On March 29, 2021 a
Party Discovery
was filed
involving a dispute between
Cullinan, Lindsay,
and
Kinney, Caitlyn,
Kinney, Caitlyn Nicole,
Kinney, Kevin,
Progressive Advanced Insurance Company,
for AUTO NEGLIGENCE
in the District Court of Indian River County.
Preview
Filing # 123904117 E-Filed 03/29/2021 10:13:16 AM
IN THE CIRCUIT COURT OF THE 19TH
JUDICIAL CIRCUIT IN AND FOR
INDIAN RIVER COUNTY, FLORIDA
CASE NO.: 312021CA000191XXXXXX
LINDSAY CULLINAN,
Plaintiff,
vs.
CAITLYN KINNEY, KEVIN KINNEY and PROGRESSIVE ADVANCED
INSURANCE COMPANY, a foreign corporation,
Defendants.
/
REQUESTS FOR ADMISSIONS SERVED WITH THE COMPLAINT ON DEFENDANT
Defendant, KEVIN KINNEY, is hereby requested to answer the attached Requests for
Admissions being 10 in number by the Plaintiff, LINDSAY CULLINAN, within the forty-five
(45) days allowed by Rule 1.370 of the Florida Rules of Civil Procedure.
Dated this 29" day of March, 2021.
LEEDER LAW
Attorneys for Plaintiff
8551 West Sunrise Blvd., Ste. 202
Plantation, FL 33322
Telephone (954) 734-2382
Pleadings@leederlaw.com
By:/s/ Collins S DelPereio
THOMAS H. LEEDER, ESQ.
FBN: 746401
COLLINS S. DELPERCIO, ESQ.
FBN: 101497110.
For each of the following questions, the relevant time period and location are described in
the complaint for this subject incident.
Admit — CAITLYN KINNEY operated the 2016 Hyundai vehicle involved in the motor
vehicle collision described in the Complaint.
Admit - CAITLYN KINNEY had permissions from KEVIN KINNEY to operate the 2016
Hyundai vehicle involved in the motor vehicle collision described in the Complaint.
Admit — CAITLYN KINNEY crashed into the vehicle operated by the Plaintiff.
Admit — KEVIN KINNEY is completely at fault for this car crash.
Admit — There is nothing LINDSAY CULLINAN could have done to avoid this car crash.
Admit — LINDSAY CULLINAN has no fault in this car crash.
Admit — LINDSAY CULLINAN was injured as a result of this car crash.
Admit — LINDSAY CULLINAN suffered a permanent injury(s) as a result of this car crash.
Admit — All of LINDSAY CULLINAN’s medical care and treatment was reasonable,
necessary and related to this car crash.
Admit — There are no Fabre Defendants responsible for the injuries sustained by
LINDSAY CULLINAN.
Document Filed Date
March 29, 2021
Case Filing Date
March 29, 2021
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Filing # 123904117 E-Filed 03/29/2021 10:13:16 AM IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR INDIAN RIVER COUNTY, FLORIDA CASE NO.: 312021CA000191XXXXXX LINDSAY CULLINAN, Plaintiff, vs. CAITLYN KINNEY, KEVIN KINNEY and PROGRESSIVE ADVANCED INSURANCE COMPANY, a foreign corporation, Defendants. / REQUESTS FOR ADMISSIONS SERVED WITH THE COMPLAINT ON DEFENDANT Defendant, KEVIN KINNEY, is hereby requested to answer the attached Requests for Admissions being 10 in number by the Plaintiff, LINDSAY CULLINAN, within the forty-five (45) days allowed by Rule 1.370 of the Florida Rules of Civil Procedure. Dated this 29" day of March, 2021. LEEDER LAW Attorneys for Plaintiff 8551 West Sunrise Blvd., Ste. 202 Plantation, FL 33322 Telephone (954) 734-2382 Pleadings@leederlaw.com By:/s/ Collins S DelPereio THOMAS H. LEEDER, ESQ. FBN: 746401 COLLINS S. DELPERCIO, ESQ. FBN: 101497110. For each of the following questions, the relevant time period and location are described in the complaint for this subject incident. Admit — CAITLYN KINNEY operated the 2016 Hyundai vehicle involved in the motor vehicle collision described in the Complaint. Admit - CAITLYN KINNEY had permissions from KEVIN KINNEY to operate the 2016 Hyundai vehicle involved in the motor vehicle collision described in the Complaint. Admit — CAITLYN KINNEY crashed into the vehicle operated by the Plaintiff. Admit — KEVIN KINNEY is completely at fault for this car crash. Admit — There is nothing LINDSAY CULLINAN could have done to avoid this car crash. Admit — LINDSAY CULLINAN has no fault in this car crash. Admit — LINDSAY CULLINAN was injured as a result of this car crash. Admit — LINDSAY CULLINAN suffered a permanent injury(s) as a result of this car crash. Admit — All of LINDSAY CULLINAN’s medical care and treatment was reasonable, necessary and related to this car crash. Admit — There are no Fabre Defendants responsible for the injuries sustained by LINDSAY CULLINAN.