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Case Number: CACE-21-009583 Division: 21
Filing # 126770334 E-Filed 05/13/2021 03:18:51 PM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.:
HEATHER GRANT,
Plaintiff,
VS.
DAVID VADILLO and
LYFT FLORIDA, INC.
d/b/a LYFT, INC.,
Defendants.
/
NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT.
LYFT FLORIDA, INC. d/b/a LYFT, INC.
Plaintiff, HEATHER GRANT by and through her undersigned counsel, hereby
gives Notice of Service of the attached Interrogatories to the Defendant, LYFT
FLORIDA, INC. d/b/a LYFT, INC. to be answered in writing, under oath, and within
forty-five (45) days of service.
/s/Jon A. Zepnick, Esq.
Jon A. Zepnick, Esq.
Florida Bar No.: 586951
ANSEL & MILLER, LLC
Counsel for the Plaintiff
1939 Tyler Street
Hollywood, Florida 33020
Phone: (954) 922-9100
Fax: (954) 922-9176
jonzepnick@anselmiler.com
Makethecall03@aol.com
rshields@anselmiller.com
ansel@anselmiller.com
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/13/2021 03:18:47 PM.**#*
TERROGATORIES TO DEFENDANT, LYFT FLORIDA, INC. d/b/a
LYFT, INC.
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?
List all former names and when you were known by those names. State all addresses
where you have lived for the past 10 years, the dates you lived at each address, your
social security number, and your date of birth.
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 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, including excess and umbrella insurance,
which you contend cover or may cover you for the allegations set forth in Plaintiff's
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 and/or DAVID VADILLO to prevent this incident.
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.
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 and/or DAVID VADILLO 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, did you enter to
the charge; 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?
10. 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.
11. 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.
12 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, video-tape, 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.
13 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.
14. Have you made an agreement with anyone that would limit that party’s liability to
anyone for any of the damages sued upon this case? If so, state the terms of the
agreement and the parties to it.
15 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.
16. Does DAVID VADILLO wear glasses, contact lenses, or hearing aids? If so, 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.
17. Was DAVID VADILLO suffering from a 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?
18. Did DAVID VADILLO 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 you consumed them.
19. Did any mechanical defect in the motor vehicle which DAVID VADILLO was
driving 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.
20. List the name and address of all persons, corporations, or entities who were
registered title owners or who had ownership interest in, or right to control, the
motor vehicle that DAVID VADILLO was 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 motor vehicle, and the vehicle itself, including the make,
model, year, and vehicle identification number.
21 Was the vehicle DAVID VADILLO driving at the time of the subject incident an
in-service Lyft transporting a passenger? If no, please state on whose behalf
DAVID VADILLO was driving his vehicle.
22. At the time of the incident, was DAVID VADILLO engaged in any mission,
activity on behalf of LYFT? If yes, please describe in detail.
B
: LYFT FLORIDA, INC., d/b/a
LYFT, INC.
STATE OF )
) SS:
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared. >
after being duly sworn, deposes and says that he/she has read the foregoing Answers to
Interrogatories and that they are true and correct to the best of his/her knowledge.
SWORN TO AND SUBSCRIBED before me in the State and County aforesaid
this day of , 2021.
NOTARY PUBLIC
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Case Number: CACE-21-009583 Division: 21 Filing # 126770334 E-Filed 05/13/2021 03:18:51 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: HEATHER GRANT, Plaintiff, VS. DAVID VADILLO and LYFT FLORIDA, INC. d/b/a LYFT, INC., Defendants. / NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT. LYFT FLORIDA, INC. d/b/a LYFT, INC. Plaintiff, HEATHER GRANT by and through her undersigned counsel, hereby gives Notice of Service of the attached Interrogatories to the Defendant, LYFT FLORIDA, INC. d/b/a LYFT, INC. to be answered in writing, under oath, and within forty-five (45) days of service. /s/Jon A. Zepnick, Esq. Jon A. Zepnick, Esq. Florida Bar No.: 586951 ANSEL & MILLER, LLC Counsel for the Plaintiff 1939 Tyler Street Hollywood, Florida 33020 Phone: (954) 922-9100 Fax: (954) 922-9176 jonzepnick@anselmiler.com Makethecall03@aol.com rshields@anselmiller.com ansel@anselmiller.com #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/13/2021 03:18:47 PM.**#* TERROGATORIES TO DEFENDANT, LYFT FLORIDA, INC. d/b/a LYFT, INC. 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? List all former names and when you were known by those names. State all addresses where you have lived for the past 10 years, the dates you lived at each address, your social security number, and your date of birth. 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 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, including excess and umbrella insurance, which you contend cover or may cover you for the allegations set forth in Plaintiff's 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 and/or DAVID VADILLO to prevent this incident. 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. 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 and/or DAVID VADILLO 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, did you enter to the charge; 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? 10. 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. 11. 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. 12 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, video-tape, 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. 13 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. 14. Have you made an agreement with anyone that would limit that party’s liability to anyone for any of the damages sued upon this case? If so, state the terms of the agreement and the parties to it. 15 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. 16. Does DAVID VADILLO wear glasses, contact lenses, or hearing aids? If so, 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. 17. Was DAVID VADILLO suffering from a 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? 18. Did DAVID VADILLO 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 you consumed them. 19. Did any mechanical defect in the motor vehicle which DAVID VADILLO was driving 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. 20. List the name and address of all persons, corporations, or entities who were registered title owners or who had ownership interest in, or right to control, the motor vehicle that DAVID VADILLO was 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 motor vehicle, and the vehicle itself, including the make, model, year, and vehicle identification number. 21 Was the vehicle DAVID VADILLO driving at the time of the subject incident an in-service Lyft transporting a passenger? If no, please state on whose behalf DAVID VADILLO was driving his vehicle. 22. At the time of the incident, was DAVID VADILLO engaged in any mission, activity on behalf of LYFT? If yes, please describe in detail. B : LYFT FLORIDA, INC., d/b/a LYFT, INC. STATE OF ) ) SS: COUNTY OF ) BEFORE ME, the undersigned authority, personally appeared. > after being duly sworn, deposes and says that he/she has read the foregoing Answers to Interrogatories and that they are true and correct to the best of his/her knowledge. SWORN TO AND SUBSCRIBED before me in the State and County aforesaid this day of , 2021. NOTARY PUBLIC