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
Case Number: CACE-15-012685 Division: 12
Filing # 29775820 E-Filed 07/17/2015 11:06:15 AM
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.
LUIS VERA,
Plaintiff,
v.
RICHARD EVANS,
Defendant.
/
ae
PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
PURSUANT to rule 1.370, Florida Rules of Civil Procedure, Defendant is hereby requested
to admit the truth of the matters hereinafter set forth on or by the forty-fifth (45th) day after service
hereof by answering in writing.
1, Admit that the Defendant owned the dog on the day of the subject accident which
gave rise to this lawsuit.
2. Admit that the Defendant controlled the premises on which the dog was kept at the
time of the subject accident which gave rise to this lawsuit,
3. Admit that the Defendant occupied the premises from which the dog came and
attacked the Plaintiff.
4. Admit that the Plaintiff suffered bodily injuries as a result of the subject accident.
5. Admit that said duty required Defendant to keep the premises in a reasonably safe
condition for the safety of the Plaintiff.
6. Admit that the Defendant breach the duty owed to the Plaintiff by failing to have the
premises in a reasonably safe condition.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/17/2015 11:06:12 AM.****7. Admit that the Plaintiff suffered injuries in and about the body and extremities.
8. Admit that the Plaintiff suffered pain and suffering.
9. Admit that the Plaintiff suffered disability.
10. Admit that the Plaintiff suffered disfigurement.
11. Admit that the Plaintiff suffered mental anguish.
12. Admit that the Plaintiff suffered loss of the capacity for the enjoyment of life.
13. Admit that the Plaintiff has incurred expenses in hospitalization, medical treatment,
nursing care, loss of earnings, loss of ability to eam money.
14. Admit that the Plaintiff suffered an aggravation of a previously existing condition.
15. Admit that the only party at fault is the Defendant.
THEREBY CERTIFY that a true and correct copy of the foregoing has been served with the
Complaint upon the Defendant.
JOSE M. FRANCISCO, P.A.
Attorneys for Plaintiff
5757 Blue Lagoon Drive
Suite 230
Miami, Florida 33126
Tel: (305) 649-2213 Ext. 2010
Primary: stieationatomey2@i imflawvers.c
Secondary: liti
BY:
DINA, ESQ.
Fla.Bar No. 48951
Document Filed Date
July 17, 2015
Case Filing Date
July 17, 2015
Category
Neg - Premises Liability Residential
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Case Number: CACE-15-012685 Division: 12 Filing # 29775820 E-Filed 07/17/2015 11:06:15 AM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. LUIS VERA, Plaintiff, v. RICHARD EVANS, Defendant. / ae PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT PURSUANT to rule 1.370, Florida Rules of Civil Procedure, Defendant is hereby requested to admit the truth of the matters hereinafter set forth on or by the forty-fifth (45th) day after service hereof by answering in writing. 1, Admit that the Defendant owned the dog on the day of the subject accident which gave rise to this lawsuit. 2. Admit that the Defendant controlled the premises on which the dog was kept at the time of the subject accident which gave rise to this lawsuit, 3. Admit that the Defendant occupied the premises from which the dog came and attacked the Plaintiff. 4. Admit that the Plaintiff suffered bodily injuries as a result of the subject accident. 5. Admit that said duty required Defendant to keep the premises in a reasonably safe condition for the safety of the Plaintiff. 6. Admit that the Defendant breach the duty owed to the Plaintiff by failing to have the premises in a reasonably safe condition. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/17/2015 11:06:12 AM.****7. Admit that the Plaintiff suffered injuries in and about the body and extremities. 8. Admit that the Plaintiff suffered pain and suffering. 9. Admit that the Plaintiff suffered disability. 10. Admit that the Plaintiff suffered disfigurement. 11. Admit that the Plaintiff suffered mental anguish. 12. Admit that the Plaintiff suffered loss of the capacity for the enjoyment of life. 13. Admit that the Plaintiff has incurred expenses in hospitalization, medical treatment, nursing care, loss of earnings, loss of ability to eam money. 14. Admit that the Plaintiff suffered an aggravation of a previously existing condition. 15. Admit that the only party at fault is the Defendant. THEREBY CERTIFY that a true and correct copy of the foregoing has been served with the Complaint upon the Defendant. JOSE M. FRANCISCO, P.A. Attorneys for Plaintiff 5757 Blue Lagoon Drive Suite 230 Miami, Florida 33126 Tel: (305) 649-2213 Ext. 2010 Primary: stieationatomey2@i imflawvers.c Secondary: liti BY: DINA, ESQ. Fla.Bar No. 48951