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Filing # 176539080 E-Filed 06/30/2023 12:45:51 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2023 CA 001154 AN
ANTHONY WILMER SANCHEZ
ROMAN,
Plaintiff,
vs.
JUSTINA RODRIGUEZ,
Defendant.
/
PLAINTIFF’S NOTICE OF SERVING INTERROGATORIES TO DEFENDANT,
JUSTINA RODRIGUEZ
Plaintiff, ANTHONY WILMER SANCHEZ ROMAN, by and through undersigned
counsel and pursuant to Fla. R. Civ. P. 1.340, propounds upon Defendant, JUSTINA RODRIGUEZ
the attached Interrogatories, to be answered, under oath, within forty-five (45) days from the date of
service.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the Defendant, along with the Summons and Complaint.
/s/ Ashley McMahan
Ashley McMahan, Esquire
Florida Bar No: 1003316
Morgan & Morgan, P.A.
2150 Goodlette-Frank Rd, Suite 750
Naples, FL 34102
Telephone: (239) 432-6664
Primary email: amcmahan@forthepeople.com
Secondary email: Morganservice@forthepeople.com
Attorneys for Plaintiff
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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2023 CA 001154 AN
ANTHONY WILMER SANCHEZ
ROMAN,
Plaintiff,
vs.
JUSTINA RODRIGUEZ,
Defendant.
/
INTERROGATORIES TO DEFENDANT, JUSTINA RODRIGUEZ
Plaintiff, ANTHONY WILMER SANCHEZ ROMAN, by and through the undersigned
counsel propounds the attached Interrogatories, numbered one (1) through twenty-five (25) to
Defendant, JUSTINA RODRIGUEZ to be answered, under oath, within forty-five (45) days from the
date of service.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the Defendant, along with the Summons and Complaint.
/s/ Ashley McMahan
Ashley McMahan, Esquire
Florida Bar No: 1003316
Morgan & Morgan, P.A.
2150 Goodlette-Frank Rd, Suite 750
Naples, FL 34102
Telephone: (239) 432-6664
Primary email: amcmahan@forthepeople.com
Secondary email: Morganservice@forthepeople.com
Attorneys for Plaintiff
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INTERROGATORIES TO DEFENDANT JUSTINA RODRIGUEZ
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. IF ANSWERING FOR ANOTHER
PERSON OR ENTITY, ANSWER WITH RESPECT TO THAT PERSON OR ENTITY, UNLESS
OTHERWISE STATED.
1. 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?
2. 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, and your date of birth.
3. 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 1 year, or that involved dishonesty or a false statement regardless of the
punishment? If so, state as to each conviction the specific crime and the date and place of
conviction.
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4. Describe any and all policies of insurance which you contend cover or may cover you for
the allegations set for in plaintiff’s complaint, detailing as to such policies the name of the
insurer, the number of the policy, the effective dates of the policy, the available limits of
liability, and the name and address of the custodian of the policy.
5. Describe in detail how the incident described in the complaint happened, including all
actions taken by you to prevent the incident.
6. 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.
7. State the facts upon which you rely for each affirmative defense in your answer.
8. Do you contend any person or entity other than you is, or may be, liable in whole or part
for the claims asserted against you in this lawsuit? If so, state the full name and address of
each such person or entity, the legal basis for your contention, the facts or evidence upon
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which your contention is based, and whether or not you have notified each such person or
entity of your contention.
9. 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 the charge, and, if so,
what is the name and address of the person or entity who 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 is the name and address of the person who
recorded the testimony?
10. List the names and addresses of all persons who are 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.
11. 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.
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12. 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 is was taken or prepared.
13. 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.
14. 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.
15. 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.
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16. 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?
17. 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?
18. Did you consume any alcoholic beverages or take any drugs or medications within 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.
19. 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 incident? If so, describe the nature of
the defect and how it contributed to the incident.
20. List the name and address of all persons, corporations, or entities who were registered title
owners or who had ownership interest in, or right to control, the motor vehicle that the
defendant driver was driving at the time of the incident described in the complaint; and
describe both the nature of the ownership interest or right to control the vehicle, and the
vehicle itself, including the make, model, year, and vehicle identification number.
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21. At the time of the incident described in the complaint, did the driver of the vehicle
described in your answer to the preceding interrogatory have permission to drive the
vehicle? If so, state the names and addresses of all persons who have such permission.
22. At the time of the incident described in the complaint, were you engaged in any mission or
activity for any other person or entity, including any employer? If so, state the name
address of that person or entity and the nature of the mission or activity.
23. Was the motor vehicle that you were driving at the time of the incident described in the
complaint damaged in the incident, and, if so, what was the cost to repair the damage.
24. Do you have a cellular phone? If so, please provide the number of your phone at the time
of the accident, the name of your cell phone carrier, and the name under which the account
is listed.
25. Describe in complete detail the appearance of the Plaintiff immediately after the Plaintiff’s
alleged occurrence, including any obvious injuries, the emotional state of the Plaintiff,
whether the Plaintiff appeared in pain or otherwise.
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STATE OF
COUNTY OF
Before me the undersigned officer, authorized to administer oaths and take acknowledgments,
personally appeared JUSTINA RODRIGUEZ, 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.
JUSTINA RODRIGUEZ
SWORN TO AND SUBSCRIBED before me this day of , .
Notary Public (signature)
Notary Public (type, print stamp commission)
My Commission Expires:
❑ Personally Known OR
❑ Produced Identification
❑ Type of Identification Produced:
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Filing # 176539080 E-Filed 06/30/2023 12:45:51 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2023 CA 001154 AN ANTHONY WILMER SANCHEZ ROMAN, Plaintiff, vs. JUSTINA RODRIGUEZ, Defendant. / PLAINTIFF’S NOTICE OF SERVING INTERROGATORIES TO DEFENDANT, JUSTINA RODRIGUEZ Plaintiff, ANTHONY WILMER SANCHEZ ROMAN, by and through undersigned counsel and pursuant to Fla. R. Civ. P. 1.340, propounds upon Defendant, JUSTINA RODRIGUEZ the attached Interrogatories, to be answered, under oath, within forty-five (45) days from the date of service. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the Defendant, along with the Summons and Complaint. /s/ Ashley McMahan Ashley McMahan, Esquire Florida Bar No: 1003316 Morgan & Morgan, P.A. 2150 Goodlette-Frank Rd, Suite 750 Naples, FL 34102 Telephone: (239) 432-6664 Primary email: amcmahan@forthepeople.com Secondary email: Morganservice@forthepeople.com Attorneys for Plaintiff 13583242 ROGD001 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2023 CA 001154 AN ANTHONY WILMER SANCHEZ ROMAN, Plaintiff, vs. JUSTINA RODRIGUEZ, Defendant. / INTERROGATORIES TO DEFENDANT, JUSTINA RODRIGUEZ Plaintiff, ANTHONY WILMER SANCHEZ ROMAN, by and through the undersigned counsel propounds the attached Interrogatories, numbered one (1) through twenty-five (25) to Defendant, JUSTINA RODRIGUEZ to be answered, under oath, within forty-five (45) days from the date of service. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the Defendant, along with the Summons and Complaint. /s/ Ashley McMahan Ashley McMahan, Esquire Florida Bar No: 1003316 Morgan & Morgan, P.A. 2150 Goodlette-Frank Rd, Suite 750 Naples, FL 34102 Telephone: (239) 432-6664 Primary email: amcmahan@forthepeople.com Secondary email: Morganservice@forthepeople.com Attorneys for Plaintiff 13583242 ROGD001 INTERROGATORIES TO DEFENDANT JUSTINA RODRIGUEZ 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. IF ANSWERING FOR ANOTHER PERSON OR ENTITY, ANSWER WITH RESPECT TO THAT PERSON OR ENTITY, UNLESS OTHERWISE STATED. 1. 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? 2. 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, and your date of birth. 3. 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 1 year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction the specific crime and the date and place of conviction. 13583242 ROGD001 4. Describe any and all policies of insurance which you contend cover or may cover you for the allegations set for in plaintiff’s complaint, detailing as to such policies the name of the insurer, the number of the policy, the effective dates of the policy, the available limits of liability, and the name and address of the custodian of the policy. 5. Describe in detail how the incident described in the complaint happened, including all actions taken by you to prevent the incident. 6. 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. 7. State the facts upon which you rely for each affirmative defense in your answer. 8. Do you contend any person or entity other than you is, or may be, liable in whole or part for the claims asserted against you in this lawsuit? If so, state the full name and address of each such person or entity, the legal basis for your contention, the facts or evidence upon 13583242 ROGD001 which your contention is based, and whether or not you have notified each such person or entity of your contention. 9. 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 the charge, and, if so, what is the name and address of the person or entity who 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 is the name and address of the person who recorded the testimony? 10. List the names and addresses of all persons who are 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. 11. 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. 13583242 ROGD001 12. 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 is was taken or prepared. 13. 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. 14. 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. 15. 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. 13583242 ROGD001 16. 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? 17. 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? 18. Did you consume any alcoholic beverages or take any drugs or medications within 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. 19. 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 incident? If so, describe the nature of the defect and how it contributed to the incident. 20. List the name and address of all persons, corporations, or entities who were registered title owners or who had ownership interest in, or right to control, the motor vehicle that the defendant driver was driving at the time of the incident described in the complaint; and describe both the nature of the ownership interest or right to control the vehicle, and the vehicle itself, including the make, model, year, and vehicle identification number. 13583242 ROGD001 21. At the time of the incident described in the complaint, did the driver of the vehicle described in your answer to the preceding interrogatory have permission to drive the vehicle? If so, state the names and addresses of all persons who have such permission. 22. At the time of the incident described in the complaint, were you engaged in any mission or activity for any other person or entity, including any employer? If so, state the name address of that person or entity and the nature of the mission or activity. 23. Was the motor vehicle that you were driving at the time of the incident described in the complaint damaged in the incident, and, if so, what was the cost to repair the damage. 24. Do you have a cellular phone? If so, please provide the number of your phone at the time of the accident, the name of your cell phone carrier, and the name under which the account is listed. 25. Describe in complete detail the appearance of the Plaintiff immediately after the Plaintiff’s alleged occurrence, including any obvious injuries, the emotional state of the Plaintiff, whether the Plaintiff appeared in pain or otherwise. 13583242 ROGD001 STATE OF COUNTY OF Before me the undersigned officer, authorized to administer oaths and take acknowledgments, personally appeared JUSTINA RODRIGUEZ, 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. JUSTINA RODRIGUEZ SWORN TO AND SUBSCRIBED before me this day of , . Notary Public (signature) Notary Public (type, print stamp commission) My Commission Expires: ❑ Personally Known OR ❑ Produced Identification ❑ Type of Identification Produced: 13583242 ROGD001