On May 01, 2021 a
Request for Admissions - Party: Plaintiff Gregory, Jessica Nicole
was filed
involving a dispute between
Gregory, Jessica Nicole,
and
Mesalien, Kesley,
Progressive Select Insurance Company,
for Auto Negligence
in the District Court of Broward County.
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Case Number: CACE-21-008836 Division: 21
Filing # 125986570 E-Filed 05/01/2021 03:59:31 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JESSICA NICOLE GREGORY, CASE NO.:
Plaintiff,
VS.
KESLEY MESALIEN and
PROGRESSIVE SELECT INSURANCE COMPANY,
Defendants.
/
PLAINTIFF’S 1* REQUEST FOR ADMISSIONS
COMES NOW the Plaintiff, JESSICA NICOLE GREGORY, by and through the
undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, hereby requests that the
Defendant, PROGRESSIVE SELECT INSURANCE COMPANY (“PROGRESSIVE”) admit or
deny the following within forty five (45) days from the service of this Request for Admissions.
1. That on May 25, 2020, Plaintiff was a named insured under the Progressive policy
number 910264345 (“Progressive Insurance Policy”).
2. That the Progressive Insurance Policy, by its terms, provided uninsured/underinsured
motorist coverage for the benefit of Plaintiff.
3. That on May 25, 2020, 2020, Plaintiff was involved in a motor vehicle accident with an
“underinsured motorist”, as defined under the Progressive Insurance Policy.
4. That as a result of being involved in a motor vehicle accident with an “underinsured
motorist”, Plaintiff is entitled to pursue a claim for underinsured motorists benefits under the
Progressive Insurance Policy.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/01/2021 03:59:28 PM.****4. That the subject accident of May 25, 2020, was caused, in whole or in part, by the
negligence of an “underinsured motorist”.
5. That the Progressive Insurance Policy was in full force and effect at the time of the subject
accident on May 25, 2020, and any conditions precedent to obtaining or extending coverage
has been met.
6. That Plaintiff has suffered at least some personal injuries as a result of the subject
accident of May 25, 2020.
7. That Plaintiff has incurred some reasonable medical expenses as a result of injuries he
suffered in the subject accident on May 25, 2020.
8. That Plaintiff has suffered permanent personal injuries as a result of the subject accident
of May 25, 2020.
I HEREBY CERTIFY that a copy of the foregoing was served upon the defendant with
the Complaint filed herein.
LAW OFFICE OF SABAN & SOLOMON
150 N. University Dr., Suite 200
Plantation, Florida 33324
P: (954) 577-2878
F: (954) 577-2215
s/ Robert Solomon
ROBERT C. SOLOMON, ESQ.
FBN: 27054
Document Filed Date
May 01, 2021
Case Filing Date
May 01, 2021
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Case Number: CACE-21-008836 Division: 21 Filing # 125986570 E-Filed 05/01/2021 03:59:31 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JESSICA NICOLE GREGORY, CASE NO.: Plaintiff, VS. KESLEY MESALIEN and PROGRESSIVE SELECT INSURANCE COMPANY, Defendants. / PLAINTIFF’S 1* REQUEST FOR ADMISSIONS COMES NOW the Plaintiff, JESSICA NICOLE GREGORY, by and through the undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, hereby requests that the Defendant, PROGRESSIVE SELECT INSURANCE COMPANY (“PROGRESSIVE”) admit or deny the following within forty five (45) days from the service of this Request for Admissions. 1. That on May 25, 2020, Plaintiff was a named insured under the Progressive policy number 910264345 (“Progressive Insurance Policy”). 2. That the Progressive Insurance Policy, by its terms, provided uninsured/underinsured motorist coverage for the benefit of Plaintiff. 3. That on May 25, 2020, 2020, Plaintiff was involved in a motor vehicle accident with an “underinsured motorist”, as defined under the Progressive Insurance Policy. 4. That as a result of being involved in a motor vehicle accident with an “underinsured motorist”, Plaintiff is entitled to pursue a claim for underinsured motorists benefits under the Progressive Insurance Policy. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/01/2021 03:59:28 PM.****4. That the subject accident of May 25, 2020, was caused, in whole or in part, by the negligence of an “underinsured motorist”. 5. That the Progressive Insurance Policy was in full force and effect at the time of the subject accident on May 25, 2020, and any conditions precedent to obtaining or extending coverage has been met. 6. That Plaintiff has suffered at least some personal injuries as a result of the subject accident of May 25, 2020. 7. That Plaintiff has incurred some reasonable medical expenses as a result of injuries he suffered in the subject accident on May 25, 2020. 8. That Plaintiff has suffered permanent personal injuries as a result of the subject accident of May 25, 2020. I HEREBY CERTIFY that a copy of the foregoing was served upon the defendant with the Complaint filed herein. LAW OFFICE OF SABAN & SOLOMON 150 N. University Dr., Suite 200 Plantation, Florida 33324 P: (954) 577-2878 F: (954) 577-2215 s/ Robert Solomon ROBERT C. SOLOMON, ESQ. FBN: 27054