PLAINTIFF=S NOTICE OF SERVING ANSWERS TO INTERROGATORIES BY DEFENDANT
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO: XXXX
PLAINTIFF=S NOTICE OF SERVING ANSWERS
TO INTERROGATORIES BY DEFENDANT
The Plaintiff, JOHN SMITH, pursuant to Rule 1.340, Florida Rules of Civil Procedure, hereby gives Notice of Serving Answers to Interrogatories propounded by Defendant, VACATION CRUISES, dated XXXX, 20__.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that on this ____ day of XXXX, 20__, a true and correct copy of the foregoing was mailed to: XXXX.
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff(s)
2100 East Hallandale Beach Blvd.
Hallandale Beach, FL 33009
ALAN D. SACKRIN
Florida Bar No. 349070
PLAINTIFF=S RESPONSE TO INTERROGATORIES
- State your full name, age, social security number, present address, and all previous resident addresses for the past ten (10) years, and the length of time which you resided at each address.
- With regards to the alleged accident which is the basis of this lawsuit, please state the following:
(a) What was the date of the accident?
(b) What time do you allege it occurred?
( c) What was the exact location of the alleged accident (where on the tender and the tender=s location at the time)?
- Describe exactly (with all factual details) how the alleged accident happened including but not limited to the people involved. State everything you did to prevent the alleged accident, and explain what you claim to be the reason(s) why the alleged accident occurred.
- List and describe with all factual details, each act or omission on the part of XX you contend constituted negligence, as alleged in the Complaint, that was a contributing cause of the accident in question, stating for each act or omission how it contributed as a cause of the accident.
- List the names, addresses and telephone numbers (business and residence) of all persons who are believed or known by you, your agents, or attorneys to have any knowledge concerning any of the issues raised in the complaint and specify the subject matter about which the witness(es) has knowledge.
- List the name, resident address and telephone number (business and residence) of each person believed and/or known to you, your agent(s) or attorneys(s) to have heard or who has purported to have heard XX, through any agent or employee, make any statement, remark or comment concerning the alleged accident and/or the claims described in the Complaint, and the substance of each statement, remark or comment.
- List the name, address and telephone number (business and residence) of each person believed and known to you, your agent(s) or attorney(s) to have heard or who has purported to have heard the offshore excursion operator, through any agent or employee, make any statement, remark or comment concerning the alleged accident and/or the claims described in the Complaint, and the substance of each statement, remark or comment.
- Did you have any physical infirmity, disability, or sickness at the time of the occurrence of the alleged accident described in the Complaint? If so, what was the precise nature of the infirmity, disability, or sickness?
- Did you consume any alcoholic beverages or take any drugs or medications within twelve (12) hours before the occurrence of the alleged accident described in the Complaint? If so, what type and amount of alcoholic beverages, drugs or medications were taken and where did you take them?
- List each item of expense and/or indebtedness that you claim to have incurred in connection with and/or as a result of the claims and/or injuries sued on in this action, giving for each item the date incurred, to whom owed or paid and the goods, services or purpose for which each was incurred.
- List the name, business address and telephone number, policy number and name of the policyholder for any healthcare (i.e. medical) insurance that covered you on the date of the alleged accident.
- Do you contend that you have lost and/or are owed any form of wages or compensation as a result of the claims and/or injuries sued on in this action? If so, what is the amount you claim, the date(s) during which it was lost or for which it is owed, the nature of the wages or compensation and the method that you use in computing the amount including any penalties you claim are due.
- Describe each injury for which you are claiming damages in this case specifying the part 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. If you are claiming damages other than or in addition to damages for injuries to your body, please state the nature and amount of all those damages and the basis on which you claim you are entitled to recover those damages.
- List each physician and/or doctor (providing name, address and telephone number) who has tested, examined or treated you and each medical facility where you have received any treatment, examination or testing for the alleged injuries for which you
- List the names, business telephone numbers of all medical doctors or healthcare providers, and all hospital at which you have been examined or treated or tested in the ten (10) years prior to the date of the subject incident to the present, stating the dates of the examinations, the treatment or test provided for, the name, address, and telephone number of each
- State whether or not you have ever sustained any injury to the parts of the body claimed to have been injured in the accident alleged in the Complaint, as a result of an accident otherwise, before the date of the accident alleged in this case, and, if so, state the nature of said accident and/or incident, the nature of your injuries, and the name and address of each physician or other medical attendant who cared for you or treated you as a result of this accident and/or incident.
- State whether you have ever sustained any injury or aggravation of any injury as a result of an accident, or otherwise, after the date of the accident alleged in the Complaint, and, if so, state the date and, place and, the nature of said accident and/or incident, the nature of your injuries, and the name and address of each physician or nurse or other medical attendant who attended or cared for you, or treated you as a result of this accident and/or incident.
- Please state whether or not you or your agent(s), attorney(s), or representative(s) has obtained any statement from any person relative to the alleged accident, injuries or damages you claim. If the answer is in the affirmative, please state:
- a) The name and address of every person from whom a statement was obtained.
- b) The date or dates said statement(s) was obtained.
- c) The name and address of the person having custody and control of the statement(s), recording or transcript of said statement(s).
- Please state whether you are currently or have in the past received government funded healthcare assistance (i.e. Medicare, Medicaid) to pay any medical expense you claim are a result of the accident alleged in the Complaint.
- Please state if you have ever been a party, either plaintiff or defendant in a lawsuit other than in 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.
- Do you wear glasses, contact lenses, or hearing aid? 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?
- 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 business entity who paid or owes said amounts, and which of those third parties have or claim a right of subrogation.
- Have you ever been charged or convicted of any crime in any state or federal jurisdiction? If so, please provide the specific crime for which you were charged or convicted (including any guilty pleas) the date of the charge or conviction, the court presiding over the charge or conviction, and the disposition or sentence ordered by the court, and length of time, if any, served in any state or federal prison or other similar facility.
- Prior to boarding the XX, did you purchase and/or receive a passenger cruise ticket for a cruise on the XX? If yes, please state the following:
(a) Date of purchase;
(b) The date you received it;
( c) From whom did you receive it;
(d) What other documentation did you receive with it?
(e) How did you received it (i.e. in person, mail, courier);
- Were you given any safety warnings and/or instructions with regards to being transported by a tender at anytime immediately prior to the accident? If yes, please state the following:
(a) What safety warnings and/or instruction were given;
(b) When were they given;
(c) How were they given (i.e. written or verbal);
(d) Who gave them;
- Describe the weather conditions at the time of the alleged accident, including but not limited to rain, wind, temperature and sea conditions.
- Please state whether you have ever made a claim for personal injuries, other than those related to the accident and injuries alleged in the Complaint. If yes, state how, by whom and why you were injured, the nature of the claim (i.e. motor vehicle accident, slip & fall accident, etc.) when and to whom such claim was made and the disposition or status of any such claims.
- List the names, ages, business and residence address and telephone numbers, and relationship to you, of any and all persons who accompanied you:
- On the cruise;
- On the tender at the time of the accident as described in the Complaint.
- Please identify your occupation, current income, and name, address and telephone number of each and every employer in the last five years.
I attest to and verify that the foregoing and/or attached document(s) is/are true, to the best of my knowledge, as stated herein and presented to me in this document.
SWORN TO AND SUBSCRIBED before me on this ____ day of XX, 20__, by JOHN SMITH, who (did)(did not) take an oath and who is either:
[ ]personally known or who presented as identification:
[ ]Drivers License________________________
[ ]Other: _______________________________
(Official Notary Signature and Notary Seal)
(Name of Notary Typed, Printed or Stamped)
Commission and Expiration:
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