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Filing # 135661113 E-Filed 09/30/2021 01:25:38 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
HEATHER GRANT,
Plaintiff,
V
CASE NO: CACE21009583 (21)
FRANCISCO GABRIEL VAILLO, DAVID CIVIL DIVISION
VADILLO AND LYFT, INC.,
Defendants,
i
V
FRANCISCO GABRIEL VADILLO,
Counter-Plaintiff,
V
HEATHER GRANT,
Counter-Defendant.
i
NOTICE OF SERVICE OF MOTOR VEHICLE NEGLIGENCE
INTERROGATORIES TO COUNTER-PLAINTIFF,FRANCISCO GABRIEL
VADILLO
The Counter-Plaintiff, FRANCISCO GABRIEL VADILLO, is hereby requested to and
required to answer the attached Motor Vehicle Negligence Interrogatories propounded by the
Counter-Defendant, HEATHER GRANT, under oath, and further, in accordance with the Florida
Rules of Civil Procedure 1.340.
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/30/2021 01:25:37 PM.****
Case No: CACE21009583 (21)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished via E-Mail on September 30, 2021 to Douglas E. Ede, Esq., Rumberger, Kirk, &
Caldwell, P.A., Attorney for Defendant, Lyft, Inc., dede@rumberger.com;
(305) 358-5577/(305) 371-7580 (F), George L. Fernandez, Esq,
Quintairos Prieto Wood & Boyer P.A., Attorney for Defendants, Francisco Gabriel Vadillo and
David Vadillo, bfetokakis-
(305) 670-1101/(305) 670-
1101 (F), Bruce F. Silver, Esq., Silver & Silver, P.A., Attorney for Counter Plaintiff, Francisco
Gabriel Vadillo,
(561) 488-3344/(561) 488-5899 (F) and Jon A. Zepnick,
Esquire, Ansel & Miller, L.L.C., Attorney for Plaintiff, Heather Grant,
Law Offices of Michael W. Carroll
Attorneys for Counter-Defendant
3230 West Commercial Blvd., Suite 400
Fort Lauderdale, FL 33309
(561) 402-8092 (Asst.)/(954) 903-6551 (Direct)
Fax: (866) 841-8921
SERVICE DESIGNATIONS:
Primary
Secondary:
Af7
By-
LISA B. SILVERMAN, ESQUIRE
Florida Bar No. 68784
"Salaried EmployeesofProgressive Casualty Imurance Company"
Case No: CACE21009583 (21)
MOTOR VEHICLE NEGLIGENCE INTERROGATORIES TO COUTNER-PLAINTIFF
FRANCISCO GABRIEL VADILLO
Please insert your answer in the spaceprovided 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.
a. If you employed at the time of the accident which is the subject
were of this case,
describe your job and its responsibilities.
b. If you returned to work since the incident described in the Complaint, state the date
of your return and if you are doing the same work you did before this incident
Case No: CACE21009583 (21)
3 List all former names and when you 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. Have you ever been convicted of a crime, other than anyjuvenile adjudication, which under
the law under which you were convicted was punishable by death or imprisonment in
excess of one year, or that involved dishonesty or a false statement regardless of the
punishment? If so, state as to each conviction, the specific crime, the date and the place of
conviction.
5. Were you suffering from 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?
Case No: CACE21009583 (21)
6. Did you consume any alcoholic beverages or take any drugs or medication within twelve
(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 you consumed them.
7. Describe in detail how the incident described in the complaint happened, including all
actions taken by you to prevent the incident.
8 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.
Case No: CACE21009583 (21)
9- 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; whatplea, 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?
10. Describe each injury for which you claiming damages in this case, specifying the part
are
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.
11. List each item of expense or damage, other than loss of income
earning capacity, that
or
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: CACE21009583 (21)
12. 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 so, state the nature of the
income, benefits, or earning capacity, and the amount and the method that you used in
computing the amount.
13. Has anything been paid or is anything payable from any third party for the damages listed
in your answers to these Interrogatories? If so, 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.
14. List the names and business addresses of each physician who has treated or examined you,
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.
Case No: CACE21009583 (21)
15. 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.
16. List the names and addresses of all persons who are believed or known by you, your agents
or attorneysto have any knowledge concerning any ofthe issues in this lawsuit; and specify
the subject matter about which the witness has knowledge.
17. 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.
Case No: CACE21009583 (21)
18. State the and address of every person known to you, your agents, or attorneys, who
name
has knowledge about, or possession, custody or control of any model, plat, map, drawing,
motion video tape, or photograph pertaining to any fact or issue involved in this
picture,
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.
19. 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'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.
20. 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 so, state the terms of the agreement and
the parties to it.
Case No: CACE21009583 (21)
21. Please state if you have 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.
22. At the time of the incident described in theComplaint, were you wearing a seat belt? If
not, please state why not; where you were seated in the
vehicle; and whether the vehicle
was equipped with a seat belt that was operational and available for your use.
23. Did any mechanical defect in the motor vehicle in which you were riding at the time ofthe
incident described in the Complaint contribute to the incident? If so, describe the nature
of the defect and how it contributed to the incident.
Case No: CACE21009583 (21)
24. Please identify by date, location and nature (type of all accidents in which you
accident)
were involved before and after the incident involved in this lawsuit, regardless of whether
or injured. ("Accidents" covers all types of incidents, and includes, but is not
not you were
limited to motor vehicle accidents).
25. As to each accident identified in response to question 24, please state whether or not you
were injured, and if injured, state the nature of the injury, if it was permanent, and the full
name and address of all physicians and providers by whom you were
treated.
26. Please identify all claims made by you for personal injuries with any insurance company
or individual (excluding court (cases) including the date of the claim, the nature of the
claim, and the name and address of the individual or business entity against whom the
claim was made or filed.
Case No: CACE21009583 (21)
27. Please state whether or not you have filed a claim for worker's
compensation,
unemploymentcompensation, or social security disability benefits withinthe past 10 years.
If so, please state the date of each claim, the name and address of the individual/agency
with whom the claim was made, and the amount of benefits received.
28. With regard to any and all cellphones you had access to on the date of the accident
described in the Complaint, please state:
a. The name and address of the carrier/provider for each cell phone.
b. The telephone number, including the area code for each cell phone.
C The billing account number for each cell phone.
d. The name and address of the account holder for each cell phone.
29. List the name, business address, telephone number, named insured, policy number, (both
group and individual number) and applicable dates of coverage for all health insurance
companies, life insurance companies and disability insurance companies, who have
provided coverage for you in the past ten (10) years.
Case No: CACE21009583 (21)
30. Identify all social/professional networking websites that Counter-Plaintiffis registered
with currently (such as Facebook, LinkedIn, Tinder, MyLife, etc.).
BY:
Name: FRANCISCO GABRIEL VADILLO
STATE OF FLORIDA I
} SS
COUNTY OF I
Sworn to (or affirmed) and subscribedbefore me by means of [] physical presence or [] online
notarization, this dayor ,
20 by
who is personally known to me (or has produced as identification)
and did/did not take an oath.
BY:
Name.
NOTARY PUBLIC STATE OF FLORIDA
Commission Expires/SerialNo./Seal
Preview
Filing # 135661113 E-Filed 09/30/2021 01:25:38 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA HEATHER GRANT, Plaintiff, V CASE NO: CACE21009583 (21) FRANCISCO GABRIEL VAILLO, DAVID CIVIL DIVISION VADILLO AND LYFT, INC., Defendants, i V FRANCISCO GABRIEL VADILLO, Counter-Plaintiff, V HEATHER GRANT, Counter-Defendant. i NOTICE OF SERVICE OF MOTOR VEHICLE NEGLIGENCE INTERROGATORIES TO COUNTER-PLAINTIFF,FRANCISCO GABRIEL VADILLO The Counter-Plaintiff, FRANCISCO GABRIEL VADILLO, is hereby requested to and required to answer the attached Motor Vehicle Negligence Interrogatories propounded by the Counter-Defendant, HEATHER GRANT, under oath, and further, in accordance with the Florida Rules of Civil Procedure 1.340. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/30/2021 01:25:37 PM.**** Case No: CACE21009583 (21) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via E-Mail on September 30, 2021 to Douglas E. Ede, Esq., Rumberger, Kirk, & Caldwell, P.A., Attorney for Defendant, Lyft, Inc., dede@rumberger.com; (305) 358-5577/(305) 371-7580 (F), George L. Fernandez, Esq, Quintairos Prieto Wood & Boyer P.A., Attorney for Defendants, Francisco Gabriel Vadillo and David Vadillo, bfetokakis- (305) 670-1101/(305) 670- 1101 (F), Bruce F. Silver, Esq., Silver & Silver, P.A., Attorney for Counter Plaintiff, Francisco Gabriel Vadillo, (561) 488-3344/(561) 488-5899 (F) and Jon A. Zepnick, Esquire, Ansel & Miller, L.L.C., Attorney for Plaintiff, Heather Grant, Law Offices of Michael W. Carroll Attorneys for Counter-Defendant 3230 West Commercial Blvd., Suite 400 Fort Lauderdale, FL 33309 (561) 402-8092 (Asst.)/(954) 903-6551 (Direct) Fax: (866) 841-8921 SERVICE DESIGNATIONS: Primary Secondary: Af7 By- LISA B. SILVERMAN, ESQUIRE Florida Bar No. 68784 "Salaried EmployeesofProgressive Casualty Imurance Company" Case No: CACE21009583 (21) MOTOR VEHICLE NEGLIGENCE INTERROGATORIES TO COUTNER-PLAINTIFF FRANCISCO GABRIEL VADILLO Please insert your answer in the spaceprovided 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. a. If you employed at the time of the accident which is the subject were of this case, describe your job and its responsibilities. b. If you returned to work since the incident described in the Complaint, state the date of your return and if you are doing the same work you did before this incident Case No: CACE21009583 (21) 3 List all former names and when you 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. Have you ever been convicted of a crime, other than anyjuvenile adjudication, which under the law under which you were convicted was punishable by death or imprisonment in excess of one year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction, the specific crime, the date and the place of conviction. 5. Were you suffering from 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? Case No: CACE21009583 (21) 6. Did you consume any alcoholic beverages or take any drugs or medication within twelve (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 you consumed them. 7. Describe in detail how the incident described in the complaint happened, including all actions taken by you to prevent the incident. 8 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. Case No: CACE21009583 (21) 9- 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; whatplea, 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? 10. Describe each injury for which you claiming damages in this case, specifying the part are 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. 11. List each item of expense or damage, other than loss of income earning capacity, that or 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: CACE21009583 (21) 12. 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 so, state the nature of the income, benefits, or earning capacity, and the amount and the method that you used in computing the amount. 13. Has anything been paid or is anything payable from any third party for the damages listed in your answers to these Interrogatories? If so, 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. 14. List the names and business addresses of each physician who has treated or examined you, 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. Case No: CACE21009583 (21) 15. 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. 16. List the names and addresses of all persons who are believed or known by you, your agents or attorneysto have any knowledge concerning any ofthe issues in this lawsuit; and specify the subject matter about which the witness has knowledge. 17. 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. Case No: CACE21009583 (21) 18. State the and address of every person known to you, your agents, or attorneys, who name has knowledge about, or possession, custody or control of any model, plat, map, drawing, motion video tape, or photograph pertaining to any fact or issue involved in this picture, 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. 19. 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'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. 20. 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 so, state the terms of the agreement and the parties to it. Case No: CACE21009583 (21) 21. Please state if you have 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. 22. At the time of the incident described in theComplaint, were you wearing a seat belt? If not, please state why not; where you were seated in the vehicle; and whether the vehicle was equipped with a seat belt that was operational and available for your use. 23. Did any mechanical defect in the motor vehicle in which you were riding at the time ofthe incident described in the Complaint contribute to the incident? If so, describe the nature of the defect and how it contributed to the incident. Case No: CACE21009583 (21) 24. Please identify by date, location and nature (type of all accidents in which you accident) were involved before and after the incident involved in this lawsuit, regardless of whether or injured. ("Accidents" covers all types of incidents, and includes, but is not not you were limited to motor vehicle accidents). 25. As to each accident identified in response to question 24, please state whether or not you were injured, and if injured, state the nature of the injury, if it was permanent, and the full name and address of all physicians and providers by whom you were treated. 26. Please identify all claims made by you for personal injuries with any insurance company or individual (excluding court (cases) including the date of the claim, the nature of the claim, and the name and address of the individual or business entity against whom the claim was made or filed. Case No: CACE21009583 (21) 27. Please state whether or not you have filed a claim for worker's compensation, unemploymentcompensation, or social security disability benefits withinthe past 10 years. If so, please state the date of each claim, the name and address of the individual/agency with whom the claim was made, and the amount of benefits received. 28. With regard to any and all cellphones you had access to on the date of the accident described in the Complaint, please state: a. The name and address of the carrier/provider for each cell phone. b. The telephone number, including the area code for each cell phone. C The billing account number for each cell phone. d. The name and address of the account holder for each cell phone. 29. List the name, business address, telephone number, named insured, policy number, (both group and individual number) and applicable dates of coverage for all health insurance companies, life insurance companies and disability insurance companies, who have provided coverage for you in the past ten (10) years. Case No: CACE21009583 (21) 30. Identify all social/professional networking websites that Counter-Plaintiffis registered with currently (such as Facebook, LinkedIn, Tinder, MyLife, etc.). BY: Name: FRANCISCO GABRIEL VADILLO STATE OF FLORIDA I } SS COUNTY OF I Sworn to (or affirmed) and subscribedbefore me by means of [] physical presence or [] online notarization, this dayor , 20 by who is personally known to me (or has produced as identification) and did/did not take an oath. BY: Name. NOTARY PUBLIC STATE OF FLORIDA Commission Expires/SerialNo./Seal