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FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.****
Filing # 92206645 E-Filed 07/08/2019 04:47:59 PM
IN THE CIRCUIT COURT OF THE 17-1-H JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
IN RE: ESTATE OF FILE NO.: PR-C-18-0002301
THEROLD JOHN RATHGEG, SR.
Deceased.
4
PETER RATHGEB, SANDRA BYRNES, and
22-0017 60
PATRICIA RATHGEB,
Petitioners,
V. ADVERSARY PROCEEDING
E.E,9 M
0.0Or..'
THEROLD J. RATHGEB, JR., as
Personal Representative and individually,
Respondent.
, ??
LBy.
DECOI 2.z
NOTICE OF SERVING PETITIONER'S, SANDRA BYRNES, RESPONSES TO
RESPONDENT'S FIRST SET OF INTERROGATORIES
COMES NOW, Petitioner, SANDRA BYRNES ("Sandra"), by and through her
undersigned counsel, pursuant to Rule 1.340, Fla. R. Civ. P., hereby serves her
responses to Respondent's First Set of Interrogatories.
Respectfully submitted,
ADRIAN PHILIP THOMAS, PA
Counsel for Petitioners
SunTrust Center, Suite 1050
515 E. Las Olas Blvd.
Ft. Lauderdale, FL 33301
(954) 764-7273 Telephone
-
/s/ Daniel A. McGowan
Daniel A. McGowan, Esq.
FBN: 94482
ADRIAN PHILIP THOMASM
Las Olas Square -
515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301
Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I
-
****
FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.****
CERTIFICATE OF SERVICE AND COMPLIANCE
I HEREBY CERTIFY that a true and correct copy of the foregoing pleading was
sent by e-mail via the Florida Courts eFiling Portal (pursuant to Rule 2.516, Florida Rules
of Judicial Administration and Administrative Order SC13-49), on this 8th day of July, 2019
to all those listed on the attached Service List where an e-mail address is indicated below;
otherwise, e-mail service was not made to pro se individuals who have not provided an
e-mail address for service but were served via regular U.S. Mail.
/s/ Daniel A. McGowan
Daniel A. McGowan, Esquire
For the Firm
ADRIAN PHILIP THOMAS PA
i '
Las Olas Square -
515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301
Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I
-
****
FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.****
SERVICE LIST
Kenneth R. Mikos, Esquire
Law Offices of Kenneth R. Mikos, PA
2780 E. Oakland Park Blvd.
Ft. Lauderdale, FL 33306
Counsel for Therold J. Rathgeb, Jr.
Alexander Platt, Esquire
Di Pietro Partners LLP
901 E. Las Olas Blvd., Suite 202
Ft. Lauderdale, FL 33301
alex@ddpalaw.com
Counsel for Therold John Rathgeb, Jr.
As Personal Representative
ADRIAN PHILIP THOMASPA
Las Olas Square 515 East Las Olas Boulevard, Suite 1050,
-
Fort Lauderdale, Florida 33301
Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I
-
****
FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.****
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
IN RE: ESTATE OF FILE NO.: PR-C-18-0002301
THEROLD JOHN RATHGEG, SR.
Deceased.
PETER RATHGEB, SANDRA BYRNES, and
PATRICIA RATHGEB,
Petitioners,
V. ADVERSARY PROCEEDING
THEROLD J. RATHGEB, JR., as
Personal Representative and individually,
Respondent.
PETITIONER'S, SANDRA BYRNES, UNVERIFIED RESPONSES TO
RESPONDENT'S FIRST SET OF INTERROGATORIES
COMES NOW, Petitioner, SANDRA BYRNES ("Sandra"), by and through her
undersigned counsel, pursuant to Rule 1.340, Fla. R. Civ. P., hereby responds to
Respondent's First Set of Interrogatories and states as follows:
GENERAL OBJECTIONS AND ASSERTIONS
Sandra objects to any request that seeks information or documents protected by
the attorney-client or work product privileges and has answered these Interrogatories
assuming that the Respondent is not seeking information or documents so privileged. No
privilege is waived by answering the Respondent's discovery requests.
ADRIAN PHILIP THOMAS ,PA
Las Olas Square -
515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301
Toll Free: (800) 249-8125 I Phone: (954) 764-7273
****
FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.****
Sandra objects to these Interrogatories as unduly burdensome and oppressive
insofar as they seek information or documents already in the Respondent's possession,
custody, or control, or documents equally available to the Respondent.
All Interrogatories are responded to as required by the Florida Rules of Civil
Procedure. Where an answer to an Interrogatory request can be answered by a
document produced in response to the Respondent's Requests for Production, Sandra
will answer the Interrogatory by indicating the location of the document responsive to the
request, pursuant to Florida Rule of Civil Procedure 1.340(c).
All of Sandra's responses are solely for the purpose of the subject matter of these
legal proceedings. Sandra has made diligent efforts to respond to the Respondent's
discovery requests. As discovery is continuing, there may be further information,
persons, or documents responsive to the Respondent's requests not presently within
Sandra's knowledge. This response does not represent an admission or representation
that additional facts, documents, or persons with relevant knowledge of the subject matter
of the above-referencedlawsuit do not exist. As discovery and litigation continue, Sandra
may obtain additional information relevant to the Respondent's discovery requests.
Sandra reserves the right to amend, alter, or supplement her discovery responses as
necessary at any time.
Except for the explicit facts stated herein, no incidental admissions are intended
hereby. The fact that Sandra responded to the Interrogatories is not an admission that
she accepts or admits the existence of facts set forth or assumed by any interrogatory.
The fact that Sandra answered all or part of any interrogatory is not intended and should
not be construed to be a waiver of all or any part of any objections to the interrogatory.
ADRIAN PHILIP THOMASPA
Las Olas Square -
515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301
Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I
-
****
FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.****
As used herein, "the Respondent" refers to THEROLD J. RATHGEB, JR., as
Personal Representative.
As used herein, "Sandra" refers to Petitioner, SANDRA BYRNES.
As used herein, "Decedent," refers to Therold John Rathgeb, Sr., the Decedent in
the above styled probate case pending in Broward County, Florida.
As used herein, "the Proceedings," refers to the above legal proceedings, pending
in Broward County with File Number PRC 18-0002301.
RESPONSES TO FIRST SET OF INTERROGATORIES
1. State 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
Interrogatoriesare directed.
ANSWER: Sandra J. Byrnes, 2620 SW 55th Street, Fort Lauderdale, FL
33312-7448.
2. Identify each person, other than a person intended to be called as an expert
witness at trial, who is believed or known by you, 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.
ANSWER: Plaintiffs and Defendant
3. each person whom you expect to call as an expert witness at trial,
Identify
and as witness, state the name and business address of the witness, the
to each such
witnesses' 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.
ANSWER: I have not yet determined.
4. If you intend to rely on any documents or other tangible things to support a
position that you have taken or intend to take in the action, including any claims for
damages, provide a brief description by category and location, of all such documents,
and other tangible things, and identify all persons having possession, custody, or control
of them.
ADRIAN PHIUPTHOMAS PA
Las Olas Square -
515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301
Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I
-
****
FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.****
ANSWER: I do not know what documents I intend to rely on to support my
positions.
5. Please identify all communications between you and Therold Rathgeb, Sr.
relating to the allegations of the Complaint. Your response should include, without
limitation, identification of all such communications relating to the subject deed which is
referred to in Count One of the Complaint (titled "Cancellation of Deed").
ANSWER: My Dad visiting us at my brother Pete's house for football
was
in late 2012. We were all three (Dad, Pete and Sandy) sitting togethertalking
when Pete asked my Dad what his wishes were as he was the Executor of
his estate. Dan answered, "1 want everything divided to you kids; Even
Steven." Peter then asked Dad, "What about the signing of the house over
"
to John" Dad answered, "1 did not do that." Pete told him, "Yes you did.'
Dad answered,"I did not want to do that and'FIX IT."' Peter asked Dad again,
"
"What is it that you wanted" Dad answered, "'Even Stevens' for all of you.'
I then asked Dad, "the house too" And Dad responded, "Yes, and the
house." On April 1, 2018, Easter, my Dad was at my home and he was in
terrible shape, he could not walk without help and he had a big swollen left
ankle.My Dad said directly to as he was about to leave, "1 feel bad about
what's happened to our family, and I really appreciate all that you did to make
me happy and I love you." I then answered, "1 love you too Dad!"
6. State the facts that support the allegations contained in Count One of the
Complaint.
ANSWER: My brother unduly influenced my father into executing the deed.
7. State the facts that support the allegations contained in Count Two of the
Complaint.
ANSWER: My brother did not inform us of the trust or its administration.
8. State the facts that support the allegations contained in Count Three of the
Complaint.
ANSWER: My brother unduly influenced my father into transferring
virtually all of his assets so that they were not distributed as he wished upon
his death.
9. Describe in detail each act or omission on the part of Therold Rathgeb, Jr.
that you contend constitute a breach of fiduciary duty that was a contributinglegal cause
of any harm to you.
ADRIAN PHILIP THOMAS M
Las Olas Square 515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301
-
Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I
-
****
FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.****
ANSWER: Upon visiting my father after church on November 11, 2012,
Therold Rathgeb, Jr. approached me and produced a copy of the Quitclaim
Deed dated 2012 that had transferred ownership from my father. He than
asked me to "sign this anywhere to show that you agree with this." I
responded, "No, I can't do that."
10. Identify all electronic devices, including without limitation, computers,
personal digital assistants and cell phones utilized by yourself, or your attorneys, or other
agents on your behalf containing any evidence to support the allegations contained in all
Counts of the Complaint.
ANSWER: Suzanne Rathgeb's and Plaintiffs Pete Rathgeb, Patricia
Rathgeb and Sandra Byrnes' iPhones, videos, texts, photos, emails and pdfs
on computers, where applicable.
11. State whether you have ever been a party, either a plaintiff, or defendant,
in lawsuit other than the present matter, and, if so, state whether you were the Plaintiff
a
or Defendant, the nature of the action, and the date, and court in which such suit was filed
and the case number of the lawsuit(s).
ANSWER: Sandra L. Byrnes v. Safepoint Insurance Company, Broward
County Circuit Court, Case No. CACE15013388, filed 07/28/2015 and
disposed on 05/21/2019, and Motion for New Trial filed 05/24/2019 (251 pages,
with exhibits pages 1 and 19 attached). Suit against property insurance
company for failure to pay claim resulting from water damage from broken
water heater.
12. Identify all documents relied upon and persons consulted in answering the
foregoing interrogatories.
ANSWER: Online court records, and copies of case documents in my
possession, Suzanne Rathgeb's and Plaintiffs Pete Rathgeb, Patricia
Rathgeb and Sandra Byrnes' iPhones, photos, videos, texts, emails and pdfs
on computers were applicable.
ADRIAN PHILIP THOMAS PA.
Las Olas Square 515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301
-
Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I
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**** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.**** Filing # 92206645 E-Filed 07/08/2019 04:47:59 PM IN THE CIRCUIT COURT OF THE 17-1-H JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IN RE: ESTATE OF FILE NO.: PR-C-18-0002301 THEROLD JOHN RATHGEG, SR. Deceased. 4 PETER RATHGEB, SANDRA BYRNES, and 22-0017 60 PATRICIA RATHGEB, Petitioners, V. ADVERSARY PROCEEDING E.E,9 M 0.0Or..' THEROLD J. RATHGEB, JR., as Personal Representative and individually, Respondent. , ?? LBy. DECOI 2.z NOTICE OF SERVING PETITIONER'S, SANDRA BYRNES, RESPONSES TO RESPONDENT'S FIRST SET OF INTERROGATORIES COMES NOW, Petitioner, SANDRA BYRNES ("Sandra"), by and through her undersigned counsel, pursuant to Rule 1.340, Fla. R. Civ. P., hereby serves her responses to Respondent's First Set of Interrogatories. Respectfully submitted, ADRIAN PHILIP THOMAS, PA Counsel for Petitioners SunTrust Center, Suite 1050 515 E. Las Olas Blvd. Ft. Lauderdale, FL 33301 (954) 764-7273 Telephone - /s/ Daniel A. McGowan Daniel A. McGowan, Esq. FBN: 94482 ADRIAN PHILIP THOMASM Las Olas Square - 515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301 Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I - **** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.**** CERTIFICATE OF SERVICE AND COMPLIANCE I HEREBY CERTIFY that a true and correct copy of the foregoing pleading was sent by e-mail via the Florida Courts eFiling Portal (pursuant to Rule 2.516, Florida Rules of Judicial Administration and Administrative Order SC13-49), on this 8th day of July, 2019 to all those listed on the attached Service List where an e-mail address is indicated below; otherwise, e-mail service was not made to pro se individuals who have not provided an e-mail address for service but were served via regular U.S. Mail. /s/ Daniel A. McGowan Daniel A. McGowan, Esquire For the Firm ADRIAN PHILIP THOMAS PA i ' Las Olas Square - 515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301 Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I - **** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.**** SERVICE LIST Kenneth R. Mikos, Esquire Law Offices of Kenneth R. Mikos, PA 2780 E. Oakland Park Blvd. Ft. Lauderdale, FL 33306 Counsel for Therold J. Rathgeb, Jr. Alexander Platt, Esquire Di Pietro Partners LLP 901 E. Las Olas Blvd., Suite 202 Ft. Lauderdale, FL 33301 alex@ddpalaw.com Counsel for Therold John Rathgeb, Jr. As Personal Representative ADRIAN PHILIP THOMASPA Las Olas Square 515 East Las Olas Boulevard, Suite 1050, - Fort Lauderdale, Florida 33301 Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I - **** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.**** IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IN RE: ESTATE OF FILE NO.: PR-C-18-0002301 THEROLD JOHN RATHGEG, SR. Deceased. PETER RATHGEB, SANDRA BYRNES, and PATRICIA RATHGEB, Petitioners, V. ADVERSARY PROCEEDING THEROLD J. RATHGEB, JR., as Personal Representative and individually, Respondent. PETITIONER'S, SANDRA BYRNES, UNVERIFIED RESPONSES TO RESPONDENT'S FIRST SET OF INTERROGATORIES COMES NOW, Petitioner, SANDRA BYRNES ("Sandra"), by and through her undersigned counsel, pursuant to Rule 1.340, Fla. R. Civ. P., hereby responds to Respondent's First Set of Interrogatories and states as follows: GENERAL OBJECTIONS AND ASSERTIONS Sandra objects to any request that seeks information or documents protected by the attorney-client or work product privileges and has answered these Interrogatories assuming that the Respondent is not seeking information or documents so privileged. No privilege is waived by answering the Respondent's discovery requests. ADRIAN PHILIP THOMAS ,PA Las Olas Square - 515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301 Toll Free: (800) 249-8125 I Phone: (954) 764-7273 **** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.**** Sandra objects to these Interrogatories as unduly burdensome and oppressive insofar as they seek information or documents already in the Respondent's possession, custody, or control, or documents equally available to the Respondent. All Interrogatories are responded to as required by the Florida Rules of Civil Procedure. Where an answer to an Interrogatory request can be answered by a document produced in response to the Respondent's Requests for Production, Sandra will answer the Interrogatory by indicating the location of the document responsive to the request, pursuant to Florida Rule of Civil Procedure 1.340(c). All of Sandra's responses are solely for the purpose of the subject matter of these legal proceedings. Sandra has made diligent efforts to respond to the Respondent's discovery requests. As discovery is continuing, there may be further information, persons, or documents responsive to the Respondent's requests not presently within Sandra's knowledge. This response does not represent an admission or representation that additional facts, documents, or persons with relevant knowledge of the subject matter of the above-referencedlawsuit do not exist. As discovery and litigation continue, Sandra may obtain additional information relevant to the Respondent's discovery requests. Sandra reserves the right to amend, alter, or supplement her discovery responses as necessary at any time. Except for the explicit facts stated herein, no incidental admissions are intended hereby. The fact that Sandra responded to the Interrogatories is not an admission that she accepts or admits the existence of facts set forth or assumed by any interrogatory. The fact that Sandra answered all or part of any interrogatory is not intended and should not be construed to be a waiver of all or any part of any objections to the interrogatory. ADRIAN PHILIP THOMASPA Las Olas Square - 515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301 Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I - **** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.**** As used herein, "the Respondent" refers to THEROLD J. RATHGEB, JR., as Personal Representative. As used herein, "Sandra" refers to Petitioner, SANDRA BYRNES. As used herein, "Decedent," refers to Therold John Rathgeb, Sr., the Decedent in the above styled probate case pending in Broward County, Florida. As used herein, "the Proceedings," refers to the above legal proceedings, pending in Broward County with File Number PRC 18-0002301. RESPONSES TO FIRST SET OF INTERROGATORIES 1. State 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 Interrogatoriesare directed. ANSWER: Sandra J. Byrnes, 2620 SW 55th Street, Fort Lauderdale, FL 33312-7448. 2. Identify each person, other than a person intended to be called as an expert witness at trial, who is believed or known by you, 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. ANSWER: Plaintiffs and Defendant 3. each person whom you expect to call as an expert witness at trial, Identify and as witness, state the name and business address of the witness, the to each such witnesses' 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. ANSWER: I have not yet determined. 4. If you intend to rely on any documents or other tangible things to support a position that you have taken or intend to take in the action, including any claims for damages, provide a brief description by category and location, of all such documents, and other tangible things, and identify all persons having possession, custody, or control of them. ADRIAN PHIUPTHOMAS PA Las Olas Square - 515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301 Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I - **** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.**** ANSWER: I do not know what documents I intend to rely on to support my positions. 5. Please identify all communications between you and Therold Rathgeb, Sr. relating to the allegations of the Complaint. Your response should include, without limitation, identification of all such communications relating to the subject deed which is referred to in Count One of the Complaint (titled "Cancellation of Deed"). ANSWER: My Dad visiting us at my brother Pete's house for football was in late 2012. We were all three (Dad, Pete and Sandy) sitting togethertalking when Pete asked my Dad what his wishes were as he was the Executor of his estate. Dan answered, "1 want everything divided to you kids; Even Steven." Peter then asked Dad, "What about the signing of the house over " to John" Dad answered, "1 did not do that." Pete told him, "Yes you did.' Dad answered,"I did not want to do that and'FIX IT."' Peter asked Dad again, " "What is it that you wanted" Dad answered, "'Even Stevens' for all of you.' I then asked Dad, "the house too" And Dad responded, "Yes, and the house." On April 1, 2018, Easter, my Dad was at my home and he was in terrible shape, he could not walk without help and he had a big swollen left ankle.My Dad said directly to as he was about to leave, "1 feel bad about what's happened to our family, and I really appreciate all that you did to make me happy and I love you." I then answered, "1 love you too Dad!" 6. State the facts that support the allegations contained in Count One of the Complaint. ANSWER: My brother unduly influenced my father into executing the deed. 7. State the facts that support the allegations contained in Count Two of the Complaint. ANSWER: My brother did not inform us of the trust or its administration. 8. State the facts that support the allegations contained in Count Three of the Complaint. ANSWER: My brother unduly influenced my father into transferring virtually all of his assets so that they were not distributed as he wished upon his death. 9. Describe in detail each act or omission on the part of Therold Rathgeb, Jr. that you contend constitute a breach of fiduciary duty that was a contributinglegal cause of any harm to you. ADRIAN PHILIP THOMAS M Las Olas Square 515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301 - Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I - **** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK. 12/1/2022 4:30:00 PM.**** ANSWER: Upon visiting my father after church on November 11, 2012, Therold Rathgeb, Jr. approached me and produced a copy of the Quitclaim Deed dated 2012 that had transferred ownership from my father. He than asked me to "sign this anywhere to show that you agree with this." I responded, "No, I can't do that." 10. Identify all electronic devices, including without limitation, computers, personal digital assistants and cell phones utilized by yourself, or your attorneys, or other agents on your behalf containing any evidence to support the allegations contained in all Counts of the Complaint. ANSWER: Suzanne Rathgeb's and Plaintiffs Pete Rathgeb, Patricia Rathgeb and Sandra Byrnes' iPhones, videos, texts, photos, emails and pdfs on computers, where applicable. 11. State whether you have ever been a party, either a plaintiff, or defendant, in lawsuit other than the present matter, and, if so, state whether you were the Plaintiff a or Defendant, the nature of the action, and the date, and court in which such suit was filed and the case number of the lawsuit(s). ANSWER: Sandra L. Byrnes v. Safepoint Insurance Company, Broward County Circuit Court, Case No. CACE15013388, filed 07/28/2015 and disposed on 05/21/2019, and Motion for New Trial filed 05/24/2019 (251 pages, with exhibits pages 1 and 19 attached). Suit against property insurance company for failure to pay claim resulting from water damage from broken water heater. 12. Identify all documents relied upon and persons consulted in answering the foregoing interrogatories. ANSWER: Online court records, and copies of case documents in my possession, Suzanne Rathgeb's and Plaintiffs Pete Rathgeb, Patricia Rathgeb and Sandra Byrnes' iPhones, photos, videos, texts, emails and pdfs on computers were applicable. ADRIAN PHILIP THOMAS PA. Las Olas Square 515 East Las Olas Boulevard, Suite 1050, Fort Lauderdale, Florida 33301 - Toll Free: (800) 249-8125 I Phone: (954) 764-7273 I