On June 16, 2021 a
Party Discovery
was filed
involving a dispute between
Vicente, Elizabeth,
and
Ebanks, Larose,
Enterprise Leasing Company Of Florida, Llc,
for 3
in the District Court of Broward County.
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Filing # 128846107 E-Filed 06/16/2021 10:13:29 AM
,TH
IN THE CIRCUIT COURT OF THE 17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
ELIZABETH VICENTE, CASE NO.:
Plaintiff,
V
LAROSE EBANKS and
ENTERPRISE LEASING COMPANY OF
FLORIDA, LLC, a Foreign Limited Liability
Company,
Defendants.
i
REOUEST FOR ADMISSIONS TO DEFENDANT
COMES NOW, the Plaintiff, by and through the undersigned counsel, and pursuant to Rule 1.390
of the Florida Rules of Civil Procedure, and files this Request for Admission to Defendant, ENTERPRISE
LEASING COMPANY OF FLORIDA, LLC, and requests said Defendant to admit or deny the following
in accordance with Rule 1.390:
1 Admit that on January 27,2020, LAROSE EBANKS caused the subject accident.
2. Admit that on January 27,2020, LAROSE EBANKS contributedto the subject accident.
3. Admit that ENTERPRISE LEASING COMPANYOF FLORIDA, LLC owns the vehicle described
in Paragraph 7 of the Complaint.
4. Admit that on
January 27, 2020, LAROSE EBANKS had permission and/or consent from
ENTERPRISE LEASING COMPANY OF FLORIDA, LLC, to drive the vehicle described in
Paragraph 7 of the Complaint.
5. Admit that on January 27,2020, ELIZABETH VICENTE did not cause the subject accident.
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/16/2021 10:13:26 AM.****
6. Admit that on January 27, 2020, ELIZABETH VICENTE did not contribute to the subject
accident.
7. Admit that on
January 27,2020, Plaintiff sustained a pennanent injury as a direct and proximate
result of the subject accident.
8 Admit that Plaintiff'smedical treatment since the subject accident has been reasonable.
9. Admit that Plaintiff'smedical treatment since the subject accident has been necessary.
10. Admit that Plaintiffs medical treatment since the subject accident has been related to the subject
accident.
11. Admit that on January 27,2020, LAROSE EBANKS negligently operated the aforedescribed
vehicle so as to collide with the vehicle Plaintiffwas driving.
12. Admit that on January 27, 2020, the negligence of LAROSE EBANKS caused the
aforedescribed motor vehicle accident.
13. Admit that there was nothing the Plaintiff could have done to avoid the subject accident that
occurred on January 27,2020.
I HEREBY CERTIFY that a true and correct copy of the foregoing served upon the Defendant,
along with the Summons and Complaint filed in this cause.
LAW OFFICES OF ANIDJAR& LEVINE, P.A.
Counsel for Plaintiff
300 SE 17th Street
Fort Lauderdale, FL 33316
Tel: (954) 525-0050/ Fax: (954) 525-0020
E-service at:
By.- /s/ Peter J. Ridge
PETER J. RIDGE, ESQ.
FBN 114263
Document Filed Date
June 16, 2021
Case Filing Date
June 16, 2021
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Filing # 128846107 E-Filed 06/16/2021 10:13:29 AM ,TH IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ELIZABETH VICENTE, CASE NO.: Plaintiff, V LAROSE EBANKS and ENTERPRISE LEASING COMPANY OF FLORIDA, LLC, a Foreign Limited Liability Company, Defendants. i REOUEST FOR ADMISSIONS TO DEFENDANT COMES NOW, the Plaintiff, by and through the undersigned counsel, and pursuant to Rule 1.390 of the Florida Rules of Civil Procedure, and files this Request for Admission to Defendant, ENTERPRISE LEASING COMPANY OF FLORIDA, LLC, and requests said Defendant to admit or deny the following in accordance with Rule 1.390: 1 Admit that on January 27,2020, LAROSE EBANKS caused the subject accident. 2. Admit that on January 27,2020, LAROSE EBANKS contributedto the subject accident. 3. Admit that ENTERPRISE LEASING COMPANYOF FLORIDA, LLC owns the vehicle described in Paragraph 7 of the Complaint. 4. Admit that on January 27, 2020, LAROSE EBANKS had permission and/or consent from ENTERPRISE LEASING COMPANY OF FLORIDA, LLC, to drive the vehicle described in Paragraph 7 of the Complaint. 5. Admit that on January 27,2020, ELIZABETH VICENTE did not cause the subject accident. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/16/2021 10:13:26 AM.**** 6. Admit that on January 27, 2020, ELIZABETH VICENTE did not contribute to the subject accident. 7. Admit that on January 27,2020, Plaintiff sustained a pennanent injury as a direct and proximate result of the subject accident. 8 Admit that Plaintiff'smedical treatment since the subject accident has been reasonable. 9. Admit that Plaintiff'smedical treatment since the subject accident has been necessary. 10. Admit that Plaintiffs medical treatment since the subject accident has been related to the subject accident. 11. Admit that on January 27,2020, LAROSE EBANKS negligently operated the aforedescribed vehicle so as to collide with the vehicle Plaintiffwas driving. 12. Admit that on January 27, 2020, the negligence of LAROSE EBANKS caused the aforedescribed motor vehicle accident. 13. Admit that there was nothing the Plaintiff could have done to avoid the subject accident that occurred on January 27,2020. I HEREBY CERTIFY that a true and correct copy of the foregoing served upon the Defendant, along with the Summons and Complaint filed in this cause. LAW OFFICES OF ANIDJAR& LEVINE, P.A. Counsel for Plaintiff 300 SE 17th Street Fort Lauderdale, FL 33316 Tel: (954) 525-0050/ Fax: (954) 525-0020 E-service at: By.- /s/ Peter J. Ridge PETER J. RIDGE, ESQ. FBN 114263