On June 30, 2022 a
Party Discovery
was filed
involving a dispute between
Malmberg, Nichol,
and
Tc Proline Flooring Llc,
in the District Court of St. Lucie County.
Preview
Filing # 152494060 E-Filed 06/30/2022 10:55:19 AM
IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT
IN AND FOR ST. LUCIE COUNTY, FLORIDA
NICHOL MALMBERG,
CASE NO:
Plaintiff,
vs.
TC PROLINE FLOORING LLC.
Defendants.
/
PLAINTIFF’S NOTICE OF SERVING INITIAL INTERROGATORIES TO
DEFENDANT, TC PROLINE FLOORING LLC.
Plaintiff, NICHOL MALMBERG, through counsel, hereby propounds upon Defendant, TC
PROLINE FLOORING LLC., 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.
/s/ Jennifer Rosinski
Jennifer Rosinski, Esq. • FBN 101182
Morgan & Morgan • Attorney for Plaintiff
8151 Peters Road, 4th Floor
Plantation, FL 33324
Telephone: (954) 694-9589
Facsimile: (954) 694-9674
E-Mail: jrosinski@forthepeople.com
ymarchfatherree@forthepeople.com
rhumphrey@forthepeople.com
INTERROGATORIES TO DEFENDANT
1. What is your name, address, and, if you are answering for someone else, your official
position.
2. Describe in detail, each act or omission on the part of Plaintiff you contend constituted
negligence that was a contributing legal cause of the crash in question.
3. List the names and addresses of all persons believed or known by you, your agents, or
attorneys to have any knowledge concerning any of the issues raised by the pleadings, and
specify the subject matter about which the witness has knowledge.
4. List the names, resident addresses, business addresses, and telephone numbers of each
person believed or known by you, your agents, or attorneys to have heard or who is
purported to have heard the plaintiff make any statement, remark or comment concerning
the crash described in the complaint and the substance of each statement, remark or
comment.
5. Did any mechanical defect in the motor vehicle you owned at the time of the crash
contribute to the occurrence of the crash? If so, what was the nature of the defect.
6. List the names and addresses of all persons or corporations who were registered title owners
or who had any legal or equitable interest in the motor vehicle involved on the date of the
crash described in the complaint.
7. Did you have liability insurance coverage that protects you from the damages sought by the
complaint? If so,
a. What is the name of the insurance company having the coverage?
b. What is the extent of coverage provided in the policy or policies of insurance,
including coverage for both personal injury and property damage?
c. What is the policy number of each policy?
8. Were there any other mechanical devices on the vehicle that recorded its speed other than
the common speedometer or measure any other action of the vehicle, if so, please provide
the name of said device?
9. Was the motor vehicle you were driving at the time of the crash described in the
Complaint equipped with Event Data Recorder, “Black Box” technology, or other
recording mechanism or device? If so, please state:
a) Whether any attempt has been made to download and/or analyze information
from such and, if so, the date it was done and by whom; and
b) Current (or last known) location of that vehicle.
VERIFICATION PAGE
_______________________________
TC PROLINE FLOORING LLC.
STATE OF _____________________
COUNTY OF ___________________
Sworn to (or affirmed) and subscribed before me by means of __ physical presence or __
online notarization, this ____ day of ____________, ____ by ________________________.
___ Personally Known or ___ Produced Identification
Type of Identification Produced_______________________________________
_____________________________________
NOTARY PUBLIC - State of Florida
My Commission Expires:
Document Filed Date
June 30, 2022
Case Filing Date
June 30, 2022
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 152494060 E-Filed 06/30/2022 10:55:19 AM IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA NICHOL MALMBERG, CASE NO: Plaintiff, vs. TC PROLINE FLOORING LLC. Defendants. / PLAINTIFF’S NOTICE OF SERVING INITIAL INTERROGATORIES TO DEFENDANT, TC PROLINE FLOORING LLC. Plaintiff, NICHOL MALMBERG, through counsel, hereby propounds upon Defendant, TC PROLINE FLOORING LLC., 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. /s/ Jennifer Rosinski Jennifer Rosinski, Esq. • FBN 101182 Morgan & Morgan • Attorney for Plaintiff 8151 Peters Road, 4th Floor Plantation, FL 33324 Telephone: (954) 694-9589 Facsimile: (954) 694-9674 E-Mail: jrosinski@forthepeople.com ymarchfatherree@forthepeople.com rhumphrey@forthepeople.com INTERROGATORIES TO DEFENDANT 1. What is your name, address, and, if you are answering for someone else, your official position. 2. Describe in detail, each act or omission on the part of Plaintiff you contend constituted negligence that was a contributing legal cause of the crash in question. 3. List the names and addresses of all persons believed or known by you, your agents, or attorneys to have any knowledge concerning any of the issues raised by the pleadings, and specify the subject matter about which the witness has knowledge. 4. List the names, resident addresses, business addresses, and telephone numbers of each person believed or known by you, your agents, or attorneys to have heard or who is purported to have heard the plaintiff make any statement, remark or comment concerning the crash described in the complaint and the substance of each statement, remark or comment. 5. Did any mechanical defect in the motor vehicle you owned at the time of the crash contribute to the occurrence of the crash? If so, what was the nature of the defect. 6. List the names and addresses of all persons or corporations who were registered title owners or who had any legal or equitable interest in the motor vehicle involved on the date of the crash described in the complaint. 7. Did you have liability insurance coverage that protects you from the damages sought by the complaint? If so, a. What is the name of the insurance company having the coverage? b. What is the extent of coverage provided in the policy or policies of insurance, including coverage for both personal injury and property damage? c. What is the policy number of each policy? 8. Were there any other mechanical devices on the vehicle that recorded its speed other than the common speedometer or measure any other action of the vehicle, if so, please provide the name of said device? 9. Was the motor vehicle you were driving at the time of the crash described in the Complaint equipped with Event Data Recorder, “Black Box” technology, or other recording mechanism or device? If so, please state: a) Whether any attempt has been made to download and/or analyze information from such and, if so, the date it was done and by whom; and b) Current (or last known) location of that vehicle. VERIFICATION PAGE _______________________________ TC PROLINE FLOORING LLC. STATE OF _____________________ COUNTY OF ___________________ Sworn to (or affirmed) and subscribed before me by means of __ physical presence or __ online notarization, this ____ day of ____________, ____ by ________________________. ___ Personally Known or ___ Produced Identification Type of Identification Produced_______________________________________ _____________________________________ NOTARY PUBLIC - State of Florida My Commission Expires: