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Filing # 100354673 E-Filed 12/16/2019 11:59:23 AM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR MARION
COUNTY, FLORIDA
CASE NO.:
ALEXANDER CHANCE KEEHNER,
Plaintiff,
vs.
MICHAEL DAVID HINES,
Defendant. /
PLAINTIFF’s NOTICE OF SERVICE OF INTERROGATORIES
TO DEFENDANT, MICHAEL DAVID HINES
Plaintiff, ALEXANDER CHANCE KEEHNER, pursuant to Florida Rule of Civil
Procedure 1.340, directs the following Interrogatories to Defendant, MICHAEL DAVID HINES, to
which written answers are required in writing and under oath within forty-five (45) days from the
date of service.
I HEREBY CERTIFY that a copy of the foregoing notice has been served on Defendant this
the same date of service as that of the Summons and Complaint filed in this case.
issHarran E. Udell
Harran E. Udell, Esquire
Florida Bar No. 037249
Morgan & Morgan, P.A.
20 N. Orange Ave., 16" Floor
Orlando, FL 32801
Telephone: (407) 420-1414
Facsimile: (407) 245-3371
Primary E-Mail: HUdell@forthepeople.com
Secondary E-Mail: lfoelker@forthepeople.com;
awhitehead@forthepeople.com
Attomeys for Plaintiff
Electronically Filed Marion Case # 19CA002721AX 12/16/2019 11:59:23 AMINTERROGATORIES TO DEFENDANT
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 ten 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 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.Describe any and all policies of insurance which you contend cover or may cover you for
the allegations set forth in plaintiffs complaint, detailing as to such policies: the name of the
insurer, 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 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.7.
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, 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 was 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 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 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 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 in 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 a plaintiff or defendant, the nature
of the action, and the date and court in which such suit was filed.16. Do you 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. 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?
18. 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
you consumed them.19. Did any mechanical defect in the motor vehicle in which you were riding 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 the
defendant driver 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 vehicle, and the
vehicle itself, including the make, model, year and vehicle identification number.
21. At the time of the incident described in the complaint, did the driver of the vehicle described
in your answer to the preceding interrogatory have permission to drive the vehicle? If so,
state the names and addresses of all persons who have permission.22.
23.
24.
At the time of the incident described in the complaint, was the defendant driver 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.
Was the motor vehicle that the defendant driver was 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?
Have you or anyone acting on your behalf obtained or attempted to obtain any photographs
or video surveillance of Plaintiff? If yes, please provide the date and the name of the
individual who obtained or attempted to obtain the photographs or surveillance.STATE OF
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared this day
of 20 who after first
being duly sworn, states that the above and foregoing Answers to Interrogatories are true and
correct.
NOTARY PUBLIC
My Commission Expires:
Preview
Filing # 100354673 E-Filed 12/16/2019 11:59:23 AM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA CASE NO.: ALEXANDER CHANCE KEEHNER, Plaintiff, vs. MICHAEL DAVID HINES, Defendant. / PLAINTIFF’s NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT, MICHAEL DAVID HINES Plaintiff, ALEXANDER CHANCE KEEHNER, pursuant to Florida Rule of Civil Procedure 1.340, directs the following Interrogatories to Defendant, MICHAEL DAVID HINES, to which written answers are required in writing and under oath within forty-five (45) days from the date of service. I HEREBY CERTIFY that a copy of the foregoing notice has been served on Defendant this the same date of service as that of the Summons and Complaint filed in this case. issHarran E. Udell Harran E. Udell, Esquire Florida Bar No. 037249 Morgan & Morgan, P.A. 20 N. Orange Ave., 16" Floor Orlando, FL 32801 Telephone: (407) 420-1414 Facsimile: (407) 245-3371 Primary E-Mail: HUdell@forthepeople.com Secondary E-Mail: lfoelker@forthepeople.com; awhitehead@forthepeople.com Attomeys for Plaintiff Electronically Filed Marion Case # 19CA002721AX 12/16/2019 11:59:23 AMINTERROGATORIES TO DEFENDANT 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 ten 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 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.Describe any and all policies of insurance which you contend cover or may cover you for the allegations set forth in plaintiffs complaint, detailing as to such policies: the name of the insurer, 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 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.7. 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, 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 was 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 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 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 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 in 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 a plaintiff or defendant, the nature of the action, and the date and court in which such suit was filed.16. Do you 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. 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? 18. 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 you consumed them.19. Did any mechanical defect in the motor vehicle in which you were riding 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 the defendant driver 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 vehicle, and the vehicle itself, including the make, model, year and vehicle identification number. 21. At the time of the incident described in the complaint, did the driver of the vehicle described in your answer to the preceding interrogatory have permission to drive the vehicle? If so, state the names and addresses of all persons who have permission.22. 23. 24. At the time of the incident described in the complaint, was the defendant driver 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. Was the motor vehicle that the defendant driver was 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? Have you or anyone acting on your behalf obtained or attempted to obtain any photographs or video surveillance of Plaintiff? If yes, please provide the date and the name of the individual who obtained or attempted to obtain the photographs or surveillance.STATE OF COUNTY OF BEFORE ME, the undersigned authority, personally appeared this day of 20 who after first being duly sworn, states that the above and foregoing Answers to Interrogatories are true and correct. NOTARY PUBLIC My Commission Expires: