Preview
Case Number: CACE-20-016958 Division: 14
Filing # 114880115 E-Filed 10/13/2020 12:58:02 PM
IN THE CIRCUIT COURT OF THE 1774
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FL
CASE NO.:
CARL LOUIS,
Plaintiff,
VS.
DAWN ADILI and STATE FARM MUTUAL
AUTOMOBILE INSURANCE COMPANY,
Defendants.
/
PLAINTIFF'S NOTICE OF SERVING INITIAL
INTERROGATORIES TO DEFENDANT, DAWN ADILI
The Plaintiff, CARL LOUIS, pursuant to Florida Rules of Civil Procedure 1.340,
propounds the attached Interrogatories to Defendant, DAWN ADILI, and requests
same to be answered fully in writing under oath, within the time and manner
prescribed by the Florida Rules of Civil Procedure.
| HEREBY CERTIFY that a copy of the foregoing has begn glectronically filed
with the Clerk of the Courts by use of the ECF system this _ ‘day of October,
2020, and served with the Complaint and Summons.
BROTMAN NUSBAUM IBRAHIM
137 West Royal Palm Road
Boca Raton, FL 33432
Email: joe@lawbni.com
PH N. NUSBAUM
lorida Bar No.: 114715
ees
BROTMAN NUSBAUM IBRAHIM
137 West Royal Palm Road - Boca Raton, FL 33432
*#* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/13/2020 12:57:59 PM.*#**PLAINTIFF'S INTERROGATORIES
TO DEFENDANT, DAWN ADILI
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?
Are you the properly named defendant for purposes of bringing the instant
lawsuit? If not, please state the name of the entity that is responsible for the
acts of negligence, if proven, as set forth in the Complaint, including the
name and address of the registered agent.
Have you ever been convicted of a crime, other than any juvenile
adjudication, which under the law under which he was convicted was
punishable by death or imprisonment in excess of 1 year, or that involved
dishonesty or a false statement regardless of the punishment? If so, state as
to each conviction the specific crime and the date and place of conviction.
Describe any and all policies of insurance which you contend cover or may
cover you for the allegations set forth in the 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 the incident described in the Complaint happened
including all actions taken by you to prevent the incident.
we
BROTMAN NUSBAUM IBRAHIM
137 West Royal Palm Road - Boca Raton, FL 33432Describe in detail each act or omission on the part of any party to this lawsuit
that you contend constituted negligence that was a contributing legal
cause of the incident in question.
State the facts upon which you rely for each affirmative defense in your
answer.
Do you contend any person or entity other than you is, or may be, liable in
whole or part for the claims asserted against you in this lawsuit? If so, state
the full name and address of each such person or entity, the legal basis for
your contention, the facts or evidence upon which your contention is based,
and whether or not you have notified each such person or entity of your
contention.
Were you charged with any violation of law (including any regulations or
ordinances) arising out of the incident described in the Complaint? If so,
what was the nature of the charge; what plea or answer, if any, 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 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
you, your agents, or your attorneys to have any knowledge concerning any
of the issues in this lawsuit; and specify the subject matter about which the
witness has knowledge.
pS aS aes eee!
BROTMAN NUSBAUM IBRAHIM
—S—— EEA EBRAHIM
137 West Royal Palm Road + Boca Raton, FL 3343211.
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 so, state the name and address of each person who
made 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 name and address of every person known to you, your agents, or
your 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.
Do you intend to call any expert witnesses at the trial of this case? If so, state
as to each such witness the name and business address of the witness, the
witness’ 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.
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? Ifso, state
the terms of the agreement and the parties to it.
Please state if you ever been a party, either Plaintiff or Defendant, in a lawsuit
other than 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.
SERRE RRRES SE SSeEeeeeeE
BROTMAN NUSBAUM IBRAHIM
137 West Royal Palm Road + Boca Raton, FL 3343220.
21.
Do you wear glasses, contact lenses, or hearing aids? If so, who prescribed
them, when were they prescribed, and, when were your eyes or ears were
last examined, what is the name and address of the examiner?
Were you suffering from any physical infirmity, disability, or sickness at the
time of the incident described in the complaint? If so, what was the nature
of the infirmity, disability, or sickness.
Did you consume any alcoholic beverages or take any drugs or medications
within 12 hours before the time of the incident described in the Complaint? If
so, state the type and amount of alcoholic beverages, drugs, or medication
which were consumed, and when and where did you consume them.
Did any mechanical defect in the motor vehicle in which you were
operating at the time of the incident described in the Complaint contribute
to the incident? If so, describe the nature of the defect and how it
contributed to the incident.
List the name and address of all persons who were registered title owners or
who had ownership interest in, or right to control, the motor vehicle that you
were driving at the time of the incident described in the Complaint; and
describe both the nature of the ownership interest or right to control the
vehicle, and the vehicle itself, including the make, model, year, and vehicle
identification number.
Was the motor vehicle that you were driving at the time of the incident
described in the complaint damaged in the incident, and, if so, what was
the cost to repair the damage.
SEE
BROTMAN NUSBAUM IBRAHIM
137 West Royal Palm Road + Boca Raton, FL 3343222.
23.
24.
At the time of the incident described in the complaint, were you
engaged in any mission or activity for any other person or entity, including
any employer? If so, state the name and address of that person or entity
and the nature of the mission or activity.
Did you have available any cell phone, portable phone, two way
radio, or other communication device inside the subject vehicle
and driven by you at the time of the incident that is the subject of this
lawsuit?
If the answer to the preceding interrogatory is Yes", please state the
following:
The brand name and model number of such device(s);
The owner of each device(s):
The name on the account for the device(s);
The account number for each such device(s);
The telephone number for each such device(s);
The service carrier's name and address as to each device.
-9a070
re
BROTMAN NUSBAUM IBRAHIM
137 West Royal Palm Road - Boca Raton, FL 33432DAWN ADILI
STATE OF
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared
, who, being duly sworn, deposes and says that the Answers
to Interrogatories attached hereto are true to the best of his/her knowledge,
information and belief.
[ ] personally known to me; or
[ ] produced Driver's License State No. as identification
SWORN TO AND SUBSCRIBED before me this ____ day of
2020.
Notary Public
My Commission Expires:
a TSE
BROTMAN NUSBAUM IBRAHIM
137 West Royal Paim Road + Boca Raton, FL 33432
Preview
Case Number: CACE-20-016958 Division: 14 Filing # 114880115 E-Filed 10/13/2020 12:58:02 PM IN THE CIRCUIT COURT OF THE 1774 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FL CASE NO.: CARL LOUIS, Plaintiff, VS. DAWN ADILI and STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendants. / PLAINTIFF'S NOTICE OF SERVING INITIAL INTERROGATORIES TO DEFENDANT, DAWN ADILI The Plaintiff, CARL LOUIS, pursuant to Florida Rules of Civil Procedure 1.340, propounds the attached Interrogatories to Defendant, DAWN ADILI, and requests same to be answered fully in writing under oath, within the time and manner prescribed by the Florida Rules of Civil Procedure. | HEREBY CERTIFY that a copy of the foregoing has begn glectronically filed with the Clerk of the Courts by use of the ECF system this _ ‘day of October, 2020, and served with the Complaint and Summons. BROTMAN NUSBAUM IBRAHIM 137 West Royal Palm Road Boca Raton, FL 33432 Email: joe@lawbni.com PH N. NUSBAUM lorida Bar No.: 114715 ees BROTMAN NUSBAUM IBRAHIM 137 West Royal Palm Road - Boca Raton, FL 33432 *#* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/13/2020 12:57:59 PM.*#**PLAINTIFF'S INTERROGATORIES TO DEFENDANT, DAWN ADILI 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? Are you the properly named defendant for purposes of bringing the instant lawsuit? If not, please state the name of the entity that is responsible for the acts of negligence, if proven, as set forth in the Complaint, including the name and address of the registered agent. Have you ever been convicted of a crime, other than any juvenile adjudication, which under the law under which he was convicted was punishable by death or imprisonment in excess of 1 year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction the specific crime and the date and place of conviction. Describe any and all policies of insurance which you contend cover or may cover you for the allegations set forth in the 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 the incident described in the Complaint happened including all actions taken by you to prevent the incident. we BROTMAN NUSBAUM IBRAHIM 137 West Royal Palm Road - Boca Raton, FL 33432Describe in detail each act or omission on the part of any party to this lawsuit that you contend constituted negligence that was a contributing legal cause of the incident in question. State the facts upon which you rely for each affirmative defense in your answer. Do you contend any person or entity other than you is, or may be, liable in whole or part for the claims asserted against you in this lawsuit? If so, state the full name and address of each such person or entity, the legal basis for your contention, the facts or evidence upon which your contention is based, and whether or not you have notified each such person or entity of your contention. Were you charged with any violation of law (including any regulations or ordinances) arising out of the incident described in the Complaint? If so, what was the nature of the charge; what plea or answer, if any, 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 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 you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. pS aS aes eee! BROTMAN NUSBAUM IBRAHIM —S—— EEA EBRAHIM 137 West Royal Palm Road + Boca Raton, FL 3343211. 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 so, state the name and address of each person who made 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 name and address of every person known to you, your agents, or your 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. Do you intend to call any expert witnesses at the trial of this case? If so, state as to each such witness the name and business address of the witness, the witness’ 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. 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? Ifso, state the terms of the agreement and the parties to it. Please state if you ever been a party, either Plaintiff or Defendant, in a lawsuit other than 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. SERRE RRRES SE SSeEeeeeeE BROTMAN NUSBAUM IBRAHIM 137 West Royal Palm Road + Boca Raton, FL 3343220. 21. Do you wear glasses, contact lenses, or hearing aids? If so, who prescribed them, when were they prescribed, and, when were your eyes or ears were last examined, what is the name and address of the examiner? Were you suffering from any physical infirmity, disability, or sickness at the time of the incident described in the complaint? If so, what was the nature of the infirmity, disability, or sickness. Did you consume any alcoholic beverages or take any drugs or medications within 12 hours before the time of the incident described in the Complaint? If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when and where did you consume them. Did any mechanical defect in the motor vehicle in which you were operating at the time of the incident described in the Complaint contribute to the incident? If so, describe the nature of the defect and how it contributed to the incident. List the name and address of all persons who were registered title owners or who had ownership interest in, or right to control, the motor vehicle that you were driving at the time of the incident described in the Complaint; and describe both the nature of the ownership interest or right to control the vehicle, and the vehicle itself, including the make, model, year, and vehicle identification number. Was the motor vehicle that you were driving at the time of the incident described in the complaint damaged in the incident, and, if so, what was the cost to repair the damage. SEE BROTMAN NUSBAUM IBRAHIM 137 West Royal Palm Road + Boca Raton, FL 3343222. 23. 24. At the time of the incident described in the complaint, were you engaged in any mission or activity for any other person or entity, including any employer? If so, state the name and address of that person or entity and the nature of the mission or activity. Did you have available any cell phone, portable phone, two way radio, or other communication device inside the subject vehicle and driven by you at the time of the incident that is the subject of this lawsuit? If the answer to the preceding interrogatory is Yes", please state the following: The brand name and model number of such device(s); The owner of each device(s): The name on the account for the device(s); The account number for each such device(s); The telephone number for each such device(s); The service carrier's name and address as to each device. -9a070 re BROTMAN NUSBAUM IBRAHIM 137 West Royal Palm Road - Boca Raton, FL 33432DAWN ADILI STATE OF COUNTY OF BEFORE ME, the undersigned authority, personally appeared , who, being duly sworn, deposes and says that the Answers to Interrogatories attached hereto are true to the best of his/her knowledge, information and belief. [ ] personally known to me; or [ ] produced Driver's License State No. as identification SWORN TO AND SUBSCRIBED before me this ____ day of 2020. Notary Public My Commission Expires: a TSE BROTMAN NUSBAUM IBRAHIM 137 West Royal Paim Road + Boca Raton, FL 33432