On October 07, 2020 a
Request for Admissions - TO DEFENDANT, JOSEPH MICHAEL CHARLESParty: Plaintiff Walters, Deborah Ann
was filed
involving a dispute between
Friedland, Lee,
Walters, Deborah Ann,
and
Baptiste, Emmanuel,
Charles, Joseph Michael,
for Auto Negligence
in the District Court of Broward County.
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Case Number: CACE-20-016603 Division: 13
Filing # 114559457 E-Filed 10/07/2020 09:51:38 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
DEBORAH ANN WALTERS, CASE NO.:
Plaintiff,
vs.
EMMANUEL BAPTISTE and JOSEPH
MICHAEL CHARLES,
Defendants.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO
DEFENDANT, JOSEPH MICHAEL CHARLES
Plaintiff, DEBORAH ANN WALTERS, by and through the undersigned counsel, hereby
requests Defendant, JOSEPH MICHAEL CHARLES, in accordance with Rule 1.370 Fla. R. Civ.
P., and within the time limits provided by said Rule, to admit or deny the following:
1. That on December 17, 2018, you were the owner of a 2007 Toyota bearing a
Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633.
2. That on December 17, 2018, EMMANUEL BAPTISTE operated the 2007 Toyota
bearing a Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633 with
your implied consent.
3. That on December 17, 2018, EMMANUEL BAPTISTE operated the 2007 Toyota
bearing a Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633 with
your explicit authorization.
4. That on December 17, 2018, the 2007 Toyota bearing a Florida vehicle license
plate JPSP32 and VIN number 5TDZT38A97S294633 operated by EMMANUEL BAPTISTE
was involved in an accident.
5. That on December 17, 2018, EMMANUEL BAPTISTE, while operating the 2007
Toyota bearing a Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633,
collided with the vehicle operated by Plaintiff, DEBORAH ANN WALTERS.
6. That on December 17, 2018, you were vicariously liable for the actions of
EMMANUEL BAPTISTE, while he operated the 2007 Toyota bearing a Florida vehicle license
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/07/2020 09:51:36 AM.****plate JPSP32 and VIN number STDZT38A978294633.
7. That at the time of the subject incident, the 2007 Toyota bearing a Florida vehicle
license plate JPSP32 and VIN number 5TDZT38A97S294633 had an operational dashboard
camera.
8. That you are in possession of a video depicting the subject accident.
9. That you did not preserve any videos depicting the subject accident.
10. That on December 17, 2018, there was an existing automobile insurance policy,
providing coverage to you, for losses of the type alleged in Plaintiff's Complaint.
11. That on December 17, 2018, there were other insurance policies, providing
coverage to you, for losses of the type alleged in Plaintiff's Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon
defendant, JOSEPH MICHAEL CHARLES, along with Summons and the Complaint in this
action.
FRIEDLAND & ASSOCIATES
707 NE 3" Avenue, Suite 201
Fort Lauderdale, Florida 33304
Telephone: (954) 321-8810
Facsimile: (954) 321-8995
Email: pleadings@yourfightourbattle.com
By: __/s/ Michael Gelety
Lee Friedland, Esq.
Florida Bar No. 991163
Michael Gelety, Esq.
Florida Bar No. 52125
Document Filed Date
October 07, 2020
Case Filing Date
October 07, 2020
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Case Number: CACE-20-016603 Division: 13 Filing # 114559457 E-Filed 10/07/2020 09:51:38 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA DEBORAH ANN WALTERS, CASE NO.: Plaintiff, vs. EMMANUEL BAPTISTE and JOSEPH MICHAEL CHARLES, Defendants. / PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT, JOSEPH MICHAEL CHARLES Plaintiff, DEBORAH ANN WALTERS, by and through the undersigned counsel, hereby requests Defendant, JOSEPH MICHAEL CHARLES, in accordance with Rule 1.370 Fla. R. Civ. P., and within the time limits provided by said Rule, to admit or deny the following: 1. That on December 17, 2018, you were the owner of a 2007 Toyota bearing a Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633. 2. That on December 17, 2018, EMMANUEL BAPTISTE operated the 2007 Toyota bearing a Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633 with your implied consent. 3. That on December 17, 2018, EMMANUEL BAPTISTE operated the 2007 Toyota bearing a Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633 with your explicit authorization. 4. That on December 17, 2018, the 2007 Toyota bearing a Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633 operated by EMMANUEL BAPTISTE was involved in an accident. 5. That on December 17, 2018, EMMANUEL BAPTISTE, while operating the 2007 Toyota bearing a Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633, collided with the vehicle operated by Plaintiff, DEBORAH ANN WALTERS. 6. That on December 17, 2018, you were vicariously liable for the actions of EMMANUEL BAPTISTE, while he operated the 2007 Toyota bearing a Florida vehicle license *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/07/2020 09:51:36 AM.****plate JPSP32 and VIN number STDZT38A978294633. 7. That at the time of the subject incident, the 2007 Toyota bearing a Florida vehicle license plate JPSP32 and VIN number 5TDZT38A97S294633 had an operational dashboard camera. 8. That you are in possession of a video depicting the subject accident. 9. That you did not preserve any videos depicting the subject accident. 10. That on December 17, 2018, there was an existing automobile insurance policy, providing coverage to you, for losses of the type alleged in Plaintiff's Complaint. 11. That on December 17, 2018, there were other insurance policies, providing coverage to you, for losses of the type alleged in Plaintiff's Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon defendant, JOSEPH MICHAEL CHARLES, along with Summons and the Complaint in this action. FRIEDLAND & ASSOCIATES 707 NE 3" Avenue, Suite 201 Fort Lauderdale, Florida 33304 Telephone: (954) 321-8810 Facsimile: (954) 321-8995 Email: pleadings@yourfightourbattle.com By: __/s/ Michael Gelety Lee Friedland, Esq. Florida Bar No. 991163 Michael Gelety, Esq. Florida Bar No. 52125