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Filing # 177333190 E-Filed 07/13/2023 11:35:51 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2023 CA 001416 AN
PEDRO GUDINO,
Plaintiff,
vs.
FERMIN SANTIAGO GUZMAN,
AND STATE FARM MUTUAL
AUTOMOBILE INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S NOTICE OF SERVING INTERROGATORIES TO DEFENDANT,
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
Plaintiff, PEDRO GUDINO, by and through undersigned counsel and pursuant to Fla. R.
Civ. P. 1.340, propounds upon Defendant, STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY the attached Interrogatories, to be answered, under oath, within forty-
five (45) days from the date of service.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the Defendant, along with the Summons and Complaint.
/s/ Andrew Rollins
Andrew Rollins, Esquire
Florida Bar No: 1026179
Morgan & Morgan, P.A.
20 N Orange Ave., Suite 1600
Orlando, Florida 32801
Telephone: (407) 849-4624
Primary email: arollins@forthepeople.com
Secondary email: Morganservice@forthepeople.com
Attorneys for Plaintiff
13690703
ROGC001
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO: 2023 CA 001416 AN
PEDRO GUDINO,
Plaintiff,
vs.
FERMIN SANTIAGO GUZMAN,
AND STATE FARM MUTUAL
AUTOMOBILE INSURANCE
COMPANY,
Defendant.
/
INTERROGATORIES TO DEFENDANT, STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY
Plaintiff, PEDRO GUDINO, by and through the undersigned counsel propounds the attached
Interrogatories, numbered one (1) through sixteen (16) to Defendant, STATE FARM MUTUAL
AUTOMOBILE INSURANCE COMPANY to be answered, under oath, within forty-five (45)
days from the date of service.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the Defendant, along with the Summons and Complaint.
/s/ Andrew Rollins
Andrew Rollins, Esquire
Florida Bar No: 1026179
Morgan & Morgan, P.A.
20 N Orange Ave., Suite 1600
Orlando, Florida 32801
13690703
ROGC001
Telephone: (407) 849-4624
Primary email: arollins@forthepeople.com
Secondary email: Morganservice@forthepeople.com
Attorneys for Plaintiff
13690703
ROGC001
INTERROGATORIES TO DEFENDANT STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY
PLEASE INSERT YOUR ANSWERS IN THE SPACE PROVIDED BELOW EACH
INTERROGATORY. SHOULD ADDITIONAL SPACE BE NEEDED, PLEASE ATTACH AN
EXTRA SHEET. “YOU” AND “YOUR” REFER TO THE DEFENDANT TO WHOM THESE
INTERROGATORIES ARE DIRECTED. DEFENDANT INCLUDES ALL AGENTS,
SERVANTS, OR EMPLOYEES OF THE DEFENDANT. IF ANSWERING FOR ANOTHER
PERSON OR ENTITY, ANSWER WITH RESPECT TO THAT PERSON OR ENTITY, UNLESS
OTHERWISE STATED.
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. State your complete corporate name, nature of your business, whether you are licensed to do
business in the State of Florida, whether you maintain agents for the transacting of your
customary business in Osceola County, and whether your name as it appears in Plaintiff's
Complaint is correct.
3. List the names, addresses and telephone numbers of all persons believed or known by you, your
agents or attorneys to have any knowledge concerning any of the issues raised in this lawsuit;
and specify the subject matter about which the witnesses have knowledge. State whether you
have obtained any statements (oral, written or recorded) from any of these witnesses, list the
dates any such witness statements were taken, by whom any such witness statements were taken
and who has present possession, custody and control of any such statements.
13690703
ROGC001
4. 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.
5. State the name and address of every person known to you, your agents, or your attorneys who
has knowledge about, or possession, custody, or control of, any model, plat, map, drawing,
motion picture, videotape, or photograph pertaining to any fact or issue involved in this
controversy; and describe as to each, what item such person has, the name and address of the
person who took or prepared it, and the date it was taken or prepared.
6. State whether any insurance agreement or agreements exist under which any person or company
carrying on an insurance business may be liable to satisfy part or all of a judgment which may
be entered in this action or to indemnify or reimburse any payments made to satisfy any such
judgment or settlement. If so,
a. What is the name of each company who has issued any such policy;
b. The limits of liability for injury to any one person under the terms of each such
policies;
c. The limits of liability for injury to more than one person under the terms of each
policies;
d. Whether any such insurer has notified you that it claims the policy provisions
have been violated or that the policy is otherwise inapplicable to the
circumstances of this case, and if so, the date of such notification and the reason
given by such insurer for such a claim;
e. the name and address of the person now having custody of a copy of each of such
insurance policies.
13690703
ROGC001
7. Please state the period of time for which the Plaintiff has been insured by any contract of
insurance issued by your company.
8. Please state the yearly premiums paid for each contract of insurance purchased by the Plaintiff
during the entire time that each contract was or is in force.
9. Please state each type of insurance contract(s) ever purchased by the Plaintiff from your
company.
10. List the names, residence addresses, business addresses and telephone numbers of all persons
who, on your behalf or on behalf of your agents or representatives, have in any way participated
in the investigation, adjusting or handling of the claim for benefits involved herein and specify
the date and the nature of the participation of each person.
13690703
ROGC001
11. For any and all policy defenses which you reasonably believe are available with regard to
Plaintiff's claim in this action, describe in detail the factual and legal basis for any such defenses
and give complete names, residence addresses, business addresses and telephone numbers of
each and every person believed or known by you, your agents or attorneys, to have knowledge
of the facts which would provide the basis for any such defenses.
12. 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.
13. State the facts upon which you rely for each affirmative defense in your answer.
14. List the names, addresses and official positions of each and every person in your employ or in
the employ of anyone on your behalf who has had any involvement in the review of the denial
or withholding of Plaintiff's uninsured motorist claim and state in what capacity they were
involved, the date they were involved and the nature of their involvement.
13690703
ROGC001
15. 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's qualifications as an expert,
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.
16. 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.
13690703
ROGC001
STATE OF
COUNTY OF
Before me the undersigned officer, authorized to administer oaths and take acknowledgments,
personally appeared ____________________________________ who after being duly sworn,
deposes and says: That the answers to the above and foregoing Interrogatories are true and correct to
the best of my knowledge and belief.
Agent and or representative on behalf of
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY
SWORN TO AND SUBSCRIBED before me this day of , .
Notary Public (signature)
Notary Public (type, print stamp commission)
My Commission Expires:
❑ Personally Known OR
❑ Produced Identification
❑ Type of Identification Produced:
13690703
ROGC001
Preview
Filing # 177333190 E-Filed 07/13/2023 11:35:51 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2023 CA 001416 AN PEDRO GUDINO, Plaintiff, vs. FERMIN SANTIAGO GUZMAN, AND STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. / PLAINTIFF’S NOTICE OF SERVING INTERROGATORIES TO DEFENDANT, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY Plaintiff, PEDRO GUDINO, by and through undersigned counsel and pursuant to Fla. R. Civ. P. 1.340, propounds upon Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY the attached Interrogatories, to be answered, under oath, within forty- five (45) days from the date of service. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the Defendant, along with the Summons and Complaint. /s/ Andrew Rollins Andrew Rollins, Esquire Florida Bar No: 1026179 Morgan & Morgan, P.A. 20 N Orange Ave., Suite 1600 Orlando, Florida 32801 Telephone: (407) 849-4624 Primary email: arollins@forthepeople.com Secondary email: Morganservice@forthepeople.com Attorneys for Plaintiff 13690703 ROGC001 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2023 CA 001416 AN PEDRO GUDINO, Plaintiff, vs. FERMIN SANTIAGO GUZMAN, AND STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant. / INTERROGATORIES TO DEFENDANT, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY Plaintiff, PEDRO GUDINO, by and through the undersigned counsel propounds the attached Interrogatories, numbered one (1) through sixteen (16) to Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY to be answered, under oath, within forty-five (45) days from the date of service. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the Defendant, along with the Summons and Complaint. /s/ Andrew Rollins Andrew Rollins, Esquire Florida Bar No: 1026179 Morgan & Morgan, P.A. 20 N Orange Ave., Suite 1600 Orlando, Florida 32801 13690703 ROGC001 Telephone: (407) 849-4624 Primary email: arollins@forthepeople.com Secondary email: Morganservice@forthepeople.com Attorneys for Plaintiff 13690703 ROGC001 INTERROGATORIES TO DEFENDANT STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY PLEASE INSERT YOUR ANSWERS IN THE SPACE PROVIDED BELOW EACH INTERROGATORY. SHOULD ADDITIONAL SPACE BE NEEDED, PLEASE ATTACH AN EXTRA SHEET. “YOU” AND “YOUR” REFER TO THE DEFENDANT TO WHOM THESE INTERROGATORIES ARE DIRECTED. DEFENDANT INCLUDES ALL AGENTS, SERVANTS, OR EMPLOYEES OF THE DEFENDANT. IF ANSWERING FOR ANOTHER PERSON OR ENTITY, ANSWER WITH RESPECT TO THAT PERSON OR ENTITY, UNLESS OTHERWISE STATED. 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. State your complete corporate name, nature of your business, whether you are licensed to do business in the State of Florida, whether you maintain agents for the transacting of your customary business in Osceola County, and whether your name as it appears in Plaintiff's Complaint is correct. 3. List the names, addresses and telephone numbers of all persons believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues raised in this lawsuit; and specify the subject matter about which the witnesses have knowledge. State whether you have obtained any statements (oral, written or recorded) from any of these witnesses, list the dates any such witness statements were taken, by whom any such witness statements were taken and who has present possession, custody and control of any such statements. 13690703 ROGC001 4. 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. 5. State the name and address of every person known to you, your agents, or your attorneys who has knowledge about, or possession, custody, or control of, any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. 6. State whether any insurance agreement or agreements exist under which any person or company carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse any payments made to satisfy any such judgment or settlement. If so, a. What is the name of each company who has issued any such policy; b. The limits of liability for injury to any one person under the terms of each such policies; c. The limits of liability for injury to more than one person under the terms of each policies; d. Whether any such insurer has notified you that it claims the policy provisions have been violated or that the policy is otherwise inapplicable to the circumstances of this case, and if so, the date of such notification and the reason given by such insurer for such a claim; e. the name and address of the person now having custody of a copy of each of such insurance policies. 13690703 ROGC001 7. Please state the period of time for which the Plaintiff has been insured by any contract of insurance issued by your company. 8. Please state the yearly premiums paid for each contract of insurance purchased by the Plaintiff during the entire time that each contract was or is in force. 9. Please state each type of insurance contract(s) ever purchased by the Plaintiff from your company. 10. List the names, residence addresses, business addresses and telephone numbers of all persons who, on your behalf or on behalf of your agents or representatives, have in any way participated in the investigation, adjusting or handling of the claim for benefits involved herein and specify the date and the nature of the participation of each person. 13690703 ROGC001 11. For any and all policy defenses which you reasonably believe are available with regard to Plaintiff's claim in this action, describe in detail the factual and legal basis for any such defenses and give complete names, residence addresses, business addresses and telephone numbers of each and every person believed or known by you, your agents or attorneys, to have knowledge of the facts which would provide the basis for any such defenses. 12. 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. 13. State the facts upon which you rely for each affirmative defense in your answer. 14. List the names, addresses and official positions of each and every person in your employ or in the employ of anyone on your behalf who has had any involvement in the review of the denial or withholding of Plaintiff's uninsured motorist claim and state in what capacity they were involved, the date they were involved and the nature of their involvement. 13690703 ROGC001 15. 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's qualifications as an expert, 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. 16. 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. 13690703 ROGC001 STATE OF COUNTY OF Before me the undersigned officer, authorized to administer oaths and take acknowledgments, personally appeared ____________________________________ who after being duly sworn, deposes and says: That the answers to the above and foregoing Interrogatories are true and correct to the best of my knowledge and belief. Agent and or representative on behalf of STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY SWORN TO AND SUBSCRIBED before me this day of , . Notary Public (signature) Notary Public (type, print stamp commission) My Commission Expires: ❑ Personally Known OR ❑ Produced Identification ❑ Type of Identification Produced: 13690703 ROGC001