Party Discovery: Kristin Bianculli Plaintiff vs. Progressive American Insurance Company Defendant

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                                Filing # 127733320 E-Filed 05/28/2021 10:02:08 AM
 19564.1
 IN THE CIRCUIT COURT OF THE
 SEVENTEENTH JUDICIAL CIRCUIT
 IN AND FOR BROWARD COUNTY, FLORIDA
 CASE NO.:
 KRISTIN BIANCULLI,
 Plaintiff.
 V
 PROGRESSIVE AMERICAN INSURANCE COMPANY
 Defendant.
 '
 PLAINTIFF'SREOUEST FOR ADMISSIONS TO DEFENDANT
 COMES NOW the Plaintiff, KRISTIN BIANCULLI, by and through her
 undersigned counsel, and requests the Defendant,PROGRESSIVE AMERICANINSURANCE
 COMPANY, to admit or deny the following:
 1.
 That on March 22, 2021, the tortfesor, Martha Ortiz Paz, was the cause of
 the accidenton March 22,2021.
 2.
 That on March 22, 2021, the tortfesor,Martha Ortiz Paz, was a cause of the
 accidenton March 22,2021.
 3
 That as a result of this motor vehicle accident Plaintiff KRISTIN
 BIANCULLI, sustained permanent injuries within a reasonable degree of medical
 probability.
 4.
 That Plaintiff, KRISTIN BIANCULLI'S conduct did not in any way
 contribute to the cause ofthe automobile accidentdescribed above.
 *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 05/28/2021 10:02:05 AM.****
 5.
 That Plaintiff, KRISTIN BIANCULLI, incurred medical expenses for
 treatment for her injuries from the accident within a reasonable degree of medical
 certainty.
 6.
 That Plaintiff, KRISTIN BIANCULLI, will continue to incur future
 medical expenses for treatment for her injuries from the accident within a reasonable
 degree ofmedical certainty.
 7.
 That as a result of this motor vehicle accident Plaintiff, KRISTIN
 BIANCULLI sustained injuries which were caused by the accident within a reasonable
 degree ofmedical probability.
 WE HEREBY CERTIFY that a true and correct copy ofthe foregoing was served
 with Summons, Complaint,Interrogatoriesand Request to Produce.
 SCHULER, HALVORSON, WEISSER,
 ZOELLER & OVERBECK, P.A.
 Attorneys for Plaintiff
 1615 Forum Place, Suite 4-D
 Barristers Building
 West Palm Beach, FL 33401
 Telephone (561) 689-8180
 By:/s/ William Zoeller
 William D. Zoeller
 Florida Bar No: 155233
 Email 1:
 Email 2: tcoffey@shw-law.com
 Email 3:
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