On August 11, 2017 a
Party Discovery
was filed
involving a dispute between
Rustam Imangulov,
and
Ilias Dimopoulos,
for CA - Auto Negligence
in the District Court of Orange County.
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Filing #62079318 E-Filed 09/27/2017 03:03:48 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
CASE NO.: 2017-CA-007329-O
RUSTAM IMANGULOV,
Plaintiff,
VS.
ILIAS DIMOPOULOS,
Defendant.
/
REQUEST FOR ADMISSIONS
COMES NOW THE Defendant, Ilias Dimopoulos, by and through the undersigned attorney
and pursuant to applicable Rules of Civil Procedure files this Request for Admissions and requests
that Plaintiff, Rustam Imangulov, admit or deny the following:
1 That at the time of the incident which is the subject of this lawsuit, the vehicle you
were driving had a fully operational seat belt which was available to you.
2, That you were not wearing the available and fully operational seat belt described
above at the time of the collision which is the subject of this lawsuit.
3 That this failure to wear a seat belt produced or contributed substantially to
producing at least a portion of the damage claimed by you.
4. Your failure to use the seat belt as set forth above was unreasonable under the
circumstances.
5 You received or are entitled to receive benefits from a collateral source, as defined.
by Florida Statute 768.76, for medical bills alleged to have been incurred as a result of the incident
described in the Complaint.
6 You received or are entitled to receive benefits from a collateral source, as defined
by Florida Statute 768.76, for loss of wages or income alleged to have been incurred as a result of
the incident described in the Complaint.
7 You received or are entitled io 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.
8 You received or are entitled to receive benefits under the Personal Injury Protection
portion of an automobile policy for loss of wages or income alleged to have been incurred as a
result of the incident described in the Complaint.
9 You received or are 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.
10. You are subject to a deductible under the Personal Injury Protection portion of an
automobile insurance policy.
11. You received or are entitled to receive benefits pursuant to personal or group health
insurance policy, for medical bills alleged to have been incurred as a result of the incident described
in the Complaint.
12. You received or are 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 incurred as a result of
the incident described in the Complaint.
13, This action is subject to the Florida Motor Vehicle No-Fault Law, Florida Statute
Sections 627.730-627.7405.
14, You are an insured person under the Personal Injury Protection portion of an
automobile insurance policy which was in full force and effect on the date of the incident described
in the Complaint, and said policy 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 injury sustained from the incident described in
the Complaint to a maximum of Ten Thousand ($10,000.00) Dollars.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Electronic Mail on this the 27" day of September, 2017 to the following designated service email
address(es): Andres I Beregovich, Esq., The Beregovich Law Firm, P.A.,
andres@beregovichlaw.com.
Law Office of Deborah N. Hartwell
/s/ Keegan R. Shel
Keegan R. Shelby
(Employees of the GEICO General Insurance
Company)
Florida Bar No.: 107072
1000 Legion Place, Suite 850
Orlando, FL 32801
Phone: (407) 648-8236
Facsimile: (407) 648-2650
Attorney for Defendant: Ilias Dimopoulos
Service Email: orlandogeico@geico.com
Document Filed Date
September 27, 2017
Case Filing Date
August 11, 2017
Category
CA - Auto Negligence
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Filing #62079318 E-Filed 09/27/2017 03:03:48 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO.: 2017-CA-007329-O RUSTAM IMANGULOV, Plaintiff, VS. ILIAS DIMOPOULOS, Defendant. / REQUEST FOR ADMISSIONS COMES NOW THE Defendant, Ilias Dimopoulos, by and through the undersigned attorney and pursuant to applicable Rules of Civil Procedure files this Request for Admissions and requests that Plaintiff, Rustam Imangulov, admit or deny the following: 1 That at the time of the incident which is the subject of this lawsuit, the vehicle you were driving had a fully operational seat belt which was available to you. 2, That you were not wearing the available and fully operational seat belt described above at the time of the collision which is the subject of this lawsuit. 3 That this failure to wear a seat belt produced or contributed substantially to producing at least a portion of the damage claimed by you. 4. Your failure to use the seat belt as set forth above was unreasonable under the circumstances. 5 You received or are entitled to receive benefits from a collateral source, as defined. by Florida Statute 768.76, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 6 You received or are entitled to receive benefits from a collateral source, as defined by Florida Statute 768.76, for loss of wages or income alleged to have been incurred as a result of the incident described in the Complaint. 7 You received or are entitled io 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. 8 You received or are entitled to receive benefits under the Personal Injury Protection portion of an automobile policy for loss of wages or income alleged to have been incurred as a result of the incident described in the Complaint. 9 You received or are 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. 10. You are subject to a deductible under the Personal Injury Protection portion of an automobile insurance policy. 11. You received or are entitled to receive benefits pursuant to personal or group health insurance policy, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 12. You received or are 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 incurred as a result of the incident described in the Complaint. 13, This action is subject to the Florida Motor Vehicle No-Fault Law, Florida Statute Sections 627.730-627.7405. 14, You are an insured person under the Personal Injury Protection portion of an automobile insurance policy which was in full force and effect on the date of the incident described in the Complaint, and said policy 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 injury sustained from the incident described in the Complaint to a maximum of Ten Thousand ($10,000.00) Dollars. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic Mail on this the 27" day of September, 2017 to the following designated service email address(es): Andres I Beregovich, Esq., The Beregovich Law Firm, P.A., andres@beregovichlaw.com. Law Office of Deborah N. Hartwell /s/ Keegan R. Shel Keegan R. Shelby (Employees of the GEICO General Insurance Company) Florida Bar No.: 107072 1000 Legion Place, Suite 850 Orlando, FL 32801 Phone: (407) 648-8236 Facsimile: (407) 648-2650 Attorney for Defendant: Ilias Dimopoulos Service Email: orlandogeico@geico.com