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Filing # 114213086 E-Filed 09/30/2020 03:33:56 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
LUERETTA SMITH,
Plaintiff, CASE NO. CACE-19-021319 (13)
VS.
WINN-DIXIE STORES, INC.,
Defendant.
/
NOTICE OF SERVING SUPPLEMENTAL INTERROGATORIES TO PLAINTIFF
Defendant, WINN-DIXIE STORES, INC., by and through its undersigned counsel,
hereby propounds the attached Supplemental Interrogatories to the Plaintiff, LUERETTA
SMITH, to be answered in writing, under oath, within thirty (30) days pursuant to Fla.R.Civ.P.
1.340.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 30th day of September, 2020, a true and correct copy
of the foregoing was filed and served via Florida Courts eFiling Portal to the following counsel
of record: Justin G. Morgan, Esq., The Law Offices of Justin G. Morgan, P.A., 2500 Weston
Road, Suite 211, Weston, FL 33331; pleadings@justinmorganlaw.com.
HINSHAW & CULBERTSON LLP
/s/ Paul J.Gamm
Paul J. Gamm
Florida Bar No. 0577146
One East Broward Boulevard
Suite 1010
Ft. Lauderdale, FL 33301
Telephone: 954-467-7900
Facsimile: 954-467-1024
Primary: pgamm@hinshawlaw.com
Secondary: kcardenas@hinshawlaw.com
Attorneys for Defendant WINN-DIXIE
1025563\306707660.v1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/30/2020 03:33:55 PM.****CASE NO. CACE-19-021319 (13)
INTERROGATORIES TO PLAINTIFF
DEFINITIONS AND INSTRUCTIONS
The word "person" means any individual, firm, partnership, corporation, association or
other business enterprise, and the word "you" refers to the Plaintiff, LUERETTA SMITH.
The word “writing” includes, but is not limited to, books, records, letters, telegrams, notes,
memoranda, diaries, worksheets, computations, tabulations, financial statements and drafts of
any of the foregoing, whether originals or copies and in whatever language, and all other tangible
things on which words, figures, notations or sounds are recorded in writing or by any other
means, and any such material underlying, supporting, or used in the preparation thereof.
The word "identify" or "state" when used with reference to an individual person, means to state
his/her full name, his/her position and business affiliation at that time referred to, his/her last
known position and business affiliation and his/her last known residence and business address;
when used with reference to a firm, partnership, corporation, association or other business
enterprise, means to state its full name and address; and when used with reference to a writing,
means
qd) to state its date, author, addressee, recipient, type (e.g., book, record, letter,
memorandum, etc., or some other means of identifying it),
(2) to state its present location and custodian, and
(3) either to state the substance thereof or to annex to and incorporate in the answers to these
Interrogatories a true and correct copy thereof.
The term "documents" as used herein refers to all written or graphic matter, however produced or
reproduced, of every kind and description, whether produced internally or received from an
outside course, including, without limitation, papers, books, letter, photographs, architectural
plans, perspectives, specifications, drawings, blueprints, sketches, feasibility studies, objects,
tangible things, correspondence, telegrams, memoranda, inter-office communications, reports,
studies, surveys, contracts, emails, licenses, permits, permit applications, agreements, ledgers,
books of account, computer printouts and other computer materials, transcripts, analyses,
proposal, suggestions, legal pleadings, deeds, mortgages, bills of sale, security agreements, legal
documents, vouchers, records of inter-bank transfers of fund, bank checks, cashier's checks,
invoices, drafts, charge slip, receipts, freight bills, working papers or drafts, statistical records,
notebooks, calendars, appointment books, diaries, agendas, time sheet, logs, bids, job or
transaction files, credit reports, notations, notes, sound records of any type, minutes of director's
or other meetings, phono-records or tape recordings or other data compilations from which
information can be obtained, any transcriptions thereof, bulletins, circulars, press releases,
notices, instructions, advertisements, work assignments, motion picture films, videotapes,
research or other articles and treaties, including all attachments and enclosures thereto.
2
1025563\306707660.v1CASE NO. CACE-19-021319 (13)
INTERROGATORIES
1. Identify all social/professional networking websites that Plaintiff is registered
with currently (including but not limited to Twitter, Facebook, Tumbler, Instagram, LinkedIn,
Google+, Four Square, Flicker, Pinterest, Meetup, etc.).
2. Please list the number and service carrier associated with each cellular telephone
used by the Plaintiff and/or registered in the Plaintiff's name (this includes all numbers registered
to and/or used by the Plaintiff under a “family plan” or similar service) at the time of loss and
currently.
1025563\306707660.v1CASE NO. CACE-19-021319 (13)
LUERETTA SMITH
STATE OF FLORIDA
COUNTY OF
LUERETTA SMITH, being duly sworn deposes and says that the attached Answers to
Supplemental Interrogatories are true and correct to the best of her knowledge, information and
belief.
The foregoing instrument was acknowledged before me this _ day of
2020, by LUERETTA SMITH, who is o personally known to me or 0 who has produced
for identification.
SWORN TO AND SUBSCRIBED before me this day of. , 2020.
Notary Public
Print Name
My Commission Expires:
{Seal}
1025563\306707660.v1
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Filing # 114213086 E-Filed 09/30/2020 03:33:56 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION LUERETTA SMITH, Plaintiff, CASE NO. CACE-19-021319 (13) VS. WINN-DIXIE STORES, INC., Defendant. / NOTICE OF SERVING SUPPLEMENTAL INTERROGATORIES TO PLAINTIFF Defendant, WINN-DIXIE STORES, INC., by and through its undersigned counsel, hereby propounds the attached Supplemental Interrogatories to the Plaintiff, LUERETTA SMITH, to be answered in writing, under oath, within thirty (30) days pursuant to Fla.R.Civ.P. 1.340. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 30th day of September, 2020, a true and correct copy of the foregoing was filed and served via Florida Courts eFiling Portal to the following counsel of record: Justin G. Morgan, Esq., The Law Offices of Justin G. Morgan, P.A., 2500 Weston Road, Suite 211, Weston, FL 33331; pleadings@justinmorganlaw.com. HINSHAW & CULBERTSON LLP /s/ Paul J.Gamm Paul J. Gamm Florida Bar No. 0577146 One East Broward Boulevard Suite 1010 Ft. Lauderdale, FL 33301 Telephone: 954-467-7900 Facsimile: 954-467-1024 Primary: pgamm@hinshawlaw.com Secondary: kcardenas@hinshawlaw.com Attorneys for Defendant WINN-DIXIE 1025563\306707660.v1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/30/2020 03:33:55 PM.****CASE NO. CACE-19-021319 (13) INTERROGATORIES TO PLAINTIFF DEFINITIONS AND INSTRUCTIONS The word "person" means any individual, firm, partnership, corporation, association or other business enterprise, and the word "you" refers to the Plaintiff, LUERETTA SMITH. The word “writing” includes, but is not limited to, books, records, letters, telegrams, notes, memoranda, diaries, worksheets, computations, tabulations, financial statements and drafts of any of the foregoing, whether originals or copies and in whatever language, and all other tangible things on which words, figures, notations or sounds are recorded in writing or by any other means, and any such material underlying, supporting, or used in the preparation thereof. The word "identify" or "state" when used with reference to an individual person, means to state his/her full name, his/her position and business affiliation at that time referred to, his/her last known position and business affiliation and his/her last known residence and business address; when used with reference to a firm, partnership, corporation, association or other business enterprise, means to state its full name and address; and when used with reference to a writing, means qd) to state its date, author, addressee, recipient, type (e.g., book, record, letter, memorandum, etc., or some other means of identifying it), (2) to state its present location and custodian, and (3) either to state the substance thereof or to annex to and incorporate in the answers to these Interrogatories a true and correct copy thereof. The term "documents" as used herein refers to all written or graphic matter, however produced or reproduced, of every kind and description, whether produced internally or received from an outside course, including, without limitation, papers, books, letter, photographs, architectural plans, perspectives, specifications, drawings, blueprints, sketches, feasibility studies, objects, tangible things, correspondence, telegrams, memoranda, inter-office communications, reports, studies, surveys, contracts, emails, licenses, permits, permit applications, agreements, ledgers, books of account, computer printouts and other computer materials, transcripts, analyses, proposal, suggestions, legal pleadings, deeds, mortgages, bills of sale, security agreements, legal documents, vouchers, records of inter-bank transfers of fund, bank checks, cashier's checks, invoices, drafts, charge slip, receipts, freight bills, working papers or drafts, statistical records, notebooks, calendars, appointment books, diaries, agendas, time sheet, logs, bids, job or transaction files, credit reports, notations, notes, sound records of any type, minutes of director's or other meetings, phono-records or tape recordings or other data compilations from which information can be obtained, any transcriptions thereof, bulletins, circulars, press releases, notices, instructions, advertisements, work assignments, motion picture films, videotapes, research or other articles and treaties, including all attachments and enclosures thereto. 2 1025563\306707660.v1CASE NO. CACE-19-021319 (13) INTERROGATORIES 1. Identify all social/professional networking websites that Plaintiff is registered with currently (including but not limited to Twitter, Facebook, Tumbler, Instagram, LinkedIn, Google+, Four Square, Flicker, Pinterest, Meetup, etc.). 2. Please list the number and service carrier associated with each cellular telephone used by the Plaintiff and/or registered in the Plaintiff's name (this includes all numbers registered to and/or used by the Plaintiff under a “family plan” or similar service) at the time of loss and currently. 1025563\306707660.v1CASE NO. CACE-19-021319 (13) LUERETTA SMITH STATE OF FLORIDA COUNTY OF LUERETTA SMITH, being duly sworn deposes and says that the attached Answers to Supplemental Interrogatories are true and correct to the best of her knowledge, information and belief. The foregoing instrument was acknowledged before me this _ day of 2020, by LUERETTA SMITH, who is o personally known to me or 0 who has produced for identification. SWORN TO AND SUBSCRIBED before me this day of. , 2020. Notary Public Print Name My Commission Expires: {Seal} 1025563\306707660.v1