On May 27, 2020 a
Party Discovery
was filed
involving a dispute between
Martin, Aaliyah,
Martin, Glorita,
and
Bradshaw, Luke,
for Circuit Civil 3-D
in the District Court of Bradford County.
Preview
Filing # MIE E-Filed 06/16/2020 11:32:15 AM
WY SL:ZE:L} 0202/91/90 XNXVWO88L 00002 # 8SeD Pudlpeig pall Al}eo1U0}09/3
IN THE CIRCUIT COURT FOR THE EIGHTH
JUDICIAL CIRCUIT IN AND FOR BRADFORD
COUNTY, STATE OF FLORIDA - CIVIL DIVISION
GLORITA MARTIN individually and
GLORITA MARTIN o/b/o
AALIYAH MARTIN,
Plaintiff,
vs. Case No: 04-2020-CA-000188
LUKE BRADSHAW,
Defendant.
/
REQUEST FOR ADMISSIONS TO PLAINTIFF
Defendant, LUKE BRADSHAW, pursuant to Florida Rule of Civil Procedure 1.370,
Florida Rules of Civil Procedure, hereby requests Plaintiff, GLORITA MARTIN o/b/o AALIYAH
MARTIN, to admit or deny the following within thirty (30) days from the date of service hereof:
1, Plaintiff received or is entitled to receive benefits from a collateral source, as defined
by §768.76, Fla. Stat., for medical bills alleged to have been incurred as a result of the
incident described in the Complaint.
2. Plaintiff received or is entitled to receive benefits from a collateral source, as defined
by §768.76, Fla. Stat., for lost wages or income alleged to have been lost as a result of
the incident described in the Complaint.
3. Plaintiff received or is entitled to receive benefits, pursuant to personal or a group wage
continuation plan, for wages or income alleged to have been lost as a result of the
incident described in the Complaint.
4. Plaintiff received or is entitled to receive benefits, pursuant to personal or a group
health insurance policy, for medical bills alleged to have been incurred as a result of the
incident described in the Complaint.
00469430.DOCX5. Plaintiff has failed to join indispensable third parties whose acts or omissions
contributed in whole or in part to cause the incident which is the subject of this dispute.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent via
email to Katherine M. Richters, Esquire, Neal J. Gambler, Esquire and Ronald E. Sholes,
Esquire (RonSholesPA-Team18-eservic
'YouHurtWeFight.com), RONALD E. SHOLES,
P.A., 486 North Temple Avenue, Starke, Florida 32091 on this day of June 2020.
T.R. UNICE, JR., ESQUIRE
Florida Bar Number: 358169
UNICE SALZMAN JENSEN, P.A.
CenterState Bank Building, Second Floor
1815 Little Road
Trinity, Florida 34655
Phone (727)723-3772
Fax (727)723-1421
Attorney for Defendant
Primary E-mail: service@unicesalzman.com
Secondary Email: jjensen@unicesalzman.com
00469430.DOCX
adilla@unicesalzman.com
cinman@unicesalzman.com
Document Filed Date
June 16, 2020
Case Filing Date
May 27, 2020
Category
Circuit Civil 3-D
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Filing # MIE E-Filed 06/16/2020 11:32:15 AM WY SL:ZE:L} 0202/91/90 XNXVWO88L 00002 # 8SeD Pudlpeig pall Al}eo1U0}09/3 IN THE CIRCUIT COURT FOR THE EIGHTH JUDICIAL CIRCUIT IN AND FOR BRADFORD COUNTY, STATE OF FLORIDA - CIVIL DIVISION GLORITA MARTIN individually and GLORITA MARTIN o/b/o AALIYAH MARTIN, Plaintiff, vs. Case No: 04-2020-CA-000188 LUKE BRADSHAW, Defendant. / REQUEST FOR ADMISSIONS TO PLAINTIFF Defendant, LUKE BRADSHAW, pursuant to Florida Rule of Civil Procedure 1.370, Florida Rules of Civil Procedure, hereby requests Plaintiff, GLORITA MARTIN o/b/o AALIYAH MARTIN, to admit or deny the following within thirty (30) days from the date of service hereof: 1, Plaintiff received or is entitled to receive benefits from a collateral source, as defined by §768.76, Fla. Stat., for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 2. Plaintiff received or is entitled to receive benefits from a collateral source, as defined by §768.76, Fla. Stat., for lost wages or income alleged to have been lost as a result of the incident described in the Complaint. 3. Plaintiff received or is entitled to receive benefits, pursuant to personal or a group wage continuation plan, for wages or income alleged to have been lost as a result of the incident described in the Complaint. 4. Plaintiff received or is entitled to receive benefits, pursuant to personal or a group health insurance policy, for medical bills alleged to have been incurred as a result of the incident described in the Complaint. 00469430.DOCX5. Plaintiff has failed to join indispensable third parties whose acts or omissions contributed in whole or in part to cause the incident which is the subject of this dispute. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent via email to Katherine M. Richters, Esquire, Neal J. Gambler, Esquire and Ronald E. Sholes, Esquire (RonSholesPA-Team18-eservic 'YouHurtWeFight.com), RONALD E. SHOLES, P.A., 486 North Temple Avenue, Starke, Florida 32091 on this day of June 2020. T.R. UNICE, JR., ESQUIRE Florida Bar Number: 358169 UNICE SALZMAN JENSEN, P.A. CenterState Bank Building, Second Floor 1815 Little Road Trinity, Florida 34655 Phone (727)723-3772 Fax (727)723-1421 Attorney for Defendant Primary E-mail: service@unicesalzman.com Secondary Email: jjensen@unicesalzman.com 00469430.DOCX adilla@unicesalzman.com cinman@unicesalzman.com