PLAINTIFF=S NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO: XXXX
The Plaintiff, JOHN SMITH, 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 Eleventh Judicial Circuit in and for Miami-Dade County, Florida, hereby files this Notice of Service of Interrogatories propounded to Defendant, VACATION CRUISES, 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
PLAINTIFF=S INTERROGATORIES TO DEFENDANT
- Please state the name and address of the person answering these interrogatories and that person=s relationship to the Defendant, VACATION CRUISES.
- Describe in detail how the Defendant contends the incident described in the complaint happened, including all actions taken by the Defendant to prevent the incident.
- Describe in detail each act or omission on the part of any party to this lawsuit that the Defendant contends constituted negligence that was the contributing legal cause of the incident in question.
- State the facts upon which the Defendant relies for each affirmative defense in its answer.
- Does the Defendant contend any person or entity other than the Defendant is, or may be, liable in whole or part for the claims asserted against Defendant in this lawsuit? If so, state the full name and address of each person or entity, the legal basis for Defendant=s contention, the factual evidence upon which the Defendant=s contention is based and whether or not Defendant has notified each such person or entity of its contention.
- List the names and last known business and residence addresses and telephone numbers of all persons who are believed or known by the Defendant, its agents or attorneys to have any knowledge concerning any of the issue in this lawsuit, and specify the subject-matter about which the witness has knowledge.
- Please state the names and last known addresses and telephone numbers of all employees or agents of the Defendant who were on the tender that Plaintiff was on in XX and those persons who ultimately made the decision on XX, 20__ to suspend tender service in XX.
- Please state the name and last known residence and business addresses of the person who had the ultimate authority to suspend tender service in XXXX on XX, 20__. Please state that person=s position with the Defendant and state that person=s current employer.
- Has the Defendant heard or does it know about any statement or remark made by or on behalf of the Plaintiff concerning any issue in this lawsuit? If so, please state the substance of the statement purportedly made by or on behalf of the Plaintiff, the date, time, and place of the statement, and the names and addresses of all persons who heard the statement.
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 on and who did/did not take an oath.
Signature of person taking acknowledgment
Name of Officer taking acknowledgment
____________________________________ Title or rank
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