Document for CIRCUIT CIVIL - DIV J (JUDGE KEIM) CONE, DYLAN T -VS- HORNBUCKLE, EVAN R et al

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                                Filing # 119222190 E-Filed 01/07/2021 12:24:20 PM

IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT
IN AND FOR ALACHUA COUNTY, STATE OF FLORIDA
CIVIL DIVISION
CASE NO.:01-2021-CA-0039
DYLAN T. CONE,
Plaintiff,

Vv.

EVAN R. HORNBUCKLE and
ANNESSA S. FREDERICK,

Defendants.
/

 

PLAINTIFF’S REQUEST FOR ADMISSION TO
DEFENDANT ANNESSA S. FREDERICK

Plaintiff, DYLAN T. CONE, through his undersigned counsel and pursuant to Florida Rule
of Civil Procedure 1.370, propounds the following request for admission to defendant ANNESSA
S. FREDERICK to be answered in writing and served on plaintiffs counsel within 45 days of
receipt of this request:

1. Please admit defendant driver was driving a 2018 Nissan motor vehicle on September 6,

2018.

RESPONSE:

2. Please admit defendant driver was involved in an automobile accident on September 6,

2018 while driving a 2018 Nissan motor vehicle.

RESPONSE:

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"2021 CA 000039" 119222190 Filed at Alachua County Clerk 01/07/2021 12:24:27 PM EST. Please admit you owned the 2018 Nissan motor vehicle driven by defendant driver on
September 6, 2018.

RESPONSE:

Please admit defendant driver did not have a valid driver's license in any state on the date
of the automobile accident on September 6, 2018.

RESPONSE:

Please admit defendant driver’s driver's license had been revoked or suspended as of the
date of the automobile accident on September 6, 2018.

RESPONSE:

Please admit defendant driver was violating a restriction placed on his driver's license on
the date of the automobile accident on September 6, 2018.

RESPONSE:

. Please admit defendant driver received a traffic ticket as a result of the automobile accident

on September 6, 2018.

RESPONSE:

Please admit the condition of the road surface did not contribute to the cause of the
automobile accident on September 6, 2018.

RESPONSE:

Please admit that lighting conditions did not contribute to the cause of the automobile
accident on September 6, 2018.

RESPONSE:

Page 2 of 410. Please admit that weather conditions did not contribute to the cause of the automobile
accident on September 6, 2018.
RESPONSE:

11. Please admit that a sudden emergency did not contribute to the cause of the automobile
accident on September 6, 2018.
RESPONSE:

12. Please admit that no defect or malfunction in the 2018 Nissan motor vehicle contributed
to the cause of the automobile accident on September 6, 2018.
RESPONSE:

13. Please admit defendant driver was required to wear corrective lenses to drive on
September 6, 2018.
RESPONSE:

14. Please admit defendant driver was not wearing corrective lenses at the time of the collision
on September 6, 2018.
RESPONSE:

21. Please admit defendant driver failed to maintain a proper lookout at the time of the
automobile accident on September 6, 2018.
RESPONSE:

22. Please admit defendant driver was under the influence of either drugs or alcohol when the
automobile accident on September 6, 2018 occurred.

RESPONSE:

Page 3 of 423. Please admit defendant driver ingested drugs or alcohol within 12 before the automobile
accident on September 6, 2018.

RESPONSE:

24. Please admit defendant driver was using an electronic device when the automobile
accident on September 6, 2018 occurred.

RESPONSE:

CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a copy of the foregoing was served on defendant owner at

the time of service of process in this case.

ALLEN LAW FIRM, P.A.

/s/ David Carlson

William T. Allen, Jr., Esq.

Florida Bar No. 950180

Steven M. Brady, Esq.

Florida Bar No.: 749516

David Carlson, Esq.

Florida Bar No.: 124058

2550 S.W. 76th Street, Suite 150

Gainesville, Florida 32608

Phone: (352) 331-6789

Fax: (352) 331-6785

Primary email: litigation@allenlaw.com

Secondary email: melissa@allenlaw.com
david@allenlaw.com

Attorneys for Plaintiff

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