On April 03, 2024 a
Proof of Service
was filed
involving a dispute between
Garcia, Sohany,
and
Price, Jerome Arthur,
Williams, Mark,
for Civil
in the District Court of Hillsborough County.
Preview
Filing # 195369580 E-Filed 04/03/2024 10:54:01 AM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA.
CIVIL ACTION
SOHANY GARCIA,
Plaintiff,
Case No.
vs.
JEROME ARTHUR PRICE
and MARK WILLIAMS,
Defendants.
________________________________/
NOTICE OF SERVICE OF PLAINTIFF’S FIRST INTERROGATORIES
TO DEFENDANT, MARK WILLIAMS
Plaintiff, by and through the undersigned attorneys, herein serves these First
Interrogatories upon the defendant, Mark Williams, and request answers in accordance with
the applicable Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing was duly served upon the
Defendants with the Complaint served in this cause.
/s/Kevin McLaughlin_____
KEVIN McLAUGHLIN
Florida Bar No. 0085928
Wagner McLaughlin& Whittemore, P.A.
601 Bayshore Blvd., Suite 910
Tampa, FL 33606
(813) 225-4000
Primary Email: Kevin@wagnerlaw.com
Secondary Email: Arelys@wagnerlaw.com
Attorneys for Plaintiff
4/3/2024 10:54 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
INTERROGATORIES TO MARK WILLIAMS
1. 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, 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. 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 and
the date and place of conviction.
3. 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.
4. Describe in detail how the incident described in the Complaint happened, including all
actions taken by you or Jerome Arthur Price prevent the incident.
5. 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.
2
4/3/2024 10:54 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
6. State the facts upon which you rely for each Affirmative Defense in your Answer.
7. 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.
8. 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.
9. Did any mechanical defect in the motor vehicle Jerome Arthur Price was driving at the
time of the accident contribute to the occurrence of the accident? If so, what was the
nature of the defect?
10. Did the motor vehicle Jerome Arthur Price was driving at the time of the accident
described in the Complaint contain any video recording devices/systems? If so, please
describe the device/system.
11. Did the motor vehicle Jerome Arthur Price was driving at the time of the accident
described in the Complaint contain any Event Data Recorder (EDR)?
12. Did the motor vehicle Jerome Arthur Price was driving at the time of the accident
described in the Complaint contain any Electronic Control Module (ECM)?
3
4/3/2024 10:54 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
VERIFICATION PAGE
_______________________________
Mark Williams
STATE OF FLORIDA
COUNTY OF _____________
The foregoing instrument was acknowledged before me this ______ day of
___________, 2024 by _____________________________, who is personally known to me or who
has produced _________________________________ as identification and who did (did not) take an
oath.
_______________________________________
NOTARY PUBLIC
STATE OF FLORIDA AT LARGE
My Commission Expires:
Serial Number:__________________________
4
4/3/2024 10:54 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4
Document Filed Date
April 03, 2024
Case Filing Date
April 03, 2024
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Filing # 195369580 E-Filed 04/03/2024 10:54:01 AM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA. CIVIL ACTION SOHANY GARCIA, Plaintiff, Case No. vs. JEROME ARTHUR PRICE and MARK WILLIAMS, Defendants. ________________________________/ NOTICE OF SERVICE OF PLAINTIFF’S FIRST INTERROGATORIES TO DEFENDANT, MARK WILLIAMS Plaintiff, by and through the undersigned attorneys, herein serves these First Interrogatories upon the defendant, Mark Williams, and request answers in accordance with the applicable Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was duly served upon the Defendants with the Complaint served in this cause. /s/Kevin McLaughlin_____ KEVIN McLAUGHLIN Florida Bar No. 0085928 Wagner McLaughlin& Whittemore, P.A. 601 Bayshore Blvd., Suite 910 Tampa, FL 33606 (813) 225-4000 Primary Email: Kevin@wagnerlaw.com Secondary Email: Arelys@wagnerlaw.com Attorneys for Plaintiff 4/3/2024 10:54 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 INTERROGATORIES TO MARK WILLIAMS 1. 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, 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. 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 and the date and place of conviction. 3. 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. 4. Describe in detail how the incident described in the Complaint happened, including all actions taken by you or Jerome Arthur Price prevent the incident. 5. 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. 2 4/3/2024 10:54 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 6. State the facts upon which you rely for each Affirmative Defense in your Answer. 7. 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. 8. 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. 9. Did any mechanical defect in the motor vehicle Jerome Arthur Price was driving at the time of the accident contribute to the occurrence of the accident? If so, what was the nature of the defect? 10. Did the motor vehicle Jerome Arthur Price was driving at the time of the accident described in the Complaint contain any video recording devices/systems? If so, please describe the device/system. 11. Did the motor vehicle Jerome Arthur Price was driving at the time of the accident described in the Complaint contain any Event Data Recorder (EDR)? 12. Did the motor vehicle Jerome Arthur Price was driving at the time of the accident described in the Complaint contain any Electronic Control Module (ECM)? 3 4/3/2024 10:54 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 VERIFICATION PAGE _______________________________ Mark Williams STATE OF FLORIDA COUNTY OF _____________ The foregoing instrument was acknowledged before me this ______ day of ___________, 2024 by _____________________________, who is personally known to me or who has produced _________________________________ as identification and who did (did not) take an oath. _______________________________________ NOTARY PUBLIC STATE OF FLORIDA AT LARGE My Commission Expires: Serial Number:__________________________ 4 4/3/2024 10:54 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4