On December 19, 2019 a
Party Discovery
was filed
involving a dispute between
Jean Baptiste, Chandler,
and
City Of Sunrise,
Otello, Frank Anthony,
for Auto Negligence
in the District Court of Broward County.
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Filing # 114987127 E-Filed 10/14/2020 04:52:20 PM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CHANDLER JEAN BAPTISTE, CASE NO.: CACE19-026009 (03)
Plaintiff,
vs.
CITY OF SUNRISE, and
FRANK ANTHONY OTELLO,
Defendants.
eee eee eee ee eee eee eee
DEFENDANT OTELLO’S RESPONSE TO
TIFF’S SECOND REQUEST FOR ADMISSIONS
The Defendant, FRANK OTELLO by and through undersigned counsel, pursuant to
Fla.R.Civ.P. 1.370, hereby responds to the Plaintiff's Second Request for Admissions, dated
September 14, 2020, and states as follows:
1. Please admit that FRANK ANTHONY OTELLO, had permission from the City
of Sunrise to use the 2008 Red Ford SPUV (VIN: 1FMEU63838UA88650) for work on August
22, 2018 at the time the subject collision occurred.
RESPONSE: Admitted.
2. Please admit that FRANK ANTHONY OTELLO was using the 2008 Red Ford
SPUV (VIN: 1FMEU63838UA88650) for work on August 22, 2018 at the time the subject
collision occurred.
RESPONSE: Admitted.
3. Please admit that FRANK ANTHONY OTELLO had permission from the City of
Sunrise to use the 2008 Red Ford SPUV (VIN: 1FMEU63838UA88650) for reasonably-[work]-
related transportation on August 22, 2018 at the time the subject collision occurred.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/14/2020 04:52:19 PM.****Jean Baptiste v. City of Sunrise, et al.
Case Number CACE-19-026009
Page 2 of 4
RESPONSE: Admitted.
4. Please admit that FRANK ANTHONY OTELLO was using the 2008 Red Ford
SPUV (VIN: 1FMEU63838UA88650) for reasonably-[work]-related transportation on August
22, 2018 at the time the subject collision occurred.
RESPONSE: Admitted.
5. Please admit that you were charged with “careless driving/Failing to Drive in a
Safe Manner/Failing to Yield Right of Way and Improper Turn” as a result of the subject
collision, as reflected in Exhibit “A”.
RESPONSE: Admit only that Frank Otello was charged with careless driving
pursuant to Fla. Stat. §316.1925(1). Objection regarding the remainder of this request
because it calls for a legal conclusion.
6. Please admit that you were convicted of “careless driving” as a result of the
subject collision on November 11, 2018 by Judge Louis Schiff as reflected in Exhibit “B”.
RESPONSE: Denied.
7. Please admit that you paid $240.00 to the Clerk of the Court for court imposed
fines and court costs as part of the Court’s disposition of traffic citation AADXCDE (Case No.:
18045580TI20A).
RESPONSE: Admitted.Jean Baptiste v. City of Sunrise, et al.
Case Number CACE-19-026009
Page 3 of 4
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
Electronically filed with the Clerk of the Court, who will electronically serve on all counsel on
the attached service list this 14th of October, 2020.
MARRERO & WYDLER
Counsel for Defendant, Otello
2600 Douglas Road, PH-4
Coral Gables, FL 33134
(305) 446-5528
(305) 446-0995 (fax)
BY _/s/__ Oscar E. Marrero
OSCAR E. MARRERO
F.B.N.: 372714
oem@marrerolegal.com
LOURDES E. WYDLER
F.B.N.: 719811
lew@marrerolegal.com
CHARLSIE J. HARRIS
F.B.N.: 1018830
cjh@marrerolegal.comSERVICE LIST
Mohammed Haider, Esq.
MILLER LAW GROUP, P.A.
1937 East Atlantic Blvd., Suite 204
Pompano Beach, FL 33060
(954) 972-8011
(954) 782-3636 (fax)
litigation@millerlaw.legal
FBN: 1003274
Attorneys for Plaintiff.
E. Bruce Johnson, Esq.
johnson@jambg.com
FBN: 262137
Johnson Anselmo Murdoch, et al.
2455 E. Sunrise Boulevard, Suite 1000
Fort Lauderdale, FL 33304-3113
(954) 463-0100
(954) 463-2444 (fax)
young@jambg.com
Attorneys for Defendant, City of Sunrise.
Jean Baptiste v. City of Sunrise, et al.
Case Number CACE-19-026009
Page 4 of 4
Document Filed Date
October 14, 2020
Case Filing Date
December 19, 2019
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Filing # 114987127 E-Filed 10/14/2020 04:52:20 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CHANDLER JEAN BAPTISTE, CASE NO.: CACE19-026009 (03) Plaintiff, vs. CITY OF SUNRISE, and FRANK ANTHONY OTELLO, Defendants. eee eee eee ee eee eee eee DEFENDANT OTELLO’S RESPONSE TO TIFF’S SECOND REQUEST FOR ADMISSIONS The Defendant, FRANK OTELLO by and through undersigned counsel, pursuant to Fla.R.Civ.P. 1.370, hereby responds to the Plaintiff's Second Request for Admissions, dated September 14, 2020, and states as follows: 1. Please admit that FRANK ANTHONY OTELLO, had permission from the City of Sunrise to use the 2008 Red Ford SPUV (VIN: 1FMEU63838UA88650) for work on August 22, 2018 at the time the subject collision occurred. RESPONSE: Admitted. 2. Please admit that FRANK ANTHONY OTELLO was using the 2008 Red Ford SPUV (VIN: 1FMEU63838UA88650) for work on August 22, 2018 at the time the subject collision occurred. RESPONSE: Admitted. 3. Please admit that FRANK ANTHONY OTELLO had permission from the City of Sunrise to use the 2008 Red Ford SPUV (VIN: 1FMEU63838UA88650) for reasonably-[work]- related transportation on August 22, 2018 at the time the subject collision occurred. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/14/2020 04:52:19 PM.****Jean Baptiste v. City of Sunrise, et al. Case Number CACE-19-026009 Page 2 of 4 RESPONSE: Admitted. 4. Please admit that FRANK ANTHONY OTELLO was using the 2008 Red Ford SPUV (VIN: 1FMEU63838UA88650) for reasonably-[work]-related transportation on August 22, 2018 at the time the subject collision occurred. RESPONSE: Admitted. 5. Please admit that you were charged with “careless driving/Failing to Drive in a Safe Manner/Failing to Yield Right of Way and Improper Turn” as a result of the subject collision, as reflected in Exhibit “A”. RESPONSE: Admit only that Frank Otello was charged with careless driving pursuant to Fla. Stat. §316.1925(1). Objection regarding the remainder of this request because it calls for a legal conclusion. 6. Please admit that you were convicted of “careless driving” as a result of the subject collision on November 11, 2018 by Judge Louis Schiff as reflected in Exhibit “B”. RESPONSE: Denied. 7. Please admit that you paid $240.00 to the Clerk of the Court for court imposed fines and court costs as part of the Court’s disposition of traffic citation AADXCDE (Case No.: 18045580TI20A). RESPONSE: Admitted.Jean Baptiste v. City of Sunrise, et al. Case Number CACE-19-026009 Page 3 of 4 WE HEREBY CERTIFY that a true and correct copy of the foregoing has been Electronically filed with the Clerk of the Court, who will electronically serve on all counsel on the attached service list this 14th of October, 2020. MARRERO & WYDLER Counsel for Defendant, Otello 2600 Douglas Road, PH-4 Coral Gables, FL 33134 (305) 446-5528 (305) 446-0995 (fax) BY _/s/__ Oscar E. Marrero OSCAR E. MARRERO F.B.N.: 372714 oem@marrerolegal.com LOURDES E. WYDLER F.B.N.: 719811 lew@marrerolegal.com CHARLSIE J. HARRIS F.B.N.: 1018830 cjh@marrerolegal.comSERVICE LIST Mohammed Haider, Esq. MILLER LAW GROUP, P.A. 1937 East Atlantic Blvd., Suite 204 Pompano Beach, FL 33060 (954) 972-8011 (954) 782-3636 (fax) litigation@millerlaw.legal FBN: 1003274 Attorneys for Plaintiff. E. Bruce Johnson, Esq. johnson@jambg.com FBN: 262137 Johnson Anselmo Murdoch, et al. 2455 E. Sunrise Boulevard, Suite 1000 Fort Lauderdale, FL 33304-3113 (954) 463-0100 (954) 463-2444 (fax) young@jambg.com Attorneys for Defendant, City of Sunrise. Jean Baptiste v. City of Sunrise, et al. Case Number CACE-19-026009 Page 4 of 4