On July 16, 2021 a
Party Discovery
was filed
involving a dispute between
and
for OTHER NEGLIGENCE
in the District Court of Citrus County.
Preview
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, Ill CASE NO.: 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, CITRUS MEMORIAL HOSPITAL, INC.
Plaintiffs, NORMAN L. CARTWRIGHT, fil, and COLLEEN CARTWRIGHT, pursuant to Florida Rules
of Civil Procedure 1.370(a), request that Defendant, CITRUS MEMORIAL HOSPITAL, INC, 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.
1. 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, Sam Saldana was an employee of CITRUS MEMORIAL
HOSPITAL, INC.
4. At the time of the incident, Sam Saldana was acting within the course and scope of his
employment.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 Complaint.
“ NASD: IPPELHEUSER, ESQUIRE
Flosida Bar No.: 0784559
_lom@bemitierlaw.com
LAW 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@bcmillerlaw.com
Attorney for Plaintiffs
Page 2 of 2
Document Filed Date
July 16, 2021
Case Filing Date
July 16, 2021
Category
OTHER NEGLIGENCE
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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, Ill CASE NO.: 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, CITRUS MEMORIAL HOSPITAL, INC. Plaintiffs, NORMAN L. CARTWRIGHT, fil, and COLLEEN CARTWRIGHT, pursuant to Florida Rules of Civil Procedure 1.370(a), request that Defendant, CITRUS MEMORIAL HOSPITAL, INC, 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. 1. 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, Sam Saldana was an employee of CITRUS MEMORIAL HOSPITAL, INC. 4. At the time of the incident, Sam Saldana was acting within the course and scope of his employment.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 Complaint. “ NASD: IPPELHEUSER, ESQUIRE Flosida Bar No.: 0784559 _lom@bemitierlaw.com LAW 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@bcmillerlaw.com Attorney for Plaintiffs Page 2 of 2