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Filing # 113343510 E-Filed 09/14/2020 05:05:25 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE 19-026009 (03)
CHANDLER JEAN BAPTISTE,
Plaintiff,
vs.
CITY OF SUNRISE AND
FRANK ANTHONY OTELLO,
Defendants.
/
PLAINTIFF’S REQUEST FOR ADMISSIONS
COMES NOW, the Plaintiff, CHANDLER JEAN BAPTISTE, by and through his
undersigned attorney, pursuant to rule 1.370, Florida Rules of Civil Procedure, and demands that
the Defendant, FRANK ANTHONY OTELLO, answer this Request for Admissions within thirty
(30) days from the date hereof.
1. Please admit that FRANK ANTHONY OTELLO, had permission from the City of
Sunrise to use the 2008 Red Ford SPUV (VIN: IFMEU63838UA88650) for work! on
August 22, 2018 at the time the subject collision occurred.”
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.”
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-
| This follow-up request for admission is begin made in the context of Plaintiff's first request for admission
number 4 (certificate of service 8/12/20). The request is intended to clarify the Defendant Frank Othello’s
indirect response to request for admission number 4 (certificate of service date: 9/11/2020).
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/14/2020 05:05:25 PM.****work]-related transportation’ on August 22, 2018 at the time the subject collision
occurred.”
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.”
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’
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’.
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).
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded by
Electronic Mail to: E. BRUCE JOHNSON, ESQ., JOHNSON, ANSELMO, MURDOCH,
BURKE, PIPER, & HOCHMAN, P.A., Attorneys for Defendant, CITY OF SUNRISE,
johnson@jambg.com, and OSCAR E. MARRERO, ESQ., MARRERO & WYDLER, Attorneys
for Defendant, FRANK ANTHON OTELLO, oem@marrerolegal.com, this 14 day of
September, 2020.
MILLER LAW GROUP, P.A.
1937 East Atlantic Boulevard, Suite 204
Pompano Beach, Florida 33060
Telephone: (954)972-8011
Telefax: (954)782-3636Primary E-Mail: litigation@millerlaw legal
/s/ Mohammed Haider
By:
MOHAMMED HAIDER
Florida Bar No. 1003274‘371080298Ea
at
1
COMPLAINT
\WOsEN PRESENTED 70 VREAATOR, Tre FOLLOWING AINOUNT WAS ENTERED
PAY ACV PRMAL IY IN TH AMOUNT OF
CASE NO
DogRET uD PAGE NO
(Dems Coen at Demir oi ee
CORFE T
TE Fe
BAW Boxe ATS OR CASH DEPQIT OF E
TEE BF RRO TG
Teor 7 r
FRAN THE AMOUNT OF B
COURT SCHEDULE
RECEIVED AB REGRAARD BY
‘BERATORE OF CER
‘CONTMuANCH TO —__ REASON.
CONTINUANDE TO. EASON
DONO ES RE ATED.
We SUED,
WAOUATOR FARED 15 APPEAR DAMEN ICENEE SUEPENDED,
Boning Ciemp error
Deearoee rare cates me Cleeriran eure
VORATOR ARRARGORED OW
FEA
‘APPEAL BOND OF $
PRS cee
a eT ee
VOUATORS PNGERDRPLT HoH
2PRADLE —mneenali
Exhibit “A’COUNTY COURT DISPOSITION ORDER IN AND FOR BROWARD COUNTY, FLORIDA
2211 - North MASHoerioy/ Trial /infemctien/Room 3
DATE: 11/20/2018 - 10:00AM CASENO. 14945580T120A arty: Unger, Kevin
CASH BOND. AMOUNT, APPLY TO COSTS RETURN TO DEPOSITOR
STATE OF FLORIDA VS Otello, Frank Anthony
CHARGES : 1 Careless Driving (907+
ZL
CHANGE OF PLEA wwrmmsro 47 sapr. GUILTY _ ops
TRIAL HELD BY COURT “LIN AMSENTIA _ ACQUITTED BY COURT. RE- EXAM
DISMISSED _—_ SUPPLEMENT F 1 LE WITH PROOF -N 30/60 DAYS TO BE DISMISSED
ABLE TO Do Ci ITY SERVICE #RATE ORS 4" ROUR TOWARD FINES cosrs
OTHER: 2 Ne IT
DEFENSE CONTINUANCE __ STATE CONTINUANCE _ COURT CONTINUANCE
SET FOR TRIAL TRANSFER TO JUDG OR INJURIES 06
ORDER ASSESSING CHARGES/COSTS/FEES
‘the defendant ia heroby order ay The following STE pAcrecne :
FINE, NBG count costs SSIES TOTAL eo a
PINE COURT COSTS: _ ‘TOTAL
PINE__ courT costs TOTAL
PINE court costs TOTAL
FINE COURT CosTS TOTAL
waapaTory costs
admin Order VI-02-D-3 (Court Comta)
_($2/count) F 8,938.19 (Taen Court /County Ordinance sec. 10-5)
(430/count) F.8.316.18(13) (a) /Court Facilities Pund
~(§3/count) P.8.318.16(27) (Radio Bysten Fas?
($2,50/count}¥.#.318.28(12) (e) (Additional Criminal Justice Education)
($5/count) F..318.1215 (Drivers Education Trust Fund)
($22.50/count) 7.8. 318.18(18) (Administrative Fee)
(810/eount) Article V (all non-criminal moving charges uider 316,320,322)
(65/count) ACDH/DOMF.5.310.18(5) (c) (Passing School Rus)
(9500/case) P,5,318.14(5) (Serious Bodily Injury)
(91000/ease)F.6.318.14 (5) (Eatality/Serious Bodily Injury)
($65/eount) 7. 8.218.185 (e) (Paseing A Stopped School Bus (ACDE)
OTHER
Other:
Late/D6 f:
fines/taen}
Revived oN
:
WUST BE PAID ay; O2-22-)4 7
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Filing # 113343510 E-Filed 09/14/2020 05:05:25 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 19-026009 (03) CHANDLER JEAN BAPTISTE, Plaintiff, vs. CITY OF SUNRISE AND FRANK ANTHONY OTELLO, Defendants. / PLAINTIFF’S REQUEST FOR ADMISSIONS COMES NOW, the Plaintiff, CHANDLER JEAN BAPTISTE, by and through his undersigned attorney, pursuant to rule 1.370, Florida Rules of Civil Procedure, and demands that the Defendant, FRANK ANTHONY OTELLO, answer this Request for Admissions within thirty (30) days from the date hereof. 1. Please admit that FRANK ANTHONY OTELLO, had permission from the City of Sunrise to use the 2008 Red Ford SPUV (VIN: IFMEU63838UA88650) for work! on August 22, 2018 at the time the subject collision occurred.” 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.” 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- | This follow-up request for admission is begin made in the context of Plaintiff's first request for admission number 4 (certificate of service 8/12/20). The request is intended to clarify the Defendant Frank Othello’s indirect response to request for admission number 4 (certificate of service date: 9/11/2020). *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/14/2020 05:05:25 PM.****work]-related transportation’ on August 22, 2018 at the time the subject collision occurred.” 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.” 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’ 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’. 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). CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded by Electronic Mail to: E. BRUCE JOHNSON, ESQ., JOHNSON, ANSELMO, MURDOCH, BURKE, PIPER, & HOCHMAN, P.A., Attorneys for Defendant, CITY OF SUNRISE, johnson@jambg.com, and OSCAR E. MARRERO, ESQ., MARRERO & WYDLER, Attorneys for Defendant, FRANK ANTHON OTELLO, oem@marrerolegal.com, this 14 day of September, 2020. MILLER LAW GROUP, P.A. 1937 East Atlantic Boulevard, Suite 204 Pompano Beach, Florida 33060 Telephone: (954)972-8011 Telefax: (954)782-3636Primary E-Mail: litigation@millerlaw legal /s/ Mohammed Haider By: MOHAMMED HAIDER Florida Bar No. 1003274‘371080298Ea at 1 COMPLAINT \WOsEN PRESENTED 70 VREAATOR, Tre FOLLOWING AINOUNT WAS ENTERED PAY ACV PRMAL IY IN TH AMOUNT OF CASE NO DogRET uD PAGE NO (Dems Coen at Demir oi ee CORFE T TE Fe BAW Boxe ATS OR CASH DEPQIT OF E TEE BF RRO TG Teor 7 r FRAN THE AMOUNT OF B COURT SCHEDULE RECEIVED AB REGRAARD BY ‘BERATORE OF CER ‘CONTMuANCH TO —__ REASON. CONTINUANDE TO. EASON DONO ES RE ATED. We SUED, WAOUATOR FARED 15 APPEAR DAMEN ICENEE SUEPENDED, Boning Ciemp error Deearoee rare cates me Cleeriran eure VORATOR ARRARGORED OW FEA ‘APPEAL BOND OF $ PRS cee a eT ee VOUATORS PNGERDRPLT HoH 2PRADLE —mneenali Exhibit “A’COUNTY COURT DISPOSITION ORDER IN AND FOR BROWARD COUNTY, FLORIDA 2211 - North MASHoerioy/ Trial /infemctien/Room 3 DATE: 11/20/2018 - 10:00AM CASENO. 14945580T120A arty: Unger, Kevin CASH BOND. AMOUNT, APPLY TO COSTS RETURN TO DEPOSITOR STATE OF FLORIDA VS Otello, Frank Anthony CHARGES : 1 Careless Driving (907+ ZL CHANGE OF PLEA wwrmmsro 47 sapr. GUILTY _ ops TRIAL HELD BY COURT “LIN AMSENTIA _ ACQUITTED BY COURT. RE- EXAM DISMISSED _—_ SUPPLEMENT F 1 LE WITH PROOF -N 30/60 DAYS TO BE DISMISSED ABLE TO Do Ci ITY SERVICE #RATE ORS 4" ROUR TOWARD FINES cosrs OTHER: 2 Ne IT DEFENSE CONTINUANCE __ STATE CONTINUANCE _ COURT CONTINUANCE SET FOR TRIAL TRANSFER TO JUDG OR INJURIES 06 ORDER ASSESSING CHARGES/COSTS/FEES ‘the defendant ia heroby order ay The following STE pAcrecne : FINE, NBG count costs SSIES TOTAL eo a PINE COURT COSTS: _ ‘TOTAL PINE__ courT costs TOTAL PINE court costs TOTAL FINE COURT CosTS TOTAL waapaTory costs admin Order VI-02-D-3 (Court Comta) _($2/count) F 8,938.19 (Taen Court /County Ordinance sec. 10-5) (430/count) F.8.316.18(13) (a) /Court Facilities Pund ~(§3/count) P.8.318.16(27) (Radio Bysten Fas? ($2,50/count}¥.#.318.28(12) (e) (Additional Criminal Justice Education) ($5/count) F..318.1215 (Drivers Education Trust Fund) ($22.50/count) 7.8. 318.18(18) (Administrative Fee) (810/eount) Article V (all non-criminal moving charges uider 316,320,322) (65/count) ACDH/DOMF.5.310.18(5) (c) (Passing School Rus) (9500/case) P,5,318.14(5) (Serious Bodily Injury) (91000/ease)F.6.318.14 (5) (Eatality/Serious Bodily Injury) ($65/eount) 7. 8.218.185 (e) (Paseing A Stopped School Bus (ACDE) OTHER Other: Late/D6 f: fines/taen} Revived oN : WUST BE PAID ay; O2-22-)4 7