On February 12, 2021 a
Party Discovery
was filed
involving a dispute between
Direct General Insurance Company,
and
Cruz, Angel Enrique,
Peralta, Victor Jose,
Torres, Jonaell R,
for OTHER - INSURANCE CLAIM
in the District Court of Flagler County.
Preview
Filing # 121332494 E-Filed 02/12/2021 03:16:33 PM
IN THE CIRCUIT COURT OF THE 7™4
JUDICIAL CIRCUIT IN AND FOR FLAGLER
COUNTY, FLORIDA
DIRECT GENERAL INSURANCE COMPANY, Case No.: 2021 CA 000079
Plaintiff,
ANGEL ENRIQUE CRUZ, VICTOR JOSE
PERALTA, and VICTOR JOSE PERALTA as
the Parent, Natural and Legal Guardian of
JONAELL R. TORRES, a minor,
Defendant(s).
/
PLAINTIFF’S SECOND REQUEST FOR ADMISSIONS TO DEFENDANT, ANGEL ENRIQUE
CRUZ
COMES NOW, the Plaintiff, DIRECT GENERAL INSURANCE COMPANY, by and through
its undersigned counsel and pursuant to F.R.C.P. 1.370, hereby files this, Plaintiff's Second Request
for Admissions to the Defendant, ANGEL ENRIQUE CRUZ, directing that the Defendant admit or
deny the following allegations, within forty-five (45) days as follows:
REQUEST FOR ADMISSION #1:
1. Admit that ANGEL ENRIQUE CRUZ was not injured in the motor vehicle accident which
occurred on November 11, 2020.
REQUEST FOR ADMISSION #2:
2. Admit that ANGEL ENRIQUE CRUZ did not seek any medical treatment as a result of
the motor vehicle accident which occurred on November 11, 2020.
REQUEST FOR ADMISSION #3:
3. Admit that ANGEL ENRIQUE CRUZ did not receive any medical treatment as a result
of the motor vehicle accident which occurred on November 11, 2020.
REQUEST FOR ADMISSION #4:
4. Admit that ANGEL ENRIQUE CRUZ did not seek any medical treatment within 14 days
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 02/15/2021 03:06 PMof the motor vehicle accident which occurred on November 11, 2020.
REQUEST FOR ADMISSION #5:
5. Admit that ANGEL ENRIQUE CRUZ did not receive any medical treatment within 14
days of the motor vehicle accident which occurred on November 11, 2020.
REQUEST FOR ADMISSION #6:
6. Admit that ANGEL ENRIQUE CRUZ is not making a claim for Personal Injury Protection
(PIP) benefits as a result of the motor vehicle accident which occurred on November
11, 2020.
REQUEST FOR ADMISSION #7:
7. Admit that ANGEL ENRIQUE CRUZ is not making a claim for Personal Injury Protection
(PIP) benefits under the policy of insurance, bearing policy number XXXXXX6006.
REQUEST FOR ADMISSION #8:
8. Admit that ANGEL ENRIQUE CRUZ did not sign any Assignment of Benefits (AOB) to
any medical provider, doctor and/or medical facility after the motor vehicle accident
which occurred on November 11, 2020.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was served with the
summons and complaint.
McFARLANE LAW
McFarlane Dolan & Prince
Attorneys for Plaintiff
210 N. University Drive, 6 Floor
Coral Springs, Florida 33071
(954) 340-0005 Broward
(954) 340-0055 Facsimile
PLEADING SERVICE E-MAIL ADDRESS:
pleadingservice@mcfarlanedolaniaw.com
By: _/s/ William J. McFarlane, Ill, Esquire
WILLIAM J. McFARLANE, ESQUIRE
Florida Bar No: 768601Master Service List
ANGEL ENRIQUE CRUZ VICTOR JOSE PERALTA As The
22B PLATEAU LN, Parent, Natural And Legal Guardian Of
PALM COAST, FL JONAELL R. TORRES, a minor
32164-7439 5411 Hutchinson ST,
Port Orange, FL 32128
VICTOR JOSE PERALTA,
5411 Hutchinson St,
Port Orange, FL 32128
Document Filed Date
February 12, 2021
Case Filing Date
February 12, 2021
Category
OTHER - INSURANCE CLAIM
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Filing # 121332494 E-Filed 02/12/2021 03:16:33 PM IN THE CIRCUIT COURT OF THE 7™4 JUDICIAL CIRCUIT IN AND FOR FLAGLER COUNTY, FLORIDA DIRECT GENERAL INSURANCE COMPANY, Case No.: 2021 CA 000079 Plaintiff, ANGEL ENRIQUE CRUZ, VICTOR JOSE PERALTA, and VICTOR JOSE PERALTA as the Parent, Natural and Legal Guardian of JONAELL R. TORRES, a minor, Defendant(s). / PLAINTIFF’S SECOND REQUEST FOR ADMISSIONS TO DEFENDANT, ANGEL ENRIQUE CRUZ COMES NOW, the Plaintiff, DIRECT GENERAL INSURANCE COMPANY, by and through its undersigned counsel and pursuant to F.R.C.P. 1.370, hereby files this, Plaintiff's Second Request for Admissions to the Defendant, ANGEL ENRIQUE CRUZ, directing that the Defendant admit or deny the following allegations, within forty-five (45) days as follows: REQUEST FOR ADMISSION #1: 1. Admit that ANGEL ENRIQUE CRUZ was not injured in the motor vehicle accident which occurred on November 11, 2020. REQUEST FOR ADMISSION #2: 2. Admit that ANGEL ENRIQUE CRUZ did not seek any medical treatment as a result of the motor vehicle accident which occurred on November 11, 2020. REQUEST FOR ADMISSION #3: 3. Admit that ANGEL ENRIQUE CRUZ did not receive any medical treatment as a result of the motor vehicle accident which occurred on November 11, 2020. REQUEST FOR ADMISSION #4: 4. Admit that ANGEL ENRIQUE CRUZ did not seek any medical treatment within 14 days Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 02/15/2021 03:06 PMof the motor vehicle accident which occurred on November 11, 2020. REQUEST FOR ADMISSION #5: 5. Admit that ANGEL ENRIQUE CRUZ did not receive any medical treatment within 14 days of the motor vehicle accident which occurred on November 11, 2020. REQUEST FOR ADMISSION #6: 6. Admit that ANGEL ENRIQUE CRUZ is not making a claim for Personal Injury Protection (PIP) benefits as a result of the motor vehicle accident which occurred on November 11, 2020. REQUEST FOR ADMISSION #7: 7. Admit that ANGEL ENRIQUE CRUZ is not making a claim for Personal Injury Protection (PIP) benefits under the policy of insurance, bearing policy number XXXXXX6006. REQUEST FOR ADMISSION #8: 8. Admit that ANGEL ENRIQUE CRUZ did not sign any Assignment of Benefits (AOB) to any medical provider, doctor and/or medical facility after the motor vehicle accident which occurred on November 11, 2020. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was served with the summons and complaint. McFARLANE LAW McFarlane Dolan & Prince Attorneys for Plaintiff 210 N. University Drive, 6 Floor Coral Springs, Florida 33071 (954) 340-0005 Broward (954) 340-0055 Facsimile PLEADING SERVICE E-MAIL ADDRESS: pleadingservice@mcfarlanedolaniaw.com By: _/s/ William J. McFarlane, Ill, Esquire WILLIAM J. McFARLANE, ESQUIRE Florida Bar No: 768601Master Service List ANGEL ENRIQUE CRUZ VICTOR JOSE PERALTA As The 22B PLATEAU LN, Parent, Natural And Legal Guardian Of PALM COAST, FL JONAELL R. TORRES, a minor 32164-7439 5411 Hutchinson ST, Port Orange, FL 32128 VICTOR JOSE PERALTA, 5411 Hutchinson St, Port Orange, FL 32128