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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA CIVIL ACTION
ELLIS HANSON and VELTA HANSON,
Plaintiffs,
2.0 #
v. Case No. 09-6515- os 2 z
tm
y @
ALMA TETI, fs 2 1
call SZ 3S 02
Q
Defendant. 8 =
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9 2 &
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PLAINTIFF, VELTA HANSON, AMENDED ANSWERS TO 8
DEFENDANT’S FIRST INTERROGATORIES TO PLAINTIFF, VELTA HANSON
Plaintiff, VELTA HANSON (“Ms. Hanson”), by and through undersigned counsel,
hereby answers Defendant’s Interrogatories as follows:
1. List all former names and when you were known by those names. State all
addresses where you have lived for the past 10 years, the dates you lived at each address, your
Social Security number, your date of birth, and, if you are or ever have been married, the name
of your spouse or spouses.
Ms. Hanson’s former names were as follows: Velta R. Watson,
which was her maiden name, and Velta R. Street, which was
her previous married name. Ms Hanson’s name changes
occurred on or around when she was married. Ms. Hanson
married Waddy D. Street, Jr., on May 19, 1963, and divorced
on July 31, 1969. She married Ellis Hanson on August 31,
1974.
Ms. Hanson has lived at 725 18th Avenue South, Naples,
Florida, for the past 10 years. Ms. Hanson also had a condo
located at 145 Pinckney St, Boston, MA, during this time
period.
Ms. Hanson considers her Social Security number to be
private, privileged information that is not relevant for the
discovery of admissible evidence and therefore it is not likely to
lead to the discovery of any admissible evidence and therefore
objects to providing this information.
Ms. Hanson’s date of birth is February 2, 1944,
‘ALNNOD 8317105
SE 03114
V42. List the names and addresses of all persons who are believed or known by you,
Name / Addr
Defendant, Alma Teti
4810 Europa Drive
Naples, FL 34105
Raymond James & Associates,
Inc. and employees of Raymond
James & Associates, Inc.-
Address unknown at this time
Plaintiff, Velta Hanson
725 18th Avenue South
Naples, Florida 34102
Shirley Moore
3203 Benicia Ct
Naples, FL 34109
Michelin Yuan
3692 Nelsons Walk
Naples, FL 34102
Margie Iorio
500 12th Ave S
Naples, FL 34102
Dr. Joseph Sullivan
Primary Care physician from
roughly 1983-2006
201 8th St S Ste 203
Naples, FL 34102
Bill Beckwith
Psychologist
1415 Panther Ln., Suite 239
Naples, FL 34109-7874
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.
Subject Matter
Knowledge of all issues in case.
Knowledge of all issues in case.
Knowledge of all issues in case.
Knowledge of issues related to Alma
Tetti, Ellis Hanson, and
Velta Hanson.
Knowledge of issues related to Alma
Tetti, Ellis Hanson, and
Velta Hanson
Knowledge of issues related to Alma
Tetti, Ellis Hanson, and
Velta Hanson
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.Name / Address
Brian Wolff
Neurologist
671 Goodlette Rd N # 120
Naples, FL 34102-5615
William Justiz
Neurologist
Collier Neurologic Spec, Suite
100A
730 Goodlette Rd. N
Robert Ouaou
Neuropsychologist
2450 Goodlette Road North
Suite 101
Naples, FL 34103
Dr. Perlo of Massachusetts
General Hospital
Subject Matter
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.
Knowledge regarding Ellis Hanson’s
medical condition regarding an
incident on or around March of 2001
where Ellis Hanson was brought to
the emergency room for memory
confusion.
3. 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 formal statements have been taken from any witnesses at
this point with the exception of the deposition of Rick Walker.
Other than conversations between Ellis Hanson and Alma Teti,
Alma Teti and other witnesses, such as (the broker at
Raymond James), and perhaps others, no particular
statements involved in this case are known. All such
Statements were in the nature of contemporaneous
conversations during the time they occurred and no specific
record of such conversations or statements has been
maintained. The Plaintiffs will be engaging in discovery and
taking depositions to verify what statements and what the
circumstances surrounding all of the acts were involved in this
case and, therefore, the same will be addressed in that fashion.VERIFICATION
I, VELTA HANSON, being first duly sworn in accordance with law, do hereby depose
and state that I have read the responses to Defendant’s Interrogatories and that the responses are
true and correct to the best of my knowledge and information.
By hela a
VELTA HANSON
STATE OF FLORIDA
COUNTY OF Cl | bo
Sworn to (or affirmed) and subscribed before me this 5 day of November, 2009, by
VELTA HANSON, who is personally known by me [or who has produced
Foto DUvers ——_as identificafiof pad Who to ath,
Notary Public
Wurdle W . CoSueel|
Type or Print Name of Notary
My Commission Expires: _| 1Y ZOU
(SEAL)
Preview
® IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION ELLIS HANSON and VELTA HANSON, Plaintiffs, 2.0 # v. Case No. 09-6515- os 2 z tm y @ ALMA TETI, fs 2 1 call SZ 3S 02 Q Defendant. 8 = > = 9 2 & o> PLAINTIFF, VELTA HANSON, AMENDED ANSWERS TO 8 DEFENDANT’S FIRST INTERROGATORIES TO PLAINTIFF, VELTA HANSON Plaintiff, VELTA HANSON (“Ms. Hanson”), by and through undersigned counsel, hereby answers Defendant’s Interrogatories as follows: 1. List all former names and when you were known by those names. State all addresses where you have lived for the past 10 years, the dates you lived at each address, your Social Security number, your date of birth, and, if you are or ever have been married, the name of your spouse or spouses. Ms. Hanson’s former names were as follows: Velta R. Watson, which was her maiden name, and Velta R. Street, which was her previous married name. Ms Hanson’s name changes occurred on or around when she was married. Ms. Hanson married Waddy D. Street, Jr., on May 19, 1963, and divorced on July 31, 1969. She married Ellis Hanson on August 31, 1974. Ms. Hanson has lived at 725 18th Avenue South, Naples, Florida, for the past 10 years. Ms. Hanson also had a condo located at 145 Pinckney St, Boston, MA, during this time period. Ms. Hanson considers her Social Security number to be private, privileged information that is not relevant for the discovery of admissible evidence and therefore it is not likely to lead to the discovery of any admissible evidence and therefore objects to providing this information. Ms. Hanson’s date of birth is February 2, 1944, ‘ALNNOD 8317105 SE 03114 V42. List the names and addresses of all persons who are believed or known by you, Name / Addr Defendant, Alma Teti 4810 Europa Drive Naples, FL 34105 Raymond James & Associates, Inc. and employees of Raymond James & Associates, Inc.- Address unknown at this time Plaintiff, Velta Hanson 725 18th Avenue South Naples, Florida 34102 Shirley Moore 3203 Benicia Ct Naples, FL 34109 Michelin Yuan 3692 Nelsons Walk Naples, FL 34102 Margie Iorio 500 12th Ave S Naples, FL 34102 Dr. Joseph Sullivan Primary Care physician from roughly 1983-2006 201 8th St S Ste 203 Naples, FL 34102 Bill Beckwith Psychologist 1415 Panther Ln., Suite 239 Naples, FL 34109-7874 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. Subject Matter Knowledge of all issues in case. Knowledge of all issues in case. Knowledge of all issues in case. Knowledge of issues related to Alma Tetti, Ellis Hanson, and Velta Hanson. Knowledge of issues related to Alma Tetti, Ellis Hanson, and Velta Hanson Knowledge of issues related to Alma Tetti, Ellis Hanson, and Velta Hanson Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory. Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory.Name / Address Brian Wolff Neurologist 671 Goodlette Rd N # 120 Naples, FL 34102-5615 William Justiz Neurologist Collier Neurologic Spec, Suite 100A 730 Goodlette Rd. N Robert Ouaou Neuropsychologist 2450 Goodlette Road North Suite 101 Naples, FL 34103 Dr. Perlo of Massachusetts General Hospital Subject Matter Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory. Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory. Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory. Knowledge regarding Ellis Hanson’s medical condition regarding an incident on or around March of 2001 where Ellis Hanson was brought to the emergency room for memory confusion. 3. 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 formal statements have been taken from any witnesses at this point with the exception of the deposition of Rick Walker. Other than conversations between Ellis Hanson and Alma Teti, Alma Teti and other witnesses, such as (the broker at Raymond James), and perhaps others, no particular statements involved in this case are known. All such Statements were in the nature of contemporaneous conversations during the time they occurred and no specific record of such conversations or statements has been maintained. The Plaintiffs will be engaging in discovery and taking depositions to verify what statements and what the circumstances surrounding all of the acts were involved in this case and, therefore, the same will be addressed in that fashion.VERIFICATION I, VELTA HANSON, being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Defendant’s Interrogatories and that the responses are true and correct to the best of my knowledge and information. By hela a VELTA HANSON STATE OF FLORIDA COUNTY OF Cl | bo Sworn to (or affirmed) and subscribed before me this 5 day of November, 2009, by VELTA HANSON, who is personally known by me [or who has produced Foto DUvers ——_as identificafiof pad Who to ath, Notary Public Wurdle W . CoSueel| Type or Print Name of Notary My Commission Expires: _| 1Y ZOU (SEAL)