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Case Number: CACE-17-007673 Division: 05
Filing # 55445174 E-Filed 04/21/2017 04:56:51 PM
IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
RONALD VOHS,
Plaintiff,
-~Vs-
JOSIMAR’S CLEANING SERVICES CORP, Case No.:
USA BR GENERAL SERVICES CORP.,
INDUSTRIAL CABLE COMMUNICATIONS
SERVICES INC., AND COMCAST
CORPORATION
Defendants.
/
REQUEST FOR ADMISSIONS
Plaintiff, RONALD VOHS, by and through the undersigned counsel and pursuant to Fla.
R. Civ. P. 1.370, requests that Defendant, USA BR GENERAL SERVICES CORP. admit or
deny the truth of the following statements, considering that these requests are intended to limit
the issues at trial and should the Plaintiff prove any statement stated below not admitted by the
Defendant, that the Plaintiff shall seek attorneys fees and costs incurred in proving the
statement, and further recognizing that a response is due within forty five (45) days of the
propounding of these requests as certified in the certificate of service as indicated below and
the failure of Defendant to make a response within forty five (45) days of the propounding of
these requests shall entitle the Plaintiff to deem the statements admitted. The definition of
"subject incident" is the accident that is described in the current Complaint filed by the Plaintiff.
"You" means the Defendant, its agents and employees. THEREUPON, do you ADMIT or
DENY:
fe You were properly named in the Complaint.
2. Venue is appropriate.
3. The Court has jurisdiction over the parties.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/21/2017 4:56:49 PM.****4. The Plaintiff, RONALD VOHS, was not negligent in causing the incident alleged
in the Complaint.
5. At the time and place of the subject accident, incident or event described in the
Complaint, you did not bury or cause to be buried the subject Comcast cable wire.
6. That Plaintiff, RONALD VOHS, suffered a permanent injury as a result of the
incident which is the subject of this lawsuit.
7. That the Plaintiff, RONALD VOHS, was injured in the incident which is the
subject of this lawsuit.
8. USA BR GENERAL SERVICES CORP.., inclusive of it's employees, agents,
and/or contractors, performed cable installation, repair and/or maintenance work for Comcast
customers at the time of the subject incident.
9. You owed a duty of reasonable care to hire competent contractors to perform
cable installation, repair and/or maintenance work to your customers.
10. | Onor about January 8, 2016, the Plaintiff, RONALD VOHS, was lawfully
on the premises where the subject accident took place.
11. You did not conduct inspections of the job site where the subject accident,
incident, or event described in the Complaint took place, prior to the date of the subject
accident.
12. The condition set forth in the Complaint, to wit: the exposed cable wire, was
created as a result of you, your employees, agents, or contractor’s acts and/or omissions.
13. You allowed the exposed cable wire to exist on the subject premises so that
Plaintiff fell.
14. | The dangerous condition, to wit: the exposed cable wire, was known to you or
had existed for a sufficient length of time so that you should have known of it.
15. You, your employees, agents and/or contractors failed to warn Plaintiff, RONALD
VOHS, of the aforesaid, dangerous and unsafe condition.16. You did not provide any warnings to Plaintiff, RONALD VOHS, with respect to
any conditions on the subject premises on or before January 8, 2016.
17. At the date and time of the incident alleged in the Complaint, JOSIMAR
OLIVEIRA and/or JOSIMAR’S CLEANING SERVICES CORP. did not possess adequate
training to perform cable work safely.
18. At the date and time of the incident alleged in the Complaint, JOSIMAR
OLIVEIRA and/or JOSIMAR’S CLEANING SERVICES CORP. did not possess adequate
knowledge to perform cable work safely.
19. At the date and time of the incident alleged in the Complaint, JOSIMAR
OLIVEIRA and/or JOSIMAR’S CLEANING SERVICES CORP. did not possess adequate
experience to perform cable work safely.
20. Atthe date and time of the incident alleged in the Complaint, Plaintiff, RONALD
VOHS, fell as a result of exposed cable wire on the ground.
21. You have a visual recording, whether still or showing motion, of Plaintiff,
RONALD VOHS.
22. — All recordings of the Plaintiff made by you, if any, remain available to you.
23. Plaintiff incurred medical expenses as a result of the fall which is the subject of
this lawsuit.
24. You are not being defended in this case pursuant to a reservation of rights.
| HEREBY CERTIFY that a copy of the foregoing has been served on the above
Defendant, USA BR GENERAL SERVICES CORP. with the Complaint.
Steinger, Iscoe & Greene, P.A.
Coastal Tower
2400 E. Commercial Blvd Suite 900
Fort Lauderdale, FL 33308
Telephone: (954) 491-7701
ychan@injurylawyers.com
ganselmo@injurylawyers.com
Attorneys for Plaintiff
aE han, Esquire
Florida Bar No.: 58355
Preview
Case Number: CACE-17-007673 Division: 05 Filing # 55445174 E-Filed 04/21/2017 04:56:51 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, Plaintiff, -~Vs- JOSIMAR’S CLEANING SERVICES CORP, Case No.: USA BR GENERAL SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES INC., AND COMCAST CORPORATION Defendants. / REQUEST FOR ADMISSIONS Plaintiff, RONALD VOHS, by and through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.370, requests that Defendant, USA BR GENERAL SERVICES CORP. admit or deny the truth of the following statements, considering that these requests are intended to limit the issues at trial and should the Plaintiff prove any statement stated below not admitted by the Defendant, that the Plaintiff shall seek attorneys fees and costs incurred in proving the statement, and further recognizing that a response is due within forty five (45) days of the propounding of these requests as certified in the certificate of service as indicated below and the failure of Defendant to make a response within forty five (45) days of the propounding of these requests shall entitle the Plaintiff to deem the statements admitted. The definition of "subject incident" is the accident that is described in the current Complaint filed by the Plaintiff. "You" means the Defendant, its agents and employees. THEREUPON, do you ADMIT or DENY: fe You were properly named in the Complaint. 2. Venue is appropriate. 3. The Court has jurisdiction over the parties. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/21/2017 4:56:49 PM.****4. The Plaintiff, RONALD VOHS, was not negligent in causing the incident alleged in the Complaint. 5. At the time and place of the subject accident, incident or event described in the Complaint, you did not bury or cause to be buried the subject Comcast cable wire. 6. That Plaintiff, RONALD VOHS, suffered a permanent injury as a result of the incident which is the subject of this lawsuit. 7. That the Plaintiff, RONALD VOHS, was injured in the incident which is the subject of this lawsuit. 8. USA BR GENERAL SERVICES CORP.., inclusive of it's employees, agents, and/or contractors, performed cable installation, repair and/or maintenance work for Comcast customers at the time of the subject incident. 9. You owed a duty of reasonable care to hire competent contractors to perform cable installation, repair and/or maintenance work to your customers. 10. | Onor about January 8, 2016, the Plaintiff, RONALD VOHS, was lawfully on the premises where the subject accident took place. 11. You did not conduct inspections of the job site where the subject accident, incident, or event described in the Complaint took place, prior to the date of the subject accident. 12. The condition set forth in the Complaint, to wit: the exposed cable wire, was created as a result of you, your employees, agents, or contractor’s acts and/or omissions. 13. You allowed the exposed cable wire to exist on the subject premises so that Plaintiff fell. 14. | The dangerous condition, to wit: the exposed cable wire, was known to you or had existed for a sufficient length of time so that you should have known of it. 15. You, your employees, agents and/or contractors failed to warn Plaintiff, RONALD VOHS, of the aforesaid, dangerous and unsafe condition.16. You did not provide any warnings to Plaintiff, RONALD VOHS, with respect to any conditions on the subject premises on or before January 8, 2016. 17. At the date and time of the incident alleged in the Complaint, JOSIMAR OLIVEIRA and/or JOSIMAR’S CLEANING SERVICES CORP. did not possess adequate training to perform cable work safely. 18. At the date and time of the incident alleged in the Complaint, JOSIMAR OLIVEIRA and/or JOSIMAR’S CLEANING SERVICES CORP. did not possess adequate knowledge to perform cable work safely. 19. At the date and time of the incident alleged in the Complaint, JOSIMAR OLIVEIRA and/or JOSIMAR’S CLEANING SERVICES CORP. did not possess adequate experience to perform cable work safely. 20. Atthe date and time of the incident alleged in the Complaint, Plaintiff, RONALD VOHS, fell as a result of exposed cable wire on the ground. 21. You have a visual recording, whether still or showing motion, of Plaintiff, RONALD VOHS. 22. — All recordings of the Plaintiff made by you, if any, remain available to you. 23. Plaintiff incurred medical expenses as a result of the fall which is the subject of this lawsuit. 24. You are not being defended in this case pursuant to a reservation of rights. | HEREBY CERTIFY that a copy of the foregoing has been served on the above Defendant, USA BR GENERAL SERVICES CORP. with the Complaint. Steinger, Iscoe & Greene, P.A. Coastal Tower 2400 E. Commercial Blvd Suite 900 Fort Lauderdale, FL 33308 Telephone: (954) 491-7701 ychan@injurylawyers.com ganselmo@injurylawyers.com Attorneys for Plaintiff aE han, Esquire Florida Bar No.: 58355