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Filing # 91586284 E-Filed 06/24/2019 04:33:37 PM
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR MIAMEDADE COUNTY, FLORIDA
JUTA BOIANGIN, AN INDIVIDUAL, CASE NO.: 18-32555-CA-01 (13)
Plaintiff,
VS.
BLUE JAY TRUCKING, INC, A FLORIDA FOR
PROFIT CORPORATION, IMPAC LOGISTIC
SERVICES, LLC, A NEW JERSEY LIMITED
LIABILITY COMPANY AND AJA PROPERTIES NO.
6 LTD, A FLORIDA LIMITED PARNERSHIP,
Defendants. /
DEFENDANT’S RESPONSE TO PLAINTIFF’S REQUESTS FOR ADMISSIONS
Defendant, AJA PROPERTIES No. 6 LTD. by and through the undersigned counsel,
hereby responds to Plaintiff's Request for Admissions as follows:
1. Admit that you are a Florida limited partnership that owns and leases commercial
warehouse space to tenants.
RESPONSE: Admitted.
2. Admit that you own and lease commercial warehouse space to tenants at real property
located in Miami-Dade Florida at 2970 NW 75th Avenue, Miami, FL 33122 (the
"Property").
RESPONSE: Denied in part.
3 Admit that you allow tenants to negligently park their trailers or motor vehicles on the
road in front of the Property.
RESPONSE: Denied.
Law Office of Hugh J. Behan * 4000 Hollywood Blvd., Suite 430-N * Hollywood, FL 33021 * 954-989-8775Case No.: 18-32555-CA-01 (13) Page 2 of 2
4 Admit that you have video surveillance footage, videos, pictures, drawings, sketches,
or the like related to the collision reference in the Amended Complaint.
RESPONSE: Denied.
5. Admit that you were on notice of tenants parking their motor vehicles or trailers on
the street in front of the property by way of the fact that the Trailer and other trailers
routinely park in the area in violation of local ordinances.
RESPONSE: Denied as phrased.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing was sent via email/eportal only on June 24.
2019, to: Ryan M. Clancy, Esq., Ainsworth & Clancy, 801 Brickell Ave., 9" Floor, Miami, FL 33131,
Attorney for Plaintiff, email: ryan@business-esqg.com; Aaron H. Epstein, Esq., Fox Rothschild LLP, 2
South Biscayne Blvd., One Biscayne Tower, Suite 2750, Miami FL 33131, Attorney for Blue Jay Trucking,
Inc., email aepstein@foxrothschild.com
A/CHARISE MORGAN-JOSEPH
Charise Morgan-Joseph, Esq
Florida Bar #: 102316
charise.morganjoseph@zurichna.com
LAW OFFICE OF HUGH BEHAN
Employees of a Member Company of Zurich Ins. Group
Presidential Circle, Suite 430-N
4000 Hollywood Boulevard
Hollywood, FL 33021
Telephone: (954) 967-6471
E-service: usz.slftl@zurichna.com
Attorneys for Defendant, AJA PROPERTIES NO. 6 LTD
Law Office of Hugh J. Behan * 4000 Hollywood Blvd., Suite 430-N * Hollywood, FL 33021 * 954-989-8775
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Filing # 91586284 E-Filed 06/24/2019 04:33:37 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMEDADE COUNTY, FLORIDA JUTA BOIANGIN, AN INDIVIDUAL, CASE NO.: 18-32555-CA-01 (13) Plaintiff, VS. BLUE JAY TRUCKING, INC, A FLORIDA FOR PROFIT CORPORATION, IMPAC LOGISTIC SERVICES, LLC, A NEW JERSEY LIMITED LIABILITY COMPANY AND AJA PROPERTIES NO. 6 LTD, A FLORIDA LIMITED PARNERSHIP, Defendants. / DEFENDANT’S RESPONSE TO PLAINTIFF’S REQUESTS FOR ADMISSIONS Defendant, AJA PROPERTIES No. 6 LTD. by and through the undersigned counsel, hereby responds to Plaintiff's Request for Admissions as follows: 1. Admit that you are a Florida limited partnership that owns and leases commercial warehouse space to tenants. RESPONSE: Admitted. 2. Admit that you own and lease commercial warehouse space to tenants at real property located in Miami-Dade Florida at 2970 NW 75th Avenue, Miami, FL 33122 (the "Property"). RESPONSE: Denied in part. 3 Admit that you allow tenants to negligently park their trailers or motor vehicles on the road in front of the Property. RESPONSE: Denied. Law Office of Hugh J. Behan * 4000 Hollywood Blvd., Suite 430-N * Hollywood, FL 33021 * 954-989-8775Case No.: 18-32555-CA-01 (13) Page 2 of 2 4 Admit that you have video surveillance footage, videos, pictures, drawings, sketches, or the like related to the collision reference in the Amended Complaint. RESPONSE: Denied. 5. Admit that you were on notice of tenants parking their motor vehicles or trailers on the street in front of the property by way of the fact that the Trailer and other trailers routinely park in the area in violation of local ordinances. RESPONSE: Denied as phrased. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was sent via email/eportal only on June 24. 2019, to: Ryan M. Clancy, Esq., Ainsworth & Clancy, 801 Brickell Ave., 9" Floor, Miami, FL 33131, Attorney for Plaintiff, email: ryan@business-esqg.com; Aaron H. Epstein, Esq., Fox Rothschild LLP, 2 South Biscayne Blvd., One Biscayne Tower, Suite 2750, Miami FL 33131, Attorney for Blue Jay Trucking, Inc., email aepstein@foxrothschild.com A/CHARISE MORGAN-JOSEPH Charise Morgan-Joseph, Esq Florida Bar #: 102316 charise.morganjoseph@zurichna.com LAW OFFICE OF HUGH BEHAN Employees of a Member Company of Zurich Ins. Group Presidential Circle, Suite 430-N 4000 Hollywood Boulevard Hollywood, FL 33021 Telephone: (954) 967-6471 E-service: usz.slftl@zurichna.com Attorneys for Defendant, AJA PROPERTIES NO. 6 LTD Law Office of Hugh J. Behan * 4000 Hollywood Blvd., Suite 430-N * Hollywood, FL 33021 * 954-989-8775