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Filing # 127608416 E-Filed 05/26/2021 04:13:58 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
RICHARD SZENTMIKLOSY
Plaintiff
wv
CASE NO: CACE2107771
KAREN OR BERDUGO and YOAV ELIE CIVIL DIVISION
SAFFAR
Defendant
/
REQUEST FOR ADMISSIONS TO PLAINTIFF, RICHARD SZENTMIKLOSY
Defendants, KEREN OR BERDUGO AND YOAV ELIE SAFFAR, by and through the
undersigned. counsel, pursuant to Florida Rule of Civil Procedure 1.370, request the Plaintiff,
RICHARD SZENTMIKLOSY, to admit in this action, that each of the following statements are
true:
1. Plaintiff received benefits from a collateral source, as defined by Florida
Statute 627.736 or Florida Statute 768.76, for medical bills alleged to have been incurred as a result
of the incident described in the Complaint.
2. Plaintiff is entitled to receive benefits from a collateral source, as defined by Florida
Statute 627.736 of Florida Statute 768.76, for medical bills alleged to have been incurred as a result
of the incident described in the Complaint.
3. Plaintiff received benefits from a collateral source, as defined by Florida
Statute 627.736 or Florida Statute 768.76, for loss of wages or income, alleged to have been
sustained as a result of the incident described in the Complaint.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/26/2021 04:13:57 PM.****Case No: CACE1007771
4. Plaintiffis entitled to receive benefits from a collateral source, as defined by Florida
Statute 627.736 or Florida Statute 768.76, for loss of wages or income, alleged to have been
sustained as a result of the incident described in the Complaint.
5. Plaintiff received benefits under the Personal Injury Protection portion of an
automobile policy for medical bills alleged to have been incurred as a result of the incident
described in the Complaint.
6. Plaintiff is entitled to receive benefits under the Personal Injury Protection portion
of an automobile policy for medical bills alleged to have been incurred as a result of the incident
described in the Complaint.
7. Plaintiff received benefits under the Personal Injury Protection portion of the
automobile insurance policy for loss of wages or income alleged to have been sustained as a result
of the incident described in the Complaint.
8. Plaintiff is entitled to receive benefits under the Personal Injury Protection portion
of the automobile insurance policy for loss of wages or income alleged to have been sustained as
a result of the incident described in the Complaint.
9. Plaintiff received benefits under the medical payments provisions of an automobile
insurance policy for medical bills alleged to have been incurred as a result of the incident described
in the Complaint.
10. _ Plaintiffis 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
incident described in the Complaint.
11. Plaintiff is subject to a deductible under the Personal Injury Protection portion of
an automobile insurance policy.Case No: CACE1007771
12. Plaintiff received benefits pursuant to a personal or group health insurance policy
or policies, for medical bills alleged to have been incurred as a result of the incident described in
the Complaint.
13. Plaintiff is entitled to receive benefits pursuant to a personal or group health
insurance policy or policies, for medical bills alleged to have been incurred as a result of the
incident described in the Complaint.
14. Plaintiff received benefits pursuant to a personal or group wage continuation plan
or policy, for loss of wages or income alleged to have been sustained as a result of the incident
described in the Complaint.
15. Plaintiff is entitled to receive benefits pursuant to a personal or group wage
continuation plan or policy, for loss of wages or income alleged to have been sustained as a result
of the incident described in the Complaint.
16. Plaintiff, at the time and place of the incident described in the Complaint, had
available a functional and operational seat belt/shoulder harness restraint system.
17. Plaintiff, at the time and place of the incident described in the Complaint was not
using the available functional and operational seat belt/shoulder harness restraint system.
18. Plaintiff's use of the available functional and operational seat belt/shoulder harness
restraint system, at the time and place of the incident described in the Complaint, would have
prevented or lessened the injury and damage alleged by the Plaintiff.
19. This action is subject to the Florida Motor Vehicle No-Fault Law, Florida Statute
Sections 627.730 - 627.7405.
20. At the time and place of the incident described in the Complaint, Plaintiff complied
with the provisions and security requirements set forth in Florida Statute 627.733.Case No: CACE1007771
21. Plaintiff is an insured person under the Personal Injury Protection portion of an
automobile insurance policy which was in force on the date of the incident described in the
Complaint which provides payment of benefits of eighty (80%) percent of all reasonable and
necessary medical expenses incurred and sixty (60%) percent of loss of income or earning capacity
from inability to work as a result of the injury sustained from the incident described in the
Complaint to a maximum of Ten Thousand Dollars ($10,000.00).
22. Asa result of the collision which is the subjective of this litigation you were not
permanently injured.
23. One or more of your medical providers has a letter of protection in their favor, for
your care and/or treatment, as a result of the incident which is the subject matter of the above
captioned matter.
24. Prior to the date of the motor vehicle accident, which is the subject of this lawsuit,
Plaintiff has suffered from the same injuries and/or conditions for which he is claiming in this
matter.
25. Prior to the date of the motor vehicle accident, which is the subject of this lawsuit,
Plaintiff was assigned a permanent impairment rating by a physician.
26. Prior to the date of the motor vehicle accident, which is the subject of this lawsuit,
Plaintiff has been involved in a motor vehicle accident in which he injured the same parts of his
body for which he is claiming injury in this matter.
27. Prior to the date of the motor vehicle accident, which is the subject of this lawsuit,
Plaintiff has made a claim and/or filed a lawsuit for the same injuries and/or conditions for which
he is claiming in this matter.Case No: CACE1007771
28. After the date of the motor vehicle accident, which is the subject of this lawsuit,
Plaintiff has been involved in a motor vehicle accident in which he injured the same parts of his
body for which he is claiming injury in this matter.
29. After the date of the motor vehicle accident, which is the subject of this lawsuit,
Plaintiff has made a claim and/or filed a lawsuit for the same injuries and/or conditions for which
he is claiming in this matter.
CERTIFICATE OF SERVICE
I] HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished via E-Mail on May 26, 2021 to Stephanie Taylor, Esq., THOMPSON LEGAL P.A.,
Attorney for Plaintiff, Richard Szentmiklosy, Pleadings@ThompsonlegalFL.com, (954) 510-
3366/(954) 944-1888 (F).
Law Offices of Michael W. Carroll
Attorneys for Defendants
3230 West Commercial Blvd., Suite 400
Fort Lauderdale, FL 33309
(954) 903-6575 (Asst.)/(954) 903-6609 (Direct)
Fax: (866) 841-8921
SERVICE DESIGNATIONS:
Primary: FtLauderdaleHC@Progressive.com
Secondary: ecacacel@Progressive.com
Cake Crewe
By:
“EMILIO CACACE, ESQUIRE
Florida Bar No. 63848
“Salaried Employees of Progressive Casualty Insurance Company”
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Filing # 127608416 E-Filed 05/26/2021 04:13:58 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RICHARD SZENTMIKLOSY Plaintiff wv CASE NO: CACE2107771 KAREN OR BERDUGO and YOAV ELIE CIVIL DIVISION SAFFAR Defendant / REQUEST FOR ADMISSIONS TO PLAINTIFF, RICHARD SZENTMIKLOSY Defendants, KEREN OR BERDUGO AND YOAV ELIE SAFFAR, by and through the undersigned. counsel, pursuant to Florida Rule of Civil Procedure 1.370, request the Plaintiff, RICHARD SZENTMIKLOSY, to admit in this action, that each of the following statements are true: 1. Plaintiff received benefits from a collateral source, as defined by Florida Statute 627.736 or Florida Statute 768.76, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 2. Plaintiff is entitled to receive benefits from a collateral source, as defined by Florida Statute 627.736 of Florida Statute 768.76, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 3. Plaintiff received benefits from a collateral source, as defined by Florida Statute 627.736 or Florida Statute 768.76, for loss of wages or income, alleged to have been sustained as a result of the incident described in the Complaint. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/26/2021 04:13:57 PM.****Case No: CACE1007771 4. Plaintiffis entitled to receive benefits from a collateral source, as defined by Florida Statute 627.736 or Florida Statute 768.76, for loss of wages or income, alleged to have been sustained as a result of the incident described in the Complaint. 5. Plaintiff received benefits under the Personal Injury Protection portion of an automobile policy for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 6. Plaintiff is entitled to receive benefits under the Personal Injury Protection portion of an automobile policy for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 7. Plaintiff received benefits under the Personal Injury Protection portion of the automobile insurance policy for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 8. Plaintiff is entitled to receive benefits under the Personal Injury Protection portion of the automobile insurance policy for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 9. Plaintiff received benefits under the medical payments provisions of an automobile insurance policy for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 10. _ Plaintiffis 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 incident described in the Complaint. 11. Plaintiff is subject to a deductible under the Personal Injury Protection portion of an automobile insurance policy.Case No: CACE1007771 12. Plaintiff received benefits pursuant to a personal or group health insurance policy or policies, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 13. Plaintiff is entitled to receive benefits pursuant to a personal or group health insurance policy or policies, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 14. Plaintiff received benefits pursuant to a personal or group wage continuation plan or policy, for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 15. Plaintiff is entitled to receive benefits pursuant to a personal or group wage continuation plan or policy, for loss of wages or income alleged to have been sustained as a result of the incident described in the Complaint. 16. Plaintiff, at the time and place of the incident described in the Complaint, had available a functional and operational seat belt/shoulder harness restraint system. 17. Plaintiff, at the time and place of the incident described in the Complaint was not using the available functional and operational seat belt/shoulder harness restraint system. 18. Plaintiff's use of the available functional and operational seat belt/shoulder harness restraint system, at the time and place of the incident described in the Complaint, would have prevented or lessened the injury and damage alleged by the Plaintiff. 19. This action is subject to the Florida Motor Vehicle No-Fault Law, Florida Statute Sections 627.730 - 627.7405. 20. At the time and place of the incident described in the Complaint, Plaintiff complied with the provisions and security requirements set forth in Florida Statute 627.733.Case No: CACE1007771 21. Plaintiff is an insured person under the Personal Injury Protection portion of an automobile insurance policy which was in force on the date of the incident described in the Complaint which provides payment of benefits of eighty (80%) percent of all reasonable and necessary medical expenses incurred and sixty (60%) percent of loss of income or earning capacity from inability to work as a result of the injury sustained from the incident described in the Complaint to a maximum of Ten Thousand Dollars ($10,000.00). 22. Asa result of the collision which is the subjective of this litigation you were not permanently injured. 23. One or more of your medical providers has a letter of protection in their favor, for your care and/or treatment, as a result of the incident which is the subject matter of the above captioned matter. 24. Prior to the date of the motor vehicle accident, which is the subject of this lawsuit, Plaintiff has suffered from the same injuries and/or conditions for which he is claiming in this matter. 25. Prior to the date of the motor vehicle accident, which is the subject of this lawsuit, Plaintiff was assigned a permanent impairment rating by a physician. 26. Prior to the date of the motor vehicle accident, which is the subject of this lawsuit, Plaintiff has been involved in a motor vehicle accident in which he injured the same parts of his body for which he is claiming injury in this matter. 27. Prior to the date of the motor vehicle accident, which is the subject of this lawsuit, Plaintiff has made a claim and/or filed a lawsuit for the same injuries and/or conditions for which he is claiming in this matter.Case No: CACE1007771 28. After the date of the motor vehicle accident, which is the subject of this lawsuit, Plaintiff has been involved in a motor vehicle accident in which he injured the same parts of his body for which he is claiming injury in this matter. 29. After the date of the motor vehicle accident, which is the subject of this lawsuit, Plaintiff has made a claim and/or filed a lawsuit for the same injuries and/or conditions for which he is claiming in this matter. CERTIFICATE OF SERVICE I] HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via E-Mail on May 26, 2021 to Stephanie Taylor, Esq., THOMPSON LEGAL P.A., Attorney for Plaintiff, Richard Szentmiklosy, Pleadings@ThompsonlegalFL.com, (954) 510- 3366/(954) 944-1888 (F). Law Offices of Michael W. Carroll Attorneys for Defendants 3230 West Commercial Blvd., Suite 400 Fort Lauderdale, FL 33309 (954) 903-6575 (Asst.)/(954) 903-6609 (Direct) Fax: (866) 841-8921 SERVICE DESIGNATIONS: Primary: FtLauderdaleHC@Progressive.com Secondary: ecacacel@Progressive.com Cake Crewe By: “EMILIO CACACE, ESQUIRE Florida Bar No. 63848 “Salaried Employees of Progressive Casualty Insurance Company”