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 # 60296529 E-Filed 08/11/2017 02:28:33 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN
AND FOR ORANGE COUNTY,
FLORIDA
CASE NO:
RUSTAM IMANGULOV
Plaintiff,
vs.
ILIAS DIMOPOULOS
Defendant.
____________________________________/
REQUEST FOR ADMISSIONS TO DEFENDANT
The Plaintiff, RUSTAM IMANGULOV, by and through the undersigned attorney, hereby
files this Request for Admissions directed to Defendant to admit the following:
1. On November 4, 2017, the Plaintiff, RUSTAM IMANGULOV, was involved in an automobile
accident with Defendant, ILIAS DIMOPOULOS.
2. At the time of the accident, you were authorized to use the motor vehicle that collided with
Plaintiff’s vehicle.
3. At the time of the accident, you were driving the vehicle at the time and the date alleged in the
Complaint.
4. At the time of the accident, you did negligently operate or maintain the motor vehicle so that it
collided with the Plaintiff’s motor vehicle.
5. At the time of the accident, you were distracted.
6. At the time of the accident, you were eating.
7. You were speaking on the phone at the time of the accident.
8. You were sending text messages at the time of the accident.
9. You were sending text messages immediately prior to the time of the accident.
10. You were recieving text messages at the time of the accident.
11. You were looking at your phone at the time of the accident.
12. No other person caused and/or contributed to the collision between Defendant and the vehicle
driven by Plaintiff.
13. You are the sole legal cause of the injuries and damages sustained by Plaintiff.
14. Service of process on you has been validly made in this case.
15. The Plaintiff sustained injuires as a result of the automobile accident at issue in this case.
16. The medical treatment the Plaintiff received after the subject accident was related to the
accident.
17. The medical expenses the Plaintiff incurred following the subject accident were reasonable.
18. The injuries the Plaintiff sustained following the subject accident are permanent injuries.
19. Plaintiff was wearing fully functional and operational shoudler restraints and/or seatbelts at the
time of the subject accident.
20. Plaintiff mitigated his damages to the extent the Plaintiff could have mitigated his damages.
21. The view of your surroundings was not obstructed when you struck Plaintiff.
22.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
service of process along with the Complaint, Request to Produce and Interrogatories to the
Defendant.
/s/ Andres I. Beregovich
___________________________________
ANDRES I. BEREGOVICH, ESQUIRE
Florida Bar No.: 0097812
The Beregovich Law Firm, P.A.
210 N. Mills Avenue
Orlando, FL 32801
Telephone: (407) 809-9000
Facsimile: (407) 809-9001
Service Email: eservice@beregovichlaw.com
Attorney for Plaintiff
Document Filed Date
August 11, 2017
Case Filing Date
August 11, 2017
Category
CA - Auto Negligence
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Filing # 60296529 E-Filed 08/11/2017 02:28:33 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO: RUSTAM IMANGULOV Plaintiff, vs. ILIAS DIMOPOULOS Defendant. ____________________________________/ REQUEST FOR ADMISSIONS TO DEFENDANT The Plaintiff, RUSTAM IMANGULOV, by and through the undersigned attorney, hereby files this Request for Admissions directed to Defendant to admit the following: 1. On November 4, 2017, the Plaintiff, RUSTAM IMANGULOV, was involved in an automobile accident with Defendant, ILIAS DIMOPOULOS. 2. At the time of the accident, you were authorized to use the motor vehicle that collided with Plaintiff’s vehicle. 3. At the time of the accident, you were driving the vehicle at the time and the date alleged in the Complaint. 4. At the time of the accident, you did negligently operate or maintain the motor vehicle so that it collided with the Plaintiff’s motor vehicle. 5. At the time of the accident, you were distracted. 6. At the time of the accident, you were eating. 7. You were speaking on the phone at the time of the accident. 8. You were sending text messages at the time of the accident. 9. You were sending text messages immediately prior to the time of the accident. 10. You were recieving text messages at the time of the accident. 11. You were looking at your phone at the time of the accident. 12. No other person caused and/or contributed to the collision between Defendant and the vehicle driven by Plaintiff. 13. You are the sole legal cause of the injuries and damages sustained by Plaintiff. 14. Service of process on you has been validly made in this case. 15. The Plaintiff sustained injuires as a result of the automobile accident at issue in this case. 16. The medical treatment the Plaintiff received after the subject accident was related to the accident. 17. The medical expenses the Plaintiff incurred following the subject accident were reasonable. 18. The injuries the Plaintiff sustained following the subject accident are permanent injuries. 19. Plaintiff was wearing fully functional and operational shoudler restraints and/or seatbelts at the time of the subject accident. 20. Plaintiff mitigated his damages to the extent the Plaintiff could have mitigated his damages. 21. The view of your surroundings was not obstructed when you struck Plaintiff. 22. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via service of process along with the Complaint, Request to Produce and Interrogatories to the Defendant. /s/ Andres I. Beregovich ___________________________________ ANDRES I. BEREGOVICH, ESQUIRE Florida Bar No.: 0097812 The Beregovich Law Firm, P.A. 210 N. Mills Avenue Orlando, FL 32801 Telephone: (407) 809-9000 Facsimile: (407) 809-9001 Service Email: eservice@beregovichlaw.com Attorney for Plaintiff