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wes CASE NUMBER: 502020CA008922XXXXMB Div: AD ****
Filing # 112166357 E-Filed 08/21/2020 09:08:35 AM
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY
ERNESTINA DE ARMAS; AND MARIO SALVADOR DE
ARMAS,
ve
Plaintiffs,
CHARLIE WILL MITCHELL; AND PROGRESSIVE CIVIL DIVISION
AMERICAN INSURANCE COMPANY,
undarcianad eouncal and nurcuant to Bula 1270 Elarida Bulac af 7
UnGeSigece COunse: anu pursuant to MWC 2.97u, rtoruG NuCS OF
CASE NO.:
Defendants.
PLAINTIFFS’, REQUEST FOR ADMISSIONS TO
DEFENDANT, PROGRESSIVE AMERICAN INSURANCE COMPANY
Plaintiffs, ERNESTINA DE ARMAS AND MARIO SALVADOR DE ARMAS, by and through the
Draradura raniacte that
PrOceaure, requests Uae
Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, admit or deny the following:
1.
i)
ga
PROGRESSIVE AMERICAN INSURANCE COMPANY has been properly named in the
Complaint (i.e., the complaint contains the name of the proper entity to be sued).
PDNEDCCCNIC ARACDICAN INCHIDANCE CANADANVY hac haan nranarhs canind
FRUURLSIVE AIVIKAILAN INSGURAINRE CUIVIFAT mas ocen propeny Servea
Summons and Complaint.
This matter has been filed within the statute of limitations.
Venue is proper in Palm Beach County, Florida.
Dininsifl CANICOTINA KE ARRARE wine iminhind In a mntaes
FIGHT, CAINCONINA UC ANIVIAS, WaS 1iVOIVEU I a MOOT Ve
vehicle owned by CHARLIE WILL MITCHELL on April 14, 2019.
th thn mntae
TU HE MOLT
Plaintiff, MARIO SALVADOR DE ARMAS, was involved in a motor vehicle collision with the
motor vehicle owned by Defendant, CHARLIE WILL MITCHELL, on April 14, 2019.
Plaintiff, ERNESTINA DE ARMAS, was injured as a result of the April 14, 2019 collision.
CHEN. DAIAARCACU AAIINTY Cl CHADAND ANFY FILED nain4ainnon na-na.2c An
PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Yule eu Ug.uU.u9 mvt10.
11.
12.
13.
14.
15.
16.
17.
18.
Plaintiff, MARIO SALVADOR DE ARMAS, was injured as a result of the April 14, 2019
collision.
Defendant, CHARLIE WILL MITCHELL had a duty to operate his vehicle in a reasonably safe
manner at all times on April 14, 2019.
On April 14, 2019, Defendant, CHARLIE WILL MITCHELL breached his duty to operate his
vehicle in a reasonably safe manner.
The negligence of Defendant, CHARLIE WILL MITCHELL, was the sole cause of the April 14,
2019 collision.
There was no negligence on the part of the Plaintiff, MARIO SALVADOR DE ARMAS, that
contributed to the cause of the April 14, 2019 collision.
PROGRESSIVE AMERICAN INSURANCE COMPANY is liable for damages to Plaintiff, MARIO
SALVADOR DE ARMAS, resulting from the April 14, 2019 collision.
Plaintiff, MARIO SALVADOR DE ARMAS, is entitled to uninsured/under insured motor
benefits from Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, resulting
from the April 14, 2019 collision.
Plaintiff, MARIO SALVADOR DE ARMAS, has met all prerequisites to entitle him to
uninsured/under insured motor benefits from Defendant, PROGRESSIVE AMERICAN
INSURANCE COMPANY, resulting from the April 14, 2019 collision.
PROGRESSIVE AMERICAN INSURANCE COMPANY is liable for damages to Plaintiff,
ERNESTINA DE ARMAS, resulting from the April 14, 2019 collision.
Plaintiff, ERNESTINA DE ARMAS, is entitled to uninsured/under insured motor benefits
from Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, resulting from the
April 14, 2019 collision.
Plaintiff, ERNESTINA DE ARMAS, has met all prerequisites to entitle her to
uninsured/under insured motor benefits from Defendant, PROGRESSIVE AMERICAN
INSURANCE COMPANY, resulting from the April 14, 2019 collision.| HEREBY CERTIFY that a true and correct copy of the foregoing was attached to the
Complaint and Summons and served to the Defendant, PROGRESSIVE AMERICAN INSURANCE
COMPANY.
Dated: August 21, 2020.
Ruinewerriart avr on
KUDEINDICIN LAW, F.A.
Attorneys for Plaintiff
250 S. Australian Avenue, Suite 1000
West Palm Beach, FL 33401
Tel: (561) LAW-FIRM
Fax: 954-515-5796
Email: Tim@rubensteiniaw.com
jmolano@Rubensteinlaw.com
eservice@rubensteinlaw.com
By: /s/ R. Timothy Vannatta
R. TIMOTHY VANNATTA
Clarida Dar Ma. Anccoan
FiUrua Dal INU.. UUs507U
Preview
wes CASE NUMBER: 502020CA008922XXXXMB Div: AD **** Filing # 112166357 E-Filed 08/21/2020 09:08:35 AM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY ERNESTINA DE ARMAS; AND MARIO SALVADOR DE ARMAS, ve Plaintiffs, CHARLIE WILL MITCHELL; AND PROGRESSIVE CIVIL DIVISION AMERICAN INSURANCE COMPANY, undarcianad eouncal and nurcuant to Bula 1270 Elarida Bulac af 7 UnGeSigece COunse: anu pursuant to MWC 2.97u, rtoruG NuCS OF CASE NO.: Defendants. PLAINTIFFS’, REQUEST FOR ADMISSIONS TO DEFENDANT, PROGRESSIVE AMERICAN INSURANCE COMPANY Plaintiffs, ERNESTINA DE ARMAS AND MARIO SALVADOR DE ARMAS, by and through the Draradura raniacte that PrOceaure, requests Uae Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, admit or deny the following: 1. i) ga PROGRESSIVE AMERICAN INSURANCE COMPANY has been properly named in the Complaint (i.e., the complaint contains the name of the proper entity to be sued). PDNEDCCCNIC ARACDICAN INCHIDANCE CANADANVY hac haan nranarhs canind FRUURLSIVE AIVIKAILAN INSGURAINRE CUIVIFAT mas ocen propeny Servea Summons and Complaint. This matter has been filed within the statute of limitations. Venue is proper in Palm Beach County, Florida. Dininsifl CANICOTINA KE ARRARE wine iminhind In a mntaes FIGHT, CAINCONINA UC ANIVIAS, WaS 1iVOIVEU I a MOOT Ve vehicle owned by CHARLIE WILL MITCHELL on April 14, 2019. th thn mntae TU HE MOLT Plaintiff, MARIO SALVADOR DE ARMAS, was involved in a motor vehicle collision with the motor vehicle owned by Defendant, CHARLIE WILL MITCHELL, on April 14, 2019. Plaintiff, ERNESTINA DE ARMAS, was injured as a result of the April 14, 2019 collision. CHEN. DAIAARCACU AAIINTY Cl CHADAND ANFY FILED nain4ainnon na-na.2c An PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Yule eu Ug.uU.u9 mvt10. 11. 12. 13. 14. 15. 16. 17. 18. Plaintiff, MARIO SALVADOR DE ARMAS, was injured as a result of the April 14, 2019 collision. Defendant, CHARLIE WILL MITCHELL had a duty to operate his vehicle in a reasonably safe manner at all times on April 14, 2019. On April 14, 2019, Defendant, CHARLIE WILL MITCHELL breached his duty to operate his vehicle in a reasonably safe manner. The negligence of Defendant, CHARLIE WILL MITCHELL, was the sole cause of the April 14, 2019 collision. There was no negligence on the part of the Plaintiff, MARIO SALVADOR DE ARMAS, that contributed to the cause of the April 14, 2019 collision. PROGRESSIVE AMERICAN INSURANCE COMPANY is liable for damages to Plaintiff, MARIO SALVADOR DE ARMAS, resulting from the April 14, 2019 collision. Plaintiff, MARIO SALVADOR DE ARMAS, is entitled to uninsured/under insured motor benefits from Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, resulting from the April 14, 2019 collision. Plaintiff, MARIO SALVADOR DE ARMAS, has met all prerequisites to entitle him to uninsured/under insured motor benefits from Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, resulting from the April 14, 2019 collision. PROGRESSIVE AMERICAN INSURANCE COMPANY is liable for damages to Plaintiff, ERNESTINA DE ARMAS, resulting from the April 14, 2019 collision. Plaintiff, ERNESTINA DE ARMAS, is entitled to uninsured/under insured motor benefits from Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, resulting from the April 14, 2019 collision. Plaintiff, ERNESTINA DE ARMAS, has met all prerequisites to entitle her to uninsured/under insured motor benefits from Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY, resulting from the April 14, 2019 collision.| HEREBY CERTIFY that a true and correct copy of the foregoing was attached to the Complaint and Summons and served to the Defendant, PROGRESSIVE AMERICAN INSURANCE COMPANY. Dated: August 21, 2020. Ruinewerriart avr on KUDEINDICIN LAW, F.A. Attorneys for Plaintiff 250 S. Australian Avenue, Suite 1000 West Palm Beach, FL 33401 Tel: (561) LAW-FIRM Fax: 954-515-5796 Email: Tim@rubensteiniaw.com jmolano@Rubensteinlaw.com eservice@rubensteinlaw.com By: /s/ R. Timothy Vannatta R. TIMOTHY VANNATTA Clarida Dar Ma. Anccoan FiUrua Dal INU.. UUs507U