PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. XX
MARY GARCIA,
Plaintiff,
v.
SMITH INC.,
Defendant.
_________________________________/
PLAINTIFF’S REQUEST FOR ADMISSIONS TO DEFENDANT
The Defendant, SMITH INC. is requested to admit or deny the following allegations pursuant to the appropriate Florida Rule of Civil Procedure:
- On XX, 20__, SMITH INC., was the owner of the XX.
- Prior to XX, 20__, an employee of the Defendant placed oil, grease, or another substance on the rungs of the ladder affixed to the Defendant’s shopping center.
- Prior to XX, 2__, an employee of the Defendant’s management company placed oil, grease, or another substance on the rungs of at least one ladder affixed to the Defendant’s shopping center.
- On XX, 20__, the Plaintiff, MARY GARCIA, was an invitee upon the Defendant’s premises at the time the subject incident occurred.
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been served upon the Defendant with the Complaint.
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
By__________________________
ALAN D. SACKRIN
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