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Filing # 192011568 E-Filed 02/15/2024 09:55:29 AM
IN THE CIRCUIT COURT OF THE
THIRD JUDICIAL CIRCUIT IN
AND FOR HAMILTON COUNTY, FLORIDA
LINDA GONZALEZ,
Plaintiffis),
CASE NUMBER: yLCPY 2224
Vs. Circuit Civil Division
PROGRESSIVE AMERICAN INSURANCE
COMPANY,
Defendant(s).
oe oe _
PLAINTIFF LINDA GONZALEZ'S NOTICE OF SERVICE OF FI ET OF
INTERROGATORIES TO DEFENDANT PROGRESSIVE AMERICA) URANCE
COMPANY
Pursuant to Rule 1.340, Florida Rules of Civil Procedure, Plaintiff LINDA GONZALEZ
serves Plaintiff LINDA GONZALEZ’s First Set of Interrogatomes to Defendant, numbered |
through 17 and requests Defendant answer the same under oath and in writing, within forty-five
(45) days from the date of service.
CERTIFICATE
SERA OF SERVICE
EE SER
1 HEREBY CERTIFY that a true copy of the foregoing has been furnished to the
Defendant, together with the Summons and Complaint.
b0B.B. 198i
Barr nnn
“ot DB. Barrow, F quire
FBN # 1011266
Morgan & Morgan, P.A.
104 North Main Stre: Suite 500
Gainesville, FL 32601
P: (904) 361-7184
F: (904) 361-4482
Ow orthepeople.com
Adri vez@forthepeople.com,
JReynol orthep com
Attorneys for Plaintiff
PLAINTIFF LINDA GONZALEZ’S FIRST SET OF INTERROGATORIES TO
DEFENDANT PROGRESSIVE AMERICAN INSURANCE COMPANY
1 What is the name, address and telephone number 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. Describe in detail any and all acts or omissions on the part of any person that you
contend constituted negligence that was a contributing legal cause of the subject collision.
3 State the facts upon which Defendant relies for each affirmative defense in
Defendant’s answer.
4 List the names, addresses and telephone numbers of all persons who have any
knowledge concerning any of the issues in this lawsuit; and specify the subject matter about
which the witness has knowledge.
5 Does Defendant contend that any coverage defense exists with respect to
Plaintiff's automobile insurance policy in this action?
6 Has Defendant obtained any written or recorded statement from any person
pertaining to the collision described in the complaint? If so, provide the name, address and phone
number of every person who provided a statement and provide the name, employer and job title
of the person who took the statement.
7 State the name, address and telephone number of every person known to
Defendant, Defendant’s 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.
8 Is Defendant aware of any prior accident, injury, personal injury claim, workers’
compensation injury or litigation involving the Plaintiff before or after the subject collision? If
so, provide the date of incident, location and general description of the incident.
9. State every fact that explains Defendant’s denial of Plaintiff LINDA
GONZALEZ’s claim for the $10,000.00 in uninsured motorist coverage available to Plaintiff
under the subject policy of automobile insurance.
10. Does Defendant contend Plaintiff LINDA GONZALEZ was not permanently
injured in the collision described in the complaint? If so, state the factual basis for Defendant’s
contention.
11. Does Defendant contend Plaintiff LINDA GONZALEZ’s medical care and
treatment provided following the subject collision was not reasonable, necessary and related to
the subject collision? If so, state the factual basis for Defendant’s contention.
12. Does Defendant contend Plaintiff LINDA GONZALEZ was in any way
comparatively negligent in causing the subject collision? If so, state the factual basis for
Defendant’s contention.
13. Does Defendant contend Plaintiff LINDA GONZALEZ is entitled to recover
under any other policy of insurance that could inure to Plaintiff’s benefit as a result of the subject
collision. This includes but is not limited to any and all excess, umbrella or other liability policies
that may provide coverage for the allegations set forth in Plaintiffs Complaint.? If so, identify
every such policy of insurance and provide the name of the insurance company, named insureds,
policy number and effective dates of coverage.
14. Please state whether Defendant contends Plaintiff LINDA GONZALEZ’s Civil
Remedy Notice lacks specificity. If the answer is yes, please identify the portion(s) of the Civil
Remedy Notice that you claim is insufficiently specific.
15. Please describe in detail all alleged defects with Plaintiff LINDA GONZALEZ’s
Civil Remedy Notice.
16. Please describe in detail what prevents Defendant from properly responding to
Plaintiff LINDA GONZALEZ’s Civil Remedy Notice.
17. Please state what additional information Defendant needs to properly respond to
Plaintiff LINDA GONZALEZ’s Civil Remedy Notice.
SIGNATURE PAGE
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 her knowledge and belief.
PROGRESSIVE AMERICAN
INSURANCE COMPANY
SWORN TO AND SUBSCRIBED before me this day of , 2024.
Notary Public (signature)
Notary Public (type, print stamp commission)
My Commission Expires:
Personally Known OR
Produced Identification
Type of Identification Produced:
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Filing # 192011568 E-Filed 02/15/2024 09:55:29 AM IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT IN AND FOR HAMILTON COUNTY, FLORIDA LINDA GONZALEZ, Plaintiffis), CASE NUMBER: yLCPY 2224 Vs. Circuit Civil Division PROGRESSIVE AMERICAN INSURANCE COMPANY, Defendant(s). oe oe _ PLAINTIFF LINDA GONZALEZ'S NOTICE OF SERVICE OF FI ET OF INTERROGATORIES TO DEFENDANT PROGRESSIVE AMERICA) URANCE COMPANY Pursuant to Rule 1.340, Florida Rules of Civil Procedure, Plaintiff LINDA GONZALEZ serves Plaintiff LINDA GONZALEZ’s First Set of Interrogatomes to Defendant, numbered | through 17 and requests Defendant answer the same under oath and in writing, within forty-five (45) days from the date of service. CERTIFICATE SERA OF SERVICE EE SER 1 HEREBY CERTIFY that a true copy of the foregoing has been furnished to the Defendant, together with the Summons and Complaint. b0B.B. 198i Barr nnn “ot DB. Barrow, F quire FBN # 1011266 Morgan & Morgan, P.A. 104 North Main Stre: Suite 500 Gainesville, FL 32601 P: (904) 361-7184 F: (904) 361-4482 Ow orthepeople.com Adri vez@forthepeople.com, JReynol orthep com Attorneys for Plaintiff PLAINTIFF LINDA GONZALEZ’S FIRST SET OF INTERROGATORIES TO DEFENDANT PROGRESSIVE AMERICAN INSURANCE COMPANY 1 What is the name, address and telephone number 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. Describe in detail any and all acts or omissions on the part of any person that you contend constituted negligence that was a contributing legal cause of the subject collision. 3 State the facts upon which Defendant relies for each affirmative defense in Defendant’s answer. 4 List the names, addresses and telephone numbers of all persons who have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. 5 Does Defendant contend that any coverage defense exists with respect to Plaintiff's automobile insurance policy in this action? 6 Has Defendant obtained any written or recorded statement from any person pertaining to the collision described in the complaint? If so, provide the name, address and phone number of every person who provided a statement and provide the name, employer and job title of the person who took the statement. 7 State the name, address and telephone number of every person known to Defendant, Defendant’s 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. 8 Is Defendant aware of any prior accident, injury, personal injury claim, workers’ compensation injury or litigation involving the Plaintiff before or after the subject collision? If so, provide the date of incident, location and general description of the incident. 9. State every fact that explains Defendant’s denial of Plaintiff LINDA GONZALEZ’s claim for the $10,000.00 in uninsured motorist coverage available to Plaintiff under the subject policy of automobile insurance. 10. Does Defendant contend Plaintiff LINDA GONZALEZ was not permanently injured in the collision described in the complaint? If so, state the factual basis for Defendant’s contention. 11. Does Defendant contend Plaintiff LINDA GONZALEZ’s medical care and treatment provided following the subject collision was not reasonable, necessary and related to the subject collision? If so, state the factual basis for Defendant’s contention. 12. Does Defendant contend Plaintiff LINDA GONZALEZ was in any way comparatively negligent in causing the subject collision? If so, state the factual basis for Defendant’s contention. 13. Does Defendant contend Plaintiff LINDA GONZALEZ is entitled to recover under any other policy of insurance that could inure to Plaintiff’s benefit as a result of the subject collision. This includes but is not limited to any and all excess, umbrella or other liability policies that may provide coverage for the allegations set forth in Plaintiffs Complaint.? If so, identify every such policy of insurance and provide the name of the insurance company, named insureds, policy number and effective dates of coverage. 14. Please state whether Defendant contends Plaintiff LINDA GONZALEZ’s Civil Remedy Notice lacks specificity. If the answer is yes, please identify the portion(s) of the Civil Remedy Notice that you claim is insufficiently specific. 15. Please describe in detail all alleged defects with Plaintiff LINDA GONZALEZ’s Civil Remedy Notice. 16. Please describe in detail what prevents Defendant from properly responding to Plaintiff LINDA GONZALEZ’s Civil Remedy Notice. 17. Please state what additional information Defendant needs to properly respond to Plaintiff LINDA GONZALEZ’s Civil Remedy Notice. SIGNATURE PAGE 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 her knowledge and belief. PROGRESSIVE AMERICAN INSURANCE COMPANY SWORN TO AND SUBSCRIBED before me this day of , 2024. Notary Public (signature) Notary Public (type, print stamp commission) My Commission Expires: Personally Known OR Produced Identification Type of Identification Produced: