On June 21, 2017 a
Request,Application
was filed
involving a dispute between
Llerena, Roberto,
Llerena, Xiomara,
and
Andres Quintana Inc,
Learning And Growing Family Child Care,
Quintana Family Day Care Home,
for Comm Premises Liability
in the District Court of Miami-Dade County.
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Filing # 61603873 E-Filed 09/15/2017 05:10:55 PM
IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 17-014926 CA 01 (31)
XIOMARA LLERENA AND.
ROBERTO LLERENA ,
Plaintiffs,
vs.
QUINTANA FAMILY DAY CARE HOME
d/b/a LEARNING AND GROWING FAMILY
CHILD CARE,
Defendant.
/
DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF
Defendant, Quintana Family Day Care Home d/b/a Learning and Growing Family
Child Care, pursuant to Florida Rule of Civil Procedure 1.370, requests that Plaintiff admit
or deny the following assertions of fact:
1. Plaintiff has not sustained any lost wages as a result of the subject accident.
2. Plaintiff is not making a wage loss claim as a result of the subject accident.
3. Plaintiff is not making a claim for loss of future earning capacity as a result of
the subject accident.
4. Plaintiff has not sustained a permanent injury as a result of the incident
referenced in Plaintiffs Complaint.
5. Defendant, Quintana Family Day Care Home d/b/a Learning and GrowingFamily Child Care, is wholly without fault with regards to the subject
incident referenced in Plaintiff’s Complaint.
6. The actions or inactions of Defendant are not the proximate cause of the
alleged injuries sustained by Plaintiff with regards to the subject incident
referenced in Plaintiffs Complaint.
7. Defendant exercised reasonable and ordinary care in the maintenance of its
premises, and therefore did not breach its duty to Plaintiff on the date of the
subject incident referenced in Plaintiffs Complaint.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via Electronic Mail, to all counsel of record on the attached Service List, this 15"
day of September, 2017.
LUKS, SANTANIELLO,
PETRILLO & JONES
Attorneys for Defendant
150 W. Flagler Street, Suite 2750
Miami, FL 33130
Telephone: (305) 377-8900
Facsimile: (305) 377-8901
By: [6] Heather M. Catheon
DANIEL J. SANTANIELLO,
Florida Bar No.: 860948
HEATHER M. CALHOON,
Florida Bar No.: 495573
LUKSMIA-Pleadings@LS-Law.comSERVICE LIST
Michael J. Carmona, Esq.
Friedland Law Group
1430 South Dixie Highway
Suite 305
Coral Gables, FL 33146
email@friedlandlawgroup.com
Document Filed Date
September 15, 2017
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 61603873 E-Filed 09/15/2017 05:10:55 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 17-014926 CA 01 (31) XIOMARA LLERENA AND. ROBERTO LLERENA , Plaintiffs, vs. QUINTANA FAMILY DAY CARE HOME d/b/a LEARNING AND GROWING FAMILY CHILD CARE, Defendant. / DEFENDANT’S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF Defendant, Quintana Family Day Care Home d/b/a Learning and Growing Family Child Care, pursuant to Florida Rule of Civil Procedure 1.370, requests that Plaintiff admit or deny the following assertions of fact: 1. Plaintiff has not sustained any lost wages as a result of the subject accident. 2. Plaintiff is not making a wage loss claim as a result of the subject accident. 3. Plaintiff is not making a claim for loss of future earning capacity as a result of the subject accident. 4. Plaintiff has not sustained a permanent injury as a result of the incident referenced in Plaintiffs Complaint. 5. Defendant, Quintana Family Day Care Home d/b/a Learning and GrowingFamily Child Care, is wholly without fault with regards to the subject incident referenced in Plaintiff’s Complaint. 6. The actions or inactions of Defendant are not the proximate cause of the alleged injuries sustained by Plaintiff with regards to the subject incident referenced in Plaintiffs Complaint. 7. Defendant exercised reasonable and ordinary care in the maintenance of its premises, and therefore did not breach its duty to Plaintiff on the date of the subject incident referenced in Plaintiffs Complaint. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Electronic Mail, to all counsel of record on the attached Service List, this 15" day of September, 2017. LUKS, SANTANIELLO, PETRILLO & JONES Attorneys for Defendant 150 W. Flagler Street, Suite 2750 Miami, FL 33130 Telephone: (305) 377-8900 Facsimile: (305) 377-8901 By: [6] Heather M. Catheon DANIEL J. SANTANIELLO, Florida Bar No.: 860948 HEATHER M. CALHOON, Florida Bar No.: 495573 LUKSMIA-Pleadings@LS-Law.comSERVICE LIST Michael J. Carmona, Esq. Friedland Law Group 1430 South Dixie Highway Suite 305 Coral Gables, FL 33146 email@friedlandlawgroup.com