Preview
Filing # 13849699 Electronically Filed 05/20/2014 08:52:48 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA
MARISELA GARCIA,
Plaintiff,
-vs- NO. 13CA3482
ROLAND JOHN ZAINER,
Defendant.
MS SSL
PLAINTIFF'S ANSWERS TO INTERROGATORIES
Plaintiff, MARISELA GARCIA, by and through the undersigned counsel and
pursuant to Fla. R. Civ. P. 1.340, gives Notice of Serving Answers to Interrogatories from
Defendant, ROLAND JOHN ZAINER dated January 23, 2014.
| certify that a copy hereof has been furnished to:
JohnFtLauderdaleHC@Progressive.com; JKorf1@Progressive.com, E. Korf, Esq., Law
Offices of Michael W. Carroll, 3250 West Commercial Blvd. Suite 220, Fort Lauderdale,
h
FL 33309 by Electronic Mail on this AO) Yay of May, 2014.
John Richardson, Esquire
Steinger, Iscoe & Greene P.A.
1645 Palm Beach Lakes Blvd., 9" Floor
West Palm Beach, FI 33401
Attorney for Plaintiff
Primary email: SIG-WPB@injurylawyers.com
Secondary email: clogan@injurylawyers.com
By: /9 Davidknigt. fo
John Richardson, Esquire
Florida Bar No.: 616450
Filed with Collier County Clerk of CourtsPLAINTIFF, MARISELA GARCIA, ANSWERS TO INTERROGATORIES Served By
Defendant, ROLAND JOHN ZAINER dated January 23, 2014
Please be advised that this information is being provided in good faith and in compliance
with your request for discovery. Before you file this discovery with the Court, you must
comply with Fla. R. Jud. Admin. 2.425 and protect the sensitive information contained
herein.
Whatis 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?
MARISELA GARCIA
1997 Rookery Bay Drive, Unit 901
Naples, FL 34114
2. List the names, business addresses, dates of employment and rates of pay
regarding all employers, including self-employment, for whom you have worked in
the past ten (10) years.
2003-2005 First Baptist Church, Teacher's Assistant
Marco Island, FL
2005-2007 Redland’s Christian Ass., Teacher’s Assistant
Naples, FL
2007-2012 Jerry’s Cleaners, Customer Service
842 6" Avenue S
Naples, FL 34102
A. If you were employed at the time of the accident, which is the subject of this
case, describe your job and its responsibilities.
I was not employed at the time of this accident.
B. If you returned to work since the incident described in the Complaint, state
the date of your return and if you are doing the same work you did before
this incident.
I have been unable to return to work due to my injuries from this
accident.
3. 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 ateach address, your social security number, your date of birth, and if you are or have
ever been married, the name of your spouse or spouses.
I have no former names and I’ve never been married.
Social Security Number to be provided at deposition.
DOB: August 26, 1976
6437 College Park Circle, Apt. 304, Naples, FL 34112
5265 Treetops Drive, Naples, FL 34113
5230 Warren Street, Naples, FL 34113
5218 Sholtz Street, Naples, FL 34113
6437 Conning Tower Circle, Apt A-1, Naples, FL 34112
1997 Rookery Bay Drive, Naples, FL 34114
I do not recall the exact dates for my previous addresses at this time.
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?
No.
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 year, or that involved dishonesty or a false statement
regardless of the punishment? Ifso, state as to each conviction, the specific crime,
the date and the place of conviction.
No.
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?
No.
Did you consume any alcoholic beverages or take any drugs or medication 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.
No.
Describe in detail how the incident described in the Complaint happened, including
all actions taken by you to prevent the incident.10.
11.
12.
13.
Iwas approaching an intersection and the defendant made a left turn into my
path. I was not able to stop prior to impact to avoid the collision. There was
nothing | could have done to prevent this accident from happening.
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.
The defendant violated my right of way.
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 this charge, and if so, what is the name and address of the person or
entity that 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 was the name and address of the person who recorded the
testimony?
No.
Describe each injury for which you are claiming damages in this case, specifying
the part of your body that was injured, the nature of the injury, and as to any injuries
you contend are permanent, the effects on you that you claim are permanent.
My neck and back were injured in this accident. Please refer to my medical
records regarding permanency.
I suffer with limited mobility, discomfort and limited physical activity due to
increased pain. In addition, daily | feel like my body is being compressed.
List each item of expense or damage, other than loss of income or earning capacity,
that you claim to have incurred as a result of the incident described in the
Complaint, giving for each item the date incurred, the name and business address
to whom each was paid or is owed, and the goods or services for which each was
incurred.
Please see attached Special Damage Table with a list of all medical providers.
Please refer to my medical records for dates of treatments and conditions
treated.
Do you contend that you have lost any income, benefits, or earning capacity in the
past or future as a result of the incident described in the Complaint? If so, state the14.
15.
nature of the income, benefits, or earning capacity, and the amount and the method
that you used in computing the amount.
Not at this time.
Has anything been paid or is anything payable from any third party for the damages
listed in your answers to these Interrogatories? If so, state the amounts paid or
payable, the name and business address of the person or entity who paid or owes
said amounts, and which of those third parties have or claim a right of subrogation.
PIP paid 10,000.00. There is no third party claim of subrogation at this time.
List the names and business addresses of each physician who has treated or
examined you, and each medical facility where you have received any treatment or
examination for the injuries for which you seek damages in this case; and state as
to each the date of treatment or examination and the injury or condition for which
you were examined or treated.
Broad Anesthesia Associates
501 Glades Road
Boca Raton, FL 33432
Florida IONM Services, LLC
Dept. 1178
Post Office Box 11407
Birmingham, AL 35246
LabCorp
5610 W. LaSalle Street
Tampa, FL 33607
Dr. Igor Levy-Reis
Neuroscience and Spine Associates
6101 Pine Ridge Road
Naples, FL 34109
Naples Diagnostic imaging
6400 Davis Boulevard
Unit 101
Naples, FL 34101
Dr. Christopher Pham
Integrated Health Services
2515 Northbrooke Plaza16.
Suite 200
Naples, FL 34119
Stand Up MRI of Southwest Florida
4521 Executive Drive
Suite 104
Naples, FL 34119
Surgicare of Boca Raton
1905 Clint Moore Road
Suite 300
Boca Raton, FL 33496
Physicians Regional Medical Center
8300 Collier Boulevard
Naples, FL 34114
Collier Emergency Group
8300 Collier Boulevard
Naples, FL 34114
EMPI, Inc.
Post Office Box 71519
Chicago, IL 60694
Collier County EMS
8075 Lely Cultural Parkway
Suite 267
Naples, FL 34113
Dr. Richard Mara, D.C.
10621 Airport Rd N Suite 2
Naples, Fl 34109
Dr. Connie Lee, M.D.
Address unknown
Please refer to Dr. Mara’s records
List the names and business addresses of all other physicians, medical facilities or
other health care providers by whom or at which you have been examined or
treated in the past ten (10) years; and state as to each the dates of examination or
treatment and the condition or injury for which you were examined or treated.
Naples Community Hospital17.
18.
19.
Naples, FL 34112
Physicians Regional Medical Center
8300 Collier Boulevard
Naples, FL 34114
Dr. Maria E. Santiago
Collier Neurological Specialists
730 Goodlette Rd. N Suite 100
Naples, FL 34102
Memorial Hospital and Manor
1500 E. Shotwell St.
Bainbridge, GA 39318
List the names and addresses of all persons who are believed or known by you,
your agents or attorneys to have any knowledge concerning any of the issues in
this lawsuit; and specify the subject matter about which the witness has
knowledge.
The parties to this lawsuit are aware of the events surrounding this
accident. My treating physicans are aware of my injury and treatments. A
witness to the accident, Lori Ellingsworth, 229 Palm Drive, Unit 2, Naples,
FL 34112, as listed on incident report, In addition, Trooper S.R. Ellis of the
Florida Highway Patrol.
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.
No.
State the name and address of every person known to you, your agents, or
attorneys who has knowledge about, or possession, custody or control of any
model, plat, map, drawing, motion picture, video tape, or photograph pertaining
to any fact or issue involved in this controversy; and describe as to each, what
such person has, the name and address of the person who took or prepared it,
and the date it was taken or prepared.
My attorney is in possession of some photographs of the scene and
property damage; as well as, the police report. These documents are20.
21.
22.
23.
24.
25.
included in the request for production.
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.
Undetermined at this time. Plaintiff will provide such information in
compliance with the court’s trial order.
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.
No.
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.
No, other than the present matter.
At the time of the accident described in the Complaint, were you wearing a seat
belt? If not, please state why not; where you were seated in the vehicle; and
whether the vehicle was equipped with a seat belt that was operational and
available for your use.
Yes, | was wearing my seatbelt and it was operational.
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 accident? Is so,
describe the nature of the defect and how it contributed to the incident.
No.
Please identify by date, location and nature (type of accident) all accidents in
which you were involved before and after the incident involved in this lawsuit,
regardless of whether or not you were injured. (“Accidents” covers all types of
incidents, and includes, but is not limited to motor vehicle accidents).
1 do not recall the exact date, but to the best of my recollection 2001 minor
motor vehicle accident with no injuries.26.
27.
28.
29.
30.
As to each accident identified in response to question 25, please state whether
or not you were injured, and if injured, state the nature of the injury, if it was
permanent, and the full name and address of all physicians and
medical/chiropractic providers by whom you were treated.
No.
Please identify all claims made by you for personal injuries with any insurance
company or individual (excluding court cases) including the date of the claim, the
nature of the claim, and the name and address of the individual or business
entity against whom the claim was made or filed.
No, other than the present matter.
Please state whether or not you have filed for worker's compensation,
unemployment compensation, or social security disability benefits within the past
ten (10) years. If so, please state the date of each claim, the name and address
of the individual/agency with whom the claim was made, and the amount of
benefits received.
I received unemployment through the State of Florida beginning in July,
2012. | received benefits for approximately one year but do not recall the
amount of the benefits received.
With regard to any and all cell phones you had access to on the date of the
accident described in the Complaint, please state:
a. The name and address of the carrier/provider for each cell phone.
Sprint
b. The telephone number including area code for each cell phone.
(239) 821-9466
c. The billing account number for each cell phone.
I do not recall the account number.
d. The name and address of the account holder for each cell phone.
Marisela Garcia, 6437 Conning Tower Circle, A1, Naples, FL 34112
List the name, business address, telephone number, named insured, policy
number (both group and individual number) and applicable dates of coverage forall health insurance companies, life insurance companies and disability
insurance companies, who have provided coverage for you in the past ten (10)
years.
None.BY:
4
Name: MARISELA GARCIA
STATE OF FLORIDA
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared:
Mar Selo Ararcio. who is
[personally known to me or
[ ] produced as identification and
[ ] did
[ ] did not take an oath,
and having been personally sworn by me deposes and says that Marisela Garcia
signed the foregoing Answers to Interrogatories and states said Answers are true to the
best of her knowledge and/or belief.
SWORN TO and subscribed before me this ein day of May 2014.
Notary Public, State of wom on
My Commission expires: g|ailo0 9
Notary Pubic tat of Fria
isse Hemanciez
YS Cree 08/31
Commission EE 126688
M2015
Preview
Filing # 13849699 Electronically Filed 05/20/2014 08:52:48 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA MARISELA GARCIA, Plaintiff, -vs- NO. 13CA3482 ROLAND JOHN ZAINER, Defendant. MS SSL PLAINTIFF'S ANSWERS TO INTERROGATORIES Plaintiff, MARISELA GARCIA, by and through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.340, gives Notice of Serving Answers to Interrogatories from Defendant, ROLAND JOHN ZAINER dated January 23, 2014. | certify that a copy hereof has been furnished to: JohnFtLauderdaleHC@Progressive.com; JKorf1@Progressive.com, E. Korf, Esq., Law Offices of Michael W. Carroll, 3250 West Commercial Blvd. Suite 220, Fort Lauderdale, h FL 33309 by Electronic Mail on this AO) Yay of May, 2014. John Richardson, Esquire Steinger, Iscoe & Greene P.A. 1645 Palm Beach Lakes Blvd., 9" Floor West Palm Beach, FI 33401 Attorney for Plaintiff Primary email: SIG-WPB@injurylawyers.com Secondary email: clogan@injurylawyers.com By: /9 Davidknigt. fo John Richardson, Esquire Florida Bar No.: 616450 Filed with Collier County Clerk of CourtsPLAINTIFF, MARISELA GARCIA, ANSWERS TO INTERROGATORIES Served By Defendant, ROLAND JOHN ZAINER dated January 23, 2014 Please be advised that this information is being provided in good faith and in compliance with your request for discovery. Before you file this discovery with the Court, you must comply with Fla. R. Jud. Admin. 2.425 and protect the sensitive information contained herein. Whatis 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? MARISELA GARCIA 1997 Rookery Bay Drive, Unit 901 Naples, FL 34114 2. List the names, business addresses, dates of employment and rates of pay regarding all employers, including self-employment, for whom you have worked in the past ten (10) years. 2003-2005 First Baptist Church, Teacher's Assistant Marco Island, FL 2005-2007 Redland’s Christian Ass., Teacher’s Assistant Naples, FL 2007-2012 Jerry’s Cleaners, Customer Service 842 6" Avenue S Naples, FL 34102 A. If you were employed at the time of the accident, which is the subject of this case, describe your job and its responsibilities. I was not employed at the time of this accident. B. If you returned to work since the incident described in the Complaint, state the date of your return and if you are doing the same work you did before this incident. I have been unable to return to work due to my injuries from this accident. 3. 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 ateach address, your social security number, your date of birth, and if you are or have ever been married, the name of your spouse or spouses. I have no former names and I’ve never been married. Social Security Number to be provided at deposition. DOB: August 26, 1976 6437 College Park Circle, Apt. 304, Naples, FL 34112 5265 Treetops Drive, Naples, FL 34113 5230 Warren Street, Naples, FL 34113 5218 Sholtz Street, Naples, FL 34113 6437 Conning Tower Circle, Apt A-1, Naples, FL 34112 1997 Rookery Bay Drive, Naples, FL 34114 I do not recall the exact dates for my previous addresses at this time. 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? No. 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 year, or that involved dishonesty or a false statement regardless of the punishment? Ifso, state as to each conviction, the specific crime, the date and the place of conviction. No. 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? No. Did you consume any alcoholic beverages or take any drugs or medication 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. No. Describe in detail how the incident described in the Complaint happened, including all actions taken by you to prevent the incident.10. 11. 12. 13. Iwas approaching an intersection and the defendant made a left turn into my path. I was not able to stop prior to impact to avoid the collision. There was nothing | could have done to prevent this accident from happening. 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. The defendant violated my right of way. 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 this charge, and if so, what is the name and address of the person or entity that 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 was the name and address of the person who recorded the testimony? No. Describe each injury for which you are claiming damages in this case, specifying the part of your body that was injured, the nature of the injury, and as to any injuries you contend are permanent, the effects on you that you claim are permanent. My neck and back were injured in this accident. Please refer to my medical records regarding permanency. I suffer with limited mobility, discomfort and limited physical activity due to increased pain. In addition, daily | feel like my body is being compressed. List each item of expense or damage, other than loss of income or earning capacity, that you claim to have incurred as a result of the incident described in the Complaint, giving for each item the date incurred, the name and business address to whom each was paid or is owed, and the goods or services for which each was incurred. Please see attached Special Damage Table with a list of all medical providers. Please refer to my medical records for dates of treatments and conditions treated. Do you contend that you have lost any income, benefits, or earning capacity in the past or future as a result of the incident described in the Complaint? If so, state the14. 15. nature of the income, benefits, or earning capacity, and the amount and the method that you used in computing the amount. Not at this time. Has anything been paid or is anything payable from any third party for the damages listed in your answers to these Interrogatories? If so, state the amounts paid or payable, the name and business address of the person or entity who paid or owes said amounts, and which of those third parties have or claim a right of subrogation. PIP paid 10,000.00. There is no third party claim of subrogation at this time. List the names and business addresses of each physician who has treated or examined you, and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this case; and state as to each the date of treatment or examination and the injury or condition for which you were examined or treated. Broad Anesthesia Associates 501 Glades Road Boca Raton, FL 33432 Florida IONM Services, LLC Dept. 1178 Post Office Box 11407 Birmingham, AL 35246 LabCorp 5610 W. LaSalle Street Tampa, FL 33607 Dr. Igor Levy-Reis Neuroscience and Spine Associates 6101 Pine Ridge Road Naples, FL 34109 Naples Diagnostic imaging 6400 Davis Boulevard Unit 101 Naples, FL 34101 Dr. Christopher Pham Integrated Health Services 2515 Northbrooke Plaza16. Suite 200 Naples, FL 34119 Stand Up MRI of Southwest Florida 4521 Executive Drive Suite 104 Naples, FL 34119 Surgicare of Boca Raton 1905 Clint Moore Road Suite 300 Boca Raton, FL 33496 Physicians Regional Medical Center 8300 Collier Boulevard Naples, FL 34114 Collier Emergency Group 8300 Collier Boulevard Naples, FL 34114 EMPI, Inc. Post Office Box 71519 Chicago, IL 60694 Collier County EMS 8075 Lely Cultural Parkway Suite 267 Naples, FL 34113 Dr. Richard Mara, D.C. 10621 Airport Rd N Suite 2 Naples, Fl 34109 Dr. Connie Lee, M.D. Address unknown Please refer to Dr. Mara’s records List the names and business addresses of all other physicians, medical facilities or other health care providers by whom or at which you have been examined or treated in the past ten (10) years; and state as to each the dates of examination or treatment and the condition or injury for which you were examined or treated. Naples Community Hospital17. 18. 19. Naples, FL 34112 Physicians Regional Medical Center 8300 Collier Boulevard Naples, FL 34114 Dr. Maria E. Santiago Collier Neurological Specialists 730 Goodlette Rd. N Suite 100 Naples, FL 34102 Memorial Hospital and Manor 1500 E. Shotwell St. Bainbridge, GA 39318 List the names and addresses of all persons who are believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. The parties to this lawsuit are aware of the events surrounding this accident. My treating physicans are aware of my injury and treatments. A witness to the accident, Lori Ellingsworth, 229 Palm Drive, Unit 2, Naples, FL 34112, as listed on incident report, In addition, Trooper S.R. Ellis of the Florida Highway Patrol. 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. No. State the name and address of every person known to you, your agents, or attorneys who has knowledge about, or possession, custody or control of any model, plat, map, drawing, motion picture, video tape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. My attorney is in possession of some photographs of the scene and property damage; as well as, the police report. These documents are20. 21. 22. 23. 24. 25. included in the request for production. 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. Undetermined at this time. Plaintiff will provide such information in compliance with the court’s trial order. 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. No. 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. No, other than the present matter. At the time of the accident described in the Complaint, were you wearing a seat belt? If not, please state why not; where you were seated in the vehicle; and whether the vehicle was equipped with a seat belt that was operational and available for your use. Yes, | was wearing my seatbelt and it was operational. 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 accident? Is so, describe the nature of the defect and how it contributed to the incident. No. Please identify by date, location and nature (type of accident) all accidents in which you were involved before and after the incident involved in this lawsuit, regardless of whether or not you were injured. (“Accidents” covers all types of incidents, and includes, but is not limited to motor vehicle accidents). 1 do not recall the exact date, but to the best of my recollection 2001 minor motor vehicle accident with no injuries.26. 27. 28. 29. 30. As to each accident identified in response to question 25, please state whether or not you were injured, and if injured, state the nature of the injury, if it was permanent, and the full name and address of all physicians and medical/chiropractic providers by whom you were treated. No. Please identify all claims made by you for personal injuries with any insurance company or individual (excluding court cases) including the date of the claim, the nature of the claim, and the name and address of the individual or business entity against whom the claim was made or filed. No, other than the present matter. Please state whether or not you have filed for worker's compensation, unemployment compensation, or social security disability benefits within the past ten (10) years. If so, please state the date of each claim, the name and address of the individual/agency with whom the claim was made, and the amount of benefits received. I received unemployment through the State of Florida beginning in July, 2012. | received benefits for approximately one year but do not recall the amount of the benefits received. With regard to any and all cell phones you had access to on the date of the accident described in the Complaint, please state: a. The name and address of the carrier/provider for each cell phone. Sprint b. The telephone number including area code for each cell phone. (239) 821-9466 c. The billing account number for each cell phone. I do not recall the account number. d. The name and address of the account holder for each cell phone. Marisela Garcia, 6437 Conning Tower Circle, A1, Naples, FL 34112 List the name, business address, telephone number, named insured, policy number (both group and individual number) and applicable dates of coverage forall health insurance companies, life insurance companies and disability insurance companies, who have provided coverage for you in the past ten (10) years. None.BY: 4 Name: MARISELA GARCIA STATE OF FLORIDA COUNTY OF BEFORE ME, the undersigned authority, personally appeared: Mar Selo Ararcio. who is [personally known to me or [ ] produced as identification and [ ] did [ ] did not take an oath, and having been personally sworn by me deposes and says that Marisela Garcia signed the foregoing Answers to Interrogatories and states said Answers are true to the best of her knowledge and/or belief. SWORN TO and subscribed before me this ein day of May 2014. Notary Public, State of wom on My Commission expires: g|ailo0 9 Notary Pubic tat of Fria isse Hemanciez YS Cree 08/31 Commission EE 126688 M2015