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Filing # 96919739 E-Filed 10/08/2019 01:41:53 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR MARION
COUNTY, FLORIDA
CASE NO:
JESUS SANTIAGO,
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
/
NOTICE OF SERVICE OF INTERROGATORIES
TO: MICHAEL OWENS HERLONG
COMES NOW the Plaintiff, JESUS SANTIAGO, by and through the undersigned counsel
and hereby propounds upon Defendant, MICHAEL OWENS HERLONG, and pursuant to Rule
1.340, Florida Rules of Civil Procedure, the attached interrogatories, answers to which will be due
within forty-five (45) days from the date of service hereof.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
said Defendant(s), along with the summons and complaint.
Js! Michael J. Smith
Michael J. Smith, Esquire
FBN# 0105368
Morgan & Morgan, P.A.
14229 US Highway 441
Tavares, FL 32778
Telephone: 352-253-2700
Facsimile: 352-253-2701
Primary email: msmith@forthepeople.com
Secondary email: ecannon@forthepeople.com
rpadgett@forthepeople.com;
khyde@forthepeople.com
Attorneys for Plaintiff
Electronically Filed Marion Case # 19CA002229AX 10/08/2019 01:41:53 PM
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdi.com.IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR MARION
COUNTY, FLORIDA
CASE NO:
JESUS SANTIAGO,
Plaintiff,
vs.
MICHAEL OWENS HERLONG,
Defendant.
/
INTERROGATORIES
Plaintiff, JESUS SANTIAGO, by and through his/her/their undersigned counsel, propounds the
attached Interrogatories, numbered one (1) through twenty-three (23) to Defendant, MICHAEL OWENS
HERLONG, to be answered, under oath, within forty-five (45) days from date of service.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
said Defendant(s), along with the summons and complaint.
Js! Michael J. Smith
Michael J. Smith, Esquire
FBN# 0105368
Morgan & Morgan, P.A.
14229 US Highway 441
Tavares, FL 32778
Telephone: 352-253-2700
Facsimile: 352-253-2701
Primary email: msmith@forthepeople.com
Secondary email: ecannon@forthepeople.com
rpadgett@forthepeople.com;
khyde@forthepeople.com
Attorneys for Plaintiff
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdi.com.GENERAL PERSONAL INJURY NEGLIGENCE-
INTERROGATORIES TO DEFENDANT (DRIVER)
PLEASE INSERT YOUR ANSWERS IN THE SPACE PROVIDED BELOW EACH
INTERROGATORY. SHOULD ADDITIONAL SPACE BE NEEDED, PLEASE ATTACH AN
EXTRA SHEET. "YOU" AND "YOUR" REFER TO THE DEFENDANT TO WHOM THESE
INTERROGATORIES ARE DIRECTED. DEFENDANT INCLUDES ALL AGENTS, SERVANTS,
OR EMPLOYEES OF THE DEFENDANT. IF ANSWERING FOR ANOTHER PERSON OR
ENTITY, ANSWER WITH RESPECT TO THAT PERSON OR ENTITY, UNLESS OTHERWISE
STATED.
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 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, and your date of birth.
3. 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 (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.
4. Describe any and all policies of 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.
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdi.com.5. Describe in detail how the incident described in the Complaint happened, including all
actions taken by you to prevent the incident.
6. 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.
8. 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.
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdi.com.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; 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, videotape, 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.
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdi.com.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 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?
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdi.com.17.
18.
19.
20.
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?
Did you consume any alcoholic beverages or take any drugs or medications 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.
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.
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.
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdi.com.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 such permission.
22. 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.
23. Was the motor vehicle that the defendant driver was driving at the time of the incident
described in the Complaint damaged in the accident, and, if so, what was the cost to repair
the damage?
You created this PDF from an application that is not licensed to print to novaPDF printer (http://www.novapdi.com.SIGNATURE PAGE
STATE OF
COUNTY OF
Before me the undersigned officer, authorized to administer oaths and take
acknowledgments, personally appeared » who after
being duly sworn, deposes and says: That the answers to the above and foregoing Interrogatories
are true and correct to the best of. knowledge and belief.
Signature of Defendant
SWORN TO AND SUBSCRIBED before me this day of
Notary Public (signature)
Notary Public (type, print stamp commission)
My Commission Expires:
a Personally Known OR
a Produced Identification
a Type of Identification Produced:
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