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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA
CIVIL ACTION
ELLIS HANSON and VELTA HANSON,
3
Plaintiffs, 2 2 3 =
m 3 mn
ve Case No. 09-65 isc 2 ae
2 o» 25
ALMA TETI, 2 =p Sw
ez =
Defendant. eQ2 oF xX
Yy w ry
— a
PLAINTIFF, ELLIS HANSON, AMENDED ANSWERS TO
DI
EFENDANT’S FIRST INTERROGATORIES TO PLAINTIFF, ELLIS HANSON
Plaintiff, ELLIS HANSON (“Mr. Hanson”), by and through undersigned counsel, hereby
answers Defendant’s Interrogatories as follows:
1. List all former names and when you were known by those names. State all
addresses where you have lived for the past 10 years, the dates you lived at each address, your
Social Security number, your date of birth, and, if you are or ever have been married, the name
of your spouse or spouses.
Mr. Hanson has no former names.
Mr. Hanson has lived at 725 18th Avenue South, Naples,
Florida, for the past 10 years. Mr. Hanson also had a condo
located at 145 Pinckney St, Boston, MA, during this time
period.
Mr. Hanson considers his Social Security number to be
private, privileged information that is not relevant for the
discovery of admissible evidence and therefore it is not likely to
lead to the discovery of any admissible evidence, and therefore
objects to providing this information.
Mr. Hanson’s date of birth is October 29, 1923.
Velta Hanson is Mr. Hanson’s spouse. Sherry Hanson was Mr.
Hanson’s former spouse.2. List the names and business addresses of each physician who has 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; and state as to each the date of treatment
or examination and the injury or condition for which you were examined or treated.
DOCTORS WHO HAVE TREATED OR EXAMINED ELLIS
HANSON, AT A MINIMUM, FOR HIS LEVEL OF
CAPACITY, HIS ALZHEIMER’S DISEASE, AND/OR HIS
MEMORY.
Dr. Joseph Sullivan
Primary Care physician from roughly 1983-2006
201 8th St S Ste 203
Naples, FL 34102
Bill Beckwith
Psychologist
1415 Panther Ln., Suite 239
Naples, FL 34109-7874
Brian Wolff
Neurologist
671 Goodlette Rd N # 120
Naples, FL 34102-5615
William Justiz
Neurologist
Collier Neurologic Spec, Suite 100A
730 Goodlette Rd. N
Robert Ouaou
Neuropsychologist
2450 Goodlette Road North Suite 101
Naples, FL 34103
Dr. Perlo of Massachusetts General Hospital (performed
follow-up for incident where Ellis Hanson was brought to
emergency room for memory confusion in 2001)3. List the names and business addresses of all other physicians, medical facilities,
or other health care providers by whom or at which you have been examined or treated in the
past 10 years; and state as to each the dates of examination or treatment and the condition or
injury for which you were examined or treated.
In addition to the Response to Interrogatory Number 2, Ellis
Hanson has been examined or treated by the following
physicians, medical facilities, or other health care providers (to
the best of Plaintiffs’ knowledge):
Scott Ross
Naples Dermatology
4085 Tamiami Trail N. Suite B203
Naples, FL
Dermatologist
William Gaskins
2335 9"" St. N., Suite 304
Eye care
Kendall Wise
Naples Medical Center
400 8" St. N.
Naples, FL
Urologist
Joseph Spano
130 Tamiami Trail N.
Naples, FL
Colonoscopy, endoscopy
David Mattingly
New England Baptist Hospital
125 Parker Hill Ave.
Boston, MA 02120
Orthopedic surgeon- performed first hip replacement in 2002
Leon Mead
Gulfcoast Orthopedic S, Suite 201
Naples, FL
Performed second hip replacement in 2007
Michael Flynn
606 Ninth St. N.
Naples, FL
Cardiologist, assisted during hip surgery
-3-®
Douglas Boynton
Naples Medical Center
400 8" St. N.
Family doctor since 2007
4. List the names and addresses of all persons who are believed or known by you,
your agents, or your attorneys to have any knowledge concerning any of the issues in this
lawsuit; and specify the subject matter about which the witness has knowledge.
Name/Address
Defendant, Alma Teti
4810 Europa Drive
Naples, FL 34105
Raymond James & Associates,
Inc. and employees of Raymond
James & Associates, Inc.-
Address unknown at this time
Plaintiff, Velta Hanson
725 18th Avenue South
Naples, Florida 34102
Shirley Moore
3203 Benicia Ct
Naples, FL 34109
Michelin Yuan
3692 Nelsons Walk
Naples, FL 34102
Margie Iorio
500 12th Ave S
Naples, FL 34102
Dr. Joseph Sullivan
Primary Care physician from
roughly 1983-2006
201 8th St S Ste 203
Naples, FL 34102
Bill Beckwith
Psychologist
1415 Panther Ln., Suite 239
Naples, FL 34109-7874
Subject Matter
Knowledge of all issues in case.
Knowledge of all issues in case.
Knowledge of all issues in case.
Knowledge of issues related to Alma
Tetti, Ellis Hanson, and
Velta Hanson.
Knowledge of issues related to Alma
Tetti, Ellis Hanson, and
Velta Hanson
Knowledge of issues related to Alma
Tetti, Ellis Hanson, and
Velta Hanson
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.5.
Name / Address
Brian Wolff
Neurologist
671 Goodlette Rd N # 120
Naples, FL 34102-5615
William Justiz
Neurologist
Collier Neurologic Spec, Suite
100A
730 Goodlette Rd. N
Robert Ouaou
Neuropsychologist
2450 Goodlette Road North
Suite 101
Naples, FL 34103
Dr. Perlo of Massachusetts
General Hospital
Subject Matter
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.
Knowledge regarding Ellis Hanson’s
medical condition, including, but not
limited to, his level of capacity, his
Alzheimer’s disease, and his
memory.
Knowledge regarding Ellis Hanson’s
medical condition regarding an
incident on or around March of 2001
where Ellis Hanson was brought to
the emergency room for memory
confusion.
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 this 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.
No formal statements have been taken from any witnesses at
this point with the exception of the deposition of Rick Walker.
Other than conversations between Ellis Hanson and Alma Teti,
Alma Teti and other witnesses, such as (the broker at
Raymond James), and perhaps others, no particular
statements involved in this case are known. All such
statements were in the nature of contemporaneous
conversations during the time they occurred and no specific
record of such conversations or statements has been
maintained. The Plaintiffs will be engaging in discovery and
taking depositions to verify what statements and what the
circumstances surrounding all of the acts were involved in this
case and, therefore, the same will be addressed in that fashion.
-5-6. Do you still have a valid Florida Driver’s license?
Yes, but only for identification purposes as he no longer drives
a vehicle due to his condition.
VERIFICATION
I, VELTA HANSON, as Power of Attorney for ELLIS HANSON, being first duly
sworn in accordance with law, do hereby depose and state that I have read the responses to
Defendant’s Interrogatories and that the responses are true and correct to the best of my
knowledge and information.
By
VELTA HANSON, as Power of Attorney
for ELLIS HANSON
STATE OF FLORIDA
county or Colle
Sworn to (or affirmed) and subscribed before me this st day of November, 2009, by
VELTA HANSON, as Power of Attorney for ELLIS HANSON, who is personally known by
me [or who has produced FLOUDA- Da)
LU EY,D
= - Wf Q
iy CSS DO 8 Print Name: Milage. W . (aswell
onda Tru Nor Pbk Underrara My Commission Expires: 201
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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION ELLIS HANSON and VELTA HANSON, 3 Plaintiffs, 2 2 3 = m 3 mn ve Case No. 09-65 isc 2 ae 2 o» 25 ALMA TETI, 2 =p Sw ez = Defendant. eQ2 oF xX Yy w ry — a PLAINTIFF, ELLIS HANSON, AMENDED ANSWERS TO DI EFENDANT’S FIRST INTERROGATORIES TO PLAINTIFF, ELLIS HANSON Plaintiff, ELLIS HANSON (“Mr. Hanson”), by and through undersigned counsel, hereby answers Defendant’s Interrogatories as follows: 1. List all former names and when you were known by those names. State all addresses where you have lived for the past 10 years, the dates you lived at each address, your Social Security number, your date of birth, and, if you are or ever have been married, the name of your spouse or spouses. Mr. Hanson has no former names. Mr. Hanson has lived at 725 18th Avenue South, Naples, Florida, for the past 10 years. Mr. Hanson also had a condo located at 145 Pinckney St, Boston, MA, during this time period. Mr. Hanson considers his Social Security number to be private, privileged information that is not relevant for the discovery of admissible evidence and therefore it is not likely to lead to the discovery of any admissible evidence, and therefore objects to providing this information. Mr. Hanson’s date of birth is October 29, 1923. Velta Hanson is Mr. Hanson’s spouse. Sherry Hanson was Mr. Hanson’s former spouse.2. List the names and business addresses of each physician who has 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; and state as to each the date of treatment or examination and the injury or condition for which you were examined or treated. DOCTORS WHO HAVE TREATED OR EXAMINED ELLIS HANSON, AT A MINIMUM, FOR HIS LEVEL OF CAPACITY, HIS ALZHEIMER’S DISEASE, AND/OR HIS MEMORY. Dr. Joseph Sullivan Primary Care physician from roughly 1983-2006 201 8th St S Ste 203 Naples, FL 34102 Bill Beckwith Psychologist 1415 Panther Ln., Suite 239 Naples, FL 34109-7874 Brian Wolff Neurologist 671 Goodlette Rd N # 120 Naples, FL 34102-5615 William Justiz Neurologist Collier Neurologic Spec, Suite 100A 730 Goodlette Rd. N Robert Ouaou Neuropsychologist 2450 Goodlette Road North Suite 101 Naples, FL 34103 Dr. Perlo of Massachusetts General Hospital (performed follow-up for incident where Ellis Hanson was brought to emergency room for memory confusion in 2001)3. List the names and business addresses of all other physicians, medical facilities, or other health care providers by whom or at which you have been examined or treated in the past 10 years; and state as to each the dates of examination or treatment and the condition or injury for which you were examined or treated. In addition to the Response to Interrogatory Number 2, Ellis Hanson has been examined or treated by the following physicians, medical facilities, or other health care providers (to the best of Plaintiffs’ knowledge): Scott Ross Naples Dermatology 4085 Tamiami Trail N. Suite B203 Naples, FL Dermatologist William Gaskins 2335 9"" St. N., Suite 304 Eye care Kendall Wise Naples Medical Center 400 8" St. N. Naples, FL Urologist Joseph Spano 130 Tamiami Trail N. Naples, FL Colonoscopy, endoscopy David Mattingly New England Baptist Hospital 125 Parker Hill Ave. Boston, MA 02120 Orthopedic surgeon- performed first hip replacement in 2002 Leon Mead Gulfcoast Orthopedic S, Suite 201 Naples, FL Performed second hip replacement in 2007 Michael Flynn 606 Ninth St. N. Naples, FL Cardiologist, assisted during hip surgery -3-® Douglas Boynton Naples Medical Center 400 8" St. N. Family doctor since 2007 4. List the names and addresses of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. Name/Address Defendant, Alma Teti 4810 Europa Drive Naples, FL 34105 Raymond James & Associates, Inc. and employees of Raymond James & Associates, Inc.- Address unknown at this time Plaintiff, Velta Hanson 725 18th Avenue South Naples, Florida 34102 Shirley Moore 3203 Benicia Ct Naples, FL 34109 Michelin Yuan 3692 Nelsons Walk Naples, FL 34102 Margie Iorio 500 12th Ave S Naples, FL 34102 Dr. Joseph Sullivan Primary Care physician from roughly 1983-2006 201 8th St S Ste 203 Naples, FL 34102 Bill Beckwith Psychologist 1415 Panther Ln., Suite 239 Naples, FL 34109-7874 Subject Matter Knowledge of all issues in case. Knowledge of all issues in case. Knowledge of all issues in case. Knowledge of issues related to Alma Tetti, Ellis Hanson, and Velta Hanson. Knowledge of issues related to Alma Tetti, Ellis Hanson, and Velta Hanson Knowledge of issues related to Alma Tetti, Ellis Hanson, and Velta Hanson Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory. Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory.5. Name / Address Brian Wolff Neurologist 671 Goodlette Rd N # 120 Naples, FL 34102-5615 William Justiz Neurologist Collier Neurologic Spec, Suite 100A 730 Goodlette Rd. N Robert Ouaou Neuropsychologist 2450 Goodlette Road North Suite 101 Naples, FL 34103 Dr. Perlo of Massachusetts General Hospital Subject Matter Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory. Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory. Knowledge regarding Ellis Hanson’s medical condition, including, but not limited to, his level of capacity, his Alzheimer’s disease, and his memory. Knowledge regarding Ellis Hanson’s medical condition regarding an incident on or around March of 2001 where Ellis Hanson was brought to the emergency room for memory confusion. 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 this 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. No formal statements have been taken from any witnesses at this point with the exception of the deposition of Rick Walker. Other than conversations between Ellis Hanson and Alma Teti, Alma Teti and other witnesses, such as (the broker at Raymond James), and perhaps others, no particular statements involved in this case are known. All such statements were in the nature of contemporaneous conversations during the time they occurred and no specific record of such conversations or statements has been maintained. The Plaintiffs will be engaging in discovery and taking depositions to verify what statements and what the circumstances surrounding all of the acts were involved in this case and, therefore, the same will be addressed in that fashion. -5-6. Do you still have a valid Florida Driver’s license? Yes, but only for identification purposes as he no longer drives a vehicle due to his condition. VERIFICATION I, VELTA HANSON, as Power of Attorney for ELLIS HANSON, being first duly sworn in accordance with law, do hereby depose and state that I have read the responses to Defendant’s Interrogatories and that the responses are true and correct to the best of my knowledge and information. By VELTA HANSON, as Power of Attorney for ELLIS HANSON STATE OF FLORIDA county or Colle Sworn to (or affirmed) and subscribed before me this st day of November, 2009, by VELTA HANSON, as Power of Attorney for ELLIS HANSON, who is personally known by me [or who has produced FLOUDA- Da) LU EY,D = - Wf Q iy CSS DO 8 Print Name: Milage. W . (aswell onda Tru Nor Pbk Underrara My Commission Expires: 201