Party Discovery: Heather Grant, et al Plaintiff vs. David Vadillo, et al Defendant

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                                Case Number: CACE-21-009583 Division: 21
Filing # 126770334 E-Filed 05/13/2021 03:18:51 PM

                                                          IN THE CIRCUIT COURT OF THE 17°
                                                          JUDICIAL CIRCUIT IN AND FOR
                                                          BROWARD COUNTY, FLORIDA

                                                          CASE NO.:


            HEATHER GRANT,

                  Plaintiff,
           vs.


            DAVID VADILLO and
            LYFT FLORIDA, INC.,
            d/b/a LYFT, INC.,
                  Defendants.
                                            /

                 REQUEST FOR ADMISSIONS TO DEFENDANT, DAVID VADILLO

                  Plaintiff, HEATHER GRANT, by and through her undersigned counsel, requests

           the Defendant, DAVID VADILLO to admit or deny the truth of the following matters

           within the time and manner set forth by law:

                  1   Admit that at the time of the subject incident that is the subject matter of this

                      lawsuit, you were logged into the “LYFT” rideshare app.

                      Admit that at the time of the incident, you were in the course of performing a

                      transportation ride for the Defendant, “LYFT”.

                      Admit that at the time of the subject incident, you were engaged in an active

                      ride on behalf of the Defendant, “LYFT”.

                      Admit that at the time of the subject incident, you were in the process of

                      transporting a passenger to his/her destination.

                      Admit that at the time of the subject incident, you were an “in service” Lyft.




          #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN,            CLERK 05/13/2021 03:18:47 PM.**#*
Admit that immediately prior to the subject incident, you attempted to make a

   left turn onto Broward Boulevard.

   Admit that in the process of making your left turn, you struck the vehicle

   driven by the Plaintiff, HEATHER GRANT who was driving southbound on

   NE   3% Ave.     at the intersection with Broward Boulevard, Fort Lauderdale,

   Florida.

   Admit that immediately prior to the subject incident, you had a clear view of

   oncoming traffic travelling southbound on NE 3" Ave. at the intersection with

   Broward Boulevard.

   Admit that prior to the subject incident, the Plaintiff, HEATHER GRANT had

   the right of way.

10. Admit that you did not yield the right of way to the Plaintiff's, HEATHER

   GRANT’S vehicle.

11 Admit that prior to completing your left turn onto Broward Boulevard, you

   did not allow all vehicles travelling southbound on NE         3” Ave. to drive

   through the intersection.

12. Admit that your actions contributed substantially to the subject incident that is

   the subject matter of this lawsuit.

13 Admit that the Plaintiff's, HEATHER GRANT’S actions did not contribute to

   the subject incident.

14. Admit     that the   Plaintiff's,   HEATHER   GRANT’S     vehicle   flipped   over

   immediately after the impact with your vehicle.

15 Admit that the Plaintiff, HEATHER         GRANT was taken to Broward General

   Medical Center following this incident.
16. Admit   that the Plaintiff, HEATHER    GRANT      has been   diagnosed   with a

   permanent injury resulting from the subject incident that is the subject matter

   of this lawsuit.

17. Admit that the Plaintiffs, HEATHER     GRANT’S medical care and treatment

   in connection to the subject incident were reasonable and necessary.

18. Admit that you are not aware of any third parties who may have contributed to

   the subject incident.

19. Admit that the Plaintiffs, HEATHER     GRANT’S medical expenses incurred

   in connection with the subject incident were reasonable and necessary;

                                            /s/Jon A. Zepnick, Esq.
                                            Jon A. Zepnick, Esq.
                                            Florida Bar No.: 586951
                                            ANSEL & MILLER, LLC
                                             Counsel for the Plaintiff
                                             1939 Tyler Street
                                            Hollywood, Florida 33020
                                            Phone: (954) 922-9100
                                            Fax: (954) 922-9176
                                             jonzepnick@anselmiler.com
                                            Makethecall03@aol.com
                                            rshields@anselmiller.com
                                             ansel@anselmiller.com