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Filing # 178093270 E-Filed 07/24/2023 03:23:44 PM
TWENTIETH JUDICIAL CIRCUIT IN AND
FOR CHARLOTTE COUNTY, FLORIDA
CASE NO.: 23000551CA
STEPHANIE STABRYLLA,
Plaintiff,
vs.
ELIZABETH WHITKOPF and SAFECO INSURANCE COMPANY OF ILLINOIS,
Defendants.
/
I certify that the foregoing document has been furnished by email on this 20th day of July,
fdiplacido@forthepeople.com; pneira@forthepeople.com; rrosenbergjordahl@forthepeople.com.
Law Office of Ignacio M. Sarmiento
PO Box 7217
London, KY 40742
(239) 895-0449
Attorney for Defendant, Safeco Insurance Company Of Illinois
Primary E-mail (eservice only): FortMyersLegalMail@LibertyMutual.com
Secondary E-mail: Laura.Johnson02@Libertymutual.com
TWENTIETH JUDICIAL CIRCUIT IN AND
FOR CHARLOTTE COUNTY, FLORIDA
CASE NO.: 23000551CA
STEPHANIE STABRYLLA,
Plaintiff,
vs.
ELIZABETH WHITKOPF and SAFECO INSURANCE COMPANY OF ILLINOIS,
Defendants.
/
STANDARD FORM AUTOMOBILE NEGLIGENCE
Defendant, propounds the following
oath, in accordance with the applicable Florida Rules of Civil Procedure:
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 ten years, the dates you have lived at each address, your social
security number, date of birth, driver's license number, and if you are or have ever been
married, the name of your spouse (s).
3. 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?
4. 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?
5. Have you ever been convicted of a crime, other than any juvenile adjudication, which under
of one year, or that involved dishonesty or a false statement regardless of the punishment?
If so, state as to each conviction, the specific crime, the date and place of conviction.
6. 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?
7. Describe in detail how the incident described in the Complaint happened, including all
actions taken by you to prevent the incident.
8. 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.
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 this charge, and if so, what is
the name and address of the person or entity that 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 was the name and address of the person who
recorded the testimony?
10. At the time of the incident described in the Complaint, were you wearing a seatbelt? If no,
please state why not; where you were seated in the vehicle; and whether the vehicle was
equipped with a seatbelt that was operational and available for your use.
11. 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.
12. List each 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.
13. Do you contend that you have lost any income, benefits, or earning capacity in the past or
income, benefits, or earning capacity, and the amount and the method that you used in
computing the amount.
14. List the names, business addresses, dates of employment and rates of pay regarding all
15. Has anything been paid or is anything payable from any third party for the damages listed in
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.
16. 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.
17. List the names and business addresses of each physician who as treated or examined you,
and each medical facility where you have received any treatment or examination for the
injuries for which you seek damages in this case
examination and the injury or condition for which you were examined or treated.
18. List the names and business addresses of all other physicians, medical facilities or other
health care providers by whom or at which you have 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.
19. 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 the lawsuit; and specify
the subject matter about which the witness has knowledge.
20. 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 the 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.
21. State the name and address of every person known to you, your agents, or attorneys, who
has knowledge about, or possession, custody or control of any model, plat, map, drawing,
motion picture, video tape, or photograph pertaining to any fact or issue involved in this
controversy; and describe as to each, what such person has, the name and address of the
person who took or prepared it, and the date it was taken or prepared.
22. 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' qualifications as an
expert, the subject matter upon which the witness is expected, 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.
23. 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.
24. Please state if you have ever been a party, either Plaintiff or Defendant, in a lawsuit other
of the action, and the date and court in which such suit was filed.
25. Are you currently being treated by a physician? If so, please state the physician’s name,
business address and business phone number along with the date of your last visit and the
date of any future appointments.
26. Have you ever suffered from any psychological or emotional illness or distress? If so, please
state:
a. The nature or symptoms of your emotional illness or distress.
b. The treating physician.
c. Whether confinement in a hospital or other facility was required?
27. Have you ever been treated for alcoholism or drug dependency? If so, please state the
nature of the drug dependency, the health care provider of treatment and the dates of
treatment.
28. If the alleged injury or injuries sustained in the accident prevent you or make it more difficult
daily activities (including recreational activities), please state specifically in what manner you
are affected.
29. Please describe your education, including all schools attended beginning with high school or
highest grade completed, dates of attendance, whether you were a full or part-time student,
course of study and any degrees attained.
STATE OF )
COUNTY OF )
The foregoing instrument was acknowledged before me this day of
, by
(type of identification) as identification and who did (did not) take an oath.
Sworn to and subscribed before me this day of 2023.
NOTARY PUBLIC, State of Florida
My Commission Expires:
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Filing # 178093270 E-Filed 07/24/2023 03:23:44 PM TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CASE NO.: 23000551CA STEPHANIE STABRYLLA, Plaintiff, vs. ELIZABETH WHITKOPF and SAFECO INSURANCE COMPANY OF ILLINOIS, Defendants. / I certify that the foregoing document has been furnished by email on this 20th day of July, fdiplacido@forthepeople.com; pneira@forthepeople.com; rrosenbergjordahl@forthepeople.com. Law Office of Ignacio M. Sarmiento PO Box 7217 London, KY 40742 (239) 895-0449 Attorney for Defendant, Safeco Insurance Company Of Illinois Primary E-mail (eservice only): FortMyersLegalMail@LibertyMutual.com Secondary E-mail: Laura.Johnson02@Libertymutual.com TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CASE NO.: 23000551CA STEPHANIE STABRYLLA, Plaintiff, vs. ELIZABETH WHITKOPF and SAFECO INSURANCE COMPANY OF ILLINOIS, Defendants. / STANDARD FORM AUTOMOBILE NEGLIGENCE Defendant, propounds the following oath, in accordance with the applicable Florida Rules of Civil Procedure: 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 ten years, the dates you have lived at each address, your social security number, date of birth, driver's license number, and if you are or have ever been married, the name of your spouse (s). 3. 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? 4. 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? 5. Have you ever been convicted of a crime, other than any juvenile adjudication, which under of one year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction, the specific crime, the date and place of conviction. 6. 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? 7. Describe in detail how the incident described in the Complaint happened, including all actions taken by you to prevent the incident. 8. 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. 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 this charge, and if so, what is the name and address of the person or entity that 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 was the name and address of the person who recorded the testimony? 10. At the time of the incident described in the Complaint, were you wearing a seatbelt? If no, please state why not; where you were seated in the vehicle; and whether the vehicle was equipped with a seatbelt that was operational and available for your use. 11. 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. 12. List each 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. 13. Do you contend that you have lost any income, benefits, or earning capacity in the past or income, benefits, or earning capacity, and the amount and the method that you used in computing the amount. 14. List the names, business addresses, dates of employment and rates of pay regarding all 15. Has anything been paid or is anything payable from any third party for the damages listed in 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. 16. 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. 17. List the names and business addresses of each physician who as treated or examined you, and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this case examination and the injury or condition for which you were examined or treated. 18. List the names and business addresses of all other physicians, medical facilities or other health care providers by whom or at which you have 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. 19. 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 the lawsuit; and specify the subject matter about which the witness has knowledge. 20. 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 the 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. 21. State the name and address of every person known to you, your agents, or attorneys, who has knowledge about, or possession, custody or control of any model, plat, map, drawing, motion picture, video tape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. 22. 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' qualifications as an expert, the subject matter upon which the witness is expected, 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. 23. 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. 24. Please state if you have ever been a party, either Plaintiff or Defendant, in a lawsuit other of the action, and the date and court in which such suit was filed. 25. Are you currently being treated by a physician? If so, please state the physician’s name, business address and business phone number along with the date of your last visit and the date of any future appointments. 26. Have you ever suffered from any psychological or emotional illness or distress? If so, please state: a. The nature or symptoms of your emotional illness or distress. b. The treating physician. c. Whether confinement in a hospital or other facility was required? 27. Have you ever been treated for alcoholism or drug dependency? If so, please state the nature of the drug dependency, the health care provider of treatment and the dates of treatment. 28. If the alleged injury or injuries sustained in the accident prevent you or make it more difficult daily activities (including recreational activities), please state specifically in what manner you are affected. 29. Please describe your education, including all schools attended beginning with high school or highest grade completed, dates of attendance, whether you were a full or part-time student, course of study and any degrees attained. STATE OF ) COUNTY OF ) The foregoing instrument was acknowledged before me this day of , by (type of identification) as identification and who did (did not) take an oath. Sworn to and subscribed before me this day of 2023. NOTARY PUBLIC, State of Florida My Commission Expires: