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Filing # 130779905 E-Filed 07/16/2021 09:10:25 AM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT IN AND FOR CITRUS
COUNTY, FLORIDA
NORMAN L. CARTWRIGHT, til CASENO.: 2021 CA 000537 A
and COLLEEN CARTWRIGHT,
Husband and Wife,
Plaintiffs,
VS.
R. T. BROWN, INC., a Florida Profit
Corporation, d/b/a BROWN FUNERAL
HOME AND CREMATORY
And
CITRUS MEMORIAL HOSPITAL, INC.,
a Florida Profit Corporation,
Defendants.
/
PLAINTIFFS’ REQUESTS FOR ADMISSION TO DEFENDANT, R. T. BROWN, INC.
Plaintiffs, NORMAN L. CARTWRIGHT, Ill, and COLLEEN CARTWRIGHT, pursuant to Florida Rules
of Civil Procedure 1.370(a), requests that Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME
AND CREMATORY, make the following admissions in this action within forty-five (45) days from the service
of the Complaint filed herein: PLEASE NOTE THAT WHEREVER THE WORD "INCIDENT" IS USED, IT
REFERS TO THE INCIDENT MORE PARTICULARLY DESCRIBED IN THE COMPLAINT FILED HEREIN.
4, The incident alleged in the Complaint occurred in the hospital morgue of Citrus Memorial
Hospital on October 6, 2017.
2. The incident occurred at approximately 6:00 p.m., on October 6, 2017.
3. At the time of the incident, Travis Ericson was an employee of R. T. BROWN, INC.
4, At the time of the incident, Travis Ericson was acting within the course and scope of his
employment.
5. Defendant, R. T. BROWN, INC., supplied the gurney used by Travis Ericson to transport
the body described in the Complaint.6. The gurney used by Travis Ericson to transport the body described in the Complaint was
not designed to transport a human body weighing more than 300 pounds.
7. At the time of the incident, Travis Ericson knew the gurney was not designed to transport a
human body weighing more than 300 pounds.
8. The body described in the Complaint weighed more than 300 pounds.
9. Prior to attempting to transfer the body, Travis Ericson knew the body was too heavy to be
safely transported on the gurney.
10. Prior to attempting to transfer the body, Travis Ericson did not inform Plaintiff, NORMAN L.
CARTWRIGHT, Ill, that the body was too heavy to be safely transported on the gurney.
41. Prior to attempting to transfer the body, Travis Ericson knew the gurney had a mechanical
defect preventing the legs from properly extending and locking as designed.
12. Prior to attempting to transfer the body, Travis Ericson did not inform Plaintiff, NORMAN L.
CARTWRIGHT, lil, that the gurney had a mechanical defect preventing the legs from properly extending
and locking as designed.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been provided for service on
the above-named Defendant with a copy of the Compiaint.
ae
THOMAS. D-HIPPELHEUSER, ESQUIRE
Florida’ Bar No.: 0784559
tom@bcmillerlaw.com
«KAW OFFICES OF BRENT C. MILLER, P.A.
205 East Burleigh Boulevard
Tavares, FL 32778
(352) 343-7400
Fax: (352) 343-9152
litigation@bemillerlaw.com
melisa@bemillerlaw.com
Attorney for Plaintiffs
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Filing # 130779905 E-Filed 07/16/2021 09:10:25 AM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA NORMAN L. CARTWRIGHT, til CASENO.: 2021 CA 000537 A and COLLEEN CARTWRIGHT, Husband and Wife, Plaintiffs, VS. R. T. BROWN, INC., a Florida Profit Corporation, d/b/a BROWN FUNERAL HOME AND CREMATORY And CITRUS MEMORIAL HOSPITAL, INC., a Florida Profit Corporation, Defendants. / PLAINTIFFS’ REQUESTS FOR ADMISSION TO DEFENDANT, R. T. BROWN, INC. Plaintiffs, NORMAN L. CARTWRIGHT, Ill, and COLLEEN CARTWRIGHT, pursuant to Florida Rules of Civil Procedure 1.370(a), requests that Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, make the following admissions in this action within forty-five (45) days from the service of the Complaint filed herein: PLEASE NOTE THAT WHEREVER THE WORD "INCIDENT" IS USED, IT REFERS TO THE INCIDENT MORE PARTICULARLY DESCRIBED IN THE COMPLAINT FILED HEREIN. 4, The incident alleged in the Complaint occurred in the hospital morgue of Citrus Memorial Hospital on October 6, 2017. 2. The incident occurred at approximately 6:00 p.m., on October 6, 2017. 3. At the time of the incident, Travis Ericson was an employee of R. T. BROWN, INC. 4, At the time of the incident, Travis Ericson was acting within the course and scope of his employment. 5. Defendant, R. T. BROWN, INC., supplied the gurney used by Travis Ericson to transport the body described in the Complaint.6. The gurney used by Travis Ericson to transport the body described in the Complaint was not designed to transport a human body weighing more than 300 pounds. 7. At the time of the incident, Travis Ericson knew the gurney was not designed to transport a human body weighing more than 300 pounds. 8. The body described in the Complaint weighed more than 300 pounds. 9. Prior to attempting to transfer the body, Travis Ericson knew the body was too heavy to be safely transported on the gurney. 10. Prior to attempting to transfer the body, Travis Ericson did not inform Plaintiff, NORMAN L. CARTWRIGHT, Ill, that the body was too heavy to be safely transported on the gurney. 41. Prior to attempting to transfer the body, Travis Ericson knew the gurney had a mechanical defect preventing the legs from properly extending and locking as designed. 12. Prior to attempting to transfer the body, Travis Ericson did not inform Plaintiff, NORMAN L. CARTWRIGHT, lil, that the gurney had a mechanical defect preventing the legs from properly extending and locking as designed. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been provided for service on the above-named Defendant with a copy of the Compiaint. ae THOMAS. D-HIPPELHEUSER, ESQUIRE Florida’ Bar No.: 0784559 tom@bcmillerlaw.com «KAW OFFICES OF BRENT C. MILLER, P.A. 205 East Burleigh Boulevard Tavares, FL 32778 (352) 343-7400 Fax: (352) 343-9152 litigation@bemillerlaw.com melisa@bemillerlaw.com Attorney for Plaintiffs Page 2 of 2