On October 18, 2019 a
Request for Admissions - DEFENDANTParty: Plaintiff Thomas, Katina
was filed
involving a dispute between
Thomas, Katina,
and
Depeine, John,
for Auto Negligence
in the District Court of Broward County.
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Case Number: CACE-19-021558 Division: 05
Filing # 97503005 E-Filed 10/18/2019 11:07:24 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
KATINA THOMAS CASE NO.:
Plaintiff,
vs.
JOHN DEPEINE
Defendant,
/
REQUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW the Plaintiff, KATINA THOMAS, by and through the undersigned counsel, and
pursuant to Florida Rules of Civil Procedure, Rule 1.370, files this Request for Admissions to Defendant,
JOHN DEPEINE, and requests said Defendant, to respond to the following in accordance with Rule
1.370:
That on December 7, 2017, Defendant, JOHN DEPEINE, caused or contributed to the
subject accident.
That on December 7, 2017, Plaintiff did not cause or contribute to the subject accident.
That on December 7, 2017, Plaintiff sustained a permanent injury as a direct result of the
subject accident.
That Plaintiff's medical treatment since the subject accident has been reasonable.
That Plaintiff's medical treatment since the subject accident has been necessary.
That Plaintiff's medical treatment since the subject accident has been related to the
subject accident.
That on December 7, 2017, JOHN DEPEINE, negligently operated a motor vehicle so
as to cause a collision with the vehicle being driven by Plaintiff.
That on December 7, 2017, the negligence of JOHN DEPEINE, caused the subject
motor vehicle accident.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/18/2019 11:07:22 AM.****9. That there was nothing that the Plaintiff could have done to avoid the accident _ that
occurred on December 7, 2017 which is the subject of this lawsuit,
10. Admit that you were using a cell phone at the time of the accident.
I HEREBY CERTIFY that a true and correct copy of the foregoing served upon the
defendant, along with the Summons and Complaint filed in this cause.
THOMAS & PEARL, P.A.
Attomeys for Plaintiff
2404 Northeast 9th Street
Fort Lauderdale, Florida 33304
Telephone: (954) 563-9225
Facsimile: (954) 563-9497
litdept@thomaspearl.com
oy $——
KEVIN B. DENNIS, ESQ.
Florida Bar No.: 829110
Document Filed Date
October 18, 2019
Case Filing Date
October 18, 2019
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Case Number: CACE-19-021558 Division: 05 Filing # 97503005 E-Filed 10/18/2019 11:07:24 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA KATINA THOMAS CASE NO.: Plaintiff, vs. JOHN DEPEINE Defendant, / REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW the Plaintiff, KATINA THOMAS, by and through the undersigned counsel, and pursuant to Florida Rules of Civil Procedure, Rule 1.370, files this Request for Admissions to Defendant, JOHN DEPEINE, and requests said Defendant, to respond to the following in accordance with Rule 1.370: That on December 7, 2017, Defendant, JOHN DEPEINE, caused or contributed to the subject accident. That on December 7, 2017, Plaintiff did not cause or contribute to the subject accident. That on December 7, 2017, Plaintiff sustained a permanent injury as a direct result of the subject accident. That Plaintiff's medical treatment since the subject accident has been reasonable. That Plaintiff's medical treatment since the subject accident has been necessary. That Plaintiff's medical treatment since the subject accident has been related to the subject accident. That on December 7, 2017, JOHN DEPEINE, negligently operated a motor vehicle so as to cause a collision with the vehicle being driven by Plaintiff. That on December 7, 2017, the negligence of JOHN DEPEINE, caused the subject motor vehicle accident. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/18/2019 11:07:22 AM.****9. That there was nothing that the Plaintiff could have done to avoid the accident _ that occurred on December 7, 2017 which is the subject of this lawsuit, 10. Admit that you were using a cell phone at the time of the accident. I HEREBY CERTIFY that a true and correct copy of the foregoing served upon the defendant, along with the Summons and Complaint filed in this cause. THOMAS & PEARL, P.A. Attomeys for Plaintiff 2404 Northeast 9th Street Fort Lauderdale, Florida 33304 Telephone: (954) 563-9225 Facsimile: (954) 563-9497 litdept@thomaspearl.com oy $—— KEVIN B. DENNIS, ESQ. Florida Bar No.: 829110