On June 16, 2017 a
Request,Application
was filed
involving a dispute between
Melara, Rafael A,
and
Miami-Dade County,
for Auto Negligence
in the District Court of Miami-Dade County.
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Filing # 64842309 E-Filed 12/01/2017 12:07:40 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
RAFAEL A. MELARA, GENERAL JURISDICTION DIVISION
Plaintiff, CASE NO. 17-14544 CA 01 (21)
v.
MIAMI-DADE COUNTY,
Defendant.
MIAMI-DADE COUNTY'S RESPONSE TO REQUEST FOR ADMISSIONS SERVED BY
PLAINTIFF ON NOVEMBER 3, 2017
Defendant MIAMI-DADE COUNTY, by and through undersigned counsel, and pursuant
to Florida Rule of Civil Procedure 1.370, hereby responds to Requests for Admissions
served by Plaintiff on November 3, 2017 as follows:
1. Plaintiff has complied with all conditions precedent prior to the institution of this
lawsuit pursuant to Florida Statute §768.28.
RESPONSE:
Cannot admit or deny; unknown.
2. Plaintiff has given written notice of the subject claim to the Defendant pursuant to
Florida Statute §768.28 at least six months prior to filing the lawsuit.
RESPONSE:
Admitted.
3. Defendant received written notice of the subject claim by the Florida Department of
Financial Services prior to filing of this lawsuit.
RESPONSE:
Denied.
4. Plaintiff has complied with the service provisions of Florida Statute §768.28.
RESPONSE:
Cannot admit or deny; unknown.
OFFICE OF COUNTY ATTORNEY, MIAMI-DADE COUNTY, FLORIDA
TELEPHONE 305.375.5151RAFAEL A. MELARA v. MIAMI-DADE COUNTY
Case No. 17-14544 CA 01 (21)
Respectfully submitted,
ABIGAIL PRICE-WILLIAMS
Miami-Dade County Attorney
Attorney for Defendant Miami-Dade County
Stephen P. Clark Center, Suite 2810
111 Northwest First Street
Miami, Florida 33128-1993
By:_/s/ Sabrina Levin
Sabrina Levin
Assistant County Attorney
Florida Bar Number 27536
Telephone: (305) 375-2806
Fax: (305) 375-5611
Email: levin@miamidade.gov
sanchez@miamidade.gov
CERTIFICATE OF SERVICE
I CERTIFY that a copy hereof has been furnished by E-MAIL generated by the Florida
Courts E-Filing Portal on December 1, 2017 to: Steven G. Jugo, Esq., Law Office of Jugo &
Murphy, 7695 SW 104th Street Offices at Pinecrest, Suite 200, Miami, FL 33156-3159,
carmen@jugomurphy.com; sjugo@jugomurphy.com; sandee@jugomurphy.com.
/s/ Sabrina Levin
Assistant County Attorney
Page 2
OFFICE OF COUNTY ATTORNEY, MIAMI-DADE COUNTY, FLORIDA
TELEPHONE 305.375.5151
Document Filed Date
December 01, 2017
Case Filing Date
June 16, 2017
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Filing # 64842309 E-Filed 12/01/2017 12:07:40 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA RAFAEL A. MELARA, GENERAL JURISDICTION DIVISION Plaintiff, CASE NO. 17-14544 CA 01 (21) v. MIAMI-DADE COUNTY, Defendant. MIAMI-DADE COUNTY'S RESPONSE TO REQUEST FOR ADMISSIONS SERVED BY PLAINTIFF ON NOVEMBER 3, 2017 Defendant MIAMI-DADE COUNTY, by and through undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.370, hereby responds to Requests for Admissions served by Plaintiff on November 3, 2017 as follows: 1. Plaintiff has complied with all conditions precedent prior to the institution of this lawsuit pursuant to Florida Statute §768.28. RESPONSE: Cannot admit or deny; unknown. 2. Plaintiff has given written notice of the subject claim to the Defendant pursuant to Florida Statute §768.28 at least six months prior to filing the lawsuit. RESPONSE: Admitted. 3. Defendant received written notice of the subject claim by the Florida Department of Financial Services prior to filing of this lawsuit. RESPONSE: Denied. 4. Plaintiff has complied with the service provisions of Florida Statute §768.28. RESPONSE: Cannot admit or deny; unknown. OFFICE OF COUNTY ATTORNEY, MIAMI-DADE COUNTY, FLORIDA TELEPHONE 305.375.5151RAFAEL A. MELARA v. MIAMI-DADE COUNTY Case No. 17-14544 CA 01 (21) Respectfully submitted, ABIGAIL PRICE-WILLIAMS Miami-Dade County Attorney Attorney for Defendant Miami-Dade County Stephen P. Clark Center, Suite 2810 111 Northwest First Street Miami, Florida 33128-1993 By:_/s/ Sabrina Levin Sabrina Levin Assistant County Attorney Florida Bar Number 27536 Telephone: (305) 375-2806 Fax: (305) 375-5611 Email: levin@miamidade.gov sanchez@miamidade.gov CERTIFICATE OF SERVICE I CERTIFY that a copy hereof has been furnished by E-MAIL generated by the Florida Courts E-Filing Portal on December 1, 2017 to: Steven G. Jugo, Esq., Law Office of Jugo & Murphy, 7695 SW 104th Street Offices at Pinecrest, Suite 200, Miami, FL 33156-3159, carmen@jugomurphy.com; sjugo@jugomurphy.com; sandee@jugomurphy.com. /s/ Sabrina Levin Assistant County Attorney Page 2 OFFICE OF COUNTY ATTORNEY, MIAMI-DADE COUNTY, FLORIDA TELEPHONE 305.375.5151