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Case Number: CACE-15-021538 Division: 13
Filing # 35255345 E-Filed 12/07/2015 06:44:15 PM
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.:
JIANNINA CARDONA-PEREZ,
Plaintiff,
v.
PROGRESSIVE SELECT INSURANCE
COMPANY, a foreign corporation,
Defendant.
/
REQUEST FOR ADMISSIONS TO DEFENDANT, PROGRESSIVE
COMES NOW, the Plaintiff, JIANNINA CARDONA-PEREZ, by and through the
undersigned counsel, and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, hereby
files this Request for Admissions to Defendant, PROGRESS e Seana ee
: ‘COMPANY (“F (“PROGRESSIVE”) a 1 foreign co SSelatih, and et said Defendant to rep
to the following in accordance with Rule 1.370:
1, Admit that on March 24, 2015, Gleb Roytman caused or contributed to the subject
accident.
2. Admit that on March 24, 2015, the Plaintiff, JANNINA CARDONA-PEREZ, did not
cause or contribute to the subject accident.
3. Admit that on March 24, 2015, Plaintiff, JANNINA CARDONA-PEREZ, sustained a
permanent injury as a direct result of the subject accident.
4. Admit that Plaintiff JIANNINA CARDONA-PEREZ’s medical treatment since the
subject accident has been reasonable.
1
The Law Offices of Anidjar & Levine, P.A.
12 SE 7 Street, Suite 604, Fort Lauderdale, Florida 33301 (954) 525-0050
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/7/2015 6:44:13 PM.****10.
1.
Admit that Plaintiff JIANNINA CARDONA-PEREZ’s medical treatment since the
subject accident has been necessary.
Admit that Plaintiff JIANNINA CARDONA-PEREZ’s medical treatment since the
subject accident has been related to the subject accident.
Admit that on March 24, 2015, Gleb Roytman negligently operated a motor vehicle so as
to collide with the vehicle being driven by the Plaintiff, JANNINA CARDONA-PEREZ.
Admit that on March 24, 2015, the negligence of Gleb Roytman caused the
aforedescribed motor vehicle accident.
Admit that there was nothing that the Plaintiff, JANNINA CARDONA-PEREZ, could
have done to avoid the accident that occurred on March 24, 2015, which is the subject of
this lawsuit.
Admit that Gleb Roytman was an uninsured and/or underinsured motorist at the date and
--time-of the subject accident herein
Admit that Plaintiff, JIANNINA CARDONA-PEREZ, was insured under the
uninsured/underinsured automobile insurance policy issued by Defendant,
PROGRESSIVE, on the date and time of the subject accident herein.
(Certificate of Service on Page 3)
2
The Law Offices of Anidjar & Levine, P.A.
12 SE 7 Street, Suite 604, Fort Lauderdale, Florida 33301 (954) 525-0050CERTIFICATE OF SERVICE
J HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the
Defendant, along with the Summons and Complaint filed in this cause.
LAW OFFICES OF ANIDJAR & LEVINE, P.A.
Counsel for Plaintiff
12 SE 7" Street, Suite 604
Ft. Lauderdale, FL 33301
0050 / Fax (954) 525-0020
adings@anl-law.com
By:
ELIF’ANIDJAR, ESQ.
FBN 932191
3
The Law Offices of Anidjar & Levine, P.A.
12 SE 7* Street, Suite 604, Fort Lauderdale, Florida 33301 (954) 525-0050
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Case Number: CACE-15-021538 Division: 13 Filing # 35255345 E-Filed 12/07/2015 06:44:15 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: JIANNINA CARDONA-PEREZ, Plaintiff, v. PROGRESSIVE SELECT INSURANCE COMPANY, a foreign corporation, Defendant. / REQUEST FOR ADMISSIONS TO DEFENDANT, PROGRESSIVE COMES NOW, the Plaintiff, JIANNINA CARDONA-PEREZ, by and through the undersigned counsel, and pursuant to Rule 1.370 of the Florida Rules of Civil Procedure, hereby files this Request for Admissions to Defendant, PROGRESS e Seana ee : ‘COMPANY (“F (“PROGRESSIVE”) a 1 foreign co SSelatih, and et said Defendant to rep to the following in accordance with Rule 1.370: 1, Admit that on March 24, 2015, Gleb Roytman caused or contributed to the subject accident. 2. Admit that on March 24, 2015, the Plaintiff, JANNINA CARDONA-PEREZ, did not cause or contribute to the subject accident. 3. Admit that on March 24, 2015, Plaintiff, JANNINA CARDONA-PEREZ, sustained a permanent injury as a direct result of the subject accident. 4. Admit that Plaintiff JIANNINA CARDONA-PEREZ’s medical treatment since the subject accident has been reasonable. 1 The Law Offices of Anidjar & Levine, P.A. 12 SE 7 Street, Suite 604, Fort Lauderdale, Florida 33301 (954) 525-0050 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/7/2015 6:44:13 PM.****10. 1. Admit that Plaintiff JIANNINA CARDONA-PEREZ’s medical treatment since the subject accident has been necessary. Admit that Plaintiff JIANNINA CARDONA-PEREZ’s medical treatment since the subject accident has been related to the subject accident. Admit that on March 24, 2015, Gleb Roytman negligently operated a motor vehicle so as to collide with the vehicle being driven by the Plaintiff, JANNINA CARDONA-PEREZ. Admit that on March 24, 2015, the negligence of Gleb Roytman caused the aforedescribed motor vehicle accident. Admit that there was nothing that the Plaintiff, JANNINA CARDONA-PEREZ, could have done to avoid the accident that occurred on March 24, 2015, which is the subject of this lawsuit. Admit that Gleb Roytman was an uninsured and/or underinsured motorist at the date and --time-of the subject accident herein Admit that Plaintiff, JIANNINA CARDONA-PEREZ, was insured under the uninsured/underinsured automobile insurance policy issued by Defendant, PROGRESSIVE, on the date and time of the subject accident herein. (Certificate of Service on Page 3) 2 The Law Offices of Anidjar & Levine, P.A. 12 SE 7 Street, Suite 604, Fort Lauderdale, Florida 33301 (954) 525-0050CERTIFICATE OF SERVICE J HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the Defendant, along with the Summons and Complaint filed in this cause. LAW OFFICES OF ANIDJAR & LEVINE, P.A. Counsel for Plaintiff 12 SE 7" Street, Suite 604 Ft. Lauderdale, FL 33301 0050 / Fax (954) 525-0020 adings@anl-law.com By: ELIF’ANIDJAR, ESQ. FBN 932191 3 The Law Offices of Anidjar & Levine, P.A. 12 SE 7* Street, Suite 604, Fort Lauderdale, Florida 33301 (954) 525-0050