Party Discovery: Myp Executive LLC Plaintiff vs. Capital Health Advisors Inc, et al Defendant

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                                Filing# 153593990 E-Filed 07/19/2022 10:54:11                       AM


                     IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                               IN AND FOR BROWARD COUNTY, FLORIDA

     MYP EXECUTIVE, LLC,
                         Plaintiff.                               Case No.: CACE-21-016649

     VS.


     CAPITAL HEALTH ADVISORS INC,
     andMARIO CALLEJAS, Individually,
                         Defendant.



                                      INTERROGATORIES TO THE DEFENDANT
                Plaintiff, MYP EXECUTIVE, LLC, by and throughits undersignedcounsel,serves pursuant
     to    Rule 1.340(a) (2), Fla.R.Civ.P.,Interrogatories
                                                         to Defendant.                The information which       is


                                     set forth below should be provided in the space below. However,
     responsive to the interrogatories

     if additional     space   is   necessary, the answering party may attach additional papers with answers and

     refer to   them   in the space providedin the interrogatories.




                1.   State your name, address, and     title   with the Defendant Corporation.




                2.   State the names, addresses, and telephone numbers of each         and every person who has
     knowledge of the       facts and issues in this case.




          *** FILED:   BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/19/2022                 10:54:11   AM.****
            3.   State tb.e names, addresses, and telephonenumbers of each person whom you intend to
       a witness at the
 call as                      trial ofthis case, and provide a brief synopsis as to the anticipated
                                                                                                  testimony
 ofeach.




       4. State the names, addresses,and telephonenumbers of each person whom you intend to
      an expert witness at the trial of this case, and providea brief synopsisas to the anticipated
call as

testimony of each.




          5. State whether your firm received the merchandise and/or services from Plaintiff which
is   the subjectmatter to this suit,and if so, list the date on which each shipment was received.




           6. State the name, address, and title of the person who ordered the merchandise and/or
services    from Plaintiff,
                          and state whether the merchandise and/or services were ordered in writing
or verbally.
        7. State the exact   amount which your records reflect   is                        and how you
                                                                      owed to the Plaintiff,
calculated said amount.




       8.    Describe in detail any reason which you believe      is the basis   of non-payment of the
Plaintiffs claim  which are the subjectmatter ofthis suit.




       9. State the   names and addresses of each   director or officer ofthe Defendant Corporation.




       10. List the   amount and date of all payments made by the Defendant to       the Plaintiff.




       11.   State the   name of the employee of the Defendant Corporationwho        is   responsiblefor
payment of invoices.
         12. State the name and address ofthe person                                            who is the records           custodian of the books and
 records of the Defendant Corporation.




             13.     Please describe in detail                 all facts which tend to                support Defendant's Affirmative Defenses
 and specifywhich affirmative defense that                                  fact     appliesto.




                                                                                       Signature


STATE OF
COUNTY OF
             I    HEREBY CERTIFY that before
                                           me, the undersigned authority,personallyappeared
                                             who, after being duly sworn, deposes and states that
                                                                              ,

the answers to the Interrogatories
                                are true and correct to the best of his/her knowledge and belief.


         WITNESS my hand aiid official seal in the county and state last                                                     aforesaid this
day of                                    ,2022.




                                                                                      Notary Public
                                                                                      My commission expires:
                                                             CERTIFICATE OF SERVICE

         I       HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
United States Mail to               MARCADIS SINGER, P.A., Attorneys for Plaintiff,
                                                                                 5104                                                        South Westshore
Blvd.,   Tampa, Florida 33611,                      this                            day of                                     ,2022.


220718/ ? 06742rnvIB

      This   is   a communication from a debt   collector.   We are attempting to   collect   a debt- Any information you provide   may be used   for that purpose.