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Filing # 195328170 E-Filed 04/02/2024 04:39:24 PM
IN THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT IN
AND FOR WALTON COUNTY, FLORIDA, CIVIL DIVISION
NIKKI MCCOTTER,
Plaintiff,
Vv. CASE NO.: 24000158CAAXMX
RUSSELL WEHRLIN, and
HAWK HEUNGSU GIM,
Defendants.
NOTICE OF SERVING PLAINTIFF'S FIRST SET OF INTERROGATORIES
TO DEFENDANT, RUSSELL WEHRLIN
Under authority of Rule 1.340, Florida Rules of Civil Procedure, you are hereby requested
to answer in writing and under oath, within forty-five (45) days from the receipt hereof, the attached
interrogatories. Perjury, or making a false statement under oath, is a felony of the third degree.
Fla. Stat. § 837.02 (1).
I HEREBY CERTIFY that a true and correct copy of the foregoing Notice, as well as the
Interrogatories themselves, has been provided to the above along with the Summons and
Complaint.
Respectfully submitted,
/s/ Drew Bruner
Drew Bruner, Esq.
Florida Bar No.: 098458
THE BRUNER LAW FIRM
110 Eglin Pkwy SE
Fort Walton Beach, FL 32548
drew@brunerfirm.com
jamie@brunerfirm.cor
neghan@brunerfirm.com
Phone: (850) 243-2222
Attorney for Plaintiff
Electronically Filed Walton Case # 24000158CAAXMX 04/02/2024 03:39:24 PM.
DEFINITIONS
As used herein, the terms "document" and documents" include, but are not limited to, all
paper material of any kind, whether written, typed, printed, punched, filmed, or marked in any way;
recording tapes or wires, film, photographs, movies or any graphic matter however produced or
reproduced; and all mechanical or electronic sound recordings or transcripts thereof.
As used herein, the term "person" includes a corporation, partnership, other business
association or entity, a natural person, and any government or governmental body, commission,
board or agency.
As used herein, the terms "identify" or "identification", when used in reference to an
individual person, means to state his full name, present address, if known, and his present
employment position and business affiliation. When used in reference to a person other than an
individual person, "identify" or "identification" means to state whether such person is a corporation,
partnership or other organization, and the name, present and last known address, and principal place
of its business. Once any person has been identified properly, it shall be sufficient thereafter, when
identifying that same person, to state his name only.
As used herein, the term "you" refers to the Defendant hereinabove mentioned.
As used herein, the term "incident" refers to the accident, casualty or event alleged in the
complaint giving rise to this action.
Please insert your answers in the space provided below each interrogatory. Should you need
additional space, please attach extra sheets.
INTERROGATORIES TO DEFENDANT RUSSELL WEHRLIN
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 years, the dates you lived at each address, your social
security number, your date of birth, and if you are, or, have ever been married, the name of your
spouse or spouses.
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 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 plaintiffs 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 this charge, and if so, what is the name and
address of the person or entity that 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 was 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 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 of 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 the statement.
12. State the name and address of every person known to you, your agents or 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 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.
< END OF INTERROGATORIES >
RUSSELL WEHRLIN
STATE OF
COUNTY OF
The foregoing instrument was sworn and subscribed before me this day of
> 2024 by RUSSELL WEHRLIN who has produced
as identification and who did/did not take an oath that the
statements therein are true and the best of his/her knowledge and belief.
Notary Public (Signature)
Printed Name
My Commission. Expires:
Preview
Filing # 195328170 E-Filed 04/02/2024 04:39:24 PM IN THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT IN AND FOR WALTON COUNTY, FLORIDA, CIVIL DIVISION NIKKI MCCOTTER, Plaintiff, Vv. CASE NO.: 24000158CAAXMX RUSSELL WEHRLIN, and HAWK HEUNGSU GIM, Defendants. NOTICE OF SERVING PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT, RUSSELL WEHRLIN Under authority of Rule 1.340, Florida Rules of Civil Procedure, you are hereby requested to answer in writing and under oath, within forty-five (45) days from the receipt hereof, the attached interrogatories. Perjury, or making a false statement under oath, is a felony of the third degree. Fla. Stat. § 837.02 (1). I HEREBY CERTIFY that a true and correct copy of the foregoing Notice, as well as the Interrogatories themselves, has been provided to the above along with the Summons and Complaint. Respectfully submitted, /s/ Drew Bruner Drew Bruner, Esq. Florida Bar No.: 098458 THE BRUNER LAW FIRM 110 Eglin Pkwy SE Fort Walton Beach, FL 32548 drew@brunerfirm.com jamie@brunerfirm.cor neghan@brunerfirm.com Phone: (850) 243-2222 Attorney for Plaintiff Electronically Filed Walton Case # 24000158CAAXMX 04/02/2024 03:39:24 PM. DEFINITIONS As used herein, the terms "document" and documents" include, but are not limited to, all paper material of any kind, whether written, typed, printed, punched, filmed, or marked in any way; recording tapes or wires, film, photographs, movies or any graphic matter however produced or reproduced; and all mechanical or electronic sound recordings or transcripts thereof. As used herein, the term "person" includes a corporation, partnership, other business association or entity, a natural person, and any government or governmental body, commission, board or agency. As used herein, the terms "identify" or "identification", when used in reference to an individual person, means to state his full name, present address, if known, and his present employment position and business affiliation. When used in reference to a person other than an individual person, "identify" or "identification" means to state whether such person is a corporation, partnership or other organization, and the name, present and last known address, and principal place of its business. Once any person has been identified properly, it shall be sufficient thereafter, when identifying that same person, to state his name only. As used herein, the term "you" refers to the Defendant hereinabove mentioned. As used herein, the term "incident" refers to the accident, casualty or event alleged in the complaint giving rise to this action. Please insert your answers in the space provided below each interrogatory. Should you need additional space, please attach extra sheets. INTERROGATORIES TO DEFENDANT RUSSELL WEHRLIN 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 years, the dates you lived at each address, your social security number, your date of birth, and if you are, or, have ever been married, the name of your spouse or spouses. 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 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 plaintiffs 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 this charge, and if so, what is the name and address of the person or entity that 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 was 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 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 of 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 the statement. 12. State the name and address of every person known to you, your agents or 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 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. < END OF INTERROGATORIES > RUSSELL WEHRLIN STATE OF COUNTY OF The foregoing instrument was sworn and subscribed before me this day of > 2024 by RUSSELL WEHRLIN who has produced as identification and who did/did not take an oath that the statements therein are true and the best of his/her knowledge and belief. Notary Public (Signature) Printed Name My Commission. Expires: