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Notice Of Interrogatories
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: 13-01xxxx
MILESTONE PROPERTIES INC. and,
DUFFY'S DINER, INC. D/B/A DUFFY'S DINER,
PLAINTIFF'S NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT
The Plaintiff, B.O.G., pursuant to Rule 1.340 and other applicable rules of the Florida Rules of Civil Procedure and Local Rules governing practice in and for the Seventeenth Judicial Circuit in and for Broward County, Florida, hereby files this Notice of Service of Interrogatories propounded to Defendant, MILESTONE PROPERTIES INC., and states that the original and one copy of said Interrogatories were served with the Complaint herein.
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff
2100 East Hallandale Beach Blvd.
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649
ALAN D. SACKRIN
Florida Bar No. 349070
INTERROGATORIES TO DEFENDANT
(If answering for another person or entity, answer with respect to that person or entity, unless otherwise stated.)
1. What is the name and address of the person answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed?
2. Describe in detail how the defendant contends the incident described in the Complaint happened.
3. Describe in detail each act or omission on the part of the Plaintiff that the defendant contends constituted negligence that was a contributing legal cause of the incident in question.
4. State the facts upon which you rely for each affirmative defense in your answer.
5. Does the defendant contend that any personal entity not named as a party in this lawsuit is, or may be, liable in whole or in part for the claims asserted against defendant in this lawsuit? If so, state the full name and address of each such person or entity, the legal basis for defendant=s contention, the facts or evidence upon which defendant's contention is based, and whether or not the defendant has notified each such person or entity of its contention.
6. List the names and addresses for all persons who are believed or known by the defendant, its agents or its attorneys to have any knowledge concerning the occurrence of the incident which is the subject matter of this lawsuit, including eye-witnesses, persons who arrived at the scene of the incident within 30 minutes of its occurrence and persons who have knowledge of any foreign or transitory substance that was on the floor at the time of and/or after the subject incident.
7. Please state the names and last known business and residence addresses and telephone numbers of all of Defendant=s employees who either witnessed Plaintiff fall or who had any responsibility for insuring that the area where plaintiff fell was free of foreign or transitory objects or substances.
8. State the name, address and telephone number of every person known to the defendant, its agents or its attorneys who has knowledge about or possession, custody, or control of any model, plat, map, drawing, motion picture, videotape or photograph pertaining to any fact or issue involved in this controversy; and describe as to each what item such person has, the name and address of the person who took or prepared it, the date it was taken or prepared.
9. Did the defendant, through any of its employees, determine that there was a foreign or transitory substance on the floor where the incident occurred? If the answer to this interrogatory is yes, please state the name(s) and last known residence and business addresses and telephone numbers of any person who saw a foreign or transitory substance on the ground and state the nature and origin of such substance.
10. Has the defendant heard or does it know about any statement or remark made by the plaintiff concerning any issue in this lawsuit? If so, state the name and address of each person who heard the remark, and the date, time, place and substance of each statement.
11. As of the date of the incident, did the Defendant have any in store surveillance that was operational? If the answer to this interrogatory is yes, please state whether the incident and/or the area of the incident is/was contained on area surveillance and whether it is still in existence.
STATE OF )ss
COUNTY OF )
The foregoing instrument was acknowledged before me this __ day of ______________, 20__, by , is personally known to me or who has produced as identification and who did/did not take an oath.
Signature of person taking acknowledgment
Name of Officer taking acknowledgment
Title or rank
This is a sample lawsuit related to a specific set of facts and circumstances and should not be used or relied upon if you have been in a slip and fall accident. We recommend and urge you to consult with an experienced slip and fall lawyer for professional advice as each case is unique.
Quick Slip And Fall Facts:
Slip and falls are the second leading cause of injuries and deaths after car accidents. Every hour an older adult dies as a result of a fall. The most common injuries resulting from slip and falls include, herniated disc, head injury and/or a knee injury. Learn more from Alan Sackrin, an expert slip and fall lawyer.
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