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Filing# 136420162 E-Filed 10/12/2021 05:46:45 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL
CIRCUIT
IN
AND
FOR
BROWARD COUNTY, FLORIDA
CASE NO.: 062021 CA016576 (25)
AARON BRUNER,
Plaintiff,
V
BONNIE JUDSON,
Defendant.
DEFENDANT'S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF
COMES NOW Defendant, BONNIE JUDSON (hereinafter"Defendant"), by and
through her undersigned counsel, and hereby propounds her First Request for
Admissions to Plaintiff,AARON BRUNER, requiringthat said Request for Admissions
be answered within thirty(30) days from the date of service hereof, as follows:
1.
Admit that the injuries that you claim are a result of the accident
referenced in your Complaint pre-date and pre-existthe date of the accident.
2.
Admit that before the accident, which is referenced in your Complaint, you
sustained an injuryto the same body part(s) as the body part(s) you are alleging
injury(ies)
to in this lawsuit.
Page 1
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-
9200 - (561) 683-8977 FAX
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/12/2021 05:46:45 PM.****
CASE NO.: 062021 CA016576 (25)
3.
Admit that you have been involved in automobile accident which predates
the incident referenced in your Complaint either as a driver,passenger or pedestrian.
4.
Admit that one (1)or more of your priortreatingphysicians opined that you
sustained significantand permanent injuriesin said priormotor vehicle accident.
5.
Admit that you have been involved in an automobile accident subsequent
to the incident referenced in your Complaint either as a driver, passenger or pedestrian.
6.
Admit that one (1)or more of your priortreatingphysicians opined that you
sustained significantand permanent injuriesin said subsequent motor vehicle accident.
7.
Admit that you have been involved in one (1) or more slipand fall type or
other non-motor vehicle accidents priorto the subject accident.
8.
Admit that one (1)or more of your priortreatingphysicians opined that you
sustained significantand permanent injuriesin the priorslip and fall type or other non-
motor vehicle accident(s).
9.
Admit that you have been involved in one (1) or more slipand fall type or
other non-vehicle accident subsequent to the subject incident.
10.
Admit that one (1)or more of your priortreatingphysicians opined that you
sustained significantand permanent injuriesin the subsequent slipand fall type or other
non-motor vehicle accident(s).
11.
Admit that you were suffering from a disabilityprior to the date of the
accident that is referenced in your Complaint.
Page 2
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-
9200 - (561) 683-8977 FAX
CASE NO.: 062021 CA016576 (25)
12.
Admit that you have previously settled a claim either pre-suit or during
litigation
for personal injuryand executed a release.
13.
Admit that you do not have lost wages as a result of the accident that is
referenced in your Complaint.
14.
Admit that you do not have a loss of earning capacity as a result of the
accident that is referenced in your Complaint.
15.
Admit that you do not have any out of pocket expenses as a result of the
accident that is referenced in your Complaint.
16.
Admit that you have private health insurance coverage through some
source that would provide coverages for the damages that you are seeking in this
lawsuit.
17.
Admit that you have received other benefits through a collateral source
provider, including but not limited to worker's compensation, social security or
Medicaid/Medicare for all or a portion of the damages you allege resulted from the
incident referenced in the Complaint.
18.
Admit that no medical provider has expressed a medical opinion that you
have sustained a permanent injuryas a result of the subject accident.
19.
Admit that you received no permanent and/or significantscarring as a
result of the subject accident.
20.
Admit that you were not gainfully employed at the time of the subject
accident.
Page 3
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-
9200 - (561) 683-8977 FAX
CASE NO.: 062021 CA016576 (25)
21.
Admit that you did not lose any wages or income as a result of the subject
accident.
22.
Admit your earning capacity was not reduced or impaired as a result of the
subject accident.
23.
Admit that you have a priorfelony conviction.
24.
Admit that you have a prior conviction involving dishonesty or false
statement.
25.
Admit that you have turned down work that you were physically able to
perform since the date of the subject accident.
26.
Admit that your current employer is willingto pay you as if you had not
been injured.
27.
Admit that your normal physical activities were impaired at the time of the
subject accident.
28.
Admit that you had been drinking alcohol and/or drugs/medications within
six (6) hours priorto the subject accident.
29.
Admit that you have made one or more worker's compensation claims
during your lifetime.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of October, 2021, a true and correct
copy of the foregoing was filed with the Clerk of Broward County by using the Florida
Court's E-Filing Portal, which will send an automatic e-mail message to the following
Page 4
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-
9200 - (561) 683-8977 FAX
CASE NO.: 062021 CA016576 (25)
parties registered with the E-Filing Portal system:
Vincent Duffy, Esq., Goldman &
Daszkal, P.A., service.duffy@gdinjurylaw.com; jfontaine@gdinjurylaw.com, 1630 West
Hillsboro Boulevard, Deerfield Beach, FL 33442, (954) 428-9333/(954) 428-9338 (F),
Attorney for Plaintiff.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant
Esperante Building
222 Lakeview Avenue, Suite 120
West Palm Beach, Florida 33401
Telephone (561) 383-9262
Facsimile (561) 683-8977
Primary brian.pita@csklegal.corn
Secondary cassandra.pierre@csklegal.corn
Alternate: kristin.miller@csklegal.com
By:
s/ Brian S. Pita
BRIAN S. PITA
Florida Bar No.- 41903
CASSANDRA PIERRE
Florida Bar No.: 127410
Page 5
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-
9200 - (561) 683-8977 FAX
Preview
Filing# 136420162 E-Filed 10/12/2021 05:46:45 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: 062021 CA016576 (25) AARON BRUNER, Plaintiff, V BONNIE JUDSON, Defendant. DEFENDANT'S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF COMES NOW Defendant, BONNIE JUDSON (hereinafter"Defendant"), by and through her undersigned counsel, and hereby propounds her First Request for Admissions to Plaintiff,AARON BRUNER, requiringthat said Request for Admissions be answered within thirty(30) days from the date of service hereof, as follows: 1. Admit that the injuries that you claim are a result of the accident referenced in your Complaint pre-date and pre-existthe date of the accident. 2. Admit that before the accident, which is referenced in your Complaint, you sustained an injuryto the same body part(s) as the body part(s) you are alleging injury(ies) to in this lawsuit. Page 1 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383- 9200 - (561) 683-8977 FAX *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/12/2021 05:46:45 PM.**** CASE NO.: 062021 CA016576 (25) 3. Admit that you have been involved in automobile accident which predates the incident referenced in your Complaint either as a driver,passenger or pedestrian. 4. Admit that one (1)or more of your priortreatingphysicians opined that you sustained significantand permanent injuriesin said priormotor vehicle accident. 5. Admit that you have been involved in an automobile accident subsequent to the incident referenced in your Complaint either as a driver, passenger or pedestrian. 6. Admit that one (1)or more of your priortreatingphysicians opined that you sustained significantand permanent injuriesin said subsequent motor vehicle accident. 7. Admit that you have been involved in one (1) or more slipand fall type or other non-motor vehicle accidents priorto the subject accident. 8. Admit that one (1)or more of your priortreatingphysicians opined that you sustained significantand permanent injuriesin the priorslip and fall type or other non- motor vehicle accident(s). 9. Admit that you have been involved in one (1) or more slipand fall type or other non-vehicle accident subsequent to the subject incident. 10. Admit that one (1)or more of your priortreatingphysicians opined that you sustained significantand permanent injuriesin the subsequent slipand fall type or other non-motor vehicle accident(s). 11. Admit that you were suffering from a disabilityprior to the date of the accident that is referenced in your Complaint. Page 2 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383- 9200 - (561) 683-8977 FAX CASE NO.: 062021 CA016576 (25) 12. Admit that you have previously settled a claim either pre-suit or during litigation for personal injuryand executed a release. 13. Admit that you do not have lost wages as a result of the accident that is referenced in your Complaint. 14. Admit that you do not have a loss of earning capacity as a result of the accident that is referenced in your Complaint. 15. Admit that you do not have any out of pocket expenses as a result of the accident that is referenced in your Complaint. 16. Admit that you have private health insurance coverage through some source that would provide coverages for the damages that you are seeking in this lawsuit. 17. Admit that you have received other benefits through a collateral source provider, including but not limited to worker's compensation, social security or Medicaid/Medicare for all or a portion of the damages you allege resulted from the incident referenced in the Complaint. 18. Admit that no medical provider has expressed a medical opinion that you have sustained a permanent injuryas a result of the subject accident. 19. Admit that you received no permanent and/or significantscarring as a result of the subject accident. 20. Admit that you were not gainfully employed at the time of the subject accident. Page 3 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383- 9200 - (561) 683-8977 FAX CASE NO.: 062021 CA016576 (25) 21. Admit that you did not lose any wages or income as a result of the subject accident. 22. Admit your earning capacity was not reduced or impaired as a result of the subject accident. 23. Admit that you have a priorfelony conviction. 24. Admit that you have a prior conviction involving dishonesty or false statement. 25. Admit that you have turned down work that you were physically able to perform since the date of the subject accident. 26. Admit that your current employer is willingto pay you as if you had not been injured. 27. Admit that your normal physical activities were impaired at the time of the subject accident. 28. Admit that you had been drinking alcohol and/or drugs/medications within six (6) hours priorto the subject accident. 29. Admit that you have made one or more worker's compensation claims during your lifetime. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 12th day of October, 2021, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Court's E-Filing Portal, which will send an automatic e-mail message to the following Page 4 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383- 9200 - (561) 683-8977 FAX CASE NO.: 062021 CA016576 (25) parties registered with the E-Filing Portal system: Vincent Duffy, Esq., Goldman & Daszkal, P.A., service.duffy@gdinjurylaw.com; jfontaine@gdinjurylaw.com, 1630 West Hillsboro Boulevard, Deerfield Beach, FL 33442, (954) 428-9333/(954) 428-9338 (F), Attorney for Plaintiff. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant Esperante Building 222 Lakeview Avenue, Suite 120 West Palm Beach, Florida 33401 Telephone (561) 383-9262 Facsimile (561) 683-8977 Primary brian.pita@csklegal.corn Secondary cassandra.pierre@csklegal.corn Alternate: kristin.miller@csklegal.com By: s/ Brian S. Pita BRIAN S. PITA Florida Bar No.- 41903 CASSANDRA PIERRE Florida Bar No.: 127410 Page 5 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383- 9200 - (561) 683-8977 FAX