PLAINTIFF’S NOTICE OF SERVING FIRST INTERROGATORIES TO DEFENDANT
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. XX
MARY GARCIA,
Plaintiff,
v.
SMITH INC.,
Defendant.
_______________________________/
PLAINTIFF’S NOTICE OF SERVING FIRST INTERROGATORIES TO DEFENDANT
The Plaintiff, MARY GARCIA, 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 and states that the original and one copy of said Interrogatories were served with the Complaint.
LAW OFFICE OF ALAN D. SACKRIN
Attorney for Plaintiff
2100 East Hallandale Beach Blvd.
Suite 200
Hallandale Beach, FL 33009
By__________________________
ALAN D. SACKRIN
PLAINTIFF’S NOTICE OF SERVING FIRST SET OF INTERROGATORIES TO DEFENDANT, SHOPPES OF PARKLAND, LTD.
(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 any and all policies of insurance which Defendant contends covers or may cover the defendant for the allegations set forth in Plaintiff’s Complaint, detailing as to such policies, the name of the insurer, the number of the policy, the effective dates of the policy, the available limits of liability and the name and address of the custodian of the policy.
- Describe in detail how this defendant contends the incident described in the Complaint happened.
- Describe in detail each act or omission on the part of any party to this lawsuit that this Defendant contends constituted negligence that was a contributing legal cause of the incident in question.
- State the facts upon which this Defendant relies upon for each affirmative defense in its answer.
- Does this Defendant contend that any person or entity is, or may be, liable in whole or in part for the claims asserted against this Defendant in this lawsuit? If so, state the full name and address of each such person or entity, the legal basis for the contention, the facts or evidence upon which the contention is based, and whether or not this Defendant has notified each such person or entity of its contention.
- Was this Defendant charged with any violation of law (including any regulations or ordinances, including OSHA regulations) arising out of the incident described in the complaint? If so, what was the nature of the charge; what plea or answer, if any, did this Defendant enter to the charge; what court or agency heard the charge; was any written report prepared by anyone regarding the charge; and, if so, what is the name and address of the person or entity who prepared the report; do you have a copy of the report; and was the testimony used at any trial, hearing or other proceeding on the charge recorded in any manner; and, if so, what is the name and address of the person who recorded the testimony?
- List the names and addresses of all persons who are believed or known by this Defendant, its agents or its attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge.
- Has this Defendant heard or does it know about any statement or remark made by or on behalf of any party to this lawsuit concerning any issue in this lawsuit? If so, state the name and address of each person who heard 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 names and address of every person known to this Defendant, its agents or its attorneys who has knowledge about, or possession, custody or control of, any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared.
- Please state the name and address of the owner of the XX for the period XX, 20__, through XX, 20__.
- Please state the name and address of the current owner of the XX.
- Please state the name and address of any maintenance or management company which performed management services at the XX for the time period XX, 20__, through XX, 20__. Please state the name and address of the supervisor of the management company who performed management services for the XX.
- Please state the names and last known business and residence addresses of all employees of this Defendant who were working for this Defendant and whose responsibilities included, at least in part, maintenance, safety, or security for the XX.
- Please state the names and last known residence and business addresses and telephone numbers of all persons who this Defendant knows, or who has reason to believe, placed any substance on the rungs of the ladders on Defendant’s premises at any time from XX, 20__, through XX, 20__.
- Please state the reason why the substance was applied or placed on the rungs of the ladders on Defendant’s premises on or prior to XX, 20__.
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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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