. You are presently able to perform numerous light duty tasks.
22. Your normal facilities were impaired at the time of the subject incident.
23. You had been drinking alcohol and/or taken drugs/medications within six (6) hours prior
to the subject incident.
24. You were distracted immediately preceding your fall.25. You were aware of the orange cable in the grass of the common area between the mobile
homes, prior to your fall.
26. You made statements to Comcast employees and/or agents days prior to the subject
incident.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via electronic mail this 28" day of July, 2017, to: Yeemee Chan, Esq., Steinger, Iscoe & Greene,
P.A., 2400 E. Commercial Blvd., Suite 900, Ft. Lauderdale, FL 33308.
17.11718/PAD/sm
RUDD & DIAMOND, P.A.
Attorneys for Defendant, Comcast
4000 Hollywood Blvd.
Presidential Circle, Suite 120-N
Hollywood, FL 33021
Tel. (954) 961-5059
Fax. (954) 961-8953
@rudddiamond.com
service:
By: /s/
Michael P. Rudd
FL Bar No.: 782416
And
Peter A. Diamond
FL Bar No.: 0180051
Document Filed Date
July 28, 2017
Case Filing Date
April 21, 2017
Category
Neg - Premises Liability Residential
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Filing # 59666985 E-Filed 07/28/2017 02:32:51 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, CASE NO.: 17-007673 CACE 05 Plaintiff, Vv. JOSIMAR’S CLEANING SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES, INC., AND COMCAST OF COLORADO/FLORIDA/ MICHIGAN/NEW MEXICO/PENNSYLVANIA /WASHINGTON, LLC., Defendants. / DEFENDANT’S REQUEST FOR ADMISSIONS TO PLAINTIFF RONALD VOHS The Defendant COMCAST OF COLORADO / FLORIDA / MICHIGAN / NEW MEXICO / PENNSYLVANIA / WASHINGTON, LLC., by and through the undersigned counsel, and in accordance with Florida Rules of Civil Procedure, 1.310, within the time limits as provided by said Rule, requests the Plaintiff, Ronald Vohs, to admit or deny the following: 1. You are entitled to receive medical payment coverage benefits as a result of the subject incident. 2. You have received medical payments coverage benefits as a result of the subject incident. 3. You sustained no permanent injuries as a result of the subject incident. 4. No medical provider has expressed a medical opinion that you have sustained a permanent injury as a result of the subject incident. 5. You were not gainfully employed at the time of the subject incident. 6. You did not lose any wages or income as a result of the subject incident. 7. Your earning capacity was not reduced or impaired as a result of the subject incident. 8. Your ability to enjoy life has not been reduced as a result of the subject incident. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/28/2017 2:32:50 PM.****9. You had been involved in one (1) or more motor vehicle accident(s) prior to the subject incident. 10. You sustained significant and permanent injuries in said prior motor vehicle accident(s). 11. You have been in one (1) or more motor vehicle accidents(s) subsequent to the subject incident. 12. You sustained significant and permanent injuries in said subsequent motor vehicle accident(s). 13. You had been involved in one (1) or more slip and fall type or other non-motor vehicle accidents prior to the subject incident. 14. You sustained significant and permanent injuries in the prior slip and fall type or other non- motor vehicle accident(s). 15. You have been involved in one (1) or more slip and fall type or other non-motor vehicle accidents subsequent to the subject incident. 16. You sustained significant and permanent injuries in the subsequent slip and fall type or other non-vehicle accident(s). 17. Some or all of the injuries you are claiming damages for in this matter pre-existed the subject incident. 18. You have a prior felony conviction. 19. You have a prior conviction involving dishonesty or false statement. 20. You have turned down work you were physically able to perform since the date of the subject incident. 21. You are presently able to perform numerous light duty tasks. 22. Your normal facilities were impaired at the time of the subject incident. 23. You had been drinking alcohol and/or taken drugs/medications within six (6) hours prior to the subject incident. 24. You were distracted immediately preceding your fall.25. You were aware of the orange cable in the grass of the common area between the mobile homes, prior to your fall. 26. You made statements to Comcast employees and/or agents days prior to the subject incident. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via electronic mail this 28" day of July, 2017, to: Yeemee Chan, Esq., Steinger, Iscoe & Greene, P.A., 2400 E. Commercial Blvd., Suite 900, Ft. Lauderdale, FL 33308. 17.11718/PAD/sm RUDD & DIAMOND, P.A. Attorneys for Defendant, Comcast 4000 Hollywood Blvd. Presidential Circle, Suite 120-N Hollywood, FL 33021 Tel. (954) 961-5059 Fax. (954) 961-8953 @rudddiamond.com service: By: /s/ Michael P. Rudd FL Bar No.: 782416 And Peter A. Diamond FL Bar No.: 0180051