Preview
Case Number:22-006061-CI
Filing # 163720752 E-Filed 12/28/2022 07:26:23 AM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
CIVIL DIVISION
BRIDGETTE LAPPEN,
Plaintiff,
vs. CASE NO:
SHRI HARI LARGO HOTEL, LLC,
Defendant.
/
INTERROGATORIES
PLEASE INSERT YOUR ANSWERS IN THE SPACE PROVIDED BELOW EACH
INTERROGATORY. SHOULD ADDITIONAL SPACE BE NEEDED, PLEASE ATTACH
AN EXTRA SHEET. "YOU" AND "YOUR" REFER TO THE DEFENDANT TO WHOM
THESE INTERROGATORIES ARE DIRECTED. DEFENDANT INCLUDES ALL
AGENTS, SERVANTS, OR EMPLOYEES OF THE DEFENDANT.
1. State the full name, address, occupation and employer of any and all persons who
answer these Interrogatories or who have provided information used in compiling the answers to
these Interrogatories.
ANSWER:
2. Is the name of the Defendant correctly stated in the Complaint? If not, please state
the correct name and ifapplicable allname changes from the date of the alleged incident to the
present.
ANSWER:
***ELECTRONICALLY FILED 12/28/2022 07:26:21 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
3. Please state the name of the desk clerk on duty on September 28, 2022 as referenced
in the Complaint.
ANSWER:
4. Are the date, time and place of the alleged incident correctly stated in the Complaint?
If not, please state the date, time and place of this alleged incident believed or known by you, your
agents or attorneys to be correct.
ANSWER:
5. Please state whether any incident report was prepared by your employees in response
to the incident giving rise to this action, and if there was one, please list the name, address and
occupation of the current custodian of said incident report.
ANSWER:
6. Please list the name, last known address and employer of each and every employee
employed by Defendant, SHRI HARI LARGO HOTEL, LLC and working at said location on the
date of the incident as alleged in the Complaint.
ANSWER:
7. State full name, address, occupation, employer and telephone number of any and all
persons known to have any information concerning the incident alleged in Plaintiff's Complaint in
this action.
ANSWER:
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8. Have you, your agents, investigators, attorneys or anyone acting on your behalf,
obtained any kind of written, recorded, or other type of statement from the Plaintiff or any persons
described in your previous Interrogatory answers? If so, please identify each statement by date,
identity of person giving statement and name of current custodian of each statement.
ANSWER:
9. Based on your knowledge at this time, describe in detail how the alleged incident
happened, including all actions taken by the Defendant to prevent the incident.
ANSWER:
10. State the frequency and dates of inspections of the area where this incident occurred
for the 30-day period prior to the incident and the 24-hour period after this incident, which is the
subject matter of this litigation. State the name, address, job title and telephone number of the person
who made the last inspection prior to the incident.
ANSWER:
11. Did any person inspect the area where the Plaintiff was allegedly injured within 24
hours prior to or following the alleged incident? If so, please state the name, address and telephone
number of each person performing said inspection, the times or frequencies of said inspection(s),
and whether or not said inspection(s) revealed any defect or condition to be present.
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ANSWER:
12. State who was responsible for the design and construction of that portion of the
premises (to include shelving/product displays and/or flooring) where Plaintiff was injured as alleged
in the Complaint.
ANSWER:
13. Please state whether or not you have experienced any other slip and fall incidents in
the subject premises for the three (3) year period of time immediately preceding the subject incident.
(NOTE: for all responsive incidents, please identify (i) date of incident; (ii) location in premises
where incident occurred and (iii) a brief description of the incident such that the Court can determine
substantial similarity to the subject incident).
ANSWER:
14. Please state whether or not you have experienced any other slip and fall incidents for
all locations in Florida for the three (3) year period of time immediately preceding the subject
incident. (NOTE: for all responsive incidents, please identify (i) date of incident; (ii)location at
which incident occurred, (iii) location in premises where incident occurred and (iv) a brief
description of the incident such that the Court can determine substantial similarity to the subject
incident).
ANSWER:
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15. Please identify the type of flooring that was used at the subject location in the area
where the subject incident is alleged to have occurred as of the date of the subject incident.
ANSWER:
16. Please specify the make and/or manufacturer of the floor surface and/or flooring in
the area where the subject incident is alleged to have occurred as of the date of the subject incident.
ANSWER:
17. Please identify all specifications of the flooring material of the floor surface and/or
flooring in the area where the subject incident is alleged to have occurred as of the date of the
incident.
ANSWER:
18. Please identify all types of sealants or floor polishes that were used on the floor
surface and/or flooring in the area where the subject incident is alleged to have occurred as of the
date of the incident for the three (3) year period of time immediately preceding the subject incident.
ANSWER:
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19. Please identify the cleaning method for the floor surface and/or flooring in the area
where the subject incident is alleged to have occurred as of the date of the incident.
ANSWER:
20. Please identify who (individuals or company) that was responsible for cleaning the
floor surface and/or flooring in the area where the subject incident is alleged to have occurred as
of the date of the incident.
ANSWER:
21. Please identify all cleaning products that were used to clean the floor surface and/or
flooring in the area where the subject incident is alleged to have occurred as of the date of the
incident for the three (3) period of time immediately preceding the subject incident.
ANSWER:
22. What was the schedule for cleaning of the floor surface and/or flooring in the area
where the subject incident is alleged to have occurred as of the date of the incident.
ANSWER:
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23. Has there ever been a walkway audit performed of the floor surface and/or flooring
in the area where the subject incident is alleged to have occurred. If so, please provide the date the
audit occurred, the company performing the audit, and the results of said audit.
ANSWER:
24. Has there ever been a risk assessment performed of the floor surface and/or flooring
in the area where the subject incident is alleged to have occurred. If not, why?
ANSWER:
25. Please provide any certification or acceptance of the slip resistance of the floor
surface and/or flooring in the area where the subject incident is alleged to have occurred as of the
date of the incident.
ANSWER:
26. What is the coefficient of friction of the floor surface and/or flooring in the area
where the subject incident is alleged to have occurred.
ANSWER:
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27. As of the date of the subject incident, did you ever assign a specific associate or
associates to continuously or periodically inspect the floor surface and/or flooring in the area where
the subject incident is alleged to have occurred for dangerous conditions such as liquid substances.
ANSWER:
28. Who was the competent individual within your company who is responsible for
walkway safety as of the date of the subject incident.
ANSWER:
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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 Representative of:
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:
9
Preview
Case Number:22-006061-CI Filing # 163720752 E-Filed 12/28/2022 07:26:23 AM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION BRIDGETTE LAPPEN, Plaintiff, vs. CASE NO: SHRI HARI LARGO HOTEL, LLC, Defendant. / INTERROGATORIES PLEASE INSERT YOUR ANSWERS IN THE SPACE PROVIDED BELOW EACH INTERROGATORY. SHOULD ADDITIONAL SPACE BE NEEDED, PLEASE ATTACH AN EXTRA SHEET. "YOU" AND "YOUR" REFER TO THE DEFENDANT TO WHOM THESE INTERROGATORIES ARE DIRECTED. DEFENDANT INCLUDES ALL AGENTS, SERVANTS, OR EMPLOYEES OF THE DEFENDANT. 1. State the full name, address, occupation and employer of any and all persons who answer these Interrogatories or who have provided information used in compiling the answers to these Interrogatories. ANSWER: 2. Is the name of the Defendant correctly stated in the Complaint? If not, please state the correct name and ifapplicable allname changes from the date of the alleged incident to the present. ANSWER: ***ELECTRONICALLY FILED 12/28/2022 07:26:21 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 3. Please state the name of the desk clerk on duty on September 28, 2022 as referenced in the Complaint. ANSWER: 4. Are the date, time and place of the alleged incident correctly stated in the Complaint? If not, please state the date, time and place of this alleged incident believed or known by you, your agents or attorneys to be correct. ANSWER: 5. Please state whether any incident report was prepared by your employees in response to the incident giving rise to this action, and if there was one, please list the name, address and occupation of the current custodian of said incident report. ANSWER: 6. Please list the name, last known address and employer of each and every employee employed by Defendant, SHRI HARI LARGO HOTEL, LLC and working at said location on the date of the incident as alleged in the Complaint. ANSWER: 7. State full name, address, occupation, employer and telephone number of any and all persons known to have any information concerning the incident alleged in Plaintiff's Complaint in this action. ANSWER: 2 8. Have you, your agents, investigators, attorneys or anyone acting on your behalf, obtained any kind of written, recorded, or other type of statement from the Plaintiff or any persons described in your previous Interrogatory answers? If so, please identify each statement by date, identity of person giving statement and name of current custodian of each statement. ANSWER: 9. Based on your knowledge at this time, describe in detail how the alleged incident happened, including all actions taken by the Defendant to prevent the incident. ANSWER: 10. State the frequency and dates of inspections of the area where this incident occurred for the 30-day period prior to the incident and the 24-hour period after this incident, which is the subject matter of this litigation. State the name, address, job title and telephone number of the person who made the last inspection prior to the incident. ANSWER: 11. Did any person inspect the area where the Plaintiff was allegedly injured within 24 hours prior to or following the alleged incident? If so, please state the name, address and telephone number of each person performing said inspection, the times or frequencies of said inspection(s), and whether or not said inspection(s) revealed any defect or condition to be present. 3 ANSWER: 12. State who was responsible for the design and construction of that portion of the premises (to include shelving/product displays and/or flooring) where Plaintiff was injured as alleged in the Complaint. ANSWER: 13. Please state whether or not you have experienced any other slip and fall incidents in the subject premises for the three (3) year period of time immediately preceding the subject incident. (NOTE: for all responsive incidents, please identify (i) date of incident; (ii) location in premises where incident occurred and (iii) a brief description of the incident such that the Court can determine substantial similarity to the subject incident). ANSWER: 14. Please state whether or not you have experienced any other slip and fall incidents for all locations in Florida for the three (3) year period of time immediately preceding the subject incident. (NOTE: for all responsive incidents, please identify (i) date of incident; (ii)location at which incident occurred, (iii) location in premises where incident occurred and (iv) a brief description of the incident such that the Court can determine substantial similarity to the subject incident). ANSWER: 4 15. Please identify the type of flooring that was used at the subject location in the area where the subject incident is alleged to have occurred as of the date of the subject incident. ANSWER: 16. Please specify the make and/or manufacturer of the floor surface and/or flooring in the area where the subject incident is alleged to have occurred as of the date of the subject incident. ANSWER: 17. Please identify all specifications of the flooring material of the floor surface and/or flooring in the area where the subject incident is alleged to have occurred as of the date of the incident. ANSWER: 18. Please identify all types of sealants or floor polishes that were used on the floor surface and/or flooring in the area where the subject incident is alleged to have occurred as of the date of the incident for the three (3) year period of time immediately preceding the subject incident. ANSWER: 5 19. Please identify the cleaning method for the floor surface and/or flooring in the area where the subject incident is alleged to have occurred as of the date of the incident. ANSWER: 20. Please identify who (individuals or company) that was responsible for cleaning the floor surface and/or flooring in the area where the subject incident is alleged to have occurred as of the date of the incident. ANSWER: 21. Please identify all cleaning products that were used to clean the floor surface and/or flooring in the area where the subject incident is alleged to have occurred as of the date of the incident for the three (3) period of time immediately preceding the subject incident. ANSWER: 22. What was the schedule for cleaning of the floor surface and/or flooring in the area where the subject incident is alleged to have occurred as of the date of the incident. ANSWER: 6 23. Has there ever been a walkway audit performed of the floor surface and/or flooring in the area where the subject incident is alleged to have occurred. If so, please provide the date the audit occurred, the company performing the audit, and the results of said audit. ANSWER: 24. Has there ever been a risk assessment performed of the floor surface and/or flooring in the area where the subject incident is alleged to have occurred. If not, why? ANSWER: 25. Please provide any certification or acceptance of the slip resistance of the floor surface and/or flooring in the area where the subject incident is alleged to have occurred as of the date of the incident. ANSWER: 26. What is the coefficient of friction of the floor surface and/or flooring in the area where the subject incident is alleged to have occurred. ANSWER: 7 27. As of the date of the subject incident, did you ever assign a specific associate or associates to continuously or periodically inspect the floor surface and/or flooring in the area where the subject incident is alleged to have occurred for dangerous conditions such as liquid substances. ANSWER: 28. Who was the competent individual within your company who is responsible for walkway safety as of the date of the subject incident. ANSWER: 8 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 Representative of: 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: 9