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`IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
`IN AND FOR PINELLAS COUNTY, FLORIDA
`CIVIL DIVISION
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`GILLIAN TATTERSALL,
`Plaintiff,
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`vs.
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`TRAVIS CORPORATION OF PINELLAS
`COUNTY, D.B.A. BAY PINES MARINA,
`Defendant.
`_________________________________________/
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`Case No.:
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`PLAINTIFF’S REQUEST FOR ADMISSIONS
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`PURSUANT TO Rule 1.370, Florida Rules of Civil Procedure, the Plaintiff, GILLIAN
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`TATTERSALL, by and through the undersigned counsel, requests the Defendant, TRAVIS
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`CORPORATION OF PINELLAS COUNTY, d.b.a. BAY PINES MARINA (hereinafter
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`“Bay Pines Marina”), to admit or deny the following under oath, for the purpose of this
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`action; that each of the following statements are true:
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`1.
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`Admit that a trip and fall incident occurred on October 14, 2020, on the property of
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`the Defendant, BAY PINES MARINA, located at 5000 92nd Avenue N., Seminole,
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`FL 33708.
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`2.
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`Admit that the above-referenced trip and fall occurred as a result of the failure of
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`BAY PINES MARINA staff to ensure that no dangerous conditions were on the
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`pathway where business invitees would walk.
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`3.
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`Admit that as a result of the trip and fall accident occurring on or about October 14,
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`2020, the Plaintiff, GILLIAN TATTERSALL, sustained permanent bodily injuries
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`legally caused by the negligence of the Defendant, BAY PINES MARINA.
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`***ELECTRONICALLY FILED 07/28/2022 04:21:02 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
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`4.
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`Admit that there was no comparative negligence on the part of the Plaintiff,
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`GILLIAN TATTERSALL, contributing to her injuries sustained in the subject trip
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`and fall incident.
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`5.
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`Admit that there was no negligence as to third parties which was a legal cause of
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`the subject trip and fall incident, which is the subject matter of the instant lawsuit.
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`6.
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`Admit that all medical treatment received by Plaintiff, GILLIAN TATTERSALL,
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`as a result of the subject incident was necessary.
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`7.
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`Admit that all charges for medical treatment received by Plaintiff, GILLAIN
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`TATTERSALL, as a result of the subject incident were reasonable in light of
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`charges for similar services in the community where rendered.
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`8.
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`Admit that the Plaintiff, GILLIAN TATTERSALL, was a BUSINESS INVITEE
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`of BAY PINES MARINA, which is a Florida Corporation, authorized to do
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`business in the state of Florida, at the time of the trip and fall incident, which is
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`the subject matter of the instant lawsuit.
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`CERTIFICATE OF SERVICE
`I HEREBY CERTIFY, that a true and correct copy of the foregoing has been served with
`the complaint in this matter.
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`/s/ William J. Flores
`WIL FLORES, P.A.
`William J. Flores, Esq.
`Fla. Bar No. 111485
`WFlores@DeliveringYouJustice.com
`5120 Central Ave.
`St. Petersburg, FL 33707
`Phone:(727) 800-6239
`Fax: (727) 328-3536
`Attorney for the Plaintiff
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