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35-2022-CA-000959-AXXX-XX
Filing # 150601279 E-Filed 05/31/2022 08:51:17 PM
IN THE CIRCUIT COURT OF THE
FIFTH JUDICIAL CIRCUIT IN AND FOR
LAKE COUNTY, FLORIDA
CASE NO: 2022-_
KYLE FRANKOS,
PLAINTIFF,
vs.
CATALIN MARIES and TENKA SOL
LLC,
DEFENDANT.
/
PLAINTIFF FRANKOS’S NOTICE OF SERVICE OF INTERROGATORIES
TO DEFENDANT CATALIN MARIES
Pursuant to Florida Civil Procedure Rule 1.340, Plaintiff, Kyle Frankos, hereby provides
notice that is has served upon Defendant, Catalin Maries (“Maries”), the attached
“INTERROGATORIES”, answers to which will be due within thirty (30) days from the date of
service hereof.
Respectfully submitted this 31st day of May, 2022.
/s/ W. Colby Roof
W. COLBY ROOF, ESQUIRE
Florida Bar Number 118888
Morgan & Morgan, P.A.
20 N. Orange Avenue, Suite 1600
Orlando, FL 32801
Telephone: (407) 420-1414
Facsimile: (407) 245-3485
Primary email: croof@forthepeople.com
Secondary email: kristiajohnson@forthepeople.com
Attorneys for Plaintiff
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 06/01/2022 09:08:59 AM
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the above-named Defendant(s), along with the Summons and Complaint.
/s/ W. Colby Roof
W. COLBY ROOF, ESQUIRE
IN THE CIRCUIT COURT OF THE
FIFTH JUDICIAL CIRCUIT IN AND FOR
LAKE COUNTY, FLORIDA
CASE NO: 2022-
KYLE FRANKOS,
PLAINTIFF,
vs.
CATALIN MARIES and TENKA SOL
LLC,
DEFENDANT.
/
PLAINTIFF FRANKOS’S INTERROGATORIES
TO DEFENDANT CATALIN MARIES
Pursuant to Florida Civil Procedure Rule 1.340, Plaintiff, Kyle Frankos, hereby propounds
upon Defendant, Catalin Maries (“Maries”), the following attached “INTERROGATORIES”,
answers to which will be due within thirty (30) days from the date of service hereof.
Respectfully submitted this 31st day of May, 2022.
/s/ W. Colby Roof.
W. COLBY ROOF, ESQUIRE
Florida Bar Number 118888
Morgan & Morgan, P.A.
20 N. Orange Avenue, Suite 1600
Orlando, FL 32801
Telephone: (407) 420-1414
Facsimile: (407) 245-3485
Primary email: croof@forthepeople.com
Secondary email: kristiajohnson@forthepeople.com
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the above-named Defendant(s), along with the Summons and Complaint.
/s/ W. Colby Roof
W. COLBY ROOF, ESQUIRE
INSTRUCTIONS FOR INTERROGATORIES
I. Definitions
As used throughout these Interrogatories, the following terms are defined as follows:
1 “Document” is used in the broad sense and means any tangible object or thing that
contains, conveys, or records information. Production is required of the original, or any copy if
the original is not available, of any book, record, minutes of meetings, reports and/or summaries
of interviews, reports and/or summaries of investigations; opinions or reports of consultants;
opinions of counsel; communications of any nature, including internal company
communications, memoranda, telegrams, telexes, letters, notes of telephone conferences,
agreements, reports or summaries of negotiations, brochures, pamphlets, advertisements,
circulars, trade letters, press releases, drafts and revisions of drafts of documents, any written,
printed, typed or other graphic matter of any kind or nature, drawings, photographs, paper,
communication, chart, tap, disk, card, wire or other electronic or mechanical recording or
transcript or any other instrument or device from which information can be perceived, in the
employees or agents, or known by Plaintiff to exist, unless otherwise privileged.
2 “Document” also includes copies containing information in addition to that
ontained on the original (such as notations, computations, attachments, etc.), and shall include
all copies of documents by whatever means made and whether or not claimed to be privileged or
otherwise excludable from discovery. To the extent that an Interrogatory calls for the production
of multiple identical documents or things, only one copy of each such identical documents or
things need be produced. Two copies are not identical if one of the copies has any information,
writing, printing, or other marks not present on the other of the copies.
3 If any tape, disk, card, wire, or other electronic or mechanical recording or
transcript or any computer program is produced, such documents as are necessity for the
decoding, putting back, printing out and/or interpretation thereof, and any other documents
which are necessity to convert such information into a useful and necessity to convert such
information into a useful and usable format shall also be produced, in order to make these
Interrogatories under Rule 1.350 meaningful and genuine.
4 “Person” means any natural person, public or private corporation (whether or not
organized for profit), partnership, unincorporated association, governmental agency or body, or
other legal entity.
5 “Company” means any business or governmental entity to which these
Interrogatories are addressed and includes all of its affiliated, subsidiaries, parents, divisions,
successors in interest, and predecessors as well as all of its directors, officers, principals,
partners, employees, agents, representatives, attorneys, any other persons working for or on
behalf thereof, whether temporary or permanent, and any “person” in which Plaintiff has
acquired an interest.
6 “Statement” means (1) any written statement made any a person and signed or
otherwise adopted or approved by him; or (2) any stenographic, mechanical, electrical, or other
recording, or a transcription thereof, which is a substantially verbatim recital of an oral statement
made by that person and recorded contemporaneously with the making of such oral statement.
7
As may be used in these Request “and” is conjunctive (meaning, e.g., A and B);
and “oi is disjunctive and inclusive (meaning, e.g., A or B, or both). No answer should be
withheld, or limited, because it refers or relates to only one, or to more than one, item in a
request.
»
8 As may be used in these Interrogatories, the terms “trademar! and “service
mark” shall be considered interchangeable, and the term “mark” shall be considered to refer to
any trademark, service mark, trade name, or business designation, or any other word, symbol,
design, logo, title, or slogan used to identify the source of origin of products or services.
References to 'products” r “goods” shall be considered to include services.
9 “Defendant,” “you,” and “your” refer to Defendant Catalin Maries, including all
agents, servants, representatives, or employees of Defendant Catalin Maries.
10. If you are answering for another person or entity, answer with respect to that
person or entity, unless otherwise stated.
ll. “The Incident” refers to the motor vehicle incident that is the subject of Plaintiff's
Complaint.
II. Claim of Privilege
If any document or statement is withheld from these Interrogatories under a claim of
privilege, then please furnish a list which identifies each document or statement for which privilege
is claimed and include the following information for each such document:
1 Description sufficient to identify.
2. The date(s).
The subject matter(s).
The sender(s) or author(s).
The recipients).
The persons to whom copies were furnished, together with their job titles.
The present depository or person having custody of the document.
The nature and basis of privilege or immunity claimed.
The paragraph(s) of this interrogatories to which each such document or
statement relates or corresponds.
III. Grouping or Numbering of Items Produced
Pursuant to Florida Rules of Civil Procedure, Plaintiff requests that the documents or other
items submitted in response to these Interrogatories be organized and labeled according to the
individual paragraphs of the Interrogatories to which they are responsive, and within each group,
arranged in chronological order.
IV. Place, Time, and Manner of Response
A response to these Interrogatories is due within thirty (30) days after service of these
Interrogatories, and shall be made to W. Colby Roof, Esquire, at the offices of Morgan & Morgan,
P.A., 20 North Orange Avenue, Suite 1600, Post Office Box 4979, Orlando, Florida 32801 (32802-
4979), or at such other place as the parties may agree. Authentic copies of non-electronic
documents may be supplied, provided that existing originals are available for inspection,
examination, and comparison.
The information, documents, and/or materials being here requested are believed to be in the
possession, custody, or control of the party to whom these Interrogatories is directed. The
information sought by these Interrogatories is relevant to the subject matter of this action and cannot
otherwise be obtained without undue hardship. In the event that all or part of the documents and/or
materials herein requested are not in the possession or control of Defendant Catalin Maries, then the
undersigned counsel further request the identity and location of all persons having such possession
and control. These Interrogatories are made in good faith and for the purposes herein expressed.
INTERROGATORIES
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
onviction.
4 Describe in detail how the Incident happened, including all actions taken by you
to prevent the Incident.
5 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.
6 State the facts upon which you rely for each affirmative defense in your Answer.
7
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.
8 Were you charged with any violation of law (including any regulations or
ordinances) arising out of the Incident? If so, what was the nature of the charge; what plea or
answer, if any, was entered 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.
9 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.
10. 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.
ll. 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.
12. 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.
13. 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.
14. 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.
15. Do you wear glasses, contact lenses, or hearing aids? If so, who prescribed them,
when were they prescribed, when was your last eye or ear examination, and what is the name and
address of the examiner(s)?
16. Were you suffering from physical infirmity, disability, or sickness at the time of
the Incident? If so, what was the nature of the infirmity, disability, or sickness?
17. Did you consume any alcoholic beverages or take any drugs or medications
within twelve (12) hours before the time of the Incident? If so, state the type and amount of
alcoholic beverages, drugs, or medication which were consumed, and when and where they were
consumed.
18. Did any mechanical defect in the motor vehicle that you was operating at the time
of the Incident contribute to the Incident? If so, describe the nature of the defect and how it
contributed to the Incident.
19. 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 you were driving at the time of the Incident; 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.
20. At the time of the Incident, did you have permission to drive the vehicle? If so,
state the names and addresses of all persons who gave such permission.
21. At the time of the Incident, were you engaged in any mission or activity for any
other person or entity (such as an employer)? If so, state the name and address of that other
person or entity and the nature of the mission or activity.
22. Was the motor vehicle that you were driving at the time of the Incident damaged
as a result of the Incident, and, if so, what was the cost to repair the damage?
23. At the time of the Incident, did you have a mobile communications device (such
as a mobile phone) in your possession in the motor vehicle you were operating? If so, please
provide:
The name and address of the company that provided mobile service to the device
(such as AT&T, Verizon, etc.);
The complete name of the account holder or registrant;
The account number;
The cell phone number(s) on the account; and
If there was more than one phone number on the account, or more than one
account, identify which phone number was available to you at the time of the
Incident.
24. Were you or any passenger in the motor vehicle using/holding a cell phone to call,
text, email, use the internet, or use any smart phone application during the period of time from
one hour before the Incident to one hour after the Incident? If so, please identify who was doing
so, when, and for what purpose?
25. At the date and time of the Incident, did you have a GPS navigation device and/or
dash camera available for your use? If so, was the GPS navigation device and/or dash camera
active and/or in use at the time of the Incident?
26. At the time of the Incident, please explain or identify:
Where were you initially driving from?
Where were you ultimately driving to?
What stops did you make between beginning your operation of the motor vehicle
and the time of the Incident?
27. Please provide the name(s), address(es), and telephone number(s) of each
insurance agency and each insurance agent who sold, procured, and/or provided insurance
coverage which covered you at the time of the Incident.
28. Please describe any and all policies of insurance which covered or may have
covered you at the time of the Incident, and please detail as to each such policy the name of the
insurer(s), the number(s) of the policies, the effective dates of the policies, the available limits of
liability, and the name(s) and address(es) of the custodians of the policies.
29. Please describe any and all excess or umbrella policies of insurance which cover
or may cover you at the time of the Incident, detailing as to such policies the name of the
insurer(s), the number(s) of the policies, the effective dates of the policies, the available limits of
liability, and the name(s) and address(es) of the custodians of the policies.
30. Please describe any and all indemnification sources, in addition to any insurance
companies not already disclosed by you, which cover or may cover or indemnify you at the time
of the Incident, detailing as to such sources the name of the source(s), the number(s) of the
contracts or policies, the effective dates of the contracts or policies, the available limits of
liability coverage and/or indemnification, and the name(s) and address(es) of the custodians of
the contracts or policies.
31. Please describe any and all co-insurers or co-insurance sources, in addition to any
insurance companies not already disclosed by you, which co-insure or may co-insure you at the
time of the Incident, detailing as to such sources the name of the source(s), the number(s) of the
contracts or policies, the effective dates of the contracts or policies, the available limits of
liability coverage and/or indemnification, and the name(s) and address(es) of the custodians of
the contracts or policies.
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 Catalin Maries
SWORN TO AND SUBSCRIBED before me this __day of , 2022.
Notary Public (signature)
Notary Public (type, print stamp commission)
My Commission Expires:
[] Personally Known OR.
[] Produced Identification
Type of Identification Produced:
Preview
35-2022-CA-000959-AXXX-XX Filing # 150601279 E-Filed 05/31/2022 08:51:17 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA CASE NO: 2022-_ KYLE FRANKOS, PLAINTIFF, vs. CATALIN MARIES and TENKA SOL LLC, DEFENDANT. / PLAINTIFF FRANKOS’S NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT CATALIN MARIES Pursuant to Florida Civil Procedure Rule 1.340, Plaintiff, Kyle Frankos, hereby provides notice that is has served upon Defendant, Catalin Maries (“Maries”), the attached “INTERROGATORIES”, answers to which will be due within thirty (30) days from the date of service hereof. Respectfully submitted this 31st day of May, 2022. /s/ W. Colby Roof W. COLBY ROOF, ESQUIRE Florida Bar Number 118888 Morgan & Morgan, P.A. 20 N. Orange Avenue, Suite 1600 Orlando, FL 32801 Telephone: (407) 420-1414 Facsimile: (407) 245-3485 Primary email: croof@forthepeople.com Secondary email: kristiajohnson@forthepeople.com Attorneys for Plaintiff FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 06/01/2022 09:08:59 AM CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the above-named Defendant(s), along with the Summons and Complaint. /s/ W. Colby Roof W. COLBY ROOF, ESQUIRE IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA CASE NO: 2022- KYLE FRANKOS, PLAINTIFF, vs. CATALIN MARIES and TENKA SOL LLC, DEFENDANT. / PLAINTIFF FRANKOS’S INTERROGATORIES TO DEFENDANT CATALIN MARIES Pursuant to Florida Civil Procedure Rule 1.340, Plaintiff, Kyle Frankos, hereby propounds upon Defendant, Catalin Maries (“Maries”), the following attached “INTERROGATORIES”, answers to which will be due within thirty (30) days from the date of service hereof. Respectfully submitted this 31st day of May, 2022. /s/ W. Colby Roof. W. COLBY ROOF, ESQUIRE Florida Bar Number 118888 Morgan & Morgan, P.A. 20 N. Orange Avenue, Suite 1600 Orlando, FL 32801 Telephone: (407) 420-1414 Facsimile: (407) 245-3485 Primary email: croof@forthepeople.com Secondary email: kristiajohnson@forthepeople.com Attorneys for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the above-named Defendant(s), along with the Summons and Complaint. /s/ W. Colby Roof W. COLBY ROOF, ESQUIRE INSTRUCTIONS FOR INTERROGATORIES I. Definitions As used throughout these Interrogatories, the following terms are defined as follows: 1 “Document” is used in the broad sense and means any tangible object or thing that contains, conveys, or records information. Production is required of the original, or any copy if the original is not available, of any book, record, minutes of meetings, reports and/or summaries of interviews, reports and/or summaries of investigations; opinions or reports of consultants; opinions of counsel; communications of any nature, including internal company communications, memoranda, telegrams, telexes, letters, notes of telephone conferences, agreements, reports or summaries of negotiations, brochures, pamphlets, advertisements, circulars, trade letters, press releases, drafts and revisions of drafts of documents, any written, printed, typed or other graphic matter of any kind or nature, drawings, photographs, paper, communication, chart, tap, disk, card, wire or other electronic or mechanical recording or transcript or any other instrument or device from which information can be perceived, in the employees or agents, or known by Plaintiff to exist, unless otherwise privileged. 2 “Document” also includes copies containing information in addition to that ontained on the original (such as notations, computations, attachments, etc.), and shall include all copies of documents by whatever means made and whether or not claimed to be privileged or otherwise excludable from discovery. To the extent that an Interrogatory calls for the production of multiple identical documents or things, only one copy of each such identical documents or things need be produced. Two copies are not identical if one of the copies has any information, writing, printing, or other marks not present on the other of the copies. 3 If any tape, disk, card, wire, or other electronic or mechanical recording or transcript or any computer program is produced, such documents as are necessity for the decoding, putting back, printing out and/or interpretation thereof, and any other documents which are necessity to convert such information into a useful and necessity to convert such information into a useful and usable format shall also be produced, in order to make these Interrogatories under Rule 1.350 meaningful and genuine. 4 “Person” means any natural person, public or private corporation (whether or not organized for profit), partnership, unincorporated association, governmental agency or body, or other legal entity. 5 “Company” means any business or governmental entity to which these Interrogatories are addressed and includes all of its affiliated, subsidiaries, parents, divisions, successors in interest, and predecessors as well as all of its directors, officers, principals, partners, employees, agents, representatives, attorneys, any other persons working for or on behalf thereof, whether temporary or permanent, and any “person” in which Plaintiff has acquired an interest. 6 “Statement” means (1) any written statement made any a person and signed or otherwise adopted or approved by him; or (2) any stenographic, mechanical, electrical, or other recording, or a transcription thereof, which is a substantially verbatim recital of an oral statement made by that person and recorded contemporaneously with the making of such oral statement. 7 As may be used in these Request “and” is conjunctive (meaning, e.g., A and B); and “oi is disjunctive and inclusive (meaning, e.g., A or B, or both). No answer should be withheld, or limited, because it refers or relates to only one, or to more than one, item in a request. » 8 As may be used in these Interrogatories, the terms “trademar! and “service mark” shall be considered interchangeable, and the term “mark” shall be considered to refer to any trademark, service mark, trade name, or business designation, or any other word, symbol, design, logo, title, or slogan used to identify the source of origin of products or services. References to 'products” r “goods” shall be considered to include services. 9 “Defendant,” “you,” and “your” refer to Defendant Catalin Maries, including all agents, servants, representatives, or employees of Defendant Catalin Maries. 10. If you are answering for another person or entity, answer with respect to that person or entity, unless otherwise stated. ll. “The Incident” refers to the motor vehicle incident that is the subject of Plaintiff's Complaint. II. Claim of Privilege If any document or statement is withheld from these Interrogatories under a claim of privilege, then please furnish a list which identifies each document or statement for which privilege is claimed and include the following information for each such document: 1 Description sufficient to identify. 2. The date(s). The subject matter(s). The sender(s) or author(s). The recipients). The persons to whom copies were furnished, together with their job titles. The present depository or person having custody of the document. The nature and basis of privilege or immunity claimed. The paragraph(s) of this interrogatories to which each such document or statement relates or corresponds. III. Grouping or Numbering of Items Produced Pursuant to Florida Rules of Civil Procedure, Plaintiff requests that the documents or other items submitted in response to these Interrogatories be organized and labeled according to the individual paragraphs of the Interrogatories to which they are responsive, and within each group, arranged in chronological order. IV. Place, Time, and Manner of Response A response to these Interrogatories is due within thirty (30) days after service of these Interrogatories, and shall be made to W. Colby Roof, Esquire, at the offices of Morgan & Morgan, P.A., 20 North Orange Avenue, Suite 1600, Post Office Box 4979, Orlando, Florida 32801 (32802- 4979), or at such other place as the parties may agree. Authentic copies of non-electronic documents may be supplied, provided that existing originals are available for inspection, examination, and comparison. The information, documents, and/or materials being here requested are believed to be in the possession, custody, or control of the party to whom these Interrogatories is directed. The information sought by these Interrogatories is relevant to the subject matter of this action and cannot otherwise be obtained without undue hardship. In the event that all or part of the documents and/or materials herein requested are not in the possession or control of Defendant Catalin Maries, then the undersigned counsel further request the identity and location of all persons having such possession and control. These Interrogatories are made in good faith and for the purposes herein expressed. INTERROGATORIES 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 onviction. 4 Describe in detail how the Incident happened, including all actions taken by you to prevent the Incident. 5 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. 6 State the facts upon which you rely for each affirmative defense in your Answer. 7 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. 8 Were you charged with any violation of law (including any regulations or ordinances) arising out of the Incident? If so, what was the nature of the charge; what plea or answer, if any, was entered 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. 9 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. 10. 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. ll. 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. 12. 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. 13. 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. 14. 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. 15. Do you wear glasses, contact lenses, or hearing aids? If so, who prescribed them, when were they prescribed, when was your last eye or ear examination, and what is the name and address of the examiner(s)? 16. Were you suffering from physical infirmity, disability, or sickness at the time of the Incident? If so, what was the nature of the infirmity, disability, or sickness? 17. Did you consume any alcoholic beverages or take any drugs or medications within twelve (12) hours before the time of the Incident? If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when and where they were consumed. 18. Did any mechanical defect in the motor vehicle that you was operating at the time of the Incident contribute to the Incident? If so, describe the nature of the defect and how it contributed to the Incident. 19. 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 you were driving at the time of the Incident; 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. 20. At the time of the Incident, did you have permission to drive the vehicle? If so, state the names and addresses of all persons who gave such permission. 21. At the time of the Incident, were you engaged in any mission or activity for any other person or entity (such as an employer)? If so, state the name and address of that other person or entity and the nature of the mission or activity. 22. Was the motor vehicle that you were driving at the time of the Incident damaged as a result of the Incident, and, if so, what was the cost to repair the damage? 23. At the time of the Incident, did you have a mobile communications device (such as a mobile phone) in your possession in the motor vehicle you were operating? If so, please provide: The name and address of the company that provided mobile service to the device (such as AT&T, Verizon, etc.); The complete name of the account holder or registrant; The account number; The cell phone number(s) on the account; and If there was more than one phone number on the account, or more than one account, identify which phone number was available to you at the time of the Incident. 24. Were you or any passenger in the motor vehicle using/holding a cell phone to call, text, email, use the internet, or use any smart phone application during the period of time from one hour before the Incident to one hour after the Incident? If so, please identify who was doing so, when, and for what purpose? 25. At the date and time of the Incident, did you have a GPS navigation device and/or dash camera available for your use? If so, was the GPS navigation device and/or dash camera active and/or in use at the time of the Incident? 26. At the time of the Incident, please explain or identify: Where were you initially driving from? Where were you ultimately driving to? What stops did you make between beginning your operation of the motor vehicle and the time of the Incident? 27. Please provide the name(s), address(es), and telephone number(s) of each insurance agency and each insurance agent who sold, procured, and/or provided insurance coverage which covered you at the time of the Incident. 28. Please describe any and all policies of insurance which covered or may have covered you at the time of the Incident, and please detail as to each such policy the name of the insurer(s), the number(s) of the policies, the effective dates of the policies, the available limits of liability, and the name(s) and address(es) of the custodians of the policies. 29. Please describe any and all excess or umbrella policies of insurance which cover or may cover you at the time of the Incident, detailing as to such policies the name of the insurer(s), the number(s) of the policies, the effective dates of the policies, the available limits of liability, and the name(s) and address(es) of the custodians of the policies. 30. Please describe any and all indemnification sources, in addition to any insurance companies not already disclosed by you, which cover or may cover or indemnify you at the time of the Incident, detailing as to such sources the name of the source(s), the number(s) of the contracts or policies, the effective dates of the contracts or policies, the available limits of liability coverage and/or indemnification, and the name(s) and address(es) of the custodians of the contracts or policies. 31. Please describe any and all co-insurers or co-insurance sources, in addition to any insurance companies not already disclosed by you, which co-insure or may co-insure you at the time of the Incident, detailing as to such sources the name of the source(s), the number(s) of the contracts or policies, the effective dates of the contracts or policies, the available limits of liability coverage and/or indemnification, and the name(s) and address(es) of the custodians of the contracts or policies. 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 Catalin Maries SWORN TO AND SUBSCRIBED before me this __day of , 2022. Notary Public (signature) Notary Public (type, print stamp commission) My Commission Expires: [] Personally Known OR. [] Produced Identification Type of Identification Produced: