On June 08, 2021 a
Party Discovery
was filed
involving a dispute between
Bradley Iii, Robert,
and
Dastjerdi, Armin,
Remote Electric Inc,
for AUTO NEGLIGENCE
in the District Court of Alachua County.
Preview
Filing # 128277065 E-Filed 06/08/2021 07:37:52 AM
IN THE CIRCUIT COURT
OF THE EIGHTH JUDICIAL CIRCUIT,
IN AND FOR ALACHUA COUNTY, FLORIDA
CASE NUMBER:01 2021 CA 001558
Circuit Civil Division DIV J
ROBERT BRADLEY III,
Plaintiff,
vs.
REMOTE ELECTRIC, INC. and
ARMIN DASTJERDI,
Defendants.
REQUEST FOR ADMISSIONS TO DEFENDANTS
Plaintiff requests Defendants to admit the truth of the following matters:
1. This action brought against the Defendants correctly names the parties in this action.
2. Venue for this action is proper in Alachua County, Florida
3. Service of process against the Defendant was proper.
4. Defendant Armin Dastjerdi was operating a motor vehicle on August 26, 2020, in
Alachua County, Florida.
5. Defendant Remote Electric, Inc. was the sole owner of the motor vehicle Defendant
Armin Dastjerdi was driving at the time of the collision described in the complaint.
6. Defendant Armin Dastjerdi was negligent in the operation of the motor vehicle,
which resulted in the subject collision with the vehicle operated by Plaintiff.
"2021 CA 001558" 128277065 Filed at Alachua County Clerk 06/08/2021 08:15:00 AM EDT7. Defendant Armin Dastjerdi operated the motor vehicle in a carless and negligent
manner immediately before crashing into the rear-end of Plaintiff's vehicle.
8. Plaintiff was injured in the subject collision.
9. Plaintiff suffered a permanent injury within a reasonable degree of medical
probability resulting from the subject collision.
10. Plaintiff was not guilty of negligence which caused or contributed to the subject
collision.
ll. Plaintiff incurred medical expenses for treatment of injuries resulting from the
subject collision.
12. There was no mechanical defect in the vehicle operated by Defendant Armin
Dastjerdi that contributed to the subject collision.
13. Plaintiff's medical expenses were reasonable and necessary for the care and
treatment of the injuries sustained in the subject collision.
14. No other person caused or contributed to the collision described in Plaintiff's
Complaint other than Defendant.
15. No other entity caused or contributed to the collision described in Plaintiff's
Complaint other than Defendant.
CERTIFICATE OF SERVICE
I certify that copy of the foregoing has been served on the Defendant by legal process
with the Summons and Complaint.MORGAN & MORGAN
/s/ James G. Biggart I]
James G. Biggart, Esq.
FBN 0037310
104 N. Main Street, Ste. 500
Gainesville, FL 32608
Telephone: (352) 253-2702
Facsimile: (352) 253-2795
E-Service: jbiggart@forthepeople.com;
swright@forthepeople.com
ashealy@forthepeople.com
Attorneys for Plaintiff
Document Filed Date
June 08, 2021
Case Filing Date
June 08, 2021
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Filing # 128277065 E-Filed 06/08/2021 07:37:52 AM IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT, IN AND FOR ALACHUA COUNTY, FLORIDA CASE NUMBER:01 2021 CA 001558 Circuit Civil Division DIV J ROBERT BRADLEY III, Plaintiff, vs. REMOTE ELECTRIC, INC. and ARMIN DASTJERDI, Defendants. REQUEST FOR ADMISSIONS TO DEFENDANTS Plaintiff requests Defendants to admit the truth of the following matters: 1. This action brought against the Defendants correctly names the parties in this action. 2. Venue for this action is proper in Alachua County, Florida 3. Service of process against the Defendant was proper. 4. Defendant Armin Dastjerdi was operating a motor vehicle on August 26, 2020, in Alachua County, Florida. 5. Defendant Remote Electric, Inc. was the sole owner of the motor vehicle Defendant Armin Dastjerdi was driving at the time of the collision described in the complaint. 6. Defendant Armin Dastjerdi was negligent in the operation of the motor vehicle, which resulted in the subject collision with the vehicle operated by Plaintiff. "2021 CA 001558" 128277065 Filed at Alachua County Clerk 06/08/2021 08:15:00 AM EDT7. Defendant Armin Dastjerdi operated the motor vehicle in a carless and negligent manner immediately before crashing into the rear-end of Plaintiff's vehicle. 8. Plaintiff was injured in the subject collision. 9. Plaintiff suffered a permanent injury within a reasonable degree of medical probability resulting from the subject collision. 10. Plaintiff was not guilty of negligence which caused or contributed to the subject collision. ll. Plaintiff incurred medical expenses for treatment of injuries resulting from the subject collision. 12. There was no mechanical defect in the vehicle operated by Defendant Armin Dastjerdi that contributed to the subject collision. 13. Plaintiff's medical expenses were reasonable and necessary for the care and treatment of the injuries sustained in the subject collision. 14. No other person caused or contributed to the collision described in Plaintiff's Complaint other than Defendant. 15. No other entity caused or contributed to the collision described in Plaintiff's Complaint other than Defendant. CERTIFICATE OF SERVICE I certify that copy of the foregoing has been served on the Defendant by legal process with the Summons and Complaint.MORGAN & MORGAN /s/ James G. Biggart I] James G. Biggart, Esq. FBN 0037310 104 N. Main Street, Ste. 500 Gainesville, FL 32608 Telephone: (352) 253-2702 Facsimile: (352) 253-2795 E-Service: jbiggart@forthepeople.com; swright@forthepeople.com ashealy@forthepeople.com Attorneys for Plaintiff