NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO. XX

ROBERT JONES,

Plaintiff,

vs.

AMUSEMENT PARKS, LLC.,

Defendant.

_______________________________________/

NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF

The Defendant, AMUSEMENT PARKS, LLC., by and through its undersigned counsel, hereby files its Interrogatories pursuant to Rule 1.340, Florida Rules of Civil Procedure and the definitions and instructions set forth in Schedule A attached. The Defendant, AMUSEMENT PARKS, LLC., requests the ROBERT JONES, answer, in writing, under oath, the attached original set of Interrogatories within thirty (30 days) from the date of service hereof.

Counsel for the Defendant

BY:

Florida Bar No. XX

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the Interrogatories was sent via U.S. Mail on this ___ day of XX, 20__, to: Alan D. Sackrin, Esq., 2100 E. Hallandale Beach Blvd., S-200, Hallandale Beach, FL 33009.

BY:

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?

List the names, business addresses, phone number, job description, dates of employment and rates of pay regarding all employers, including self-employment, for whom you have worked in the past ten years.

List all former names and when you were known by those names.

Do you wear glasses, contact lenses or hearing aids? If so, who prescribed them; when were they prescribed; when were your eyes or ears last examined; and what is the name and address of the examiner?

State all addresses where you have lived for the past ten years, the dates you lived at each address, your social security number, your date of birth, and if you are or have ever been married, the name of your spouse or spouses.

Have you ever been convicted of a crime, other than any juvenile adjudication, which under the law under which you were convicted was punishable by death or imprisonment in excess of one year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction, the specific crime, the date and the place of conviction.

XX.

Were you suffering from physical infirmity, disability, or sickness at the time of the incident described in the complaint? If so, what was the nature of the infirmity, disability, or sickness?

Did you consume any alcoholic beverages or take any drugs or medication within twelve hours before the time of the incident described in the complaint? If so, state the type and amount of alcoholic beverages, drugs or medication which were consumed and where you consumed them.

Describe each injury for which you are claiming damages in this case, specifying the party of your body that was injured, the nature of the injury, and, as to any injuries you contend are permanent, the effects on you that you claim are permanent.

List each item of expense or damage, other than loss of income or earning capacity, that you claim to have incurred as a result of the incident described in the complaint, giving for each item the date incurred, the name and business address to whom each was paid or is owed, and the goods or services for which each was incurred.

Do you contend that you have lost any income, benefits, or earning capacity in the past or future as a result of the incident described in the complaint? If so, state the nature of the income, benefits, or earning capacity, and the amount and the method that you used in computing the amount.

Has anything been paid or is anything payable from any third party for the damages listed in your answers to these interrogatories? If so, state the amounts paid or payable, the name and business address of the person or entity who paid or owes said amounts, and which of those third parties have or claim a right of subrogation.

List the names and business addresses of each physician who has treated or examined you, and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this case; and state as to each the date of treatment or examination and the injury or condition for which you were examined or treated.

List the names and business addresses of all other physicians, medical facilities or other health care providers by whom or at which you have been examined or treated in the past ten years; and state as to each the dates of examination or treatment and the condition or injury for which you were examined or treated.

List the names and addresses of all persons who are believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge.

Have you heard or do you know about any statement or remark made by or on behalf of any party to this lawsuit, other than yourself, concerning any issue in this lawsuit? If so, state the name and address of each person who made the statement or statements, the name and address of each person who heard it, and the date, time, place and substance of each statement.

State the name and address of every person known to you, your agents, or attorneys, who has knowledge about, or possession, custody or control of any model, plat, map, drawing, motion picture, video tape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared.

Do you intend to call any expert witnesses at the trial of this case? If so, state as to each such witness the name and business address of the witness, the witness’s qualifications as an expert, the subject matter upon which the witness is expected to testify, the substance of the facts and opinions to which the witness is expected to testify, and a summary of the grounds for each opinion.

Have you made an agreement with anyone that would limit that party’s liability to anyone for any of the damages sued upon in this case? If so, state the terms of the agreement and the parties to it.

Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit or workers compensation claim other than the present matter and if so, state whether you were plaintiff or defendant, the nature of the action, and the date and court in which such suit was filed.

Please describe any and all psychiatric/psychological problems you claim have resulted from the incident which is the subject matter of this lawsuit, whether you received treatment from any psychiatrist, psychologist, and/or mental health counselor, and if so, please state the name, last known address and the date the treatment was received from the psychiatrist, psychologist and/or mental health counselor.

Please state whether or not any photographs exist which depict the objects and/or injuries to the Plaintiff. If so, please identify the subject matter of said photographs and the person presently having custody of photographs.

________________________

ROBERT JONES

STATE OF FLORIDA )

)SS.

COUNTY OF BROWARD__)

SWORN TO AND SUBSCRIBED BEFORE ME this day of XX, 20_ by Robert Jones, qwho is personally known to me or qwho has produced his Driver’s License as identification and who qdid qdid not take an oath.

Notary Public, State of Florida at Large

Type or Print Name: __________________

My Commission Expires:

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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.

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NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF – case 5

NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF

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