On March 15, 2019 a
Party Discovery
was filed
involving a dispute between
Lucas, Dean,
and
Florida Farm Bureau General Insurance Company,
Helm, Ronna Lee,
Jagoda, Lisa N,
Jagoda, Neal,
for AUTO NEGLIGENCE
in the District Court of Indian River County.
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Filing # 86459264 E-Filed 03/15/2019 01:10:16 PM
IN THE CIRCUIT COURT OF THE
NINETEENTH JUDICIAL CIRCUIT, IN AND
FOR INDIAN RIVER COUNTY, FLORIDA
CASE NO. 312019CA000223XXXXXX
DEAN LUCAS,
Plaintiff,
vs.
RONNA LEE HELM, NEAL JAGODA
AND FLORIDA FARM BUREAU.
GENERAL INSURANCE COMPANY,
Defendants. /
REQUEST FOR ADMISSIONS TO DEFENDANT, NEAL JAGODA
COMES NOW the Plaintiff, DEAN LUCAS, by and through her undersigned counsel,
pursuant to Rule 1.370, Florida Rules of Civil Procedure, and hereby requests that Defendant,
NEAL JAGODA, admit the following within 45 days from date of service:
1. Please admit that this action brought against Defendant, NEAL JAGODA,
properly and correctly name the party to be sued in this cause.
2. Please admit that jurisdiction for the Complaint filed by Plaintiff is properly
brought before the Circuit Court in Indian River County, Florida.
3. Please admit that the service of process against the Defendant, NEAL JAGODA,
was proper.
4. Please admit that this is an action for damages in excess of Fifteen Thousand
Dollars ($15,000.00) arising in Indian River County, Florida.
5. Please admit that Defendant, RONNA LEE HELM, was operating a motor vehicle
on or about July 22, 2017, traveling west on 65" Street in Vero Beach, Indian River County,
Florida.6. Please admit that the motor vehicle operated by Defendant, RONNA LEE HELM,
was owned by Defendant, NEAL JAGODA, and was being operated by RONNA LEE HELM, with
your permission and consent.
7. Please admit that Defendant, RONNA LEE HELM, was negligent in the operation
of a motor vehicle when she failed to yield the right of way and proceeded through the intersection
causing Plaintiffs vehicle to collide with her vehicle.
8. Please admit that Defendant, RONNA LEE HELM, received a citation issued by the
investigating law enforcement agency arising out of the subject accident.
9. Please admit that Defendant, RONNA LEE HELM, pled guilty to said citation in
connection with the subject accident.
10. Please admit that Plaintiff was injured in the subject accident.
11. Please admit that Plaintiff suffered a permanent injury within a reasonable degree of
medical probability resulting from the subject accident.
12. Please admit that Plaintiff was not guilty of negligence which caused or contributed
to the subject accident.
13. Please admit that Plaintiff incurred medical expenses for treatment of injuries
resulting from the subject accident.
14. Please admit that Plaintiff's medical expenses were reasonable and necessary for the
care and treatment of the injuries sustained in the subject accident.Dated this 15" day of March, 2019
/s/ W. Clay Mitchell, Jr.
W. Clay Mitchell, Jr., Esquire
FBN 0077488
Morgan & Morgan, P.A.
20 N. Orange Avenue, 9" Floor
Orlando, FL 32801
Telephone: (407) 420-1414
Facsimile: (407) 245-3416
Primary email: CMitchell@forthepeople.com
Secondary email: daliarivera@forthepeople.com
Attorneys for Plaintiff
Document Filed Date
March 15, 2019
Case Filing Date
March 15, 2019
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Filing # 86459264 E-Filed 03/15/2019 01:10:16 PM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, IN AND FOR INDIAN RIVER COUNTY, FLORIDA CASE NO. 312019CA000223XXXXXX DEAN LUCAS, Plaintiff, vs. RONNA LEE HELM, NEAL JAGODA AND FLORIDA FARM BUREAU. GENERAL INSURANCE COMPANY, Defendants. / REQUEST FOR ADMISSIONS TO DEFENDANT, NEAL JAGODA COMES NOW the Plaintiff, DEAN LUCAS, by and through her undersigned counsel, pursuant to Rule 1.370, Florida Rules of Civil Procedure, and hereby requests that Defendant, NEAL JAGODA, admit the following within 45 days from date of service: 1. Please admit that this action brought against Defendant, NEAL JAGODA, properly and correctly name the party to be sued in this cause. 2. Please admit that jurisdiction for the Complaint filed by Plaintiff is properly brought before the Circuit Court in Indian River County, Florida. 3. Please admit that the service of process against the Defendant, NEAL JAGODA, was proper. 4. Please admit that this is an action for damages in excess of Fifteen Thousand Dollars ($15,000.00) arising in Indian River County, Florida. 5. Please admit that Defendant, RONNA LEE HELM, was operating a motor vehicle on or about July 22, 2017, traveling west on 65" Street in Vero Beach, Indian River County, Florida.6. Please admit that the motor vehicle operated by Defendant, RONNA LEE HELM, was owned by Defendant, NEAL JAGODA, and was being operated by RONNA LEE HELM, with your permission and consent. 7. Please admit that Defendant, RONNA LEE HELM, was negligent in the operation of a motor vehicle when she failed to yield the right of way and proceeded through the intersection causing Plaintiffs vehicle to collide with her vehicle. 8. Please admit that Defendant, RONNA LEE HELM, received a citation issued by the investigating law enforcement agency arising out of the subject accident. 9. Please admit that Defendant, RONNA LEE HELM, pled guilty to said citation in connection with the subject accident. 10. Please admit that Plaintiff was injured in the subject accident. 11. Please admit that Plaintiff suffered a permanent injury within a reasonable degree of medical probability resulting from the subject accident. 12. Please admit that Plaintiff was not guilty of negligence which caused or contributed to the subject accident. 13. Please admit that Plaintiff incurred medical expenses for treatment of injuries resulting from the subject accident. 14. Please admit that Plaintiff's medical expenses were reasonable and necessary for the care and treatment of the injuries sustained in the subject accident.Dated this 15" day of March, 2019 /s/ W. Clay Mitchell, Jr. W. Clay Mitchell, Jr., Esquire FBN 0077488 Morgan & Morgan, P.A. 20 N. Orange Avenue, 9" Floor Orlando, FL 32801 Telephone: (407) 420-1414 Facsimile: (407) 245-3416 Primary email: CMitchell@forthepeople.com Secondary email: daliarivera@forthepeople.com Attorneys for Plaintiff