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Filing # 162696127 E-Filed 12/08/2022 06:23:57 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2020 CA 001330
MARIABELEN PAREJA,
Plaintiff,
vs.
SOHAN S. SAINI AND DANA CARRIERS,
LLC,
Defendants.
/
PLAINTIFF’S NOTICE OF SERVING BOECHER INTERROGATORIES
Plaintiff, Mariabelen Pareja, and through the undersigned counsel, pursuant to Rule 1.340
of the Florida Rules of Civil Procedure, hereby propound the attached Boecher Interrogatories
upon Defendants, Sohan S. Saini and Dana Carriers, LLC answers to which shall be due thirty
(30) days from the date of service.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on December 8, 2022, I electronically filed the foregoing with
the Clerk of Courts by using the using the Florida Courts eFiling Portal, which will send a copy
via email to: Daniel A. Shapiro, Esquire, Michelle M. Bartels, Esquire, and Aaryn F. Ledoux,
Cole, Scott & Kissane, P.A., 4301 West Boy Scout Boulevard, Suite 400, Tampa, FL 33607
[michelle.bartels@csklegal.com; aaryn.ledoux@csklegal.com; chelsea.santiago@csklegal.com].
s/ Hannah Dantzler-Fleming
________________________________________
Hannah Dantzler-Fleming, Esquire
FBN 1002953
Morgan & Morgan, P.A.
20 N. Orange Avenue
Suite 1600
Orlando, FL 32801
Telephone: (407) 420-3980
Facsimile: (407) 245-3369
Primary email: hfleming@forthepeople.com
Secondary email: karlag@forthepeople.com
swinkle@forthepeople.com
Attorneys for Plaintiff
Page 1 of 4
BOECHER INTERROGATORIES TO DEFENDANTS
1. Please identify each person answering or providing information used to answer these
interrogatories.
2. Please identify each person you expect to call as an expert witness at trial by name,
address, and profession.
3. Please state how much each expert witness has charged, has received in retainer, or will
charge, and the amount and method of compensation. Please state each rate if it
changes for different types of work.
4. Please provide the following information for each expert witness listed above and each
of the expert witnesses previously disclosed by the Defendant:
a. State the scope of each expert's employment in the pending case and the
compensation for such service;
b. Describe the expert witness' general litigation experience, including the
percentage of work performed for plaintiffs and for defendants; if work has
been performed for worker's compensation reviews requested by an insurer or
carrier, describe that amount separately and whether it is included as work
performed for plaintiffs or defendants:
c. Identify any other cases within the past three years in which each expert has
testified by deposition or at trial for the defendants or anyone acting on the
Defendants’ behalf, such as current attorneys, and as described above in
definitions, including the name of the case and case number, the names and
addresses of the attorneys involved, whether the testimony was transcribed, the
current location of copies of the transcription, and the name, address and
telephone number of the court reporter who took down the information;
d. Identify (by case name and court) all other claims or legal actions in which each
listed expert has been retained, rendered opinions, or testified for you or anyone
acting on your behalf in the past five years.
e. Provide an approximation of each expert's involvement as an expert witness or
medical examiner, based upon the number of hours, percentage of hours,
percentage of earned income derived from serving as an expert witness or from
performing independent or compulsory medical examinations and record
Page 2 of 4
reviews.
5. Please state the total amount of money that those representing the defense in this case
have paid to each expert witness identified in Interrogatories 2 & 3 above for each of
the last three (3) years, and identify by date, title, type of document and number of
pages any W-9 or 1099 forms, including, but not limited to, computer records,
accounting records, ledgers, disks, reports, writings, notes or other documents
containing such information. See, Springer v. West, 769 So. 2d 1068, 1070 (Fla 5th
DCA 2000)
6. Provide the name, address, telephone number and job title of all persons working for
you or anyone on your behalf who have knowledge about the records including manual
and automated accounting records regarding the employment history and/or total
payments made to each expert.
7. Describe each expert's qualifications to render expert testimony in this matter,
including his or her background, education, and experience and the title and
bibliographic information for each paper or presentation authored by the expert in the
area of his/her expertise, and the individual's places of employment for the past 10
years. [You may answer this question by producing a resume or curriculum vitae for
each expert.]
8. State the subject matter upon which each expert is expected to testify.
9. State the substance of the facts to which each expert is expected to testify.
10. State every opinion to which each expert is expected to testify and the substance of the
facts upon which each opinion is based.
11. Provide a summary of the grounds or basis for each opinion stated above.
12. For each expert listed above, please identify any written reports which you reasonably
expect to introduce at trial.
13. Have any of the expert witnesses listed in Interrogatory No. 2 or 3 ever had their
testimony limited, stricken, been sanctioned, or in any other manner been disqualified
in whole or in part from testifying before any court? If so, name each such expert and
identify each and every instance the expert has been disqualified; state the case name,
number, and court for each instance; completely describe the facts and circumstances
of each such disqualification; and explain why the testimony was limited, stricken,
sanctioned, or the expert was disqualified.
Page 3 of 4
SIGNATURE PAGE
I HAVE READ THE FOREGOING ANSWERS TO PLAINTIFFS’ SURVEILLANCE
INTERROGATORIES AND DO SWEAR THAT THEY ARE TRUE AND CORRECT TO THE
BEST OF MY KNOWLEDGE AND BELIEF.
______________________________
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 his/her knowledge and belief.
SWORN TO AND SUBSCRIBED before me this ______ day of _________________, 2022.
Notary Public (signature)
Notary Public (type, print stamp commission)
My Commission Expires:
Personally Known OR
Produced Identification
Type of Identification Produced:
Page 4 of 4
Preview
Filing # 162696127 E-Filed 12/08/2022 06:23:57 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2020 CA 001330 MARIABELEN PAREJA, Plaintiff, vs. SOHAN S. SAINI AND DANA CARRIERS, LLC, Defendants. / PLAINTIFF’S NOTICE OF SERVING BOECHER INTERROGATORIES Plaintiff, Mariabelen Pareja, and through the undersigned counsel, pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby propound the attached Boecher Interrogatories upon Defendants, Sohan S. Saini and Dana Carriers, LLC answers to which shall be due thirty (30) days from the date of service. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 8, 2022, I electronically filed the foregoing with the Clerk of Courts by using the using the Florida Courts eFiling Portal, which will send a copy via email to: Daniel A. Shapiro, Esquire, Michelle M. Bartels, Esquire, and Aaryn F. Ledoux, Cole, Scott & Kissane, P.A., 4301 West Boy Scout Boulevard, Suite 400, Tampa, FL 33607 [michelle.bartels@csklegal.com; aaryn.ledoux@csklegal.com; chelsea.santiago@csklegal.com]. s/ Hannah Dantzler-Fleming ________________________________________ Hannah Dantzler-Fleming, Esquire FBN 1002953 Morgan & Morgan, P.A. 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 Telephone: (407) 420-3980 Facsimile: (407) 245-3369 Primary email: hfleming@forthepeople.com Secondary email: karlag@forthepeople.com swinkle@forthepeople.com Attorneys for Plaintiff Page 1 of 4 BOECHER INTERROGATORIES TO DEFENDANTS 1. Please identify each person answering or providing information used to answer these interrogatories. 2. Please identify each person you expect to call as an expert witness at trial by name, address, and profession. 3. Please state how much each expert witness has charged, has received in retainer, or will charge, and the amount and method of compensation. Please state each rate if it changes for different types of work. 4. Please provide the following information for each expert witness listed above and each of the expert witnesses previously disclosed by the Defendant: a. State the scope of each expert's employment in the pending case and the compensation for such service; b. Describe the expert witness' general litigation experience, including the percentage of work performed for plaintiffs and for defendants; if work has been performed for worker's compensation reviews requested by an insurer or carrier, describe that amount separately and whether it is included as work performed for plaintiffs or defendants: c. Identify any other cases within the past three years in which each expert has testified by deposition or at trial for the defendants or anyone acting on the Defendants’ behalf, such as current attorneys, and as described above in definitions, including the name of the case and case number, the names and addresses of the attorneys involved, whether the testimony was transcribed, the current location of copies of the transcription, and the name, address and telephone number of the court reporter who took down the information; d. Identify (by case name and court) all other claims or legal actions in which each listed expert has been retained, rendered opinions, or testified for you or anyone acting on your behalf in the past five years. e. Provide an approximation of each expert's involvement as an expert witness or medical examiner, based upon the number of hours, percentage of hours, percentage of earned income derived from serving as an expert witness or from performing independent or compulsory medical examinations and record Page 2 of 4 reviews. 5. Please state the total amount of money that those representing the defense in this case have paid to each expert witness identified in Interrogatories 2 & 3 above for each of the last three (3) years, and identify by date, title, type of document and number of pages any W-9 or 1099 forms, including, but not limited to, computer records, accounting records, ledgers, disks, reports, writings, notes or other documents containing such information. See, Springer v. West, 769 So. 2d 1068, 1070 (Fla 5th DCA 2000) 6. Provide the name, address, telephone number and job title of all persons working for you or anyone on your behalf who have knowledge about the records including manual and automated accounting records regarding the employment history and/or total payments made to each expert. 7. Describe each expert's qualifications to render expert testimony in this matter, including his or her background, education, and experience and the title and bibliographic information for each paper or presentation authored by the expert in the area of his/her expertise, and the individual's places of employment for the past 10 years. [You may answer this question by producing a resume or curriculum vitae for each expert.] 8. State the subject matter upon which each expert is expected to testify. 9. State the substance of the facts to which each expert is expected to testify. 10. State every opinion to which each expert is expected to testify and the substance of the facts upon which each opinion is based. 11. Provide a summary of the grounds or basis for each opinion stated above. 12. For each expert listed above, please identify any written reports which you reasonably expect to introduce at trial. 13. Have any of the expert witnesses listed in Interrogatory No. 2 or 3 ever had their testimony limited, stricken, been sanctioned, or in any other manner been disqualified in whole or in part from testifying before any court? If so, name each such expert and identify each and every instance the expert has been disqualified; state the case name, number, and court for each instance; completely describe the facts and circumstances of each such disqualification; and explain why the testimony was limited, stricken, sanctioned, or the expert was disqualified. Page 3 of 4 SIGNATURE PAGE I HAVE READ THE FOREGOING ANSWERS TO PLAINTIFFS’ SURVEILLANCE INTERROGATORIES AND DO SWEAR THAT THEY ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE AND BELIEF. ______________________________ 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 his/her knowledge and belief. SWORN TO AND SUBSCRIBED before me this ______ day of _________________, 2022. Notary Public (signature) Notary Public (type, print stamp commission) My Commission Expires: Personally Known OR Produced Identification Type of Identification Produced: Page 4 of 4