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Filing # 169108452 E-Filed 03/20/2023 01:09:16 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO:
LUIS ANTONIO DAVILA,
Plaintiff,
vs.
RALPH JACQUES AND
HOME DEPOT USA INC,
Defendants.
/
NOTICE OF SERVICE OF INTERROGATORIES
TO: RALPH JACQUES
COMES NOW the Plaintiff, LUIS ANTONIO DAVILA, by and through the undersigned
counsel and hereby propounds upon Defendant, RALPH JACQUES, within forty-five (45) days
from the date of service hereof.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
said Defendant, along with the summons and complaint.
/s/ Manuel Stefan, Esq.
Manuel “Manny” Stefan, Esq.
Florida Bar No.: 0103389
MORGAN & MORGAN, P.A.
4495 South Semoran Blvd.
Orlando, FL 32822
Telephone No.: (407) 452-6982
Facsimile No.: (407) 572-0124
Primary email: MStefan@forthepeople.com
Secondary email: cvictor@forthepeople.com
Attorney for Plaintiff
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO:
LUIS ANTONIO DAVILA,
Plaintiff,
vs.
RALPH JACQUES AND
HOME DEPOT USA, INC,
Defendants.
/
INTERROGATORIES TO DEFENDANT RALPH JACQUES
Plaintiff, LUIS ANTONIO DAVILA, by and through his/her/their undersigned counsel,
propounds the attached Interrogatories, numbered one (1) through twenty-five (25) to Defendant,
RALPH JACQUES, to be answered, under oath, within forty-five (45) days from date of service.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
said Defendant, along with the summons and complaint.
/s/ Manuel Stefan, Esq.
Manuel “Manny” Stefan, Esq.
Florida Bar No.: 0103389
MORGAN & MORGAN, P.A.
4495 South Semoran Blvd.
Orlando, FL 32822
Telephone No.: (407) 452-6982
Facsimile No.: (407) 572-0124
Primary email: MStefan@forthepeople.com
Secondary email: cvictor@forthepeople.com
Attorney for Plaintiff
GENERAL PERSONAL INJURY NEGLIGENCE-
INTERROGATORIES TO DEFENDANT RALPH JACQUES
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. 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 was punishable 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 and the date and 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.
5. Describe in detail how the incident described in the Complaint happened, including all actions
taken by you to prevent the incident.
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 cause of the incident 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 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 described in the Complaint? If so, what was the nature of the charge; 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, hearing, or other proceeding on the charge recorded in any manner, and, if so, what is
the name and address of the person who recorded the testimony.
10. List the names and addresses of all persons who are believed or known by you, your agents, or
your attorneys to have any knowledge concerning any of the issues in this lawsuit; 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 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.
12. 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.
13. 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.
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, contact lenses, or hearing aids? If so, who prescribed them, when were
they prescribed, when were your eyes or ears last examined, and what is the name and address of
the examiner?
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 medications within twelve (12)
hours before the time of the incident described in the Complaint? If so, state the type and
amount of alcoholic beverages, drugs, or medication which were consumed, and when and where
you consumed them.
19. Did any mechanical defect in the motor vehicle in which you were riding at the time of the incident
described in the Complaint contribute to the incident? If so, describe the nature of the defect and
how it contributed to the incident.
20. List the name and address of all persons, corporations, or entities who were registered title owners
or who had ownership interest in, or right to control, the motor vehicle that you were driving at
the time of the incident 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. Describe in complete detail the appearance of the Plaintiff immediately after the Plaintiff’s alleged
occurrence, including any obvious injuries, the emotional state of the Plaintiff, whether the
Plaintiff appeared in pain or otherwise.
22. On the date of the subject incident described in the complaint, did you have a contract for
service of with cellular telephone service provider or access to any cellular service, regardless
of whose phone you were using, if not your own? If the answer is yes, please state the cell
phone number, account number, service provider and state if the account was in your name, a
business name or any another name for your use and benefit. If you were in possession of
multiple devices, please provide all in your possession on date of the incident described in
complaint.
23. At the time of the accident, were you utilizing your cellular phone or device? If yes, please
describe in what way you were utilizing the device or phone (i.e.; texting, calling, internet, or
application use).
24. Was the motor vehicle that you were driving at the time of the incident described in the Complaint
damaged in the accident, and, if so, what was the cost to repair the damage?
25. Have you ever been diagnosed with a neurological condition or sleep apnea? If so, when were you
diagnosed and what is the name of the doctor that diagnosed you?
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 _________ knowledge and belief.
Signature of Defendant
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:
Preview
Filing # 169108452 E-Filed 03/20/2023 01:09:16 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: LUIS ANTONIO DAVILA, Plaintiff, vs. RALPH JACQUES AND HOME DEPOT USA INC, Defendants. / NOTICE OF SERVICE OF INTERROGATORIES TO: RALPH JACQUES COMES NOW the Plaintiff, LUIS ANTONIO DAVILA, by and through the undersigned counsel and hereby propounds upon Defendant, RALPH JACQUES, within forty-five (45) days from the date of service hereof. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon said Defendant, along with the summons and complaint. /s/ Manuel Stefan, Esq. Manuel “Manny” Stefan, Esq. Florida Bar No.: 0103389 MORGAN & MORGAN, P.A. 4495 South Semoran Blvd. Orlando, FL 32822 Telephone No.: (407) 452-6982 Facsimile No.: (407) 572-0124 Primary email: MStefan@forthepeople.com Secondary email: cvictor@forthepeople.com Attorney for Plaintiff IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: LUIS ANTONIO DAVILA, Plaintiff, vs. RALPH JACQUES AND HOME DEPOT USA, INC, Defendants. / INTERROGATORIES TO DEFENDANT RALPH JACQUES Plaintiff, LUIS ANTONIO DAVILA, by and through his/her/their undersigned counsel, propounds the attached Interrogatories, numbered one (1) through twenty-five (25) to Defendant, RALPH JACQUES, to be answered, under oath, within forty-five (45) days from date of service. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon said Defendant, along with the summons and complaint. /s/ Manuel Stefan, Esq. Manuel “Manny” Stefan, Esq. Florida Bar No.: 0103389 MORGAN & MORGAN, P.A. 4495 South Semoran Blvd. Orlando, FL 32822 Telephone No.: (407) 452-6982 Facsimile No.: (407) 572-0124 Primary email: MStefan@forthepeople.com Secondary email: cvictor@forthepeople.com Attorney for Plaintiff GENERAL PERSONAL INJURY NEGLIGENCE- INTERROGATORIES TO DEFENDANT RALPH JACQUES 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. 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 was punishable 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 and the date and 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. 5. Describe in detail how the incident described in the Complaint happened, including all actions taken by you to prevent the incident. 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 cause of the incident 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 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 described in the Complaint? If so, what was the nature of the charge; 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, hearing, or other proceeding on the charge recorded in any manner, and, if so, what is the name and address of the person who recorded the testimony. 10. List the names and addresses of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; 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 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. 12. 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. 13. 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. 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, contact lenses, or hearing aids? If so, who prescribed them, when were they prescribed, when were your eyes or ears last examined, and what is the name and address of the examiner? 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 medications within twelve (12) hours before the time of the incident described in the Complaint? If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when and where you consumed them. 19. Did any mechanical defect in the motor vehicle in which you were riding at the time of the incident described in the Complaint contribute to the incident? If so, describe the nature of the defect and how it contributed to the incident. 20. List the name and address of all persons, corporations, or entities who were registered title owners or who had ownership interest in, or right to control, the motor vehicle that you were driving at the time of the incident 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. Describe in complete detail the appearance of the Plaintiff immediately after the Plaintiff’s alleged occurrence, including any obvious injuries, the emotional state of the Plaintiff, whether the Plaintiff appeared in pain or otherwise. 22. On the date of the subject incident described in the complaint, did you have a contract for service of with cellular telephone service provider or access to any cellular service, regardless of whose phone you were using, if not your own? If the answer is yes, please state the cell phone number, account number, service provider and state if the account was in your name, a business name or any another name for your use and benefit. If you were in possession of multiple devices, please provide all in your possession on date of the incident described in complaint. 23. At the time of the accident, were you utilizing your cellular phone or device? If yes, please describe in what way you were utilizing the device or phone (i.e.; texting, calling, internet, or application use). 24. Was the motor vehicle that you were driving at the time of the incident described in the Complaint damaged in the accident, and, if so, what was the cost to repair the damage? 25. Have you ever been diagnosed with a neurological condition or sleep apnea? If so, when were you diagnosed and what is the name of the doctor that diagnosed you? 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 _________ knowledge and belief. Signature of Defendant 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: