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Filing # 46926897 E-Filed 09/26/2016 04:13:34 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K. SCHMITZ,
as Husband and Wife,
Plaintiffs,
v. CASE NO.: 16001754CA
ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO LI,
Defendants.
/
NOTICE OF SERVICE OF PLAINTIFF, WILLIAM H. SCHMITZ'S FIRST INTERROGATORIES
TO DEFENDANTS, JLL LOGISTIC INC and ROBERTO LI
Pursuant to Rule 1.340 and other applicable Rules of Civil Procedure, Defendants, JLL
LOGISTIC INC and ROBERTO LI, are required to answer the following interrogatories in writing
and under oath within thirty (30) days of service hereof.
Wherever an interrogatory herein employs the pronoun "you", and whenever a request
for information is made herein, such interrogatory is directed to and is to be answered on the
basis of information known to the party to whom the interrogatories are addressed, such party's
attorneys, agents and employees, and the party's insurance carrier and its agents and
employees.
When using these interrogatories, the following words or phrases have the following meaning:
4 Identify, when referring to a document, means to state:
The nature of the document, i.e., letter, memorandum, report, ete.
The full name, current address and current telephone number of the
author of the document;
The date the document was originated;
Each addressee of the document and each recipient thereof;
A detailed description of the substance of the document; and
The present location of the document and the full name, current address
and current telephone number of the person(s) having custody thereof.
2. Identify, when referring to a person, means to state:
A The full name of the person;
B The person's current address; and
c The person's current telephone number.
Identify, when referring to an organization, means to state:
The organization's full legal name;
The name(s) under which the organization does business;
The address of the organization's current principal place of business; and
If the organization is a corporation, the nation and state of incorporation
and the date of incorporation.
Document, used in the most broad and liberal sense, means written, typed, printed,
recorded or graphic material, however produced or reproduced, of any and every
kind and description.
ALEXMAR PIMIENTA GARRIDO refers to defendant, Alexmar Pimienta Garrido, his
agents, employees, officers, directors, attorneys or other designated representatives.
CRASH refers to the motor vehicle collision involving William H. Schmitz and
Defendant, Alexmar Pimienta Garrido, that occurred on or about November 24, 2015
on US 17 at or near the intersection of Regent Road, Punta Gorda, Charlotte County,
Florida.
TRACTOR the 1999 commercial motor vehicle
refers to bearing VIN
4VG7DARJ9XN769587 owned by JLL Logistic Inc and Roberto Li.
TRAILER refers to any trailer that was attached to the TRACTOR at the time of the
CRASH.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished by Electronic Mail to William Boltrek, Esquire, Henderson, Franklin, et al., Attorney for
Defendants, P.O. Box 280, Fort Myers, FL 33902-0280 at the designated email addresses of:
William.boltrek@henlaw.com; Brenda.sitar@henlaw.com on this day of September, 2016.
GOLDBERG, RACILA,
D'ALESSANDRO & NOONE, LLC
Attorneys for Plaintiff
Post Office Box 190
Fort Myers, Florida 33902-0190
(239) 461-5508
{239) 461-3915 (Facsimile)
Michael M.)Noone
Florida Bar No.: 0105139
Email: MikeNoone joldberg-law.com
ervice! Oo! idberg-law.com
Elizete D. Velado
Florida Bar No.: 0099668
Email: ElizeteVelado joldberg-law.com
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Filing # 46926897 E-Filed 09/26/2016 04:13:34 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and Wife, Plaintiffs, v. CASE NO.: 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / NOTICE OF SERVICE OF PLAINTIFF, WILLIAM H. SCHMITZ'S FIRST INTERROGATORIES TO DEFENDANTS, JLL LOGISTIC INC and ROBERTO LI Pursuant to Rule 1.340 and other applicable Rules of Civil Procedure, Defendants, JLL LOGISTIC INC and ROBERTO LI, are required to answer the following interrogatories in writing and under oath within thirty (30) days of service hereof. Wherever an interrogatory herein employs the pronoun "you", and whenever a request for information is made herein, such interrogatory is directed to and is to be answered on the basis of information known to the party to whom the interrogatories are addressed, such party's attorneys, agents and employees, and the party's insurance carrier and its agents and employees. When using these interrogatories, the following words or phrases have the following meaning: 4 Identify, when referring to a document, means to state: The nature of the document, i.e., letter, memorandum, report, ete. The full name, current address and current telephone number of the author of the document; The date the document was originated; Each addressee of the document and each recipient thereof; A detailed description of the substance of the document; and The present location of the document and the full name, current address and current telephone number of the person(s) having custody thereof. 2. Identify, when referring to a person, means to state: A The full name of the person; B The person's current address; and c The person's current telephone number. Identify, when referring to an organization, means to state: The organization's full legal name; The name(s) under which the organization does business; The address of the organization's current principal place of business; and If the organization is a corporation, the nation and state of incorporation and the date of incorporation. Document, used in the most broad and liberal sense, means written, typed, printed, recorded or graphic material, however produced or reproduced, of any and every kind and description. ALEXMAR PIMIENTA GARRIDO refers to defendant, Alexmar Pimienta Garrido, his agents, employees, officers, directors, attorneys or other designated representatives. CRASH refers to the motor vehicle collision involving William H. Schmitz and Defendant, Alexmar Pimienta Garrido, that occurred on or about November 24, 2015 on US 17 at or near the intersection of Regent Road, Punta Gorda, Charlotte County, Florida. TRACTOR the 1999 commercial motor vehicle refers to bearing VIN 4VG7DARJ9XN769587 owned by JLL Logistic Inc and Roberto Li. TRAILER refers to any trailer that was attached to the TRACTOR at the time of the CRASH. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished by Electronic Mail to William Boltrek, Esquire, Henderson, Franklin, et al., Attorney for Defendants, P.O. Box 280, Fort Myers, FL 33902-0280 at the designated email addresses of: William.boltrek@henlaw.com; Brenda.sitar@henlaw.com on this day of September, 2016. GOLDBERG, RACILA, D'ALESSANDRO & NOONE, LLC Attorneys for Plaintiff Post Office Box 190 Fort Myers, Florida 33902-0190 (239) 461-5508 {239) 461-3915 (Facsimile) Michael M.)Noone Florida Bar No.: 0105139 Email: MikeNoone joldberg-law.com ervice! Oo! idberg-law.com Elizete D. Velado Florida Bar No.: 0099668 Email: ElizeteVelado joldberg-law.com