Preview
Filing # 129833959 E-Filed 06/30/2021 03:16:31 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO: CACE-21-007713 (08)
VICKI KATCHMERE,
Plaintiff,
V
MEADOWBROOK LAKES VIEW
CONDOMINIUM ASSOCIATION"A",INC.,
a Florida Not for Profit Corporation, and
FRANCISCO COLET,
Defendant.
1
NOTICE OF SERVICE OF INTERROGATORIES TO PLAINTIFF
Defendant, MEADOWBROOK LAKES VIEW CONDOMINIUM ASSOCIATION"A",
INC. (hereinafter"MEADOWBROOK"),by and through its undersigned counsel, pursuantto Fla.
R. Civ. P. Rule 1.340, hereby files this Notice of Serving Initial Interrogatories to Plaintiff to be
answered under oath, in writing, within thirty (30) days.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy hereofhas been furnished by E-service on this 30h day
of June, 2021, to: Edward F. Holodak, Esq., EDWARD F. HOLODAK, P.A., Counsel for
Plainti#; Ficki Katchmere, 7580 NW 5th St., Ste.
Plantation, FL 33317,
15125,
Dylan E. Goldberg, Esq., Vincent F. Vaccaralla, P.A., Counsel for
Francisco Colet, 888 E. Las Olas Blvd., Suite 700, Fort Lauderdale, FL 33301; (dgoldberg@v-
law.net; vincent@v-law.net);and Scott R. Shapiro, Esq., SHAPIRO, STRALEY I OTTO, Counsel
M MEADOWBROOK LAKES VIEWCONDOMNIUMASSOCIMONA, INC.,2699 Stirling
Rd., Ste. C-207, Fort Lauderdale, FL 33312;
[SIGNATURE TO FOLLOW ON NEXT PAGE]
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/30/2021 03:16:31 PM.****
CASE NO: CACE-21-007713 (08)
Page 2 of 6
PETERSON BERNARD
Counsel for Defendant MeadowbrookLakes
1550 Southern Boulevard #300
West Palm Beach, FL 33406-3240
bryan. com
com
561-686-5005 I Office 561-471-5603 I Fax
BY: /s/ BrymAMLOUU
BRYAN ASHLOCK, ESQ.
Florida Bar No. 114038
CASE NO: CACE-21-007713 (08)
Page 3 of 6
DEFINITIONS:
1. The capitalized terms "You" and "Your" mean VICKI KATCHMERE,
individually, and/or one or more agents, employees, and/or entities or persons acting on behalf of
or at the direction of any ofthe preceding.
2. The capitalized terms "Home" and "Property" mean the property located 301 se
3RD Street, Unit 107, Dania Beach, FL 33004.
3 The capitalized terms "Loss" and "Claim" refer to the events described in the
Complaint for Case No.. CACE-21-007713 (08).
4. The capitalize term "Date of Loss" means the date of the events listed in the
Complaint for Case No.. CACE-21-007713 (08) and/or February 15, 2021.
INTERROGATORIES:
1. What is the name and address of the person(s) answering these Interrogatories, and, if
applicable, theperson(s) official position or relationship with the party to whom the
Interrogatories are directed?
2. Describe the Loss in
specific detail, including but not limited to what happened, what was
observed, the dates of what
happened and what was observed, and the complete contact
informationof anyone with personal knowledge of these facts.
3 Describe what You understand to be the cause of the Loss and
please provide the facts
supporting that understanding ofwhat happened, and please identify the names, addresses,
electronic mail addresses, facsimile numbers, and phone numbers of any person and/or
entitywho/that has assisted you at arriving at any ofthese conclusions.Identify each person
and entity who/that observed the Loss, the date each person and entity first observed the
Loss, and a narrative describing each person's and entity's observations of the damage at
the Property.
4. Describe any and all steps or measures You or any other person took to mitigate the Loss
or damage and to protect the Property after the Loss or damage was discovered, including
who(m) or what entity(s) took such action(s) and when each step(s) to protect the Property
occurred.
5. Describe the total dollar amount of damages You are claiming Defendant is obligated to
pay according to the Policy for the Loss, and include a detailed breakdown of each scope
item of damage and the cause of each scope item of damage, the person(s) and/or
entity(ies), whom/that You rely on to support Your claim for damages, and please also
CASE NO: CACE-21-007713 (08)
Page 4 of 6
describe whether any of the Property or part of it claimed damaged has been repaired or
replaced, and if so, which Property or part o f it has been repaired or replaced.
6. State whether You have ever been a party, either plaintiffor defendant (includingpetitioner
or respondent), in a lawsuit other than the present matter, and, if so, state whether You
were plaintiffor defendant, the nature ofthe action, and the date and court and case number
under which such suit was filed.
7. 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 of 1 year, or that involved dishonesty or a false statement regardless of the
excess
punishment? If so, state as to each conviction the specific crime and the date and place of
conviction.
8 List all persons who lived at the Home for the five (5) years prior to the Date of Loss. For
each person, state the person's name, date of birth, relation to You, and the dates during
which the person lived there. If You had a spouse during that time who lived somewhere
other than the Home, specify where he/she lived.
9- List all persons and businesses that performed any mold, leak detection or plumbing tests
at, in, or to the Home from the four years prior to the Date o f Loss through the present. For
each, specify the name, address, and phone number of the person or business, specify the
nature of the work performed, and state the dates during which the work was performed.
10. Describe any and all claims You have submitted to an insurance company within the last
eight (8) years and describe each claim, the cause of the damages underlying each claim,
the estimated cost to repair the damages underlying each claim, the name of the insurer for
each claim and, if You filed
a lawsuit arising out of any o f these claims, the case number
for each lawsuit arising from the claim, and the final terms and conditions of any resolution
reached with respect to each claim and lawsuit.
11. Describe any and all instances of any damage occurring at the Property related to water,
which instances of damage have occurred within the last ten (10) years, and which
description should include but not be limited to a description ofthe damages, a description
ofthe cause, the date of each water damage event at the Property, a description of whether
a claim was submitted for any water damage, and the name of each insurer who received a
claim for water damage at the Property.
CASE NO: CACE-21-007713 (08)
Page 5 of 6
12. List the names and addresses ofall persons who are believed or known by You, Your agents
or attorneys to have any
knowledge concerning the cause, extent, or repair of any damage
at issue in this lawsuit and specify the subject matter about which the witness has
knowledge.
13. State the name and address
ofevery 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 photographpertaining to: any damage to the Home
You claim is covered by the Policy, related damage or repairs, any request for appraisal, or
any other related issues; 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.
14. 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(s), the date made, and
a brief description of the substance of each statement(s).
15. State whether any engineers, appraisers, or adjusters (independent or public) have visited
and/or inspected the Home in the last five (5) years. If so, state the name of the party, the
company's name and address, the reason for the visit, the date of the visit, and whether or
report was prepared regarding the visit.
not a
16. Identify all insurance companies that You have had policies with during preceding ten (10)
years, including but not limited to, homeowners or tenant/renters insurance, and any
commercial insurance. For each insurance company, state the name, address, telephone
number ofthe insurance company, the policy number, type of insurance coverage, effective
date of the policy, whether the policy was cancelled, or the insurance company refused to
renew any policy and, if a policy was nonrenewal or cancelled, please provide the reason(s)
for nonrenewal or the cancellation.
17. Please identify with specificityevery attempt You made to
distinguish the damages alleged
in Your Complaint from any other damages or any other causes of damage at the Property.
18. Do you intend to call any expert witnesses at the trial ofthis case? If so, state as to each such
witness the name and business address ofthe witness, the witness's qualifications as an expert,
thesubject 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.
CASE NO: CACE-21-007713 (08)
Page 6 of 6
I HAVE READ THE FOREGOINGANSWERS TO INTERROGATOR-IES IN FULL AND
SWEAR SUCH ANSWERS ARE TRUE, CORRECT, AND COMPLETE.
AFFIANT
Print Name:
STATE OF
)SS
COUNTY OF
BEFORE ME, the undersigned authority,personally appeared
and ,
who swear and depose that they
has read the Answers to Interrogatories and that the same are true and correct.
SWORN TO AND SUBSCRIBED before me this dayor 2021.
NOTARY PUBLIC
PRINT NAME-
Personally known by me, or
Produced Identification
Type o f Identification:
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Filing # 129833959 E-Filed 06/30/2021 03:16:31 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE-21-007713 (08) VICKI KATCHMERE, Plaintiff, V MEADOWBROOK LAKES VIEW CONDOMINIUM ASSOCIATION"A",INC., a Florida Not for Profit Corporation, and FRANCISCO COLET, Defendant. 1 NOTICE OF SERVICE OF INTERROGATORIES TO PLAINTIFF Defendant, MEADOWBROOK LAKES VIEW CONDOMINIUM ASSOCIATION"A", INC. (hereinafter"MEADOWBROOK"),by and through its undersigned counsel, pursuantto Fla. R. Civ. P. Rule 1.340, hereby files this Notice of Serving Initial Interrogatories to Plaintiff to be answered under oath, in writing, within thirty (30) days. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy hereofhas been furnished by E-service on this 30h day of June, 2021, to: Edward F. Holodak, Esq., EDWARD F. HOLODAK, P.A., Counsel for Plainti#; Ficki Katchmere, 7580 NW 5th St., Ste. Plantation, FL 33317, 15125, Dylan E. Goldberg, Esq., Vincent F. Vaccaralla, P.A., Counsel for Francisco Colet, 888 E. Las Olas Blvd., Suite 700, Fort Lauderdale, FL 33301; (dgoldberg@v- law.net; vincent@v-law.net);and Scott R. Shapiro, Esq., SHAPIRO, STRALEY I OTTO, Counsel M MEADOWBROOK LAKES VIEWCONDOMNIUMASSOCIMONA, INC.,2699 Stirling Rd., Ste. C-207, Fort Lauderdale, FL 33312; [SIGNATURE TO FOLLOW ON NEXT PAGE] *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/30/2021 03:16:31 PM.**** CASE NO: CACE-21-007713 (08) Page 2 of 6 PETERSON BERNARD Counsel for Defendant MeadowbrookLakes 1550 Southern Boulevard #300 West Palm Beach, FL 33406-3240 bryan. com com 561-686-5005 I Office 561-471-5603 I Fax BY: /s/ BrymAMLOUU BRYAN ASHLOCK, ESQ. Florida Bar No. 114038 CASE NO: CACE-21-007713 (08) Page 3 of 6 DEFINITIONS: 1. The capitalized terms "You" and "Your" mean VICKI KATCHMERE, individually, and/or one or more agents, employees, and/or entities or persons acting on behalf of or at the direction of any ofthe preceding. 2. The capitalized terms "Home" and "Property" mean the property located 301 se 3RD Street, Unit 107, Dania Beach, FL 33004. 3 The capitalized terms "Loss" and "Claim" refer to the events described in the Complaint for Case No.. CACE-21-007713 (08). 4. The capitalize term "Date of Loss" means the date of the events listed in the Complaint for Case No.. CACE-21-007713 (08) and/or February 15, 2021. INTERROGATORIES: 1. What is the name and address of the person(s) answering these Interrogatories, and, if applicable, theperson(s) official position or relationship with the party to whom the Interrogatories are directed? 2. Describe the Loss in specific detail, including but not limited to what happened, what was observed, the dates of what happened and what was observed, and the complete contact informationof anyone with personal knowledge of these facts. 3 Describe what You understand to be the cause of the Loss and please provide the facts supporting that understanding ofwhat happened, and please identify the names, addresses, electronic mail addresses, facsimile numbers, and phone numbers of any person and/or entitywho/that has assisted you at arriving at any ofthese conclusions.Identify each person and entity who/that observed the Loss, the date each person and entity first observed the Loss, and a narrative describing each person's and entity's observations of the damage at the Property. 4. Describe any and all steps or measures You or any other person took to mitigate the Loss or damage and to protect the Property after the Loss or damage was discovered, including who(m) or what entity(s) took such action(s) and when each step(s) to protect the Property occurred. 5. Describe the total dollar amount of damages You are claiming Defendant is obligated to pay according to the Policy for the Loss, and include a detailed breakdown of each scope item of damage and the cause of each scope item of damage, the person(s) and/or entity(ies), whom/that You rely on to support Your claim for damages, and please also CASE NO: CACE-21-007713 (08) Page 4 of 6 describe whether any of the Property or part of it claimed damaged has been repaired or replaced, and if so, which Property or part o f it has been repaired or replaced. 6. State whether You have ever been a party, either plaintiffor defendant (includingpetitioner or respondent), in a lawsuit other than the present matter, and, if so, state whether You were plaintiffor defendant, the nature ofthe action, and the date and court and case number under which such suit was filed. 7. 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 of 1 year, or that involved dishonesty or a false statement regardless of the excess punishment? If so, state as to each conviction the specific crime and the date and place of conviction. 8 List all persons who lived at the Home for the five (5) years prior to the Date of Loss. For each person, state the person's name, date of birth, relation to You, and the dates during which the person lived there. If You had a spouse during that time who lived somewhere other than the Home, specify where he/she lived. 9- List all persons and businesses that performed any mold, leak detection or plumbing tests at, in, or to the Home from the four years prior to the Date o f Loss through the present. For each, specify the name, address, and phone number of the person or business, specify the nature of the work performed, and state the dates during which the work was performed. 10. Describe any and all claims You have submitted to an insurance company within the last eight (8) years and describe each claim, the cause of the damages underlying each claim, the estimated cost to repair the damages underlying each claim, the name of the insurer for each claim and, if You filed a lawsuit arising out of any o f these claims, the case number for each lawsuit arising from the claim, and the final terms and conditions of any resolution reached with respect to each claim and lawsuit. 11. Describe any and all instances of any damage occurring at the Property related to water, which instances of damage have occurred within the last ten (10) years, and which description should include but not be limited to a description ofthe damages, a description ofthe cause, the date of each water damage event at the Property, a description of whether a claim was submitted for any water damage, and the name of each insurer who received a claim for water damage at the Property. CASE NO: CACE-21-007713 (08) Page 5 of 6 12. List the names and addresses ofall persons who are believed or known by You, Your agents or attorneys to have any knowledge concerning the cause, extent, or repair of any damage at issue in this lawsuit and specify the subject matter about which the witness has knowledge. 13. State the name and address ofevery 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 photographpertaining to: any damage to the Home You claim is covered by the Policy, related damage or repairs, any request for appraisal, or any other related issues; 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. 14. 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(s), the date made, and a brief description of the substance of each statement(s). 15. State whether any engineers, appraisers, or adjusters (independent or public) have visited and/or inspected the Home in the last five (5) years. If so, state the name of the party, the company's name and address, the reason for the visit, the date of the visit, and whether or report was prepared regarding the visit. not a 16. Identify all insurance companies that You have had policies with during preceding ten (10) years, including but not limited to, homeowners or tenant/renters insurance, and any commercial insurance. For each insurance company, state the name, address, telephone number ofthe insurance company, the policy number, type of insurance coverage, effective date of the policy, whether the policy was cancelled, or the insurance company refused to renew any policy and, if a policy was nonrenewal or cancelled, please provide the reason(s) for nonrenewal or the cancellation. 17. Please identify with specificityevery attempt You made to distinguish the damages alleged in Your Complaint from any other damages or any other causes of damage at the Property. 18. Do you intend to call any expert witnesses at the trial ofthis case? If so, state as to each such witness the name and business address ofthe witness, the witness's qualifications as an expert, thesubject 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. CASE NO: CACE-21-007713 (08) Page 6 of 6 I HAVE READ THE FOREGOINGANSWERS TO INTERROGATOR-IES IN FULL AND SWEAR SUCH ANSWERS ARE TRUE, CORRECT, AND COMPLETE. AFFIANT Print Name: STATE OF )SS COUNTY OF BEFORE ME, the undersigned authority,personally appeared and , who swear and depose that they has read the Answers to Interrogatories and that the same are true and correct. SWORN TO AND SUBSCRIBED before me this dayor 2021. NOTARY PUBLIC PRINT NAME- Personally known by me, or Produced Identification Type o f Identification: