Preview
Filing # 162692599 E-Filed 12/08/2022 05:14:55 PM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT, IN AND
FOR DUVAL COUNTY, FLORIDA
CASE NO. 16-2022-CA-006093
BRITTINIA VANE HUGHES, DIVISION: CV-A
Plaintiff,
V.
EAN HOLDINGS, LLC, a foreign
liability company, and
KATELAND WYATT,
Defendant.
/
DEFENDANT, KATELAND WYATT’S, NOTICE OF SERVING
FIRST SET OF INTERROGATORIES TO PLAINTIFF
Defendant, KATELAND WYATT, by and through his undersigned attorneys,
pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby propounds the
attached Interrogatories to Plaintiff to be answered in writing, under oath, or objected to
within the time provided by the applicable Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 8th day of December, 2022, a true and correct
copy of the foregoing was filed with the Clerk of Court using the Florida Courts e-Filing
Portal, which will send an automatic e-mail message to counsel and parties of record.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant Kateland Wyatt
4190 Belfort Road #300
Jacksonville, FL 32216
Telephone (904) 672-4100
Facsimile (904) 672-4050
Patrick.Snyder@csklegal.com
Alexandra.Dabek@csklegal.com
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/08/2022 10:19:02 PM
CASE NO. 16-2022-CA-006093
Justine.Shields@csklegal.com
Melody.Drew@csklegal.com
By: _/s/ Alexandra A. Dabek
Patrick J. Snyder, Esq.
Florida Bar No. 669962
Alexandra A. Dabek, Esq.
Florida Bar No. 1025105
Page 2
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT, IN AND
FOR DUVAL COUNTY, FLORIDA
CASE NO. 16-2022-CA-006093
BRITTINIA VANE HUGHES, DIVISION: CV-A
Plaintiff,
Vv.
EAN HOLDINGS, LLC, a foreign
liability company, and
KATELAND WYATT,
Defendant.
/
A. INSTRUCTIONS AND DEFINITIONS
1 In answering these Interrogatories, you are instructed to provide not only
such information as is in your possession, but also all information as is reasonably
available, whether or not it is in your possession. In the event you are able to provide
only part of the information called for by any particular Interrogatory, provide all of the
information you are able to provide, and state the reason for your inability to state the
remainder.
2. If you object to, or otherwise decline to answer any portion of any
Interrogatory, please provide all information called for in that portion of the
Interrogatory to which you do not object, or to which you do not decline to answer. If
you object to any Interrogatory on the ground that it is overly broad, please provide
such information as you concede to be relevant and within the scope of permitted
discovery. If you object to an Interrogatory on the ground that it would constitute an
undue burden to provide an answer, please provide such requested information as
can be supplied without undertaking such undue burden and state your reasons why
the Interrogatory is otherwise burdensome. For those portions of any Interrogatory to
which you object or otherwise decline to answer, state the reason for such objection
or declination.
3. “You” and “your” refer to the party to whom these Interrogatories are
directed, each and every name by which the party is known or has been known and
each and every officer, director, employee, attorney, and other agent for such party.
4 “Document” shall include all records, books of account, journals, ledgers,
statements, receipts, contracts, correspondence, worksheets, checks, instructions,
Page 3
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
specifications, manuals, reports, books, periodicals, publications, raw and refined
data, memoranda, drafts, drawings, notes, advertisements, lists, studies, meeting
minutes, working papers, transcripts, magnetic tapes or discs, punch cards, computer
printouts, letters, telegrams, drafts, proposals, recommendations, and any other data
recorded in readable and/or retrievable form, or capable of being transmitted, whether
typed, handwritten, reproduced, magnetically recorded, coded, computer generated
or stored in any other way readable or retrievable.
5. “And” and “or” shall be construed conjunctively and disjunctively in each
Interrogatory in order to request the broadest scope of information possible.
INTERROGATORIES PROPOUNDED TO PLAINTIFF
1.Please state the name and address of any person or persons who contributed to
answering these interrogatories.
2.What is your name, address, telephone number, social security number, driver
license number and date of birth?
3.Describe in detail, each act or omission on the part of EACH Defendant you
contend constituted negligence that was a contributing legal cause of the accident in
question.
Page 4
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
4.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 raised by
the pleadings and specify the subject matter about which the witness has knowledge.
5.List the name, residence address, business address and telephone number of
each person believed or known by you, your agents, or attorneys to have heard or who
is purported to have heard any persons make any statement, remark or comment
concerning the accident described in the complaint and the substance of each statement,
remark or comment.
6. Were you suffering from any physical infirmity, disability, or sickness at the time
of the occurrence of the accident described in the Complaint? If so, what was the nature
of the infirmity, disability or sickness?
7.Did you consume any alcoholic beverages or take any drugs or medications
within twelve (12) hours before the occurrence of the accident described in the
Page 5
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
Complaint? If so, what type and amount of alcoholic beverages, drugs or medication were
consumed and where did you consume them?
8.Have you ever been convicted of a crime? If so, please provide a description of
the conviction, the date and place of the conviction and the outcome/punishment of the
conviction?
9.Do you wear glasses or contact lenses? If so, who prescribed them, when were
they prescribed, when were your eyes last examined and by whom?
10.Do you wear a hearing aid? If so, who last examined your ears?
11.Describe in detail how the accident happened, including all actions taken by
you to prevent the accident.
Page 6
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
12.List each item of expense that you claim to have incurred as a result of the
injuries sued on in this action, giving for each item the date incurred, to whom owed or
paid and the goods or services for which each was incurred.
13.Do you contend that you have lost any form of compensation as a result of the
injuries sued on in this action? If so, what was the amount lost, the period during which
it was lost, the nature of the compensation and the method that you used in computing
the amount.
14.Have any benefits been paid or are any payable for the expenses listed in your
answers to Interrogatories 12 and 13? If so, which expenses are covered by insurance,
what type of insurance, and who paid the premium for the insurance?
15.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.
Page 7
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
16.List each physician who has treated you and each medical facility where you
have received any treatment for the injuries which you seek damages in this case, giving
the dates that the treatment was received and stating which of the injuries described in
your answer to Interrogatory No. 15 the treatment was rendered for.
17.Do you intend to call any non-medical expert witnesses at the trial of this case?
If so, identify each witness; describe his qualifications as an expert; state the subject
matter upon which he is expected to testify; state the substance of the facts and opinions
to which he is expected to testify; and give a summary of the grounds for each opinion.
18.List the names, business addresses and business telephone numbers of all
medical doctors by whom you have been treated in the seven (7) years prior to the
accident described in the Complaint, and all hospitals at which you have been examined
and/or treated in the seven (7) years prior to the accident described in the Complaint.
Page 8
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
19.List the names, addresses, telephone numbers and rate of pay for all employers
for whom you have worked in the seven (7) years prior to the accident described in the
Complaint.
20.Describe any and all accidents, illnesses and/or personal injuries you have
suffered SINCE the happening of the event in question, including in your answer the date,
place, time and nature of the incidents, the names and addresses of all parties involved
in the incident, the injuries sustained by you in this incident as well as the names and
addresses of any of the treating and consulting physicians and hospitals or places of
confinement in which you were a patient in connection with such injury.
21.Describe any and all accidents, illnesses and/or personal injuries which you
have suffered BEFORE the happening of the incident in this suit, including in your answer
the date, time, place and nature of the incident, the names and addresses of all parties
involved in the incident, all injuries sustained by you in the incidents, as well as the names
Page 9
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
and addresses of any treating and consulting physicians and the names and addresses
of the hospitals or places of confinement in which you were a patient in connection with
such injuries.
22.State whether or not you have had in effect any health and accident or disability
insurance, or medical or hospitalization insurance in the seven (7) years prior to the
accident described in the Complaint. If so, please state the type of policy, the name of
the insurance carrier, the address, and the dates of coverage.
23.Identify in detail any payments that have been made to you or on your behalf,
including payments made by public programs providing medical expenses and disability
payments, as well as any payments that have been made to you or on your behalf by or
pursuant to any contract or agreement of any group, organization, partnership or
corporation which provides for or pays for the reimbursement of hospital, medical and
dental costs.
24.State the name, residence and business address, residence and business
telephone numbers of all persons for whom you, your attorneys or investigators, either
for your attorneys or your insurance company, have obtained statements. For each
Page 10
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
statement obtained, please state the substance of such statement, whether such
statement was written or oral, and the name and address of the person who took the
statement.
25.Have you during the past five (5) years up to the present date filed a Petition
for Relief Under the Bankruptcy Laws of the United States?
26.Please describe Plaintiff's whereabouts for the twenty-four (24) hours prior to
the subject accident. In your answer, please describe where Plaintiff was, what times he
was at a particular location and whether he was with anyone (give name and contact
information) at each location.
27.Please indicate where Plaintiff was travelling from and where Plaintiff was
travelling to at the time the accident occurred.
Page 11
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
CASE NO. 16-2022-CA-006093
AFFIDAVIT
BRITTINIA HUGHES
STATE OF FLORIDA
)ss
COUNTY OF
BEFORE ME, the undersigned authority, this day of , 2022,
personally appeared , who, after being duly sworn, deposes and
says that the Answers to the Interrogatories hereto propounded are true and correct to
the best of his knowledge and belief.
NOTARY PUBLIC, State of Florida at Large
My commission expires:
Page 12
COLE, SCOTT & KISSANE, P.A.
4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX
Preview
Filing # 162692599 E-Filed 12/08/2022 05:14:55 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO. 16-2022-CA-006093 BRITTINIA VANE HUGHES, DIVISION: CV-A Plaintiff, V. EAN HOLDINGS, LLC, a foreign liability company, and KATELAND WYATT, Defendant. / DEFENDANT, KATELAND WYATT’S, NOTICE OF SERVING FIRST SET OF INTERROGATORIES TO PLAINTIFF Defendant, KATELAND WYATT, by and through his undersigned attorneys, pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby propounds the attached Interrogatories to Plaintiff to be answered in writing, under oath, or objected to within the time provided by the applicable Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 8th day of December, 2022, a true and correct copy of the foregoing was filed with the Clerk of Court using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to counsel and parties of record. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant Kateland Wyatt 4190 Belfort Road #300 Jacksonville, FL 32216 Telephone (904) 672-4100 Facsimile (904) 672-4050 Patrick.Snyder@csklegal.com Alexandra.Dabek@csklegal.com COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 12/08/2022 10:19:02 PM CASE NO. 16-2022-CA-006093 Justine.Shields@csklegal.com Melody.Drew@csklegal.com By: _/s/ Alexandra A. Dabek Patrick J. Snyder, Esq. Florida Bar No. 669962 Alexandra A. Dabek, Esq. Florida Bar No. 1025105 Page 2 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO. 16-2022-CA-006093 BRITTINIA VANE HUGHES, DIVISION: CV-A Plaintiff, Vv. EAN HOLDINGS, LLC, a foreign liability company, and KATELAND WYATT, Defendant. / A. INSTRUCTIONS AND DEFINITIONS 1 In answering these Interrogatories, you are instructed to provide not only such information as is in your possession, but also all information as is reasonably available, whether or not it is in your possession. In the event you are able to provide only part of the information called for by any particular Interrogatory, provide all of the information you are able to provide, and state the reason for your inability to state the remainder. 2. If you object to, or otherwise decline to answer any portion of any Interrogatory, please provide all information called for in that portion of the Interrogatory to which you do not object, or to which you do not decline to answer. If you object to any Interrogatory on the ground that it is overly broad, please provide such information as you concede to be relevant and within the scope of permitted discovery. If you object to an Interrogatory on the ground that it would constitute an undue burden to provide an answer, please provide such requested information as can be supplied without undertaking such undue burden and state your reasons why the Interrogatory is otherwise burdensome. For those portions of any Interrogatory to which you object or otherwise decline to answer, state the reason for such objection or declination. 3. “You” and “your” refer to the party to whom these Interrogatories are directed, each and every name by which the party is known or has been known and each and every officer, director, employee, attorney, and other agent for such party. 4 “Document” shall include all records, books of account, journals, ledgers, statements, receipts, contracts, correspondence, worksheets, checks, instructions, Page 3 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 specifications, manuals, reports, books, periodicals, publications, raw and refined data, memoranda, drafts, drawings, notes, advertisements, lists, studies, meeting minutes, working papers, transcripts, magnetic tapes or discs, punch cards, computer printouts, letters, telegrams, drafts, proposals, recommendations, and any other data recorded in readable and/or retrievable form, or capable of being transmitted, whether typed, handwritten, reproduced, magnetically recorded, coded, computer generated or stored in any other way readable or retrievable. 5. “And” and “or” shall be construed conjunctively and disjunctively in each Interrogatory in order to request the broadest scope of information possible. INTERROGATORIES PROPOUNDED TO PLAINTIFF 1.Please state the name and address of any person or persons who contributed to answering these interrogatories. 2.What is your name, address, telephone number, social security number, driver license number and date of birth? 3.Describe in detail, each act or omission on the part of EACH Defendant you contend constituted negligence that was a contributing legal cause of the accident in question. Page 4 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 4.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 raised by the pleadings and specify the subject matter about which the witness has knowledge. 5.List the name, residence address, business address and telephone number of each person believed or known by you, your agents, or attorneys to have heard or who is purported to have heard any persons make any statement, remark or comment concerning the accident described in the complaint and the substance of each statement, remark or comment. 6. Were you suffering from any physical infirmity, disability, or sickness at the time of the occurrence of the accident described in the Complaint? If so, what was the nature of the infirmity, disability or sickness? 7.Did you consume any alcoholic beverages or take any drugs or medications within twelve (12) hours before the occurrence of the accident described in the Page 5 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 Complaint? If so, what type and amount of alcoholic beverages, drugs or medication were consumed and where did you consume them? 8.Have you ever been convicted of a crime? If so, please provide a description of the conviction, the date and place of the conviction and the outcome/punishment of the conviction? 9.Do you wear glasses or contact lenses? If so, who prescribed them, when were they prescribed, when were your eyes last examined and by whom? 10.Do you wear a hearing aid? If so, who last examined your ears? 11.Describe in detail how the accident happened, including all actions taken by you to prevent the accident. Page 6 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 12.List each item of expense that you claim to have incurred as a result of the injuries sued on in this action, giving for each item the date incurred, to whom owed or paid and the goods or services for which each was incurred. 13.Do you contend that you have lost any form of compensation as a result of the injuries sued on in this action? If so, what was the amount lost, the period during which it was lost, the nature of the compensation and the method that you used in computing the amount. 14.Have any benefits been paid or are any payable for the expenses listed in your answers to Interrogatories 12 and 13? If so, which expenses are covered by insurance, what type of insurance, and who paid the premium for the insurance? 15.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. Page 7 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 16.List each physician who has treated you and each medical facility where you have received any treatment for the injuries which you seek damages in this case, giving the dates that the treatment was received and stating which of the injuries described in your answer to Interrogatory No. 15 the treatment was rendered for. 17.Do you intend to call any non-medical expert witnesses at the trial of this case? If so, identify each witness; describe his qualifications as an expert; state the subject matter upon which he is expected to testify; state the substance of the facts and opinions to which he is expected to testify; and give a summary of the grounds for each opinion. 18.List the names, business addresses and business telephone numbers of all medical doctors by whom you have been treated in the seven (7) years prior to the accident described in the Complaint, and all hospitals at which you have been examined and/or treated in the seven (7) years prior to the accident described in the Complaint. Page 8 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 19.List the names, addresses, telephone numbers and rate of pay for all employers for whom you have worked in the seven (7) years prior to the accident described in the Complaint. 20.Describe any and all accidents, illnesses and/or personal injuries you have suffered SINCE the happening of the event in question, including in your answer the date, place, time and nature of the incidents, the names and addresses of all parties involved in the incident, the injuries sustained by you in this incident as well as the names and addresses of any of the treating and consulting physicians and hospitals or places of confinement in which you were a patient in connection with such injury. 21.Describe any and all accidents, illnesses and/or personal injuries which you have suffered BEFORE the happening of the incident in this suit, including in your answer the date, time, place and nature of the incident, the names and addresses of all parties involved in the incident, all injuries sustained by you in the incidents, as well as the names Page 9 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 and addresses of any treating and consulting physicians and the names and addresses of the hospitals or places of confinement in which you were a patient in connection with such injuries. 22.State whether or not you have had in effect any health and accident or disability insurance, or medical or hospitalization insurance in the seven (7) years prior to the accident described in the Complaint. If so, please state the type of policy, the name of the insurance carrier, the address, and the dates of coverage. 23.Identify in detail any payments that have been made to you or on your behalf, including payments made by public programs providing medical expenses and disability payments, as well as any payments that have been made to you or on your behalf by or pursuant to any contract or agreement of any group, organization, partnership or corporation which provides for or pays for the reimbursement of hospital, medical and dental costs. 24.State the name, residence and business address, residence and business telephone numbers of all persons for whom you, your attorneys or investigators, either for your attorneys or your insurance company, have obtained statements. For each Page 10 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 statement obtained, please state the substance of such statement, whether such statement was written or oral, and the name and address of the person who took the statement. 25.Have you during the past five (5) years up to the present date filed a Petition for Relief Under the Bankruptcy Laws of the United States? 26.Please describe Plaintiff's whereabouts for the twenty-four (24) hours prior to the subject accident. In your answer, please describe where Plaintiff was, what times he was at a particular location and whether he was with anyone (give name and contact information) at each location. 27.Please indicate where Plaintiff was travelling from and where Plaintiff was travelling to at the time the accident occurred. Page 11 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX CASE NO. 16-2022-CA-006093 AFFIDAVIT BRITTINIA HUGHES STATE OF FLORIDA )ss COUNTY OF BEFORE ME, the undersigned authority, this day of , 2022, personally appeared , who, after being duly sworn, deposes and says that the Answers to the Interrogatories hereto propounded are true and correct to the best of his knowledge and belief. NOTARY PUBLIC, State of Florida at Large My commission expires: Page 12 COLE, SCOTT & KISSANE, P.A. 4190 BELFORT ROAD #300, JACKSONVILLE, FLORIDA 32216 - (904) 672-4100 (904) 672-4050 FAX