PLAINTIFF’S NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. XXX
SMITH ROOFING COMPANY,
PLAINTIFF’S NOTICE OF SERVICE
OF INTERROGATORIES TO DEFENDANT
The Plaintiff, RICHARD ROGERS, 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, SMITH ROOFING COMPANY, 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
ALAN D. SACKRIN
INTERROGATORIES TO DEFENDANT
(If answering for another person or entity, answer with respect to that person or entity, unless otherwise stated.)
- 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?
- Describe in detail how the defendant contends the incident described in the Complaint happened.
- 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.
- State the facts upon which you rely for each affirmative defense in your answer.
- 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.
- 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.
- 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.
- What was Defendant’s role at the subject construction site?
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