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Filing # 57123344 E-Filed 05/31/2017 03:14:37 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
SAL ANTHONY NUNZIATA, CASE NO.:
Plaintiff,
v.
STEPHEN MEREDITH SPENCER,
Defendant.
_______________________________________________/
PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS
TO DEFENDANT STEPHEN MEREDITH SPENCER
Plaintiff, SAL ANTHONY NUNZIATA, by and through the undersigned counsel,
pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant,
STEPHEN MEREDITH SPENCER, admit or deny the following within forty-five (45) days
from the date of service:
INSTRUCTIONS
In complying with this request, the following instructions shall govern:
1. For each request not admitted or denied provide the reasons why the request
cannot be admitted or denied.
2. The grounds for an objection must be given with it and are limited to privilege,
relevancy with the latter being determined in accordance with the meaning of relevancy in
discovery, and improper form.
3. If you assert lack of information or knowledge as the reason for not admitting or
denying the request, you must state that you have made reasonable inquiry to obtain the
information or knowledge and the information known or readily obtainable is insufficient for you
to admit or deny the request.
REQUESTS
1. The subject Complaint correctly names all Defendants to be sued.
2. The motor vehicle operated by Defendant, STEPHEN MEREDITH SPENCER,
on the incident date, as alleged in the Complaint, was owned only by Defendant, STEPHEN
MEREDITH SPENCER.
3. The motor vehicle being operated by Defendant, STEPHEN MEREDITH
SPENCER, on the date of the subject incident came into contact with the vehicle in which
Plaintiff, SAL ANTHONY NUNZIATA, was operating.
4. You, STEPHEN MEREDITH SPENCER, were traveling eastbound on East
Orlando Street, pulled from a stop sign and directly into the path of Plaintiff’s vehicle, causing
your vehicle to collide with the vehicle being operated by Plaintiff, SAL ANTHONY
NUNZIATA.
5. Plaintiff, SAL ANTHONY NUNZIATA, sustained injuries as a result of the
actions of Defendant, STEPHEN MEREDITH SPENCER.
6. Plaintiff, SAL ANTHONY NUNZIATA, suffered a permanent injury as a result
of the actions of Defendant, STEPHEN MEREDITH SPENCER.
7. Plaintiff, SAL ANTHONY NUNZIATA, was wearing a seat belt at the time of
the subject accident.
8. Plaintiff, SAL ANTHONY NUNZIATA, incurred medical expenses as a result
of the subject accident.
9. The medical bills incurred by Plaintiff, SAL ANTHONY NUNZIATA, were
reasonably related to the injuries sustained by Plaintiff, SAL ANTHONY NUNZIATA, in the
subject accident.
10. The medical bills incurred by Plaintiff, SAL ANTHONY NUNZIATA, were
reasonable and necessary as a result of the injuries the Plaintiff, SAL ANTHONY NUNZIATA,
sustained in the subject accident.
11. Defendant, STEPHEN MEREDITH SPENCER, was solely negligent for the
subject accident.
12. Plaintiff, SAL ANTHONY NUNZIATA, was not in any way responsible for the
subject accident.
13. Defendant, STEPHEN MEREDITH SPENCER, is solely responsible for the
subject accident.
14. Plaintiff, SAL ANTHONY NUNZIATA, is not subject to any comparative
negligence related to the subject accident.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
contemporaneously with the Summons and Complaint.
/s/ Jonathan E. Bukowski
Vaughan Law Group, P.A.
121 S. Orange Avenue, Suite 900
Orlando, FL 32801
P: (407) 648-4535, F: (407) 426-9512
E-Mail: jbukowski@vaughanpa.com
Florida Bar No: 0093557
Attorney for Plaintiff
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Filing # 57123344 E-Filed 05/31/2017 03:14:37 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA SAL ANTHONY NUNZIATA, CASE NO.: Plaintiff, v. STEPHEN MEREDITH SPENCER, Defendant. _______________________________________________/ PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT STEPHEN MEREDITH SPENCER Plaintiff, SAL ANTHONY NUNZIATA, by and through the undersigned counsel, pursuant to Rule 1.370, Florida Rules of Civil Procedure, hereby requests that Defendant, STEPHEN MEREDITH SPENCER, admit or deny the following within forty-five (45) days from the date of service: INSTRUCTIONS In complying with this request, the following instructions shall govern: 1. For each request not admitted or denied provide the reasons why the request cannot be admitted or denied. 2. The grounds for an objection must be given with it and are limited to privilege, relevancy with the latter being determined in accordance with the meaning of relevancy in discovery, and improper form. 3. If you assert lack of information or knowledge as the reason for not admitting or denying the request, you must state that you have made reasonable inquiry to obtain the information or knowledge and the information known or readily obtainable is insufficient for you to admit or deny the request. REQUESTS 1. The subject Complaint correctly names all Defendants to be sued. 2. The motor vehicle operated by Defendant, STEPHEN MEREDITH SPENCER, on the incident date, as alleged in the Complaint, was owned only by Defendant, STEPHEN MEREDITH SPENCER. 3. The motor vehicle being operated by Defendant, STEPHEN MEREDITH SPENCER, on the date of the subject incident came into contact with the vehicle in which Plaintiff, SAL ANTHONY NUNZIATA, was operating. 4. You, STEPHEN MEREDITH SPENCER, were traveling eastbound on East Orlando Street, pulled from a stop sign and directly into the path of Plaintiff’s vehicle, causing your vehicle to collide with the vehicle being operated by Plaintiff, SAL ANTHONY NUNZIATA. 5. Plaintiff, SAL ANTHONY NUNZIATA, sustained injuries as a result of the actions of Defendant, STEPHEN MEREDITH SPENCER. 6. Plaintiff, SAL ANTHONY NUNZIATA, suffered a permanent injury as a result of the actions of Defendant, STEPHEN MEREDITH SPENCER. 7. Plaintiff, SAL ANTHONY NUNZIATA, was wearing a seat belt at the time of the subject accident. 8. Plaintiff, SAL ANTHONY NUNZIATA, incurred medical expenses as a result of the subject accident. 9. The medical bills incurred by Plaintiff, SAL ANTHONY NUNZIATA, were reasonably related to the injuries sustained by Plaintiff, SAL ANTHONY NUNZIATA, in the subject accident. 10. The medical bills incurred by Plaintiff, SAL ANTHONY NUNZIATA, were reasonable and necessary as a result of the injuries the Plaintiff, SAL ANTHONY NUNZIATA, sustained in the subject accident. 11. Defendant, STEPHEN MEREDITH SPENCER, was solely negligent for the subject accident. 12. Plaintiff, SAL ANTHONY NUNZIATA, was not in any way responsible for the subject accident. 13. Defendant, STEPHEN MEREDITH SPENCER, is solely responsible for the subject accident. 14. Plaintiff, SAL ANTHONY NUNZIATA, is not subject to any comparative negligence related to the subject accident. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served contemporaneously with the Summons and Complaint. /s/ Jonathan E. Bukowski Vaughan Law Group, P.A. 121 S. Orange Avenue, Suite 900 Orlando, FL 32801 P: (407) 648-4535, F: (407) 426-9512 E-Mail: jbukowski@vaughanpa.com Florida Bar No: 0093557 Attorney for Plaintiff