Preview
Filing # 191872883 E-Filed 02/13/2024 03:15:59 PM
IIN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
ARIANA KARISA ROMAN,
Plaintiff,
Case No:
vs. Division:
CHLOE CORREIA PLEASANTS and
PROGRESSIVE AMERICAN INSURANCE COMPANY,
Defendants.
/
PLAINTIFF’S NOTICE OF SERVING INTERROGATORIES TO DEFENDANT,
CHLOE CORREIA PLEASANTS
Plaintiff, ARIANA KARISA ROMAN, by and through undersigned counsel, hereby gives Notice of
Serving Interrogatories to the Defendant, CHLOE CORREIA PLEASANTS, with the Summons and Complaint
to be answered under oath within forty-five (45) days hereof in accordance with the applicable Rules of Civil
Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was filed February 13, 2024, to
be served upon Defendant, CHLOE CORREIA PLEASANTS, with the Summons and Complaint.
/s/ Alan Bulnes
ALAN BULNES, ESQUIRE
Florida Bar No. 0036853
ab@mickeykeenan.com
MICKEY KEENAN, P.A.
324 N. Dale Mabry Hwy., Ste. 101
Tampa, FL 33609
Attorneys for Plaintiff
Service email: service@mickeykeenan.com
2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
INTERROGATORIES TO DEFENDANT, CHLOE CORREIA PLEASANTS
Please insert your answers in the space provided following each question. If additional space is needed, so
indicate in the space provided, prepare your answer on separate paper and attach.
1. What is your name, address and, if you are answering for someone else, your 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 (10) years, the dates you lived at each address, your social security
number, and your date of birth.
3. Have you ever been convicted of a crime, other than any juvenile adjudication, which under the law
under which you were convicted punishable was by death or imprisonment in excess of one (1) 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 the place of conviction.
4. Describe any and all policies of insurance which you contend cover or may cover you for the
allegations set forth in plaintiff’s complaint, detailing as to such policies the name of the insurer, the
number of the policy, the effective dates of the policy, the available limits of liability, and the name
and address of the custodian of the policy.
2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
5. Describe in detail how the accident happened, including all actions taken by you to prevent the
accident.
6. 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 case of the accident in question.
7. State the facts upon which you rely for each affirmative defense in your answer.
8. Do you contend any person or entity other than you is or may be, liable in whole or in part for the
claims asserted against you in this lawsuit? If so, state the full name and address of each such
person or entity, the legal basis for your contention, the facts or evidence upon which your contention
is based, and whether or not you have notified each such person or entity of your contention.
9. Were you charged with any violation of law (including any regulations or ordinances) arising out of
the incident referred to in the Complaint? If so, what was the nature of the chart, 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 the charge, and if so, what is the name and address of the person or
entity who prepared the report; do you have a copy of the report; and was the testimony at any trial,
2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
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. List the names and addresses of all persons believed or known to you, your agents or attorneys to
have any knowledge concerning any of the issues raised by the pleadings and specify the subject
matter about which the witness has knowledge.
11. 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 issues in this lawsuit? If so, state the name,
residence address, business address and telephone number of each person believed or known by
you, your agents or attorneys to have heard or who is purported to have heard the Plaintiff make any
statement, remark or comment concerning the accident described in the Complaint and the
substance of each statement, remark or comment.
12. State the name and address of each person known to you, your agents or attorneys who have
knowledge about, or possession, custody or control of any model, plat, map, drawing, motion picture,
video tape, or photographs 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.
13. Do you intend to call any expert witness at the trial of this case? If so, please identify such witness,
describe his qualifications as an expert, state the subject matter upon which he is expected to testify,
state the substance of the facts and opinions to which he is expected to testify, and give a summary
of the grounds for each opinion.
2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4
14. 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.
15. Please state if you have ever been a party either plaintiff or defendant in a lawsuit other than the
present matter and, if so, state whether you were plaintiff or defendant, the nature of the action, and
the date and court in which such suit was filed.
16. Do you wear glasses or contact lenses? If so, who prescribed them, when were they prescribed,
when were your eyes last examined and by whom?
17. 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?
18. Did you consume any alcoholic beverages or take any drugs or medication within 12 hours before
the occurrence of the accident described in the Complaint? If so, what type and amount of alcoholic
beverages, drugs or medications were consumed and where did you consume them?
19. Did any mechanical defect in the motor vehicle you were driving at the time of the accident contribute
to the occurrence of the accident? If so, what was the nature of the defect?
2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5
20. List the names and addresses of all persons, corporations, or entities who were the registered title
owners or who had any legal or ownership interest in, or right to control the motor vehicle that was
being driven on the date of the accident described in the Complaint and describe both the nature of
the ownership interest or right to control the vehicle, and the vehicle itself, including the make,
model, year and vehicle identification number.
21. At the time of the incident described in the Complaint, was the defendant driver engaged in any
mission or activity for any other person or entity, including any employer? If so, state the name and
address of that person or entity and the nature of the mission or activity.
22. Was the motor vehicle that you owned or were operating at the time of the accident described in
the complaint damaged in the incident and if so, what was the cost to repair the damage?
23. Do you, your agents, investigators, or attorneys have surveillance tape, movies, or film of any kind
of the Plaintiff? If so, please state the name and address of the current custodian of the same.
24. Did you have a cellular telephone(s) and/or other mobile devices available for your use on the day
of the subject accident? If so, for each available cellular telephone and/or mobile device, please
provide the following: the name and address of the carrier; the account number; the cellular
telephone/mobile number and/or account; and the name of the account holder.
2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6
________________________
CHLOE CORREIA PLEASANTS
STATE OF ____________________
COUNTY OF __________________________
The foregoing instrument was acknowledged before me, an officer duly authorized in the State and
County aforesaid, to take acknowledgments, this _____ day of _________, 2024, who states that the
foregoing answers to Interrogatories are true to the best of his/her information and belief and who:
[ ] is personally know to me; or
[ ] who has produced __________________as identification; and who:
[ ] did or [ ] did not, take an oath.
_____________________________
NOTARY PUBLIC
My Commission Expires: _____________________________
(Print Name)
(Seal)
_____________________________
(Serial Number, if any)
2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7
Preview
Filing # 191872883 E-Filed 02/13/2024 03:15:59 PM IIN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION ARIANA KARISA ROMAN, Plaintiff, Case No: vs. Division: CHLOE CORREIA PLEASANTS and PROGRESSIVE AMERICAN INSURANCE COMPANY, Defendants. / PLAINTIFF’S NOTICE OF SERVING INTERROGATORIES TO DEFENDANT, CHLOE CORREIA PLEASANTS Plaintiff, ARIANA KARISA ROMAN, by and through undersigned counsel, hereby gives Notice of Serving Interrogatories to the Defendant, CHLOE CORREIA PLEASANTS, with the Summons and Complaint to be answered under oath within forty-five (45) days hereof in accordance with the applicable Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was filed February 13, 2024, to be served upon Defendant, CHLOE CORREIA PLEASANTS, with the Summons and Complaint. /s/ Alan Bulnes ALAN BULNES, ESQUIRE Florida Bar No. 0036853 ab@mickeykeenan.com MICKEY KEENAN, P.A. 324 N. Dale Mabry Hwy., Ste. 101 Tampa, FL 33609 Attorneys for Plaintiff Service email: service@mickeykeenan.com 2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 INTERROGATORIES TO DEFENDANT, CHLOE CORREIA PLEASANTS Please insert your answers in the space provided following each question. If additional space is needed, so indicate in the space provided, prepare your answer on separate paper and attach. 1. What is your name, address and, if you are answering for someone else, your 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 (10) years, the dates you lived at each address, your social security number, and your date of birth. 3. Have you ever been convicted of a crime, other than any juvenile adjudication, which under the law under which you were convicted punishable was by death or imprisonment in excess of one (1) 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 the place of conviction. 4. Describe any and all policies of insurance which you contend cover or may cover you for the allegations set forth in plaintiff’s complaint, detailing as to such policies the name of the insurer, the number of the policy, the effective dates of the policy, the available limits of liability, and the name and address of the custodian of the policy. 2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 5. Describe in detail how the accident happened, including all actions taken by you to prevent the accident. 6. 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 case of the accident in question. 7. State the facts upon which you rely for each affirmative defense in your answer. 8. Do you contend any person or entity other than you is or may be, liable in whole or in part for the claims asserted against you in this lawsuit? If so, state the full name and address of each such person or entity, the legal basis for your contention, the facts or evidence upon which your contention is based, and whether or not you have notified each such person or entity of your contention. 9. Were you charged with any violation of law (including any regulations or ordinances) arising out of the incident referred to in the Complaint? If so, what was the nature of the chart, 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 the charge, and if so, what is the name and address of the person or entity who prepared the report; do you have a copy of the report; and was the testimony at any trial, 2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 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. List the names and addresses of all persons believed or known to you, your agents or attorneys to have any knowledge concerning any of the issues raised by the pleadings and specify the subject matter about which the witness has knowledge. 11. 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 issues in this lawsuit? If so, state the name, residence address, business address and telephone number of each person believed or known by you, your agents or attorneys to have heard or who is purported to have heard the Plaintiff make any statement, remark or comment concerning the accident described in the Complaint and the substance of each statement, remark or comment. 12. State the name and address of each person known to you, your agents or attorneys who have knowledge about, or possession, custody or control of any model, plat, map, drawing, motion picture, video tape, or photographs 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. 13. Do you intend to call any expert witness at the trial of this case? If so, please identify such witness, describe his qualifications as an expert, state the subject matter upon which he is expected to testify, state the substance of the facts and opinions to which he is expected to testify, and give a summary of the grounds for each opinion. 2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4 14. 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. 15. Please state if you have ever been a party either plaintiff or defendant in a lawsuit other than the present matter and, if so, state whether you were plaintiff or defendant, the nature of the action, and the date and court in which such suit was filed. 16. Do you wear glasses or contact lenses? If so, who prescribed them, when were they prescribed, when were your eyes last examined and by whom? 17. 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? 18. Did you consume any alcoholic beverages or take any drugs or medication within 12 hours before the occurrence of the accident described in the Complaint? If so, what type and amount of alcoholic beverages, drugs or medications were consumed and where did you consume them? 19. Did any mechanical defect in the motor vehicle you were driving at the time of the accident contribute to the occurrence of the accident? If so, what was the nature of the defect? 2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5 20. List the names and addresses of all persons, corporations, or entities who were the registered title owners or who had any legal or ownership interest in, or right to control the motor vehicle that was being driven on the date of the accident described in the Complaint and describe both the nature of the ownership interest or right to control the vehicle, and the vehicle itself, including the make, model, year and vehicle identification number. 21. At the time of the incident described in the Complaint, was the defendant driver engaged in any mission or activity for any other person or entity, including any employer? If so, state the name and address of that person or entity and the nature of the mission or activity. 22. Was the motor vehicle that you owned or were operating at the time of the accident described in the complaint damaged in the incident and if so, what was the cost to repair the damage? 23. Do you, your agents, investigators, or attorneys have surveillance tape, movies, or film of any kind of the Plaintiff? If so, please state the name and address of the current custodian of the same. 24. Did you have a cellular telephone(s) and/or other mobile devices available for your use on the day of the subject accident? If so, for each available cellular telephone and/or mobile device, please provide the following: the name and address of the carrier; the account number; the cellular telephone/mobile number and/or account; and the name of the account holder. 2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6 ________________________ CHLOE CORREIA PLEASANTS STATE OF ____________________ COUNTY OF __________________________ The foregoing instrument was acknowledged before me, an officer duly authorized in the State and County aforesaid, to take acknowledgments, this _____ day of _________, 2024, who states that the foregoing answers to Interrogatories are true to the best of his/her information and belief and who: [ ] is personally know to me; or [ ] who has produced __________________as identification; and who: [ ] did or [ ] did not, take an oath. _____________________________ NOTARY PUBLIC My Commission Expires: _____________________________ (Print Name) (Seal) _____________________________ (Serial Number, if any) 2/13/2024 3:15 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7