Preview
Filing # 157879705 E-Filed 09/21/2022 03:22:53 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
CASE NO:
PAUL DENNIS,
Plaintiff,
v.
PATRICIA THOMPSON and
GOVERNMENT EMPLOYEES
INSURANCE COMPANY, a Foreign Profit
Corporation,
Defendants.
/
PLAINTIFF’S NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT,
GOVERNMENT EMPLOYEES INSURANCE COMPANY
Plaintiff, Paul Dennis, pursuant to Rule 1.340(e) of the Florida Rules of Civil Procedure,
hereby files Notice of Service of the original and one (1) copy of a set of Interrogatories
numbered 1 through 16 to be answered under oath and in writing, within forty-five (45) days
from the date of service hereof.
I HEREBY CERTIFY that I have furnished a true and correct copy of the foregoing by
service of process contemporaneously with the Complaint in this matter.
/s/ PAIGE S. STAUDENMAIER, ESQUIRE
Paige S. Staudenmaier, Esquire
Florida Bar No. 0124251
Dan Newlin & Partners
7335 W. Sand Lake Road, Suite 300
Orlando, FL 32819
Direct: (407) 203-6564
Fax: (321) 710-1325
Attorneys for Plaintiff
PRINCIPAL EMAIL ADDRESS:
Smithpleadings@newlinlaw.com
Electronically Filed Marion Case # 22CA001971AX 09/21/2022 03:22:53 PMINTERROGATORIES TO DEFENDANT,
GOVERNMENT EMPLOYEES INSURANCE COMPANY
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?
State your complete corporate name, nature of your business, whether you are licensed to
do business in the State of Florida, whether you maintain agents for the transacting of
your customary business in Marion County, and whether your name as it appears in the
Complaint is correct.
List the names, addresses and telephone numbers of all persons believed or known by
you, your agents or attorneys to have any knowledge concerning any of the issues raised
in this lawsuit; and specify the subject matter about which the witnesses have knowledge.
State whether you have obtained any statements (oral, written or recorded) from any of
these witnesses, list the dates any such witness statements were taken, by whom any such
witness statements were taken and who has present possession, custody and control of
any such statements.
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.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.
State whether any insurance agreement or agreements exist under which any person or
company carrying on an insurance business may be liable to satisfy part or all of a
judgment which may be entered in this action or to indemnify or reimburse any payments
made to satisfy any such judgment or settlement. If so,
a. What is the name of each company who has issued any such policy;
b. The limits of liability for injury to any one person under the terms of each such
policies;
c. The limits of liability for injury to more than one person under the terms of each
policies;
d. Whether any such insurer has notified you that it claims the policy provisions have
been violated or the policy is otherwise inapplicable to circumstances of this case, and if
so, the date of such notification and the reason given by such insurer for such a claim;
e. The name/address of person now having custody of a copy of each of such insurance
policies.10.
11.
Please state the period of time for which Plaintiff had been insured by any contract of
insurance issued by your company.
Please state the yearly premiums paid for each contract of insurance purchased by
Plaintiff during the entire time that each contract was or is in force.
Please state each type of insurance contract(s) ever purchased by Plaintiff from your
company.
List the names, residence addresses, business addresses and telephone numbers of all
persons who, on your behalf or on behalf of your agents or representatives, have in any
way participated in the investigation, adjusting or handling of the claim for benefits
involved herein and specify the date and the nature of the participation of each person.
For any and all policy defenses which you reasonably believe are available with regard to
Plaintiff's claim in this action, describe in detail the factual and legal basis for any such
defenses and give complete names, residence addresses, business addresses and telephone
numbers of each and every person believed or known by you, your agents or attorneys, to
have knowledge of the facts which would provide the basis for any such defenses.12.
13.
14.
15.
16.
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.
State the facts upon which you rely for each affirmative defense in your answer.
List the names, addresses and official positions of each and every person in your employ
or in the employ of anyone on your behalf who has had any involvement in the review of
the denial or withholding of Plaintiff's uninsured motorist claim and state in what
capacity they were involved, the date they were involved and the nature of their
involvement.
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' 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.
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.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 my knowledge and belief.
Agent and/or Representative of GOVERNMENT
EMPLOYEES INSURANCE COMPANY
SWORN TO AND SUBSCRIBED before me this day of » 20
Notary Public (signature)
Notary Public (type, print stamp commission)
My Commission Expires:
Personally Known OR
Produced Identification
Type of Identification Produced
Preview
Filing # 157879705 E-Filed 09/21/2022 03:22:53 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA CASE NO: PAUL DENNIS, Plaintiff, v. PATRICIA THOMPSON and GOVERNMENT EMPLOYEES INSURANCE COMPANY, a Foreign Profit Corporation, Defendants. / PLAINTIFF’S NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT, GOVERNMENT EMPLOYEES INSURANCE COMPANY Plaintiff, Paul Dennis, pursuant to Rule 1.340(e) of the Florida Rules of Civil Procedure, hereby files Notice of Service of the original and one (1) copy of a set of Interrogatories numbered 1 through 16 to be answered under oath and in writing, within forty-five (45) days from the date of service hereof. I HEREBY CERTIFY that I have furnished a true and correct copy of the foregoing by service of process contemporaneously with the Complaint in this matter. /s/ PAIGE S. STAUDENMAIER, ESQUIRE Paige S. Staudenmaier, Esquire Florida Bar No. 0124251 Dan Newlin & Partners 7335 W. Sand Lake Road, Suite 300 Orlando, FL 32819 Direct: (407) 203-6564 Fax: (321) 710-1325 Attorneys for Plaintiff PRINCIPAL EMAIL ADDRESS: Smithpleadings@newlinlaw.com Electronically Filed Marion Case # 22CA001971AX 09/21/2022 03:22:53 PMINTERROGATORIES TO DEFENDANT, GOVERNMENT EMPLOYEES INSURANCE COMPANY 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? State your complete corporate name, nature of your business, whether you are licensed to do business in the State of Florida, whether you maintain agents for the transacting of your customary business in Marion County, and whether your name as it appears in the Complaint is correct. List the names, addresses and telephone numbers of all persons believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues raised in this lawsuit; and specify the subject matter about which the witnesses have knowledge. State whether you have obtained any statements (oral, written or recorded) from any of these witnesses, list the dates any such witness statements were taken, by whom any such witness statements were taken and who has present possession, custody and control of any such statements. 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.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. State whether any insurance agreement or agreements exist under which any person or company carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse any payments made to satisfy any such judgment or settlement. If so, a. What is the name of each company who has issued any such policy; b. The limits of liability for injury to any one person under the terms of each such policies; c. The limits of liability for injury to more than one person under the terms of each policies; d. Whether any such insurer has notified you that it claims the policy provisions have been violated or the policy is otherwise inapplicable to circumstances of this case, and if so, the date of such notification and the reason given by such insurer for such a claim; e. The name/address of person now having custody of a copy of each of such insurance policies.10. 11. Please state the period of time for which Plaintiff had been insured by any contract of insurance issued by your company. Please state the yearly premiums paid for each contract of insurance purchased by Plaintiff during the entire time that each contract was or is in force. Please state each type of insurance contract(s) ever purchased by Plaintiff from your company. List the names, residence addresses, business addresses and telephone numbers of all persons who, on your behalf or on behalf of your agents or representatives, have in any way participated in the investigation, adjusting or handling of the claim for benefits involved herein and specify the date and the nature of the participation of each person. For any and all policy defenses which you reasonably believe are available with regard to Plaintiff's claim in this action, describe in detail the factual and legal basis for any such defenses and give complete names, residence addresses, business addresses and telephone numbers of each and every person believed or known by you, your agents or attorneys, to have knowledge of the facts which would provide the basis for any such defenses.12. 13. 14. 15. 16. 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. State the facts upon which you rely for each affirmative defense in your answer. List the names, addresses and official positions of each and every person in your employ or in the employ of anyone on your behalf who has had any involvement in the review of the denial or withholding of Plaintiff's uninsured motorist claim and state in what capacity they were involved, the date they were involved and the nature of their involvement. 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' 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. 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.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 my knowledge and belief. Agent and/or Representative of GOVERNMENT EMPLOYEES INSURANCE COMPANY SWORN TO AND SUBSCRIBED before me this day of » 20 Notary Public (signature) Notary Public (type, print stamp commission) My Commission Expires: Personally Known OR Produced Identification Type of Identification Produced