On December 18, 2006 a
Party Discovery
was filed
involving a dispute between
Nadine A Bignall,
and
Adrianne P Ditlefsen,
Amber L Moll,
for CA - Auto Negligence
in the District Court of Orange County.
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IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND FOR
ORANGE COUNTY, FLORIDA
NADINE A. BIGNALL,
Plaintiff,
CASE NO: 06-CA-10847 39
vs.
AMBER L. MOLL AND ADRIANNE
P. DITLEFSEN,
Defendants.
PLAINTIFF'S RESPONSE TO DEFENDANTS' REQUEST FOR ADMISSIONS
COME(S) NOW the Plaintiff, NADINE A. BIGNALL, by and through the undersigned
attorneys, and in response to the Defendants', AMBER L. MOLL AND ADRIANNE P.
• .• • i •.-
DITLEFSEN, Request for Admissions served on or about January 17,2007, and states as follows:"
1. Denied.
2. Denied. " '.
3. Denied.
4. Denied. _ . - .'
-'•""..
5. Plaintiff admits to receiving Personal Injury Protection benefits from an-•automobile'
u/
insurance policy for a portion of the medical expenses incurred by Plaintiff as a result of the
subject incident. Plaintiff denies that those Personal Injury Protection benefits have
provided payment in full for all medical expenses incurred by the Plaintiff.
6. Plaintiff admits to being entitled to Personal Injury Protection benefits from an automobile
...insurance policy for a portion of the medical expenses incurred by Plaintiff as a result of the
subject incident. Plaintiff denies that those Personal Injury Protection benefits have
provided payment in full for all medical expenses incurred by the Plaintiff.
7. Denied due to lack of knowledge.
8. Plaintiff admits to being entitled to Personal Injury Protection benefits from an automobile
insurance policy for a portion of the lost wages incurred by Plaintiff as a result of the subject
incident. Plaintiff denies that those Personal Injury Protection benefits have provided
payment in full for all lost wages incurred by the Plaintiff.
9. Denied due to lack of knowledge.
10. Plaintiff admits to being entitled to medical payment benefits from an automobile insurance
policy for a portion of the medical expenses incurred by Plaintiff as a result of the subject
incident. Plaintiff denies that those medical payment benefits have provided payment in full
for all medical expenses incurred by the Plaintiff.
11. Denied.
12. Denied.
13. Denied.
14. Denied.
15. Denied.
16. Admitted Plaintiff had a seatbelt in her vehicle, the remainder of the admission is denied.
17. Denied, Plaintiff was wearing the proper restraint.
18. Denied.
19. Denied calls for a legal conclusion.
20. Denied.
21. Admitted as phrased.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished,
by U.S. Mail - postage paid, this day of February, 2007, to: Michelle Gerjel, Esquire,
Law Offices of Robert Soifer, 390 North Orange Avenue, Suite 1550, Orlando, FL 32801.
J. Smith, Esquire"
FBfcM) 105668
Morgan/& Morgan, P.A.
20 N. Orange Ave., 16th Floor
P.O. Box 4979
Orlando, FL 32802-4979
Telephone: (407) 420-1414
Facsimile: (407)425-8171
Attorneys for Plaintiff
Document Filed Date
February 21, 2007
Case Filing Date
December 18, 2006
Category
CA - Auto Negligence
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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA NADINE A. BIGNALL, Plaintiff, CASE NO: 06-CA-10847 39 vs. AMBER L. MOLL AND ADRIANNE P. DITLEFSEN, Defendants. PLAINTIFF'S RESPONSE TO DEFENDANTS' REQUEST FOR ADMISSIONS COME(S) NOW the Plaintiff, NADINE A. BIGNALL, by and through the undersigned attorneys, and in response to the Defendants', AMBER L. MOLL AND ADRIANNE P. • .• • i •.- DITLEFSEN, Request for Admissions served on or about January 17,2007, and states as follows:" 1. Denied. 2. Denied. " '. 3. Denied. 4. Denied. _ . - .' -'•"".. 5. Plaintiff admits to receiving Personal Injury Protection benefits from an-•automobile' u/ insurance policy for a portion of the medical expenses incurred by Plaintiff as a result of the subject incident. Plaintiff denies that those Personal Injury Protection benefits have provided payment in full for all medical expenses incurred by the Plaintiff. 6. Plaintiff admits to being entitled to Personal Injury Protection benefits from an automobile ...insurance policy for a portion of the medical expenses incurred by Plaintiff as a result of the subject incident. Plaintiff denies that those Personal Injury Protection benefits have provided payment in full for all medical expenses incurred by the Plaintiff. 7. Denied due to lack of knowledge. 8. Plaintiff admits to being entitled to Personal Injury Protection benefits from an automobile insurance policy for a portion of the lost wages incurred by Plaintiff as a result of the subject incident. Plaintiff denies that those Personal Injury Protection benefits have provided payment in full for all lost wages incurred by the Plaintiff. 9. Denied due to lack of knowledge. 10. Plaintiff admits to being entitled to medical payment benefits from an automobile insurance policy for a portion of the medical expenses incurred by Plaintiff as a result of the subject incident. Plaintiff denies that those medical payment benefits have provided payment in full for all medical expenses incurred by the Plaintiff. 11. Denied. 12. Denied. 13. Denied. 14. Denied. 15. Denied. 16. Admitted Plaintiff had a seatbelt in her vehicle, the remainder of the admission is denied. 17. Denied, Plaintiff was wearing the proper restraint. 18. Denied. 19. Denied calls for a legal conclusion. 20. Denied. 21. Admitted as phrased. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished, by U.S. Mail - postage paid, this day of February, 2007, to: Michelle Gerjel, Esquire, Law Offices of Robert Soifer, 390 North Orange Avenue, Suite 1550, Orlando, FL 32801. J. Smith, Esquire" FBfcM) 105668 Morgan/& Morgan, P.A. 20 N. Orange Ave., 16th Floor P.O. Box 4979 Orlando, FL 32802-4979 Telephone: (407) 420-1414 Facsimile: (407)425-8171 Attorneys for Plaintiff