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Filing # 57695945 E-Filed 06/13/2017 03:06:04 PM
IN THE CIRCUIT COURT OF THE 117
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
BERTONNY FLERIGENE, Individually, GENERAL JURISDICTION DIVISION
Plaintiff, CASE NO.
VS.
DARLINE ALEXANDRE, Individually,
Defendant.
/
REQUEST FOR ADMISSIONS TO DEFENDANT, DARLINE ALEXANDRE
COMES NOW Plaintiff, BERTONNY FLERIGENE, by and through his undersigned
attorneys and request Defendant, DARLINE ALEXANDRE, to admit or deny the following on
or before forty five (45) days after service of same by the Sheriff or an authorized Process Serv-
er:
1. That on September 9, 2016, at approximately 11:12 A.M., Defendant, DARLINE
ALEXANDRE, was the operator and owner of a 2003 Mercedes automobile
2. That on September 9, 2016, DARLINE ALEXANDRE, while operating the automo-
bile described in Request for Admissions No. 1, above, was involved in an automobile accident
at the intersection of N.W. 2"4 Avenue and N.W. 188" Street in Miami Gardens, Florida, with a
taxicab operated by BERTONNY FLERIGENE
3. That the happening of the collision which occurred on September 9, 2016, at the inter-
section of N.W. 2" Avenue and N.W. 188" Street in Miami Gardens, Florida, between the 2003
Mercedes operated by Defendant, DARLINE ALEXANDRE, and a taxicab operated by
BERTONNY FLERIGENE was not the fault, nor was it contributed to by any actions of
BERTONNY FLERIGENE.Page No. 2
4. That as a result of the collision which occurred on September 9, 2016, between the
2003 Mercedes operated by Defendant, DARLINE ALEXANDRE and a taxicab occupied by
BERTONNY FLERIGENE, BERTONNY FLERIGENE sustained injuries which are permanent
and/or continuing in nature.
5. That on September 9, 2016, there were no road defects which caused or contributed to
cause the incident complained of in the lawsuit filed by BERTONNY FLERIGENE, against De-
fendant DARLINE ALEXANDRE
6. That on September 9, 2016, there were no weather conditions which caused or con-
tributed to cause the incident complained of in the lawsuit filed by BERTONNY FLERIGENE,
against Defendant, DARLINE ALEXANDRE
7. That on September 9, 2016, the 2003 Mercedes operated by Defendant, DARLINE
ALEXANDRE, had no defects which caused or contributed to cause the incident complained of
in the lawsuit filed by BERTONNY FLERIGENE, against DARLINE ALEXANDRE
8. That on September 9, 2016, at the intersection of N.W. 2" Avenue and N.W. 188"
Street in Miami Gardens, Florida, Defendant, DARLINE ALEXANDRE did operate the 2003
Mercedes he was driving with such negligence so as to cause it to collide with the taxicab oper-
ated by BERTONNY FLERIGENE,
9. That BERTONNY FLERIGENE was not himself negligent in the happening of the
accident which occurred on September 9, 2016 between the 2003 Mercedes operated by Defend-
ant, DARLINE ALEXANDRE and the taxicab occupied by BERTONNY FLERIGENE.
10. That as a result of the collision between the vehicle operated by DARLINE
ALEXANDRE and the taxicab operated by BERTONNY FLERIGENE, DARLINE
ALEXANDRE was issued a traffic citation.Page No. 3
11. That Defendant, DARLINE ALEXANDRE pled guilty to the traffic citation referred
to in Request for Admission No. 10, above.
12. That the claims of BERTONNY FLERIGENE, in the lawsuit are not subject to nor
governed by the provisions of the Florida Motor Vehicle No-Fault Law, specifically Florida
Statute §627.737,
13 That Plaintiff, BERTONNY FLERIGENE was operating a taxicab when this loss
occurred on September 9, 2016.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was delivered to the
Sheriff or an authorized Process Server for service upon Defendant, DARLINE ALEXANDRE,
an individual, together with the Complaint, Request to Produce and Interrogatories, all directed
to the Defendant herein.
LAW OFFICES OF LEVY & LEVY, P.A.
1000 Sawgrass Corporate Pkwy Suite 588
Sunrise, Florida 33323
Telephone: (954) 763-5722
Facsimile: (954) 763-5723
Email: bryan@levylevylaw.com
Secondary: assistant@levylevylaw.com
Attorneys for Plaintiff
BY: s/Bryan Levy
BRYAN P. LEVY
FBN: 675806
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Filing # 57695945 E-Filed 06/13/2017 03:06:04 PM IN THE CIRCUIT COURT OF THE 117 JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA BERTONNY FLERIGENE, Individually, GENERAL JURISDICTION DIVISION Plaintiff, CASE NO. VS. DARLINE ALEXANDRE, Individually, Defendant. / REQUEST FOR ADMISSIONS TO DEFENDANT, DARLINE ALEXANDRE COMES NOW Plaintiff, BERTONNY FLERIGENE, by and through his undersigned attorneys and request Defendant, DARLINE ALEXANDRE, to admit or deny the following on or before forty five (45) days after service of same by the Sheriff or an authorized Process Serv- er: 1. That on September 9, 2016, at approximately 11:12 A.M., Defendant, DARLINE ALEXANDRE, was the operator and owner of a 2003 Mercedes automobile 2. That on September 9, 2016, DARLINE ALEXANDRE, while operating the automo- bile described in Request for Admissions No. 1, above, was involved in an automobile accident at the intersection of N.W. 2"4 Avenue and N.W. 188" Street in Miami Gardens, Florida, with a taxicab operated by BERTONNY FLERIGENE 3. That the happening of the collision which occurred on September 9, 2016, at the inter- section of N.W. 2" Avenue and N.W. 188" Street in Miami Gardens, Florida, between the 2003 Mercedes operated by Defendant, DARLINE ALEXANDRE, and a taxicab operated by BERTONNY FLERIGENE was not the fault, nor was it contributed to by any actions of BERTONNY FLERIGENE.Page No. 2 4. That as a result of the collision which occurred on September 9, 2016, between the 2003 Mercedes operated by Defendant, DARLINE ALEXANDRE and a taxicab occupied by BERTONNY FLERIGENE, BERTONNY FLERIGENE sustained injuries which are permanent and/or continuing in nature. 5. That on September 9, 2016, there were no road defects which caused or contributed to cause the incident complained of in the lawsuit filed by BERTONNY FLERIGENE, against De- fendant DARLINE ALEXANDRE 6. That on September 9, 2016, there were no weather conditions which caused or con- tributed to cause the incident complained of in the lawsuit filed by BERTONNY FLERIGENE, against Defendant, DARLINE ALEXANDRE 7. That on September 9, 2016, the 2003 Mercedes operated by Defendant, DARLINE ALEXANDRE, had no defects which caused or contributed to cause the incident complained of in the lawsuit filed by BERTONNY FLERIGENE, against DARLINE ALEXANDRE 8. That on September 9, 2016, at the intersection of N.W. 2" Avenue and N.W. 188" Street in Miami Gardens, Florida, Defendant, DARLINE ALEXANDRE did operate the 2003 Mercedes he was driving with such negligence so as to cause it to collide with the taxicab oper- ated by BERTONNY FLERIGENE, 9. That BERTONNY FLERIGENE was not himself negligent in the happening of the accident which occurred on September 9, 2016 between the 2003 Mercedes operated by Defend- ant, DARLINE ALEXANDRE and the taxicab occupied by BERTONNY FLERIGENE. 10. That as a result of the collision between the vehicle operated by DARLINE ALEXANDRE and the taxicab operated by BERTONNY FLERIGENE, DARLINE ALEXANDRE was issued a traffic citation.Page No. 3 11. That Defendant, DARLINE ALEXANDRE pled guilty to the traffic citation referred to in Request for Admission No. 10, above. 12. That the claims of BERTONNY FLERIGENE, in the lawsuit are not subject to nor governed by the provisions of the Florida Motor Vehicle No-Fault Law, specifically Florida Statute §627.737, 13 That Plaintiff, BERTONNY FLERIGENE was operating a taxicab when this loss occurred on September 9, 2016. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was delivered to the Sheriff or an authorized Process Server for service upon Defendant, DARLINE ALEXANDRE, an individual, together with the Complaint, Request to Produce and Interrogatories, all directed to the Defendant herein. LAW OFFICES OF LEVY & LEVY, P.A. 1000 Sawgrass Corporate Pkwy Suite 588 Sunrise, Florida 33323 Telephone: (954) 763-5722 Facsimile: (954) 763-5723 Email: bryan@levylevylaw.com Secondary: assistant@levylevylaw.com Attorneys for Plaintiff BY: s/Bryan Levy BRYAN P. LEVY FBN: 675806