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Filing # 134001977 E-Filed 09/03/2021 10:39:00 AM
USA MEDICARE ADVISORS INSURANCE IN THE CIRCUIT COURT OF THE 17TH
AGENCY LLC, a Florida Limited Liability JUDICIAL CIRCUIT IN AND FOR
Company, BROWARD COUNTY, FLORIDA
CASE NO: CACE-21-010364
VS.
ELITE HEALTH INVESTMENTS, INC., a
Florida Profit Corporation,
NOTICE OF SERVING
FIRST SET OF INTERROGATORIES TO
The ELITE HEALTH INVESTMENTS, INC., a Florida
Profit Corporation (Hereinafter "ELITE"), by and through undersigned counsel, and
pursuant to Florida Rule of Civil Procedure 1.340, hereby propounds the attached
Interrogatories to USA MEDICARE ADVISORS
INSURANCE AGENCY LLC, a Florida Limited Liability Company, to be answered within
thirty (30) days.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via the e-portal to: Veronika Balbuzanova, Esq., Johnson I Dalal, 111 N. Pine Island Road,
Suite 103, Plantation, FL 33324; on :
September 3, 2021
BECK LAW, P.A.
901 Clint Moore Road, Suite C
Boca Raton, FL 33487
Tel: (561) 990-1647
Fax: (561) 717-9673
By: /s/ JOSHUA S. BECK, ESQ.
Florida Bar No.- 040659
Primary E-Mail:
Secondary E-Mail: beck@becklawpa.corn
Attorney for
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/03/2021 10:38:59 AM.****
INTERROGATORIES TO
1. Please state the name, social security number and address of the person
answering these interrogatories, and if applicable, the person's title or relationship
with the party whom these interrogatories are directed to.
Answer:
2. List the names, addresses, and telephone numbers of all persons who are believed
or known by you, your agents, or your attorneys to have any knowledge concerning
the issues in this lawsuit and specify the subject matter about which the witness
has knowledge.
Answer:
3. List the names, addresses, and telephone numbers of all persons who are believed
or knownby you, your agents, your attorneys to have any made any statements
or
concerning the issues in this lawsuit and specify the subject matter about which
the witness has knowledge.
Answer:
4. List all facts, including but not limited to all relevant dates, and damage amounts,
that support each claim assertion listed in the Complaint.
Answer:
5. Describe in detail each act or omission on the part of any party to this lawsuit that
you contend constitute a Breach of Contract that was a contributing legal cause of
the incident in question.
Answer:
6. Describe in detail each and every way in which you contend you have suffered
damages, including, but not limited to:
a. The total amount of damages claimed;
b. Itemizing the amount of each element of damage claimed:
C State the facts andground upon which you relied upon to
support each element of damages claimed;
d. State the methods, theories or calculation by which you
arrived at the claimed dollar amount of each element of
damages claims.
e. Identify and person(s) who you know or whom you believe has
know edge of the basis of the damages claimed.
f- List a I documents that support the damages being claimed.
Answer:
7. Please describe the specific nature of the Downline Agent Agreement between the
Parties.
Answer:
8. P ease describe the specific services which were to be rendered by the
P to in the Downline Agent
Agreement.
Answer:
9. Please describe the specific services which were to be rendered by the
to in the Downline Agent
Agreement.
Answer:
10. Please state in detail all steps you have taken to mitigate damages in this matter.
Answer:
11. Please state, in detail, when, with whom and the specific details of all
conversations you have had with any of Defendant/Counter-
Plaintiff regarding the Downline Agent Agreement.
Answer:
12. Please describe in detail when the allegations contained in the Complaint were
first brought to your attention.
Answer:
13. P ease state in detail the dates and amounts paid by you to Defendant/Counter-
P aintiffs for all Cash Purchase Price commission bonuses owed to ELITE.
Answer:
14. Please list all lawsuits in which you have been a party in the past ten (10) years
Answer:
USA MEDICARE ADVISORS INSURANCE
AGENCY LLC
STATE OF
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared
, personally known or produced identification
(type of identification produced: ), who, after first
being duly sworn, deposes and says that he/she executed the foregoing and they are true
and correct to the best of his/her knowledge and belief.
WITNESS my hands and official seal, this day of ,2021.
NOTARY PUBLIC
STATE OF FLORIDA
Commission Number:
My Commission Expires
Preview
Filing # 134001977 E-Filed 09/03/2021 10:39:00 AM USA MEDICARE ADVISORS INSURANCE IN THE CIRCUIT COURT OF THE 17TH AGENCY LLC, a Florida Limited Liability JUDICIAL CIRCUIT IN AND FOR Company, BROWARD COUNTY, FLORIDA CASE NO: CACE-21-010364 VS. ELITE HEALTH INVESTMENTS, INC., a Florida Profit Corporation, NOTICE OF SERVING FIRST SET OF INTERROGATORIES TO The ELITE HEALTH INVESTMENTS, INC., a Florida Profit Corporation (Hereinafter "ELITE"), by and through undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.340, hereby propounds the attached Interrogatories to USA MEDICARE ADVISORS INSURANCE AGENCY LLC, a Florida Limited Liability Company, to be answered within thirty (30) days. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the e-portal to: Veronika Balbuzanova, Esq., Johnson I Dalal, 111 N. Pine Island Road, Suite 103, Plantation, FL 33324; on : September 3, 2021 BECK LAW, P.A. 901 Clint Moore Road, Suite C Boca Raton, FL 33487 Tel: (561) 990-1647 Fax: (561) 717-9673 By: /s/ JOSHUA S. BECK, ESQ. Florida Bar No.- 040659 Primary E-Mail: Secondary E-Mail: beck@becklawpa.corn Attorney for *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/03/2021 10:38:59 AM.**** INTERROGATORIES TO 1. Please state the name, social security number and address of the person answering these interrogatories, and if applicable, the person's title or relationship with the party whom these interrogatories are directed to. Answer: 2. List the names, addresses, and telephone numbers of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning the issues in this lawsuit and specify the subject matter about which the witness has knowledge. Answer: 3. List the names, addresses, and telephone numbers of all persons who are believed or knownby you, your agents, your attorneys to have any made any statements or concerning the issues in this lawsuit and specify the subject matter about which the witness has knowledge. Answer: 4. List all facts, including but not limited to all relevant dates, and damage amounts, that support each claim assertion listed in the Complaint. Answer: 5. Describe in detail each act or omission on the part of any party to this lawsuit that you contend constitute a Breach of Contract that was a contributing legal cause of the incident in question. Answer: 6. Describe in detail each and every way in which you contend you have suffered damages, including, but not limited to: a. The total amount of damages claimed; b. Itemizing the amount of each element of damage claimed: C State the facts andground upon which you relied upon to support each element of damages claimed; d. State the methods, theories or calculation by which you arrived at the claimed dollar amount of each element of damages claims. e. Identify and person(s) who you know or whom you believe has know edge of the basis of the damages claimed. f- List a I documents that support the damages being claimed. Answer: 7. Please describe the specific nature of the Downline Agent Agreement between the Parties. Answer: 8. P ease describe the specific services which were to be rendered by the P to in the Downline Agent Agreement. Answer: 9. Please describe the specific services which were to be rendered by the to in the Downline Agent Agreement. Answer: 10. Please state in detail all steps you have taken to mitigate damages in this matter. Answer: 11. Please state, in detail, when, with whom and the specific details of all conversations you have had with any of Defendant/Counter- Plaintiff regarding the Downline Agent Agreement. Answer: 12. Please describe in detail when the allegations contained in the Complaint were first brought to your attention. Answer: 13. P ease state in detail the dates and amounts paid by you to Defendant/Counter- P aintiffs for all Cash Purchase Price commission bonuses owed to ELITE. Answer: 14. Please list all lawsuits in which you have been a party in the past ten (10) years Answer: USA MEDICARE ADVISORS INSURANCE AGENCY LLC STATE OF COUNTY OF BEFORE ME, the undersigned authority, personally appeared , personally known or produced identification (type of identification produced: ), who, after first being duly sworn, deposes and says that he/she executed the foregoing and they are true and correct to the best of his/her knowledge and belief. WITNESS my hands and official seal, this day of ,2021. NOTARY PUBLIC STATE OF FLORIDA Commission Number: My Commission Expires