On March 31, 2017 a
Party Discovery
was filed
involving a dispute between
and
for AUTO NEGLIGENCE
in the District Court of Citrus County.
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Filing # 57057995 E-Filed 05/30/2017 04:50:20 PM.
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
MEGAN ALEXANDER,
Plaintiff,
v. Case No./Division: 2017-CA-000276-A
ASHLEY MAE KAVANAUGH
Defendant. /
DEFENDANT'S REQUEST FOR ADMISSIONS
Plaintiff, Megan Alexander, is requested to admit or deny the following allegations pursuant
to the Florida Rules of Civil Procedure:
1. At the time of the accident that is the subject of this lawsuit, the vehicle in which you were
riding had a fully operational seatbelt that was readily available for your use.
2. At the time of the accident that is the subject of this lawsuit, the vehicle in which you were
riding had a fully operational shoulder harness that was readily available for your use.
3. You were not wearing a seatbelt at the time of this accident.
4. Your failure to use a seatbelt produced or contributed to at least a portion of your
claimed injuries or damages.
5. Your claim is subject to the provisions of the "Florida Vehicle No-Fault Law".
6. You have or had available No-Fault/PIP benefits paid or payable toward your claims
for medical bills and/or wage losses.
7. You have exhausted your No-Fault/PIP benefits.
8. All PIP and/or medical payments coverage paid or payable for bills/losses incurred up to the
time of trial are properly characterized as collateral sources, to be set off against any jury
award for past medical expenses and past wage losses.
9. You did not incur any lost wages as a result of the accident, which is the subject matter of
this lawsuit.10. You did not incur any loss of earning capacity as a result of the accident, which is the
subject matter of this lawsuit.
11. All or part of your medical bills incurred to date have been paid or are payable by your No-
Fault benefits.
12. All or part of your lost wages incurred to date have been paid or are payable by your
available No-Fault benefits.
13. You did not sustain a "threshold" injury, as defined by the Florida Motor Vehicle No-Fault
Law, in the incident alleged in your complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Electronic Mail on this the 30th day of May, 2017 to the following designated service email
addresses: Michael C. Peckham, Esq., Schwed, Adams, Sobel & McGinley, P.A.,
eservice@schwedlawfirm.com, MPeckham@schwedlawfirm.com.
Law Office of Ellen H. Ehrenpreis
/s/ Rachel Leach
Rachel Leach, Esq.
(Employees of GEICO General Insurance Company)
Florida Bar No.: 190438
4300 West Cypress Street, Suite 500
Tampa, FL 33607
Phone: 813-373-7814
Facsimile: (813) 288-1699
Attorney for Defendant Ashley Mae Kavanaugh
Service Email: tampageico@geico.com
Document Filed Date
May 30, 2017
Case Filing Date
March 31, 2017
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Filing # 57057995 E-Filed 05/30/2017 04:50:20 PM. IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION MEGAN ALEXANDER, Plaintiff, v. Case No./Division: 2017-CA-000276-A ASHLEY MAE KAVANAUGH Defendant. / DEFENDANT'S REQUEST FOR ADMISSIONS Plaintiff, Megan Alexander, is requested to admit or deny the following allegations pursuant to the Florida Rules of Civil Procedure: 1. At the time of the accident that is the subject of this lawsuit, the vehicle in which you were riding had a fully operational seatbelt that was readily available for your use. 2. At the time of the accident that is the subject of this lawsuit, the vehicle in which you were riding had a fully operational shoulder harness that was readily available for your use. 3. You were not wearing a seatbelt at the time of this accident. 4. Your failure to use a seatbelt produced or contributed to at least a portion of your claimed injuries or damages. 5. Your claim is subject to the provisions of the "Florida Vehicle No-Fault Law". 6. You have or had available No-Fault/PIP benefits paid or payable toward your claims for medical bills and/or wage losses. 7. You have exhausted your No-Fault/PIP benefits. 8. All PIP and/or medical payments coverage paid or payable for bills/losses incurred up to the time of trial are properly characterized as collateral sources, to be set off against any jury award for past medical expenses and past wage losses. 9. You did not incur any lost wages as a result of the accident, which is the subject matter of this lawsuit.10. You did not incur any loss of earning capacity as a result of the accident, which is the subject matter of this lawsuit. 11. All or part of your medical bills incurred to date have been paid or are payable by your No- Fault benefits. 12. All or part of your lost wages incurred to date have been paid or are payable by your available No-Fault benefits. 13. You did not sustain a "threshold" injury, as defined by the Florida Motor Vehicle No-Fault Law, in the incident alleged in your complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic Mail on this the 30th day of May, 2017 to the following designated service email addresses: Michael C. Peckham, Esq., Schwed, Adams, Sobel & McGinley, P.A., eservice@schwedlawfirm.com, MPeckham@schwedlawfirm.com. Law Office of Ellen H. Ehrenpreis /s/ Rachel Leach Rachel Leach, Esq. (Employees of GEICO General Insurance Company) Florida Bar No.: 190438 4300 West Cypress Street, Suite 500 Tampa, FL 33607 Phone: 813-373-7814 Facsimile: (813) 288-1699 Attorney for Defendant Ashley Mae Kavanaugh Service Email: tampageico@geico.com