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Filing # 165437808 E-Filed 01/25/2023 01:12:02 PM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT IN AND FOR
DUVAL COUNTY, FLORIDA
Case No.: 16-2022-CA-007207
Division:
NANCY STRACHAN,
Plaintiff,
v.
GEICO CASUALTY COMPANY, a
Foreign Profit Corporation, and
ALLSTATE PROPERTY AND
CASUALTY INSURANCE COMPANY, a
Foreign Profit Corporation,
Defendants.
____________________________/
DEFENDANT’S NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF,
NANCY STRACHAN
To: Nancy Strachan
c/o Said Farhat, Esq.
Morgan & Morgan
501 Riverside Avenue, Suite 1200,
Jacksonville, Florida 32202
The Defendant, Government Employees Insurance Company, by and through the undersigned
attorney, propounds the attached Interrogatories numbered 1 through 29 to be answered under oath in
writing, within thirty (30) days from the receipt hereof in accordance with the applicable Rules of
Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Electronic Mail on this, the 25th day of January, 2023 to the following designated service email
address(es): Said Farhat, Esq., Morgan & Morgan, sfarhat@forthepeople.com.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/26/2023 11:43:19 AM
Law Office of Aurora D. Brown
Daniel Lake, Esq.
(Employees of GEICO General Insurance)
Florida Bar No.: 381240
200 West Forsyth Street, Suite 1020
Jacksonville, Florida 32202
Phone: 904-355-1921
Facsimile: 904-354-7041
Attorney for Defendant
Service Email: jaxgeico@geico.com
DEFINITIONS
A. Reference in these interrogatories to "you" or "your" is intended to include the Plaintiff,
and all corporations, firms and other entities owned or controlled by the Plaintiff, together with the
officers, directors, agents, employers and attorneys, and other representatives of such entities now,
or any time in the past.
B. As used herein, "document" shall mean: Every writing or record of every type and
description that is or has been in your possession, control or custody or of which you have
knowledge, including without limitation on the generality of the foregoing, correspondence,
memoranda, tapes, stenographic or hand-written notes, computer records, including e-mail, studies,
publications, books, pamphlets, pictures, films, voice records, maps, reports, surveys, minutes or
statistical complications; every copy of such writing or record, where the original is not in your
possession, custody or control; and every copy of any original or where such copy contains any
commentary or notation whatsoever that does appear in the original.
C. As used herein, "date" shall mean: the exact day, month, and year if ascertainable, or if
not, the best approximation (including relationship in time to other events).
D. As used herein, "identify" when used in reference to:
(1) An individual, shall mean to state his full name, present or last known address
(designating which) and present or last known employment, position or business affiliation
(designating which) including job title and employment address.
(2) A firm, partnership, corporation, proprietorship, association or other organization or
entity, shall mean to state its full name and present or last known address (designating which),
the legal form of such entity or organization and the residence address, job title and business
address for the chief executive officer.
(3) Data, shall mean to state: In the case of a document, the title (if any), date, author, sender
recipient, type of document (i.e. letter, memorandum, book, telegram, chart, etc.), or some
other means of identifying it, a summary of its contents and its present location or custodian;
in the case of an oral communication, the date, the communicator, communicatee, and a
sufficient summary of the contents of such oral communication to indicate its nature and
substance.
The identification of documents covered by these Interrogatories is not required for any such
documents which you are willing to produce voluntarily for inspection and copying by the
undersigned attorney with the time period specified for your answers or such other time as may be
mutually agreed upon.
INTERROGATORIES TO PLAINTIFF
1. What is the name, address, telephone number, date of birth, driver's license number and social
security number 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 the names, business addresses, dates of employment and rates of pay regarding all
employers, including self-employment, for whom you have worked in the past ten years.
3. List all former names and when you were known by those names. State all addresses where
you have lived for the past ten years, the dates you lived at each address, and if you are or
have ever been married, the name of your spouse or spouses.
4. Do you wear glasses, contact lenses or hearing aids? If so, state who prescribed them; when
they were prescribed; when your eyes or ears were last examined; and the name and address
of the examiner?
5. Have you ever been convicted of a crime, other than any juvenile adjudication, which was a
felony or was punishable by death or imprisonment in excess of one year, or a crime that
involved dishonesty or a false statement regardless of the punishment? If so, state as to each
conviction the specific crime, the date and the place of conviction.
6. Have you applied at any time for short or long term disability benefits including Social
Security Disability benefits? If so, please state the name of any company or governmental
agency to whom you have applied for disability benefits; when you first applied for disability
benefits and the nature of all disabilities that you claimed in your application.
7. Did you consume any alcoholic beverages or take any drugs or medication within twelve
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.
8. Describe in detail how the incident described in the Complaint happened, including all actions
taken by you to prevent the incident.
9. 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.
10. At the time of the accident that is the subject of your Complaint, were you prescribed
prescription medication for any disease or illness? If so, and for each such prescription, state
the name of the physician prescribing the medication, the name of the medication and the
disease or illness for which the medication was prescribed.
11. 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.
12. List each medical bill or other item of expense or damage, other than loss of income or earning
capacity, that you claim to have incurred as a result of the incident described in the Complaint,
giving for each item the date incurred, the name and business address to whom each was paid
or is owed, and the goods or services for which each was incurred. Include all medical bills
and any other damages.
13. Do you contend that you have lost any income, benefits, or earning capacity in the past or
future as a result of the incident described in the Complaint? If so, state the nature of the
income, benefits, or earning capacity, and the amount and the method that you used in
computing the amount.
14. Has anything been paid or is anything payable from any third party (including any PIP or Med
Pay insurer) for the damages listed in your answers to these interrogatories? If so, state the
amounts paid or payable, the name and business address of the person or entity who paid or
owes said amounts, and which of those third parties have or claim a right of subrogation.
15. List the names and business addresses of each physician, clinic or medical facility where you
have received any treatment or examination for the injuries for which you seek damages in
this case. State, as to each physician, clinic or medical facility, the date of treatment or
examination and the injury or condition for which you were examined or treated.
16. List the names and business addresses of all other physicians, medical facilities or other health
care providers where you have been examined or treated in the past ten years, and state as to
each the dates of examination or treatment and the condition or injury for which you were
examined or treated.
17. 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 in this lawsuit; and specify
the subject matter about which the witness has knowledge.
18. Have you heard or do you know about any statement or remark relating to the accident made
by anyone at the scene of the accident including the drivers of the vehicles involved in the
accident and the passengers in the vehicles and any witnesses to the accident? If so, state the
name and address of each person who made the statement or remark, the name and address of
each person who heard it, and the date, time, place and substance of each statement.
19. State the name and address of every person known to you, your agents, or attorneys, to have
knowledge about, or possession, custody or control of any photographs or video pertaining to
any fact or issue involved in this controversy including any photographs or video taken at the
scene of the accident and any vehicle photographs. As to each such person describe what
such person has, the name and address of the person who took or prepared it, and the date it
was taken or prepared.
20. With regard to any recommendation for surgery you have received, state: the name and
address of the surgeon who made the recommendation; the surgery recommended including
the part of the body; whether surgery is scheduled; and whether you presently intend to have
the surgery.
21. 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.
22. At the time of the incident described in the Complaint, were you wearing a seat belt? If not,
please state why not; where you were seated in the vehicle; and whether the vehicle was
equipped with a seat belt that was operational and available for your use.
23. Please list by name and address every entity, including without limitation medical providers,
to whom you or your attorney has issued a letter of protection or lien in connection with this
action.
24. Have you belonged to or been a member of health clubs, gyms, athletic or fitness clubs or
organizations within the past five (5) years? If so, state the name and address of each such
facility and your dates of memberships.
25. Please state the name and address of any health care provider from whom you have sought
treatment for any psychological, psychiatric or emotional illness.
26. If the alleged injury or injuries sustained in the accident prevent you or make it more difficult
for you to perform your work or occupation or in any way inhibit you or interfere with your
daily activities (including recreational activities), please state specifically in what manner you
are affected.
27. Please state what diagnostic studies including MRIs, CT scans and x-rays, that you or your
attorney possess and list the date of the study, the type of study, the part of the body involved
and the name and address of the facility the film was taken.
28. Have you ever suffered any injuries in any accident, including but is not limited to, motor
vehicle accidents (whether you were a driver, passenger or a pedestrian), slip and falls, or on
the job injuries) either prior to or subsequent to the accident referred to in the complaint? If
so, for each such accident state: the date and place of such injury; a detailed description of all
the injuries you received; the names and addresses of all health care providers and hospitals
rendering treatment to you as a result of your injuries; and whether you made any claim for
bodily injury including workers compensation claims and the name and address of each
attorney retained to represent you for such claims.
29. As to each body part you claim to have injured as a result of the subject accident, please state
whether, prior to the subject accident, you ever treated with any medical provider concerning
such body parts? If so, please identify the name and address of any such medical providers
with whom you treated, the approximate dates of treatment and the specific reason for the
treatment.
VERIFICATION OF ANSWERS TO INTERROGATORIES
__________________________________________
(Signature)
STATE OF FLORIDA )
)
COUNTY OF ___________________ )
The foregoing instrument was sworn to (or affirmed) and subscribed before me, by means
of ☐ physical presence or ☐ online notarization, this ____ day of _______, 2023, by
______________________________. Before me, the undersigned authority, personally appeared
_______________________________, who after being duly sworn, deposes and says that he/she is
the person named in the foregoing Answers to Interrogatories, that he/she has read the same, knows
the contents thereof and the same are true as stated, who is personally known to me or who has
produced ____________________________ as identification.
___________________________ ____________________________________
DATE NOTARY PUBLIC
(SEAL)
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Filing # 165437808 E-Filed 01/25/2023 01:12:02 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA Case No.: 16-2022-CA-007207 Division: NANCY STRACHAN, Plaintiff, v. GEICO CASUALTY COMPANY, a Foreign Profit Corporation, and ALLSTATE PROPERTY AND CASUALTY INSURANCE COMPANY, a Foreign Profit Corporation, Defendants. ____________________________/ DEFENDANT’S NOTICE OF SERVING INTERROGATORIES TO PLAINTIFF, NANCY STRACHAN To: Nancy Strachan c/o Said Farhat, Esq. Morgan & Morgan 501 Riverside Avenue, Suite 1200, Jacksonville, Florida 32202 The Defendant, Government Employees Insurance Company, by and through the undersigned attorney, propounds the attached Interrogatories numbered 1 through 29 to be answered under oath in writing, within thirty (30) days from the receipt hereof in accordance with the applicable Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic Mail on this, the 25th day of January, 2023 to the following designated service email address(es): Said Farhat, Esq., Morgan & Morgan, sfarhat@forthepeople.com. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/26/2023 11:43:19 AM Law Office of Aurora D. Brown Daniel Lake, Esq. (Employees of GEICO General Insurance) Florida Bar No.: 381240 200 West Forsyth Street, Suite 1020 Jacksonville, Florida 32202 Phone: 904-355-1921 Facsimile: 904-354-7041 Attorney for Defendant Service Email: jaxgeico@geico.com DEFINITIONS A. Reference in these interrogatories to "you" or "your" is intended to include the Plaintiff, and all corporations, firms and other entities owned or controlled by the Plaintiff, together with the officers, directors, agents, employers and attorneys, and other representatives of such entities now, or any time in the past. B. As used herein, "document" shall mean: Every writing or record of every type and description that is or has been in your possession, control or custody or of which you have knowledge, including without limitation on the generality of the foregoing, correspondence, memoranda, tapes, stenographic or hand-written notes, computer records, including e-mail, studies, publications, books, pamphlets, pictures, films, voice records, maps, reports, surveys, minutes or statistical complications; every copy of such writing or record, where the original is not in your possession, custody or control; and every copy of any original or where such copy contains any commentary or notation whatsoever that does appear in the original. C. As used herein, "date" shall mean: the exact day, month, and year if ascertainable, or if not, the best approximation (including relationship in time to other events). D. As used herein, "identify" when used in reference to: (1) An individual, shall mean to state his full name, present or last known address (designating which) and present or last known employment, position or business affiliation (designating which) including job title and employment address. (2) A firm, partnership, corporation, proprietorship, association or other organization or entity, shall mean to state its full name and present or last known address (designating which), the legal form of such entity or organization and the residence address, job title and business address for the chief executive officer. (3) Data, shall mean to state: In the case of a document, the title (if any), date, author, sender recipient, type of document (i.e. letter, memorandum, book, telegram, chart, etc.), or some other means of identifying it, a summary of its contents and its present location or custodian; in the case of an oral communication, the date, the communicator, communicatee, and a sufficient summary of the contents of such oral communication to indicate its nature and substance. The identification of documents covered by these Interrogatories is not required for any such documents which you are willing to produce voluntarily for inspection and copying by the undersigned attorney with the time period specified for your answers or such other time as may be mutually agreed upon. INTERROGATORIES TO PLAINTIFF 1. What is the name, address, telephone number, date of birth, driver's license number and social security number 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 the names, business addresses, dates of employment and rates of pay regarding all employers, including self-employment, for whom you have worked in the past ten years. 3. List all former names and when you were known by those names. State all addresses where you have lived for the past ten years, the dates you lived at each address, and if you are or have ever been married, the name of your spouse or spouses. 4. Do you wear glasses, contact lenses or hearing aids? If so, state who prescribed them; when they were prescribed; when your eyes or ears were last examined; and the name and address of the examiner? 5. Have you ever been convicted of a crime, other than any juvenile adjudication, which was a felony or was punishable by death or imprisonment in excess of one year, or a crime that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction the specific crime, the date and the place of conviction. 6. Have you applied at any time for short or long term disability benefits including Social Security Disability benefits? If so, please state the name of any company or governmental agency to whom you have applied for disability benefits; when you first applied for disability benefits and the nature of all disabilities that you claimed in your application. 7. Did you consume any alcoholic beverages or take any drugs or medication within twelve 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. 8. Describe in detail how the incident described in the Complaint happened, including all actions taken by you to prevent the incident. 9. 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. 10. At the time of the accident that is the subject of your Complaint, were you prescribed prescription medication for any disease or illness? If so, and for each such prescription, state the name of the physician prescribing the medication, the name of the medication and the disease or illness for which the medication was prescribed. 11. 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. 12. List each medical bill or other item of expense or damage, other than loss of income or earning capacity, that you claim to have incurred as a result of the incident described in the Complaint, giving for each item the date incurred, the name and business address to whom each was paid or is owed, and the goods or services for which each was incurred. Include all medical bills and any other damages. 13. Do you contend that you have lost any income, benefits, or earning capacity in the past or future as a result of the incident described in the Complaint? If so, state the nature of the income, benefits, or earning capacity, and the amount and the method that you used in computing the amount. 14. Has anything been paid or is anything payable from any third party (including any PIP or Med Pay insurer) for the damages listed in your answers to these interrogatories? If so, state the amounts paid or payable, the name and business address of the person or entity who paid or owes said amounts, and which of those third parties have or claim a right of subrogation. 15. List the names and business addresses of each physician, clinic or medical facility where you have received any treatment or examination for the injuries for which you seek damages in this case. State, as to each physician, clinic or medical facility, the date of treatment or examination and the injury or condition for which you were examined or treated. 16. List the names and business addresses of all other physicians, medical facilities or other health care providers where you have been examined or treated in the past ten years, and state as to each the dates of examination or treatment and the condition or injury for which you were examined or treated. 17. 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 in this lawsuit; and specify the subject matter about which the witness has knowledge. 18. Have you heard or do you know about any statement or remark relating to the accident made by anyone at the scene of the accident including the drivers of the vehicles involved in the accident and the passengers in the vehicles and any witnesses to the accident? If so, state the name and address of each person who made the statement or remark, the name and address of each person who heard it, and the date, time, place and substance of each statement. 19. State the name and address of every person known to you, your agents, or attorneys, to have knowledge about, or possession, custody or control of any photographs or video pertaining to any fact or issue involved in this controversy including any photographs or video taken at the scene of the accident and any vehicle photographs. As to each such person describe what such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. 20. With regard to any recommendation for surgery you have received, state: the name and address of the surgeon who made the recommendation; the surgery recommended including the part of the body; whether surgery is scheduled; and whether you presently intend to have the surgery. 21. 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. 22. At the time of the incident described in the Complaint, were you wearing a seat belt? If not, please state why not; where you were seated in the vehicle; and whether the vehicle was equipped with a seat belt that was operational and available for your use. 23. Please list by name and address every entity, including without limitation medical providers, to whom you or your attorney has issued a letter of protection or lien in connection with this action. 24. Have you belonged to or been a member of health clubs, gyms, athletic or fitness clubs or organizations within the past five (5) years? If so, state the name and address of each such facility and your dates of memberships. 25. Please state the name and address of any health care provider from whom you have sought treatment for any psychological, psychiatric or emotional illness. 26. If the alleged injury or injuries sustained in the accident prevent you or make it more difficult for you to perform your work or occupation or in any way inhibit you or interfere with your daily activities (including recreational activities), please state specifically in what manner you are affected. 27. Please state what diagnostic studies including MRIs, CT scans and x-rays, that you or your attorney possess and list the date of the study, the type of study, the part of the body involved and the name and address of the facility the film was taken. 28. Have you ever suffered any injuries in any accident, including but is not limited to, motor vehicle accidents (whether you were a driver, passenger or a pedestrian), slip and falls, or on the job injuries) either prior to or subsequent to the accident referred to in the complaint? If so, for each such accident state: the date and place of such injury; a detailed description of all the injuries you received; the names and addresses of all health care providers and hospitals rendering treatment to you as a result of your injuries; and whether you made any claim for bodily injury including workers compensation claims and the name and address of each attorney retained to represent you for such claims. 29. As to each body part you claim to have injured as a result of the subject accident, please state whether, prior to the subject accident, you ever treated with any medical provider concerning such body parts? If so, please identify the name and address of any such medical providers with whom you treated, the approximate dates of treatment and the specific reason for the treatment. VERIFICATION OF ANSWERS TO INTERROGATORIES __________________________________________ (Signature) STATE OF FLORIDA ) ) COUNTY OF ___________________ ) The foregoing instrument was sworn to (or affirmed) and subscribed before me, by means of ☐ physical presence or ☐ online notarization, this ____ day of _______, 2023, by ______________________________. Before me, the undersigned authority, personally appeared _______________________________, who after being duly sworn, deposes and says that he/she is the person named in the foregoing Answers to Interrogatories, that he/she has read the same, knows the contents thereof and the same are true as stated, who is personally known to me or who has produced ____________________________ as identification. ___________________________ ____________________________________ DATE NOTARY PUBLIC (SEAL)