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Filing # 192922026 E-Filed 02/28/2024 12:45:42 PM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
SMALL CLAIMS
GULF COAST INJURY CENTER, LLC,
as assignee of MARCIA NAVARRO,
Plaintiff, CASE NO..:
vs.
OCEAN HARBOR CASUALTY INSURANCE COMPANY,
Defendant.
NOTICE OF SERVICE OF PLAINTIFF’S INTERROGATORIES
To: Ocean Harbor Casualty Insurance Company
C/o Insurance Commissioner
Department of Financial Services
200 East Gaines St.
Tallahassee, FL 32399
Plaintiff, Gulf Coast Injury Center, LLC, (hereinafter “Plaintiff”), by and through its
undersigned attorney, propounds to the Defendant, Ocean Harbor Casualty Insurance
Company, (hereinafter referred to as Defendant), pursuant to Rule 1.340 of the Florida Rules of
Civil Procedure, the attached written Interrogatories, answers to which will be due under oath
within thirty (45) days from the date of service hereof.
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EXPLANATION OF TERMS
As used in these Interrogatories, the following terms and definitions are intended to apply:
“You or Your” refers to the Defendant and its agents, employees, representatives and all
other persons acting on its behalf or at its request. Your response to these Interrogatories
must reflect and contain the knowledge of all persons embraced by the term “Defendant”
or the terms “you” or “your”.
“Person” refers to any corporation, individual, joint venture, partnership, group,
association, government agency, or any other identifiable entity.
“Communication” refers to the transmission, transfer or receipt of information in any
form, by any means, in any manner, at any time or place, under any circumstances
whatsoever.
“Document or Documents” refers to writings, letters, telegrams, memoranda, recorded
recollections of conferences or telephone conversations, reports, studies, lists, any written
compilation of data, papers, books, records, records, contracts, drawings, photographs,
mechanical or electronic recordings in any form, and all other identifiable objects upon
which any inscription, handwriting, typing, printing, drawing, representation by any
means, weather magnetic, electrical, photo static, or any other form of communication is
recorded, reproduced, perpetuated, maintained or preserved. These terms similarly
embrace the reproduction or copies of the foregoing.
“Identify a Document” refers to the requirement that the identity of the person preparing
the document be disclosed, the identity of all persons signing, issuing and/or attesting to
such document be disclosed, the identity of addresses or distributes be disclosed with
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sufficient particularity so as to enable identification. The date which the document was
prepared, released, or transmitted should be disclosed, and the physical location of the
document, together with the names and addresses of the custodian or custodians of the
documents should be disclosed.
“Identify a Person” when employed, with regard to a natural person, it refers to the name
of such person, the present or last known address of such person, the name and the
address of such person, the name and address of such person’s employer and the position
of employment held by such person. When the clause “identify person” is employed with
reference to a person that is not an individual, such term shall require the name and
principal office of such person, the date and place of incorporation, if applicable, and
such other information as necessary to identify, locate and/or communicate with such
person.
Gulf Coast Injury Center, LLC refers to the above-named Plaintiff in this action.
“Insured” refers to “Insured”.
“Injured Party” refers to Marcia Navarro.
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by
email on the date filed with the ePortal, to the above-named addressee.
/s/ C. Spencer Petty
C. Spencer Petty, Esq.
FBN: 051396
IRVIN & PETTY, P.A.
111 Second Ave. NE, Suite 630
St. Petersburg, FL 33701
Phone: (727) 350-7770
Designated service e-mail:
Pipservice@irvinandpetty.com
Attorney for Plaintiff
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Filing # 192922026 E-Filed 02/28/2024 12:45:42 PM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SMALL CLAIMS GULF COAST INJURY CENTER, LLC, as assignee of MARCIA NAVARRO, Plaintiff, CASE NO..: vs. OCEAN HARBOR CASUALTY INSURANCE COMPANY, Defendant. NOTICE OF SERVICE OF PLAINTIFF’S INTERROGATORIES To: Ocean Harbor Casualty Insurance Company C/o Insurance Commissioner Department of Financial Services 200 East Gaines St. Tallahassee, FL 32399 Plaintiff, Gulf Coast Injury Center, LLC, (hereinafter “Plaintiff”), by and through its undersigned attorney, propounds to the Defendant, Ocean Harbor Casualty Insurance Company, (hereinafter referred to as Defendant), pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, the attached written Interrogatories, answers to which will be due under oath within thirty (45) days from the date of service hereof. 2/28/2024 12:45 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 1 EXPLANATION OF TERMS As used in these Interrogatories, the following terms and definitions are intended to apply: “You or Your” refers to the Defendant and its agents, employees, representatives and all other persons acting on its behalf or at its request. Your response to these Interrogatories must reflect and contain the knowledge of all persons embraced by the term “Defendant” or the terms “you” or “your”. “Person” refers to any corporation, individual, joint venture, partnership, group, association, government agency, or any other identifiable entity. “Communication” refers to the transmission, transfer or receipt of information in any form, by any means, in any manner, at any time or place, under any circumstances whatsoever. “Document or Documents” refers to writings, letters, telegrams, memoranda, recorded recollections of conferences or telephone conversations, reports, studies, lists, any written compilation of data, papers, books, records, records, contracts, drawings, photographs, mechanical or electronic recordings in any form, and all other identifiable objects upon which any inscription, handwriting, typing, printing, drawing, representation by any means, weather magnetic, electrical, photo static, or any other form of communication is recorded, reproduced, perpetuated, maintained or preserved. These terms similarly embrace the reproduction or copies of the foregoing. “Identify a Document” refers to the requirement that the identity of the person preparing the document be disclosed, the identity of all persons signing, issuing and/or attesting to such document be disclosed, the identity of addresses or distributes be disclosed with 2/28/2024 12:45 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 2 sufficient particularity so as to enable identification. The date which the document was prepared, released, or transmitted should be disclosed, and the physical location of the document, together with the names and addresses of the custodian or custodians of the documents should be disclosed. “Identify a Person” when employed, with regard to a natural person, it refers to the name of such person, the present or last known address of such person, the name and the address of such person, the name and address of such person’s employer and the position of employment held by such person. When the clause “identify person” is employed with reference to a person that is not an individual, such term shall require the name and principal office of such person, the date and place of incorporation, if applicable, and such other information as necessary to identify, locate and/or communicate with such person. Gulf Coast Injury Center, LLC refers to the above-named Plaintiff in this action. “Insured” refers to “Insured”. “Injured Party” refers to Marcia Navarro. 2/28/2024 12:45 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by email on the date filed with the ePortal, to the above-named addressee. /s/ C. Spencer Petty C. Spencer Petty, Esq. FBN: 051396 IRVIN & PETTY, P.A. 111 Second Ave. NE, Suite 630 St. Petersburg, FL 33701 Phone: (727) 350-7770 Designated service e-mail: Pipservice@irvinandpetty.com Attorney for Plaintiff 2/28/2024 12:45 PM Electronically Filed: Hillsborough County/13th J udicial Circuit Page 4