On May 26, 2021 a
Party Discovery
was filed
involving a dispute between
Bastianelli, Lola,
Berrabi, Stephanie,
and
Rudder, Jason R,
for Auto Negligence
in the District Court of Broward County.
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Filing # 128919377 E-Filed 06/17/2021 12:31:53 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
Case No.:
CACE21-010539
Division:
LOLA BASTIANELLI AND
STEPHANIE BERRABI,
Plaintiffs,
V
JASON R. RUDDER,
Defendant.
i
DEFENDANT'SREQUEST FOR ADMISSIONS
Plaintiff, STEPHANIE BERRABI, 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 availablefor your use.
2.
You were not wearing a seatbelt at the time ofthis accident.
3. Your failure to use a seatbelt produced or contributed to at least a portion of your claimed
injuries or damages.
4.
Your claim is subject to the provisionsofthe "Florida Vehicle No-Fault Law".
5.
You have or had available No-Fault/PIP benefits paid or payable toward your claims for
medical bills and/or wage losses.
6.
You have exhausted your No-Fault/PIPbenefits.
7.
All PIP and/or medical payments coverage paid or payable for bills/lossesincurredup 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.
8.
You did not incur any lost wages as a result ofthe accident,which is the subject matter ofthis
lawsuit.
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/17/2021 12:31:52 AM.****
9.
You did not incur any loss ofearning capacity as a result ofthe accident,whichis the subject
matter ofthis lawsuit.
10. All or part ofyour medical bills incurred to date have been paid or are payable by your No-
Fault benefits.
11. All or part ofyour lost wages incurredto date have been paid or are payableby your available
No-Fault benefits.
12. 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 15th day of June, 2021 to the following designated service email
address(est Thomas H. Leeder, Esq.,
The Law Office of George L. Cimballa, III
Sonia Mardarewich,Esq.
Sonia Mardarewich,Esq.
(Employees of GEICO General Insurance Company)
FloridaBar No.. 108358
600 N. Pine Island Road, STE 400
Plantation,Florida 33324
Phone: 954-472-6585
Facsimile: 954-472-6586
Attorney for Defendant(s) Jason Rudder
Service Email:
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Preview
Filing # 128919377 E-Filed 06/17/2021 12:31:53 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE21-010539 Division: LOLA BASTIANELLI AND STEPHANIE BERRABI, Plaintiffs, V JASON R. RUDDER, Defendant. i DEFENDANT'SREQUEST FOR ADMISSIONS Plaintiff, STEPHANIE BERRABI, 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 availablefor your use. 2. You were not wearing a seatbelt at the time ofthis accident. 3. Your failure to use a seatbelt produced or contributed to at least a portion of your claimed injuries or damages. 4. Your claim is subject to the provisionsofthe "Florida Vehicle No-Fault Law". 5. You have or had available No-Fault/PIP benefits paid or payable toward your claims for medical bills and/or wage losses. 6. You have exhausted your No-Fault/PIPbenefits. 7. All PIP and/or medical payments coverage paid or payable for bills/lossesincurredup 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. 8. You did not incur any lost wages as a result ofthe accident,which is the subject matter ofthis lawsuit. *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/17/2021 12:31:52 AM.**** 9. You did not incur any loss ofearning capacity as a result ofthe accident,whichis the subject matter ofthis lawsuit. 10. All or part ofyour medical bills incurred to date have been paid or are payable by your No- Fault benefits. 11. All or part ofyour lost wages incurredto date have been paid or are payableby your available No-Fault benefits. 12. 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 15th day of June, 2021 to the following designated service email address(est Thomas H. Leeder, Esq., The Law Office of George L. Cimballa, III Sonia Mardarewich,Esq. Sonia Mardarewich,Esq. (Employees of GEICO General Insurance Company) FloridaBar No.. 108358 600 N. Pine Island Road, STE 400 Plantation,Florida 33324 Phone: 954-472-6585 Facsimile: 954-472-6586 Attorney for Defendant(s) Jason Rudder Service Email: