Preview
Filing # 127545776 E-Filed 05/26/2021 09:15:21 AM
0484592340.1 JLT
Total Pages: 1
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
MARIA ALICIA GUZMAN, CASE NO.
50-2020-CA-007500-XXXX-MB
PLAINTIFF,
VS.
ANDREA D’ADDARIO AS CURATOR
OF THE ESTATE OF EDWARD JOSEPH
PARADISE,
DEFENDANT. |
DEFENDANT(S) NOTICE OF SERVICE OF AUTOMOBILE
ITERROGATORIES TO PLAINTIFF
Plaintiff, MARIA GUZMAN, is hereby requested and required to answer, under oath, in
wilting, aiid wiinii ine ime allowed by ine Florida Rules of Civil Procedure, ine aitached iniriy
(30) Interrogatories propounded by the Defendant(s), EDWARD JOSEPH PARADISE. The
Plaintiff is further requested to serve said answers in accordance with Florida Rule of Civil
Procedure 1.340.
IHEREBY CERTIFY that onthe 26 day of May » 2021,
CHIEN. DAM BCARURAIINTY Cl INeCDU ARDIIV7ZA FILED AEINaINND NO4AE-O4 ANA
Pm. PAL DLA VUUINE TT, FL, vUOL I mDnueey, ULLIAN, Yoreuizue! ug. iu. 1 miCASE NO. 50-2020-CA-007500-XXXX-MB
pursuant to Administrative Order No. AOSC13-49, a copy of the foregoing Defendant(s) Notice
of Service of Interrogatories to Plaintiff, MARIA GUZMAN, has been electronically filed and
served using the Florida Courts E-Filing Portal; AND a copy of the foregoing Notice of Service
together with the Interrogatories has been furnished by E-mail to:
Attorney for Plaintiff
Carlos J. Jimenez, P.L.
1880 N Congress Ave., Ste 315
Boynton Beach, FL 33426
(Tel: 561 253-0434; Fax: 561 253-0435)
eservice@247injurylaw.com.
Carlos J. Jimenez, Esq.
FBN: 0636746
LAW OFFICES OF ROBERT J. SMITH
110 SE 6th St Ste 1800
Ft. Lauderdale, FL 33301-5015
Telephone: (954) 767-1387
Toll Free: (877) 250-9958 ext 7671387
Attorney Direct: (954) 767-1394
Fax: (877) 838-0840
By: 7 :
Electronically Signed
JOSEPH MARYUMA
FL Bar No. 28102
Attorney for Defendant(s)
EDWARD JOSEPH PARADISE
PRINCIPAL E-MAIL ADDRESS:
FTLAUDERDALELEGAL@ALLSTATE.COM
Personal E-mail Address
(NOT for Service of Pleadings and Documents):
Joe.Maryuma@allstate.comAUTOMOBILE INTERROGATORIES TO PLAINTIFF
MARIA GUZMAN
INSTRUCTIONS: Please insert your answers in the space provided following each question.
If additional space is needed, so indicate in the space provided, prepare
your answer on a separate paper and attach.
1. 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?
2. List the names, business addresses, dates of employment, and rates of pay regarding all
employers, including self-employment, for whom you have worked in the past ten (10) years.CASE NO. 50-2020-CA-007500-XXXX-MB
3. List all former names and when vou were known by those names. State all addresses where
you have lived for the past ten (10) years, the dates you lived at each address, your social
security number, your date of birth, and if you are or have ever been married, the name of
your spouse or spouses.
4. Do you wear glasses, contact lenses or hearing aids?
If yes, 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?
5. Have you ever been convicted of a crime, other than any juvenile adjudication, which under
the law under which you were convicted was punishable by death or imprisonment in excess
of one (1) year, or that involved dishonesty or a false statement regardless of the punishment?
If yes, state as to each conviction, the specific crime, the date and the place of conviction.CASE NO. 50-2020-CA-007500-XXXX-MB
6. Were you suffering from any physical infirmity, disability, or sickness at the time of the
occurrence of the incident described in the Complaint?
If yes, what was the nature of the infirmity, disability, or sickness?
7. Did you consume any alcoholic beverages or take any drugs or medications within twelve
(12) hours before the occurrence of the accident described in the Complaint?
If yes, what type and amount of alcoholic beverages, drugs or medication were consumed
and where did you consume them?
8. Describe in detail how the incident described in the Complaint happened, including all
actions taken by you to prevent the incident.CASE NO. 50-2020-CA-007500-XXXX-MB
9. Describe in detail each act or omission on the part of any party to this lawsuit that vou
contend constituted negligence that was a contributing legal cause of the incident in question.
10. Were you charged with any violation of law (including any regulations or ordinances) arising
out of the incident described in the Complaint?
If yes, what was the nature of the charge; what plea, or answer, if any, did you enter to the
charge; what court or agency heard the charge; was any written report prepared by anyone
regarding this charge, and if so, what is the name and address of the person or entity that
prepared the report; do you have a copy of the report; and was the testimony at any trial,
hearing, or other proceeding on the charge recorded in any manner, and if so, what was the
name and address of the person who recorded the testimony?CASE NO. 50-2020-CA-007500-XXXX-MB
11. Describe each injury for which vou are claiming damages in this case snecifving 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.
12. List each item of expense or damage, other than loss of income or earning capacity that you
claim to have incurred as a result of the incident described in the Complaint, giving for each
item the date incurred, the name and business address to whom each was paid or is owed, and
the goods or services for which each was incurred.CASE NO. 50-2020-CA-007500-XXXX-MB
13.
14.
Do you contend that you have lost any income, benefits, or earning capacity in the past or
future as a result of the incident described in the ‘Complaint?
If yes, state the nature of the income, benefits, or earning capacity, and the amount and the
method that you used in computing the amount.
Has anything been paid or is anything payable from any third party or other entity (including
but not limited to Medicare, Medicare Advantage Plan, Medicaid, PIP insurer, medical
payments, health insurance, workers compensation, etc.) for the damages listed in your
answers to these Interrogatories?
If yes, state the amounts paid or payable, the name and business address of the person or
entity who paid or owes said amounts, and which of those third parties have or claim a right
of subrogation. If Medicare or Medicare Advantage Plan has paid for any damages,
please ensure to include your HICN/MIB number.CASE NO. 50-2020-CA-007500-XXXX-MB
15. List the name and business address of each physician who has treated or examined vou, and
each medical facility where you have received any treatment or examination for the injuries
for which you seek damages in this case; and state as to each the date of treatment or
examination and the injury or condition for which you were examined or treated.
16. List the names and business addresses of all other physicians, medical facilities or other
health care providers by whom or at which you have been examined or treated in the past ten
(10) years; and state as to each the dates of examination or treatment and the condition or
injury for which you were examined or treated.CASE NO. 50-2020-CA-007500-XXXX-MB
17. List the names and addresses of all persons who are believed or known bv vou. vour agents
or attorneys to have any knowledge concerning any of the issues in this lawsuit, and specify
the subject matter about which the witness has knowledge.
18. Have you heard or do you know about any statement or remark made by or on behalf of any
party to this lawsuit, other than yourself, concerning any issue in this lawsuit?
If yes, state the name and address of each person who made the statement or remark, the
name and address of each person who heard it, and the date, time, place and substance of
each statement or remark.CASE NO. 50-2020-CA-007500-XXXX-MB
19. State the name and address of every person known to vou, your agents, or attorneys. who has
knowledge about, or possession, custody or control of any model, plat, map, drawing, motion
picture, video tape, or photograph pertaining to any fact or issue involved in this controversy;
and describe as to each, what such person has, the name and address of the person who took
or prepared it, and the date it was taken or prepared.
20. Do you intend to call any expert witness at the trial of this case?
If yes, state as to each such witness the name and business address of the witness, the
witness's qualifications as an expert, the subject matter upon which the witness is expected to
testify, the substance of the facts and opinions to which the witness is expected to testify, and
a summary of the grounds for each opinion.CASE NO. 50-2020-CA-007500-XXXX-MB
21.
22.
23.
Have you made an agreement with anyone that would limit that party's liability to anyone for
any of the damages sued upon in this case?
If yes, state the terms of the agreement and the parties to it.
Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other than
the present matter?
If yes, state whether you were the plaintiff or defendant, the nature of the action, and the date
and Court in which suit was filed.
At the time of the incident described in the Complaint, were you wearing a seat belt?
Tf no, please state why not; were you seated in the vehicle; and whether the vehicle was
equipped with a seat belt that was operational and available for your use.
10CASE NO. 50-2020-CA-007500-XXXX-MB
24.
25.
26.
Did any mechanical defect in the motor vehicle in which vou were riding at the time of the
incident described in the Complaint contribute to the incident?
If yes, describe the nature of the defect and how it contributed to the incident?
List the names, addresses, telephone numbers of all companies, entities, or individuals where
you have applied for employment in the past three (3) years.
With respect to any injuries or symptoms described in your answer to Interrogatory 11,
please state whether you, at any other time, ever had any similar injury to or similar symptom
of the same or similar area of your body?
If yes, itemize each such injury or symptom, the part of your body involved, the date and
duration of such injury or symptom, and the names and addresses of any physician or
hospitals that treated you for such injury or symptom.
11CASE NO. 50-2020-CA-007500-XXXX-MB
27. State whether or not you have been involved in any accidents or incidents resulting in
personal injury prior to or after the incident described in the Complaint?
If yes, state the place of each of said accidents or incidents, the date of each said accident or
incident, any personal injuries that you may have received in any such accident or incident,
the name of each and every medical practitioner treating you or examining you for each of
the said injuries.
28. State whether or not, in the past five (5) years, you made application for any insurance or
employment requiring a physical examination?
Tf yes, state the name and address of the medical practitioner who examined you, giving the
date of the examination, and the name and address of such insurance company and/or
employer.
12CASE NO. 50-2020-CA-007500-XXXX-MB
29.
30.
Have vou ever received a disability rating of any tvpe whatsoever from any individual or
private governmental organization before or after the incident described in the Complaint and
not related to the incident described in the Complaint?
If yes, state as to each the name and address of the physician or organization giving such
rating, the date of the rating, the amount of the disability rating, and describe the nature of the
incident causing the disability rating.
List the names of all individuals who resided at the same address with you on the date of the
incident alleged in the Complaint; and whether any such individuals owned a motor vehicle
at the time of the incident alleged in the Complaint?
If yes, identify the individual owning the motor vehicle, the type of motor vehicle owned,
and the name and address of the insurer, if any, providing insurance coverage for the owner
or vehicle identified.
13CASE NO. 50-2020-CA-007500-XXXX-MB
STATE OF )
:SS
COUNTY OF )
MARIA GUZMAN, who being duly sworn, on oath, deposes and says (or affirms) that
the foregoing Answers to Interrogatories propounded on the day of
2021, are true and correct to the best of his/her knowledge, and that he/she has read the foregoing
Answers to Interrogatories and knows the contents thereof.
MARIA GUZMAN
Sworn to (or affirmed) and subscribed before me by means of oO physical presence, or
LC online notarization, this day of , 2021, by
, who [_] is personally known to me, or
C produced a , as identification.
Notary Public (Signature)
Notary Public (Printed Name)
My Commission Expires:
14