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Filing # 125427417 E-Filed 04/22/2021 01:51:38 PM
IN THE CIRCUIT COURT OF THE
17" JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
LILLY WILLIAMS, and her husband,
BLAKE McLOUD,
Plaintiffs,
vs. Case No.: CACE-21-007626
BAYWATCH BOAT RENTALS,
TOURS & CHARTERS, INC.,
a Florida Corporation, d/b/a
CAPTAIN JOE’S BOAT RENTALS,
TOURS & CHARTERS, INC.,
Defendant,
IEEE,
INTERROGATORIES TO DEFENDANT
(Baywatch)
COMES NOW, the Plaintiffs, Lilly Williams and her husband, Blake McLoud, by and
through their undersigned attorneys, and propound the attached Interrogatories to the
Defendant, Baywatch Boat Rentals, Tours & Charters, Inc., (“Baywatch”), to be answered
under oath within forty-five (45) days, in accordance with the applicable Rules of Court.
| DO HEREBY CERTIFY that an original copy of the foregoing Interrogatories was served
with the Summons and Complaint.
The Ben Law Firm, PLLC
Attorneys for the Plaintiffs
/s/
ANDREW S. BEN
FBN: 109024
LAWRENCE S. BEN
FBN: 300888
2699 Stirling Road, Suite C-301
Fort Lauderdale, FL 33312
Telephone: (954) 961-2055
Andy@TheBenLawFirm.com
Larry@TheBenLawFirm.com
Mailroom@TheBenLawFirm.com
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/22/2021 01:51:35 PM.****PLAINTIFF’s INTERROGATORIES TO DEFENDANT, BAYWATCH
(1* Set)
DEFINITIONS
A. The word “vessel” as used herein shall refer to the “45' Chris Craft Vessel,” described
in the Complaint, which was involved in the incident of 06/23/2020.
B. The word “incident” as used herein shall refer to the incident 06/23/2020, described
in the Complaint
Cc The word “Baywatch” as used herein shall refer to the Defendant, Baywatch Boat
Rentals, Tours & Charters, Inc.
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. Please state the complete name and address of the entity who owned the vessel on the
date of the incident alleged in the Complaint.3. Describe any and all policies of insurance which you contend cover or may cover Baywatch
or the vessel for the allegations set forth in plaintiffs 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.
4. Describe in detail how the incident described in the Complaint happened, including all
actions taken by you to prevent the incident.5. Describe 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.
6. State the facts upon which you rely for each affirmative defense in your answer.7, 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.
8. 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.9. 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.
10. State the name and address of every person known to you, your agents, or your attorney
who has knowledge about, or possession, custody, or control of, any model, plat, map,
drawing, motion picture, video-tape, digital recording and/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.11. Have you made an agreement with anyone that would limit that party’s liability or
obligation to pay to anyone for any of the damages sued upon in this case? If so, state the
terms of the agreement and the parties to it.
12. Please state the precise name and address of any witnesses to the incident describe in the
Complaint.13. Please state the precise name and address of each person/corporation/and or other entity
who is responsible for controlling and/or maintaining the vessel.
14. With reference to the negligence alleged in the complaint in this action, please state
whether there have been any claims or lawsuits made against you pertaining to the same or
similar alleged conditions. If so, please the name of the claimant/plaintiff, the date of the
incident(s), the nature of the alleged conditions, and the name and address of the
claimant/plaintiff’s attorney.15. At the time of the incident alleged in the Complaint, were there any surveillance cameras
on the vessel, or near the vessel, which covered the area where the alleged incident occurred
at the time of the incident. If so, please state whether the camera was operational (or non-
operational) on the date of the incident and the name and address of each person having
custody of any surveillance tape(s) or digital recording(s) for that date.
16. Please state whether on the date of the incident alleged in the Complaint, the Defendant,
Baywatch, was a party to a contract with any company to provide maintenance or cleaning
services to the vessel. If so, please state the precise name and address for said maintenance
or cleaning company. Please state further whether you contend that the maintenance or
cleaning company had any involvement or responsibility with regard to the allegations of
negligence made in the Complaint against the Defendant , Baywatch. If so, please state the
basis of this company’s responsibility including the citation to any provisions in any contract.17. 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.
18. Please describe, in detail, the vessel where the incident alleged in the Complaint occurred.
19. Please state the precise names and addresses, of all crew members, employees, or
personnel, working on the vessel on the date of the incident, or assocaited with the incident
alleged in the Complaint.
1020. Please state the name and describe the other vessels that were associated with the boat
outing which preceded the incident alleged in the Complaint, and all crew members,
employees, or personnel, working on these vessels, on the date of the incident alleged in the
Complaint.
ilSIGNATURE PAGE FOR INTERROGATORIES
(x),
Print Name:
STATE OF FLORIDA
COUNTY OF
The foregoing answers to interrogatories were sworn to (or affirmed) before me this
__ day of 7 by
NOTARY PUBLIC
[Print, type or stamp commissioned name of notary]
Personally known
Produced identification
Type of identification produced
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Preview
Filing # 125427417 E-Filed 04/22/2021 01:51:38 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA LILLY WILLIAMS, and her husband, BLAKE McLOUD, Plaintiffs, vs. Case No.: CACE-21-007626 BAYWATCH BOAT RENTALS, TOURS & CHARTERS, INC., a Florida Corporation, d/b/a CAPTAIN JOE’S BOAT RENTALS, TOURS & CHARTERS, INC., Defendant, IEEE, INTERROGATORIES TO DEFENDANT (Baywatch) COMES NOW, the Plaintiffs, Lilly Williams and her husband, Blake McLoud, by and through their undersigned attorneys, and propound the attached Interrogatories to the Defendant, Baywatch Boat Rentals, Tours & Charters, Inc., (“Baywatch”), to be answered under oath within forty-five (45) days, in accordance with the applicable Rules of Court. | DO HEREBY CERTIFY that an original copy of the foregoing Interrogatories was served with the Summons and Complaint. The Ben Law Firm, PLLC Attorneys for the Plaintiffs /s/ ANDREW S. BEN FBN: 109024 LAWRENCE S. BEN FBN: 300888 2699 Stirling Road, Suite C-301 Fort Lauderdale, FL 33312 Telephone: (954) 961-2055 Andy@TheBenLawFirm.com Larry@TheBenLawFirm.com Mailroom@TheBenLawFirm.com 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/22/2021 01:51:35 PM.****PLAINTIFF’s INTERROGATORIES TO DEFENDANT, BAYWATCH (1* Set) DEFINITIONS A. The word “vessel” as used herein shall refer to the “45' Chris Craft Vessel,” described in the Complaint, which was involved in the incident of 06/23/2020. B. The word “incident” as used herein shall refer to the incident 06/23/2020, described in the Complaint Cc The word “Baywatch” as used herein shall refer to the Defendant, Baywatch Boat Rentals, Tours & Charters, Inc. 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. Please state the complete name and address of the entity who owned the vessel on the date of the incident alleged in the Complaint.3. Describe any and all policies of insurance which you contend cover or may cover Baywatch or the vessel for the allegations set forth in plaintiffs 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. 4. Describe in detail how the incident described in the Complaint happened, including all actions taken by you to prevent the incident.5. Describe 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. 6. State the facts upon which you rely for each affirmative defense in your answer.7, 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. 8. 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.9. 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. 10. State the name and address of every person known to you, your agents, or your attorney who has knowledge about, or possession, custody, or control of, any model, plat, map, drawing, motion picture, video-tape, digital recording and/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.11. Have you made an agreement with anyone that would limit that party’s liability or obligation to pay to anyone for any of the damages sued upon in this case? If so, state the terms of the agreement and the parties to it. 12. Please state the precise name and address of any witnesses to the incident describe in the Complaint.13. Please state the precise name and address of each person/corporation/and or other entity who is responsible for controlling and/or maintaining the vessel. 14. With reference to the negligence alleged in the complaint in this action, please state whether there have been any claims or lawsuits made against you pertaining to the same or similar alleged conditions. If so, please the name of the claimant/plaintiff, the date of the incident(s), the nature of the alleged conditions, and the name and address of the claimant/plaintiff’s attorney.15. At the time of the incident alleged in the Complaint, were there any surveillance cameras on the vessel, or near the vessel, which covered the area where the alleged incident occurred at the time of the incident. If so, please state whether the camera was operational (or non- operational) on the date of the incident and the name and address of each person having custody of any surveillance tape(s) or digital recording(s) for that date. 16. Please state whether on the date of the incident alleged in the Complaint, the Defendant, Baywatch, was a party to a contract with any company to provide maintenance or cleaning services to the vessel. If so, please state the precise name and address for said maintenance or cleaning company. Please state further whether you contend that the maintenance or cleaning company had any involvement or responsibility with regard to the allegations of negligence made in the Complaint against the Defendant , Baywatch. If so, please state the basis of this company’s responsibility including the citation to any provisions in any contract.17. 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. 18. Please describe, in detail, the vessel where the incident alleged in the Complaint occurred. 19. Please state the precise names and addresses, of all crew members, employees, or personnel, working on the vessel on the date of the incident, or assocaited with the incident alleged in the Complaint. 1020. Please state the name and describe the other vessels that were associated with the boat outing which preceded the incident alleged in the Complaint, and all crew members, employees, or personnel, working on these vessels, on the date of the incident alleged in the Complaint. ilSIGNATURE PAGE FOR INTERROGATORIES (x), Print Name: STATE OF FLORIDA COUNTY OF The foregoing answers to interrogatories were sworn to (or affirmed) before me this __ day of 7 by NOTARY PUBLIC [Print, type or stamp commissioned name of notary] Personally known Produced identification Type of identification produced 12