On July 17, 2015 a
Party Discovery
was filed
involving a dispute between
Vera, Luis,
and
Evans, Richard,
for Neg - Premises Liability Residential
in the District Court of Broward County.
Preview
Filing # 30990480 E-Filed 08/18/2015 12:06:39 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL
CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA
LUIS VERA,
Plaintiff, CASE NO. CACE 15-012685(12)
vs.
RICHARD EVANS
Defendant.
DEFENDANT’S RESPONSE TO PLAINTIFF’S REQUEST FOR ADMISSIONS
COMES NOW, the Defendant, RICHARD EVANS, by and through the undersigned
counsel and files his Response to Plaintiff's Request for Admissions and states as follows:
1. Defendant objects to the term “the dog” as it is vague and ambiguous as there was more
than one dog present. Subject to and without waiving the foregoing objections, Defendant
denies.
2. Defendant objects to the term “controlled” as it is vague and ambiguous and it implies a
legal conclusion. Subject to and without waiving the foregoing objections, Defendant
denies.
w
Defendant objects to the term “premises” as it is vague and ambiguous and it implies a
legal conclusion. Subject to and without waiving the foregoing objections, Defendant
denies.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/18/2015 12:06:39 PM.****10.
11.
12.
13.
14.
15.
Defendant objects to the term “bodily injuries” as it is vague and ambiguous as it fails to
allege which part of the body sustained injuries and to what extent. Subject to and without
waiving the foregoing objections, Defendant denies.
. Defendant objects to the term “premises” as it is vague and ambiguous as it fails to allege
which premises is being referenced. Subject to and without waiving the foregoing
objections, Defendant denies.
Denied.
Denied.
Denied.
Denied.
Denied.
Denied
Denied.
Defendant is without sufficient knowledge or information to form a belief to the truth of
the allegation set forth in paragraph 14. Therefore, Defendant denies and demands strict
proof thereof.
. Defendant is without sufficient knowledge or information to form a belief to the truth of
the allegation set forth in paragraph 14. Therefore, Defendant denies and demands strict
proof thereof.
Denied.Respectfully submitted,
RENIER LEDEZMA
4440 PGA Blvd Suite 600 Palm Beach
Gardens, FL
33410
/s/ Renier Ledezma
Renier Ledezma
Bar No. 0073874
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served on
this 17th day of August, 2015 to: Monica Medina, Esq. located at 5757 Blue Lagoon Drive Suite
230 Miami, Florida 33472.
/s/ Renier Ledezma
Renier Ledezma
Bar No. 0073874
Document Filed Date
August 18, 2015
Case Filing Date
July 17, 2015
Category
Neg - Premises Liability Residential
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Filing # 30990480 E-Filed 08/18/2015 12:06:39 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA LUIS VERA, Plaintiff, CASE NO. CACE 15-012685(12) vs. RICHARD EVANS Defendant. DEFENDANT’S RESPONSE TO PLAINTIFF’S REQUEST FOR ADMISSIONS COMES NOW, the Defendant, RICHARD EVANS, by and through the undersigned counsel and files his Response to Plaintiff's Request for Admissions and states as follows: 1. Defendant objects to the term “the dog” as it is vague and ambiguous as there was more than one dog present. Subject to and without waiving the foregoing objections, Defendant denies. 2. Defendant objects to the term “controlled” as it is vague and ambiguous and it implies a legal conclusion. Subject to and without waiving the foregoing objections, Defendant denies. w Defendant objects to the term “premises” as it is vague and ambiguous and it implies a legal conclusion. Subject to and without waiving the foregoing objections, Defendant denies. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/18/2015 12:06:39 PM.****10. 11. 12. 13. 14. 15. Defendant objects to the term “bodily injuries” as it is vague and ambiguous as it fails to allege which part of the body sustained injuries and to what extent. Subject to and without waiving the foregoing objections, Defendant denies. . Defendant objects to the term “premises” as it is vague and ambiguous as it fails to allege which premises is being referenced. Subject to and without waiving the foregoing objections, Defendant denies. Denied. Denied. Denied. Denied. Denied. Denied Denied. Defendant is without sufficient knowledge or information to form a belief to the truth of the allegation set forth in paragraph 14. Therefore, Defendant denies and demands strict proof thereof. . Defendant is without sufficient knowledge or information to form a belief to the truth of the allegation set forth in paragraph 14. Therefore, Defendant denies and demands strict proof thereof. Denied.Respectfully submitted, RENIER LEDEZMA 4440 PGA Blvd Suite 600 Palm Beach Gardens, FL 33410 /s/ Renier Ledezma Renier Ledezma Bar No. 0073874 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served on this 17th day of August, 2015 to: Monica Medina, Esq. located at 5757 Blue Lagoon Drive Suite 230 Miami, Florida 33472. /s/ Renier Ledezma Renier Ledezma Bar No. 0073874