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Filing # 134021747 E-Filed 09/03/2021 01:10:23 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION:
NORMAN L. CARTWRIGHT, III,
Plaintiff,
v. CASE NO.: 2021 CA 000537 A
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL,
INC.,
Defendants.
/
DEFENDANT, R. T. BROWN, INC.’S,
REQUEST FOR ADMISSIONS TO PLAINTIFF
Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND
CREMATORY, by and through undersigned counsel, pursuant to Florida Rules of Civil Procedure
1.370, requests Plaintiff, NORMAN L. CARTWRIGHT, IIL, within thirty (30) days from the date
of service of these requests, admit in this action, that each of the following statements are true:
1. The injuries that you claim as a result of the incident on October 6, 2017, referenced
in the Complaint pre-date and pre-exist the date of the accident.
2. Before the incident on October 6, 2017, which is reference in your Complaint, you
sustained an injury to the same body part(s) as the body (s) you are alleging injuries to in this
lawsuit.
3. You have been involved in one (1) or more motor vehicle accidents which predate
the incident on October 6, 2017, referenced in the Complaint either as a driver, passenger, or
pedestrian.
4, One (1) or more of your prior treating physicians opined that you sustained
significant and/or permanent injury(ies) in said prior motor vehicle accident.
5. You have been involved in one (1) or more motor vehicle accidents subsequent to
the incident on October 6, 2017, referenced in the Complaint either as a driver, passenger, or
pedestrian.
6. One (1) or more of your prior treating physicians opined that you sustained
significant and/or permanent injury(ies) in said subsequent motor vehicle accident.Case No.: 2021 CA 000537 A
Request for Admissions to Plaintiff
Page 2 of 3
7. You have been involved in one (1) or more slip and fall type or other non-motor
vehicle accidents prior to the subject incident on October 6, 2017, described in the Complaint.
8. One (1) or more of your prior treating physicians opined that you sustained
significant and/or permanent injuries in the prior slip and fall type or other non-motor vehicle
accident(s).
9. You have been involved in one (1) or more slip and fall type or other non-motor
vehicle accidents subsequent to the subject incident on October 6, 2017 described in the
Complaint.
10. | One (1) or more of your prior treating physicians opined that you sustained
significant and/or permanent injuries in the subsequent slip and fall type or other non-motor
vehicle accident(s).
11. | You have been involved in any other type of accident, prior to the incident on
October 6, 2017, described in the Complaint.
12. You have been involved in any other type.of accident, subsequent to the incident
on October 6, 2017, described in the Complaint.
13. You were suffering from a disability prior to the date of the incident on October 6,
2017 described in the Complaint.
4. You have previously been involved in litigation where you sued someone for
damages.
5. You have previously settled a claim either pre-suit or during litigation for personal
injury, and executed a release.
6. You have no outstanding bills from the incident on October 6, 2017, that is
referenced in the Complaint.
7. You have no outstanding medical bills from the incident on October 6, 2017, that
is referenced in the Complaint.
8. You were unemployed at the time of the incident on October 6, 2017 that is
referenced in the Complaint.
9 You do not have lost wages as a result of the incident on October 6, 2017, that is
referenced in the Complaint.
20. You do not have a loss of earning capacity as a result of the incident on October 6,
2017, that is referenced in the Complaint.Case No,: 2021 CA 000537 A
Request for Admissions to Plaintiff
Page 3 of 3
21. You do not have any out-of-pocket expenses as a result of the incident on October
6, 2017, that is referenced in your Complaint.
22. You have a private health insurance coverage through some source that would
provide coverage for the damage that you are seeking in this lawsuit.
23. You have received benefits pursuant to a personal or group health insurance policy
for medical bills alleged to have been incurred as a result of the incident on October 6, 2017.
24. You have received other benefits through:a collateral source provider, including
but not limited to a workman’s compensation, social security, or Medicaid/Medicare, for all or a
portion of the damages that you allege resulted from the incident on October 6, 2017, referenced
in the Complaint.
25. No medical provider has expressed a medical opinion that you have sustained a
permanent injury as a result of the subject incident on October 6, 2017, referenced in the
Complaint.
26. Your normal physical abilities were impaired at the time of the October 6, 2017
incident referenced in the Complaint.
27. You have made one or more worker’s compensation claims during your lifetime.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via E-Portal to: Thomas D. Hippelheuser, Esquire, LAW OFFICES OF BRENT C. MILLER,
PA, 205 E. Burleigh Blvd, Tavares, FL 32778 (tom@bemillerlaw.com
litigation@bemillerlaw.com melisa@bemillerlaw.com) and Joseph F. Kinman, Esquire,
BEYTIN, McLAUGHLIN, MCLAUGHLIN, O’HARA, KINMAN & BOCCHINO, 1706 E 11"
Ave., Tampa, FL 33605 (jfk@law-fla.com jlb@law-fla.com), on this Za day of September,
2021.
METZGER LAW GROUP, P.A.
3018 W. Horatio St.
Tampa, FL 33609
(813) 288-2650
(813) 288-2670 Fax
Attorneys for the Defendant,
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY
JOSEPH/T. METZGER, ESQUIRE
Florida Bar No. 894478
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Filing # 134021747 E-Filed 09/03/2021 01:10:23 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION: NORMAN L. CARTWRIGHT, III, Plaintiff, v. CASE NO.: 2021 CA 000537 A R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants. / DEFENDANT, R. T. BROWN, INC.’S, REQUEST FOR ADMISSIONS TO PLAINTIFF Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, by and through undersigned counsel, pursuant to Florida Rules of Civil Procedure 1.370, requests Plaintiff, NORMAN L. CARTWRIGHT, IIL, within thirty (30) days from the date of service of these requests, admit in this action, that each of the following statements are true: 1. The injuries that you claim as a result of the incident on October 6, 2017, referenced in the Complaint pre-date and pre-exist the date of the accident. 2. Before the incident on October 6, 2017, which is reference in your Complaint, you sustained an injury to the same body part(s) as the body (s) you are alleging injuries to in this lawsuit. 3. You have been involved in one (1) or more motor vehicle accidents which predate the incident on October 6, 2017, referenced in the Complaint either as a driver, passenger, or pedestrian. 4, One (1) or more of your prior treating physicians opined that you sustained significant and/or permanent injury(ies) in said prior motor vehicle accident. 5. You have been involved in one (1) or more motor vehicle accidents subsequent to the incident on October 6, 2017, referenced in the Complaint either as a driver, passenger, or pedestrian. 6. One (1) or more of your prior treating physicians opined that you sustained significant and/or permanent injury(ies) in said subsequent motor vehicle accident.Case No.: 2021 CA 000537 A Request for Admissions to Plaintiff Page 2 of 3 7. You have been involved in one (1) or more slip and fall type or other non-motor vehicle accidents prior to the subject incident on October 6, 2017, described in the Complaint. 8. One (1) or more of your prior treating physicians opined that you sustained significant and/or permanent injuries in the prior slip and fall type or other non-motor vehicle accident(s). 9. You have been involved in one (1) or more slip and fall type or other non-motor vehicle accidents subsequent to the subject incident on October 6, 2017 described in the Complaint. 10. | One (1) or more of your prior treating physicians opined that you sustained significant and/or permanent injuries in the subsequent slip and fall type or other non-motor vehicle accident(s). 11. | You have been involved in any other type of accident, prior to the incident on October 6, 2017, described in the Complaint. 12. You have been involved in any other type.of accident, subsequent to the incident on October 6, 2017, described in the Complaint. 13. You were suffering from a disability prior to the date of the incident on October 6, 2017 described in the Complaint. 4. You have previously been involved in litigation where you sued someone for damages. 5. You have previously settled a claim either pre-suit or during litigation for personal injury, and executed a release. 6. You have no outstanding bills from the incident on October 6, 2017, that is referenced in the Complaint. 7. You have no outstanding medical bills from the incident on October 6, 2017, that is referenced in the Complaint. 8. You were unemployed at the time of the incident on October 6, 2017 that is referenced in the Complaint. 9 You do not have lost wages as a result of the incident on October 6, 2017, that is referenced in the Complaint. 20. You do not have a loss of earning capacity as a result of the incident on October 6, 2017, that is referenced in the Complaint.Case No,: 2021 CA 000537 A Request for Admissions to Plaintiff Page 3 of 3 21. You do not have any out-of-pocket expenses as a result of the incident on October 6, 2017, that is referenced in your Complaint. 22. You have a private health insurance coverage through some source that would provide coverage for the damage that you are seeking in this lawsuit. 23. You have received benefits pursuant to a personal or group health insurance policy for medical bills alleged to have been incurred as a result of the incident on October 6, 2017. 24. You have received other benefits through:a collateral source provider, including but not limited to a workman’s compensation, social security, or Medicaid/Medicare, for all or a portion of the damages that you allege resulted from the incident on October 6, 2017, referenced in the Complaint. 25. No medical provider has expressed a medical opinion that you have sustained a permanent injury as a result of the subject incident on October 6, 2017, referenced in the Complaint. 26. Your normal physical abilities were impaired at the time of the October 6, 2017 incident referenced in the Complaint. 27. You have made one or more worker’s compensation claims during your lifetime. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via E-Portal to: Thomas D. Hippelheuser, Esquire, LAW OFFICES OF BRENT C. MILLER, PA, 205 E. Burleigh Blvd, Tavares, FL 32778 (tom@bemillerlaw.com litigation@bemillerlaw.com melisa@bemillerlaw.com) and Joseph F. Kinman, Esquire, BEYTIN, McLAUGHLIN, MCLAUGHLIN, O’HARA, KINMAN & BOCCHINO, 1706 E 11" Ave., Tampa, FL 33605 (jfk@law-fla.com jlb@law-fla.com), on this Za day of September, 2021. METZGER LAW GROUP, P.A. 3018 W. Horatio St. Tampa, FL 33609 (813) 288-2650 (813) 288-2670 Fax Attorneys for the Defendant, R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY JOSEPH/T. METZGER, ESQUIRE Florida Bar No. 894478