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Case Number: CACE-18-000308 Division: 03
Filing # 66138786 E-Filed 01/05/2018 09:20:55 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
THOMAS ROSS,
Plaintiff, )
)
-vs- )
) CASE NO.:
BRIAN LIEFER and GEICO
GENERAL INSURANCE COMPANY, )
Defendants. )
/
REQUEST FOR ADMISSIONS
COMES NOW the Plaintiff, THOMAS ROSS, by and through the undersigned counsel and
pursuant to Fla, R. Civ. P. 1.370, requests that Defendant, BRIAN LIEFER and GEICO GENERAL
INSURANCE COMPANY, to admit or deny the truth of the following statement(s), 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 as against that Defendant.
The definition of "subject incident” is the incident that is described in the current complaint file by
the Plaintiff. "You" means the specific Defendant responding to these Requests for Admissions and
not every party to whom they were served. Each Defendant shall serve its own response.
THEREUPON, do you ADMIT or DENY;
1, 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 1/5/2018 9:20:53 AM.****4. You are the appropriate party to the case based on the allegations contained in the
Complaint.
5. There was a collision at the time and location set forth the Complaint involving you,
your vehicle or a vehicle that if negligently operated or maintained could lead to your liability for
resulting damages.
6. No act or omission of the Plaintiff herein contributed to causing the collision that is
the subject of this lawsuit.
7. As a result of the crash which is the subject of this lawsuit, the Plaintiff suffered 1)
a permanent injury within a reasonable degree of medical probability other than scarring or
disfigurement; 2) significant and permanent scarring; and/or 3) the loss of an important bodily
function.
8. Plaintiff was injured in the crash which is the subject of this lawsuit.
9. Plaintiff incurred medical expenses as a result of the crash which is the subject of this
lawsuit.
10. Plaintiff was wearing a seatbelt at the time of the subject incident.
lL. Defendant, BRIAN LIEFER, owned the vehicle involved in the crash set forth in the
Complaint.
12. At the time of the incident set forth in the Complaint, Defendant, BRIAN LIEFER,
was neither acting as the agent, apparent agent, employee and/or servant of any person or entity nor
acting within the course and scope of any agency, apparent agency, employment and/or servitude or
in furtherance of the business pursuits of any person or entity.
13. You are not being defended in this case pursuant to a reservation of rights.
14. BRIAN LIEFER was at fault for causing the crash set forth in the Complaint.15. The crash set forth in the Complaint happened solely as a result of the acts and/or
omissions of the Defendant , BRIAN LIEFER.
16. Defendant, BRIAN LIEFER’s vehicle collided with Plaintiff’s vehicle.
17. At the time of the crash set forth in the Complaint, Defendant, BRIAN LIEFER, was
using a cellular, PCS, similar telephone, Ipod, portable electronic device, computer, electronic
organizer or PDA.
18. Medical Bills were paid by GEICO GENERAL INSURANCE COMPANY under
the PIP portion of the policy at issue in this case.
FOR DEFENDANT, GEICO GENERAL INSURANCE COMPANY, ONLY
19. Defendant, GEICO GENERAL INSURANCE COMPANY, issued an automobile
insurance policy to Plaintiff, THOMAS ROSS that was in full force and effect on July 15, 2016,
the date of the incident described in the subject Complaint.
20. | You have no policy or coverage defenses to this claim.
21. __ Plaintiff, THOMAS ROSS, has complied and performed all conditions precedent with
regard to the insurance policy which is the subject of this lawsuit.
1 HEREBY CERTIFY that a copy of the foregoing has been served on the above Defendant,
BRIAN LIEFER and GEICO GENERAL INSURANCE COMPANY, with the Complaint.
STEINGER, ISCOE & GREENE, P.A.
Coastal Tower
2400 E. Commercial Blvd Suite 900
Fort Lauderdale, FL 33308
Telephone: (954) 491-7701
Facsimile: (954) 634-8329
Email: mpurow@injurylawyers.com
acox@injurylawyers.com
Attorneys for Plaintiffs
Malcolm A. Purow, Esquire
Florida Bar No.: 282790
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Case Number: CACE-18-000308 Division: 03 Filing # 66138786 E-Filed 01/05/2018 09:20:55 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA THOMAS ROSS, Plaintiff, ) ) -vs- ) ) CASE NO.: BRIAN LIEFER and GEICO GENERAL INSURANCE COMPANY, ) Defendants. ) / REQUEST FOR ADMISSIONS COMES NOW the Plaintiff, THOMAS ROSS, by and through the undersigned counsel and pursuant to Fla, R. Civ. P. 1.370, requests that Defendant, BRIAN LIEFER and GEICO GENERAL INSURANCE COMPANY, to admit or deny the truth of the following statement(s), 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 as against that Defendant. The definition of "subject incident” is the incident that is described in the current complaint file by the Plaintiff. "You" means the specific Defendant responding to these Requests for Admissions and not every party to whom they were served. Each Defendant shall serve its own response. THEREUPON, do you ADMIT or DENY; 1, 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 1/5/2018 9:20:53 AM.****4. You are the appropriate party to the case based on the allegations contained in the Complaint. 5. There was a collision at the time and location set forth the Complaint involving you, your vehicle or a vehicle that if negligently operated or maintained could lead to your liability for resulting damages. 6. No act or omission of the Plaintiff herein contributed to causing the collision that is the subject of this lawsuit. 7. As a result of the crash which is the subject of this lawsuit, the Plaintiff suffered 1) a permanent injury within a reasonable degree of medical probability other than scarring or disfigurement; 2) significant and permanent scarring; and/or 3) the loss of an important bodily function. 8. Plaintiff was injured in the crash which is the subject of this lawsuit. 9. Plaintiff incurred medical expenses as a result of the crash which is the subject of this lawsuit. 10. Plaintiff was wearing a seatbelt at the time of the subject incident. lL. Defendant, BRIAN LIEFER, owned the vehicle involved in the crash set forth in the Complaint. 12. At the time of the incident set forth in the Complaint, Defendant, BRIAN LIEFER, was neither acting as the agent, apparent agent, employee and/or servant of any person or entity nor acting within the course and scope of any agency, apparent agency, employment and/or servitude or in furtherance of the business pursuits of any person or entity. 13. You are not being defended in this case pursuant to a reservation of rights. 14. BRIAN LIEFER was at fault for causing the crash set forth in the Complaint.15. The crash set forth in the Complaint happened solely as a result of the acts and/or omissions of the Defendant , BRIAN LIEFER. 16. Defendant, BRIAN LIEFER’s vehicle collided with Plaintiff’s vehicle. 17. At the time of the crash set forth in the Complaint, Defendant, BRIAN LIEFER, was using a cellular, PCS, similar telephone, Ipod, portable electronic device, computer, electronic organizer or PDA. 18. Medical Bills were paid by GEICO GENERAL INSURANCE COMPANY under the PIP portion of the policy at issue in this case. FOR DEFENDANT, GEICO GENERAL INSURANCE COMPANY, ONLY 19. Defendant, GEICO GENERAL INSURANCE COMPANY, issued an automobile insurance policy to Plaintiff, THOMAS ROSS that was in full force and effect on July 15, 2016, the date of the incident described in the subject Complaint. 20. | You have no policy or coverage defenses to this claim. 21. __ Plaintiff, THOMAS ROSS, has complied and performed all conditions precedent with regard to the insurance policy which is the subject of this lawsuit. 1 HEREBY CERTIFY that a copy of the foregoing has been served on the above Defendant, BRIAN LIEFER and GEICO GENERAL INSURANCE COMPANY, with the Complaint. STEINGER, ISCOE & GREENE, P.A. Coastal Tower 2400 E. Commercial Blvd Suite 900 Fort Lauderdale, FL 33308 Telephone: (954) 491-7701 Facsimile: (954) 634-8329 Email: mpurow@injurylawyers.com acox@injurylawyers.com Attorneys for Plaintiffs Malcolm A. Purow, Esquire Florida Bar No.: 282790