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Filing # 88413240 E-Filed 04/23/2019 04:27:07 PM
1932201/3
IN THE CIRCUIT COURT OF THE 19TH JUDICIAL
CIRCUIT IN AND FOR INDIAN RIVER COUNTY,
FLORIDA
CASE NO. 312019CA000232
LEAH M. HUBBARD,
Plaintiff,
Vv.
E. CLAYTON YATES, P.A.,
Defendant.
/
DEFENDANT, E. CLAYTON YATES P.A.’S, FIRST REQUEST FOR ADMISSIONS TO
PLAINTIFF, LEAH M. HUBBARD
Defendant, E. CLAYTON YATES P.A., by and through its undersigned counsel
and pursuant to Rules 1.280 and 1.370 of the Florida Rules of Civil Procedure, requests
that the Plaintiff, LEAH M. HUBBARD, admit or deny the following statements within 30
days of service hereof:
1. Admit that on April 11, 2018 you entered a plea of nolo contendere to a charge
of aggravated assault with a deadly weapon before the Honorable Cynthia Cox
in Indian River County, Florida.
2. Admit that on April 11, 2018 the Honorable Cynthia Cox in Indian River County,
Florida ordered that you be confined to the county jail for 181 days, of which
181 days had been time served.
3. Admit that on April 2, 2018 you entered a plea of nolo contendere to a charge
of aggravated assault with a deadly weapon before the Honorable Cynthia Cox
in Indian River County, Florida.CASE NO. 312019CA000232
DEFENDANT'S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF
4. Admit that on April 2, 2018 the Honorable Cynthia Cox in Indian River County,
Florida ordered that you be confined to the county jail for 181 days, of which
181 days had been time served.
5. Admit that on April 11, 2018 you entered a plea of nolo contendere to a charge
of carrying a concealed firearm before the Honorable Cynthia Cox in Indian
River County, Florida.
6. Admit that on April 2, 2018 you entered a plea of nolo contendere to a charge
of carrying a concealed firearm before the Honorable Cynthia Cox in Indian
River County, Florida.
7. Admit that on April 11, 2018 the Honorable Cynthia Cox in Indian River County,
Florida ordered that you be confined to the county jail for 179 days, of which
179 days had been time served.
8. Admit that on April 2, 2018 the Honorable Cynthia Cox in Indian River County,
Florida ordered that you be confined to the county jail for 179 days, of which
179 days had been time served.
9. Admit that on April 11, 2018 the Honorable Cynthia Cox in Indian River County,
Florida ordered that you be placed on probation for a period of one year.
10.Admit that on April 2, 2018 the Honorable Cynthia Cox in Indian River County,
Florida ordered that you be placed on probation for a period of one year.
11. Admit that on April 11, 2018 the Honorable Cynthia Cox in Indian River County,
Florida ordered that you be placed on community control for a period of one
year.CASE NO. 312019CA000232
DEFENDANT'S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF
12. Admit that on April 2, 2018 the Honorable Cynthia Cox in Indian River County,
Florida ordered that you be placed on community control for a period of one
year.
13. Admit that you have not been exonerated of any charge of aggravated assault
with a deadly weapon.
14. Admit that you have not been exonerated of any charge of carrying a concealed
firearm.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a copy hereof has been furnished by service through the
eportal to Leah M. Hubbard, 2046 79th Avenue, Vero Beach, FL 32966, Pro Se, Leah
Hubbard, leahhubbard0706@gmail.com, on this _23rd__ day of April, 2019.
CONROY SIMBERG
Attorney for Defendant, E. Clayton Yates, P.A.
1801 Centrepark Drive East, Suite 200
West Palm Beach, FL 33401
Telephone: (561) 697-8088
Facsimile: (561) 697-8664
Primary Email: eservicewpb@conroysimberg.com
Secondary Email: jrubin@conroysimberg.com
By: _/s/ Jeffrey K. Rubin
John A. Lurvey, Esquire
Florida Bar No. 570222
Jeffrey K. Rubin, Esquire
Florida Bar No. 42084
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Filing # 88413240 E-Filed 04/23/2019 04:27:07 PM 1932201/3 IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR INDIAN RIVER COUNTY, FLORIDA CASE NO. 312019CA000232 LEAH M. HUBBARD, Plaintiff, Vv. E. CLAYTON YATES, P.A., Defendant. / DEFENDANT, E. CLAYTON YATES P.A.’S, FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF, LEAH M. HUBBARD Defendant, E. CLAYTON YATES P.A., by and through its undersigned counsel and pursuant to Rules 1.280 and 1.370 of the Florida Rules of Civil Procedure, requests that the Plaintiff, LEAH M. HUBBARD, admit or deny the following statements within 30 days of service hereof: 1. Admit that on April 11, 2018 you entered a plea of nolo contendere to a charge of aggravated assault with a deadly weapon before the Honorable Cynthia Cox in Indian River County, Florida. 2. Admit that on April 11, 2018 the Honorable Cynthia Cox in Indian River County, Florida ordered that you be confined to the county jail for 181 days, of which 181 days had been time served. 3. Admit that on April 2, 2018 you entered a plea of nolo contendere to a charge of aggravated assault with a deadly weapon before the Honorable Cynthia Cox in Indian River County, Florida.CASE NO. 312019CA000232 DEFENDANT'S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 4. Admit that on April 2, 2018 the Honorable Cynthia Cox in Indian River County, Florida ordered that you be confined to the county jail for 181 days, of which 181 days had been time served. 5. Admit that on April 11, 2018 you entered a plea of nolo contendere to a charge of carrying a concealed firearm before the Honorable Cynthia Cox in Indian River County, Florida. 6. Admit that on April 2, 2018 you entered a plea of nolo contendere to a charge of carrying a concealed firearm before the Honorable Cynthia Cox in Indian River County, Florida. 7. Admit that on April 11, 2018 the Honorable Cynthia Cox in Indian River County, Florida ordered that you be confined to the county jail for 179 days, of which 179 days had been time served. 8. Admit that on April 2, 2018 the Honorable Cynthia Cox in Indian River County, Florida ordered that you be confined to the county jail for 179 days, of which 179 days had been time served. 9. Admit that on April 11, 2018 the Honorable Cynthia Cox in Indian River County, Florida ordered that you be placed on probation for a period of one year. 10.Admit that on April 2, 2018 the Honorable Cynthia Cox in Indian River County, Florida ordered that you be placed on probation for a period of one year. 11. Admit that on April 11, 2018 the Honorable Cynthia Cox in Indian River County, Florida ordered that you be placed on community control for a period of one year.CASE NO. 312019CA000232 DEFENDANT'S FIRST REQUEST FOR ADMISSIONS TO PLAINTIFF 12. Admit that on April 2, 2018 the Honorable Cynthia Cox in Indian River County, Florida ordered that you be placed on community control for a period of one year. 13. Admit that you have not been exonerated of any charge of aggravated assault with a deadly weapon. 14. Admit that you have not been exonerated of any charge of carrying a concealed firearm. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy hereof has been furnished by service through the eportal to Leah M. Hubbard, 2046 79th Avenue, Vero Beach, FL 32966, Pro Se, Leah Hubbard, leahhubbard0706@gmail.com, on this _23rd__ day of April, 2019. CONROY SIMBERG Attorney for Defendant, E. Clayton Yates, P.A. 1801 Centrepark Drive East, Suite 200 West Palm Beach, FL 33401 Telephone: (561) 697-8088 Facsimile: (561) 697-8664 Primary Email: eservicewpb@conroysimberg.com Secondary Email: jrubin@conroysimberg.com By: _/s/ Jeffrey K. Rubin John A. Lurvey, Esquire Florida Bar No. 570222 Jeffrey K. Rubin, Esquire Florida Bar No. 42084