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PLAINTIFF=S NOTICE OF SERVICE OF ANSWERS TO INTERROGATORIES – case 3

PLAINTIFF=S NOTICE OF SERVICE OF ANSWERS TO INTERROGATORIES

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

CASE NO:  XX

ALEXANDER WILLIAMS,

 

Plaintiff,

vs.

 

PATIO INC.

 

Defendants.

_______________________                        /

 

PLAINTIFF=S NOTICE OF SERVICE OF

ANSWERS TO INTERROGATORIES

The Plaintiff, ALEXANDER WILLIAMS, pursuant to Rule 1.340, Florida Rules of Civil Procedure, gives notice of filing her Answers to Interrogatories from the Defendant, PATIO INC., served XX, 20__.

 

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on this ____ day of XX, 20__, a true and correct copy of the foregoing was mailed to:  XX

 

LAW OFFICE OF ALAN D. SACKRIN

Attorney for Plaintiff(s)

2100 East Hallandale Beach Blvd.

Suite 200

Hallandale Beach, FL  33009

 

By______________________________

ALAN D. SACKRIN

/kb

PLAINTIFF, ALEXANDER WILLIAMS’, ANSWERS TO INTERROGATORIES PROPOUNDED BY DEFENDANT

The Defendant, PATIO INC., propounds the following Interrogatories to the Plaintiff, ALEXANDER WILLIAMS, to be answered in writing, under oath, in accordance with the applicable Florida Rules of Civil Procedure.

  1. State your full name, present address, date of birth, and social security number.

          XX

  1. State the number of your driver’s license(s) at the time of the accident/incident referred to in the Complaint occurred and the state(s) which issued said license(s).

          XX

  1. Have you ever been convicted of a crime?  If so, state when, where, the Court and the State.

XX

  1.     State your present marital status, and if you have ever been married, state as to each marriage:  the place of marriage, the date of marriage, and the date and method of termination of said marriage.

XX

  1. Of your own knowledge describe any and all infirmities and disabilities that you have had before the accident sued upon in this case.

XX

  1. Describe any and all accidents and/or personal injuries you had suffered before the accident here and sued upon and give the date(s) and place(s) where such accidents and/or personal injuries occurred.

XX

  1. State the names and addresses of all the hospitals where you have been either an in-patient or an out-patient at any time during your life priorto the date of the accident sued upon in this case and state the dates on which you were hospitalized.

XX

  1. State the names and addresses of all doctors whom you have seen or consulted during the ten years proceeding the accident sued upon in this case and state the nature of the ailment or illness or other reason for which such doctor was consulted.

XX

  1. Please state what injuries you received in the accident sued upon in this case and if you have not fully recovered from all your injuries, describe in detail any and all pains, ailments, complaints, injuries or disability that you presently have as a result of the accident.
  1. State the names and addresses of all doctors whom you have seen or consulted on account of the accident sued upon in this case and the exact dates on which you have seen or consulted said doctors.

XX

  1. State the names and addresses of all hospitals where you have been either an in-patient or an out-patient on account of the accident sued upon in this case and state the dates on which you were so hospitalized.

XX

  1. State in itemized form the amounts of all medical expenses you are claiming were incurred by you as a result of the accident sued upon in this case.

          XX

  1. State in itemized form the amounts of all other expenses (other than medical expenses) you are claiming were incurred by you as a result of the accident sued upon in this case.

XX

  1. Describe any and all accidents and/or personal injuries you have suffered after the accident here sued upon and give the date(s) and place(s) where such accidents and or personal injuries occurred.

XX

  1. Describe the names and addresses of all hospitals where you have been either an in-patient or an out-patient at any time, for any reason unconnected with the accident and state the dates on which you were so hospitalized.

XX

  1. State the names and addresses of all doctors whom you have seen or consulted at any time, for any reason unconnected with the accident sued upon in this case, after the date of said accident and state the dates on which you have seen or consulted said doctors.

XX

  1. If you have ever made a claim or filed a lawsuit against anyone as a result of a personal injury to yourself or any member of your family, other than the accident sued upon in this case, list such claims or lawsuits and the dates and places where same were presented.

XX

  1. Please state the names and present addresses, or such information as is known regarding same, of all persons known to you and/or your attorneys and/or your representatives who were eyewitnesses and/or claim to have been in sight, hearing or in the approximate vicinity of the Plaintiff(s) at the time and place alleged in the Complaint.

XX

  1. Please state the names and present addresses of all persons – other than eyewitnesses and/or those referred to in Interrogatory Number 18 above — who have knowledge concerning the facts upon which the issues of this suit is based, including others with knowledge of the facts and circumstances surrounding the event or incident upon which this suit is based.

XX

  1. As to any photographs, motion pictures, maps, drawings, diagrams, measurements, surveys or other descriptions, within your possession, concerning the events and happenings alleged in the Complaint, please state its nature, specific subject matter, the date it was made or taken, and what each such item purports to show or illustrate or represent.

XX

  1. State your occupation at the time of the accident sued upon in this case and the dates you were absent from your employment by reason of the injuries sustained in this accident.

XX

  1. If you are claiming any impairment of earning capacity or loss of earnings because of this accident, please state the total amount of each loss and the method of computation.

XX

  1.     Please state the names and addresses of all employers for the seven years preceding this accident and your total yearly earnings for each of the seven years prior to the year of the accident sued upon in this case.

XX

  1. Please state the names and addresses of all employers you have worked for since the accident sued upon in this case, and your total yearly earnings for each of the years following the year of the accident.

XX

  1. Please state the specific location on the Defendant’s premises where the alleged accident/incident occurred, including reference to any signs, objects, landmarks, etc. at or near the location.

XX

  1. Please list the names and addresses of all pharmacies where you have had prescriptions filled over the last ten (10) years.

                    XX

______________                                                                                                    ALEXANDER WILLIAMS

STATE OF FLORIDA                 )                        

                                                  SS:

COUNTY OF                              )

        BEFORE ME, the undersigned authority, on this day personally appeared ALEXANDER WILLIAMS who after being first duly sworn, deposes and says that he read the foregoing interrogatories attached hereto, knows the contents thereof, and that to the best of his knowledge, and belief, the same are true and correct.

The foregoing instrument was acknowledged before me this                day

of __________         20__, ALEXANDER WILLIAMS is personally known to me or has produced                                  (type of identification presented – giving detail)  as an identification and taken an oath.

                              _____________                  

NOTARY PUBLIC, State of Florida at Large 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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