On June 01, 1974 a
Party Discovery
was filed
involving a dispute between
Hanedi Bashjawish,
Mohammed Bashjawish,
Rihanna Bashjawish,
Sophia Bashjawish,
and
Agathe Civil,
Geico General Insurance Company,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
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Filing # 113325175 E-Filed 09/14/2020 03:00:04 PM
1D 1M JUUIUIAL ULKUULL LN
AND FOR PALM BEACH
COUNTY, FLORIDA
Case No.: 502020CA008464 AD
MOHAMMED BASHJAWISH, HANEDI
BASHJAWISH, SOPHIA BASHJAWISH, and
RIHANNA BASHJAWISH, a minor by and
through her natural parent and guardian,
MOHAMMED BASHJAWISH,
Plaintiff(s),
Vv.
AGATHE CIVIL and GEICO GENERAL
INSURANCE COMPANY, a foreign profit
corporation,
Defendant(s).
REQUEST FOR ADMISSIONS
Defendant, GEICO General Insurance Company, by and through the undersigned
attorney and pursuant to Fla.R.Civ.P. 1.370, requests the Plaintiff, RIHANNA
BASHJAWISH, a minor by and through her natural parent and guardian, MOHAMMED
BASHJAWISH, to admit or deny the following:
1. That at the time of the subject accident, your vehicle had a seat belt which
was available for your use.
2. That you were not using the available seat belt at the time of the subject
accident.
3. That you are not aware of any defect in the operation of the available seat
belt.
4. That your failure to use the available seat belt produced or contributed to
producing at least a portion of the damage claimed by you.
5. Your failure to use the seat belt as set forth above was unreasonable under
the circumstances.
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 09/14/2020 03:00:04 PM ***6. Plaintiff received or is entitled to receive benefits under the Personal Injury
Protection portion of an automobile policy for medical bills and lost wages alleged to have
been incurred as a result of the subject accident.
7. Plaintiff received or is entitled to receive benefits under the medical
payments provisions of an automobile insurance policy for medical bills alleged to have
been incurred as a result of the subject accident.
8. Your Personal Injury Protection insurance has paid all or a portion of your
medical bills allegedly incurred as a result of the subject accident.
9. Your medical payments insurance coverage has paid all or a portion of your
medical bills allegedly incurred as a result of the subject accident.
10. Your Personal Injury Protection insurance has paid all or a portion of your
lost wages allegedly incurred as a result of the subject accident.
11. If a verdict is rendered for Plaintiff, the Defendant is entitled to a set-off for
any Personal Injury Protection and/or medical payments insurance benefits paid or payable
on behalf of the Plaintiff for medical expenses or lost wages incurred as a result of the
subject accident.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by Electronic Mail on this the 14" day of September, 2020 to the following
designated service email address(es): Collins DelPercio, Esq., Leeder Law, Pleadings
@leederlaw.com.
The Law Office of Jeffrey R. Hickman
/s Marni Adams
Marni Adams, Esq.
(Employees of GEICO General Insurance Company)
Florida Bar No. 91289
1555 Palm Beach Lakes Blvd., Ste. 1000
West Palm Beach, FL 33401
Phone: 561-689-1479 EXT. 7925
Attorney for Defendant(s): GEICO General
Insurance Company
Service Email: wpbgeico@geico.com
Document Filed Date
January 21, 2024
Case Filing Date
June 01, 1974
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Filing # 113325175 E-Filed 09/14/2020 03:00:04 PM 1D 1M JUUIUIAL ULKUULL LN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: 502020CA008464 AD MOHAMMED BASHJAWISH, HANEDI BASHJAWISH, SOPHIA BASHJAWISH, and RIHANNA BASHJAWISH, a minor by and through her natural parent and guardian, MOHAMMED BASHJAWISH, Plaintiff(s), Vv. AGATHE CIVIL and GEICO GENERAL INSURANCE COMPANY, a foreign profit corporation, Defendant(s). REQUEST FOR ADMISSIONS Defendant, GEICO General Insurance Company, by and through the undersigned attorney and pursuant to Fla.R.Civ.P. 1.370, requests the Plaintiff, RIHANNA BASHJAWISH, a minor by and through her natural parent and guardian, MOHAMMED BASHJAWISH, to admit or deny the following: 1. That at the time of the subject accident, your vehicle had a seat belt which was available for your use. 2. That you were not using the available seat belt at the time of the subject accident. 3. That you are not aware of any defect in the operation of the available seat belt. 4. That your failure to use the available seat belt produced or contributed to producing at least a portion of the damage claimed by you. 5. Your failure to use the seat belt as set forth above was unreasonable under the circumstances. *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 09/14/2020 03:00:04 PM ***6. Plaintiff received or is entitled to receive benefits under the Personal Injury Protection portion of an automobile policy for medical bills and lost wages alleged to have been incurred as a result of the subject accident. 7. Plaintiff received or is entitled to receive benefits under the medical payments provisions of an automobile insurance policy for medical bills alleged to have been incurred as a result of the subject accident. 8. Your Personal Injury Protection insurance has paid all or a portion of your medical bills allegedly incurred as a result of the subject accident. 9. Your medical payments insurance coverage has paid all or a portion of your medical bills allegedly incurred as a result of the subject accident. 10. Your Personal Injury Protection insurance has paid all or a portion of your lost wages allegedly incurred as a result of the subject accident. 11. If a verdict is rendered for Plaintiff, the Defendant is entitled to a set-off for any Personal Injury Protection and/or medical payments insurance benefits paid or payable on behalf of the Plaintiff for medical expenses or lost wages incurred as a result of the subject accident. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic Mail on this the 14" day of September, 2020 to the following designated service email address(es): Collins DelPercio, Esq., Leeder Law, Pleadings @leederlaw.com. The Law Office of Jeffrey R. Hickman /s Marni Adams Marni Adams, Esq. (Employees of GEICO General Insurance Company) Florida Bar No. 91289 1555 Palm Beach Lakes Blvd., Ste. 1000 West Palm Beach, FL 33401 Phone: 561-689-1479 EXT. 7925 Attorney for Defendant(s): GEICO General Insurance Company Service Email: wpbgeico@geico.com