Proof of Service: ALEXANDER LLERENA, ASHEL vs. RODRIGUEZ CHAVEZ, ADRIAN

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                                Filing # 189181448 E-Filed 01/05/2024 01:05:14 PM


                    IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
                            IN AND FOR OSCEOLA COUNTY FLORIDA

        ASBEL ALEXANDER LLERENA,                                          CASE NO: 2020 CA 002872 AN

                        Plaintiff,
        vs.

        ADRIAN RODRIGUEZ CHAVEZ,
        and GRANNY’S GARDEN II, INC.,

                        Defendant.
                                                       /

                    NOTICE OF SERVICE OF SURVEILLANCE INTERROGATORIES

                COMES NOW, the Plaintiff, ASBEL ALEXANDER LLERENA, by and through the

        undersigned counsel and hereby propounds upon Defendants, ADRIAN RODRIGUEZ CHAVEZ,

        and GRANNY’S GARDEN II, INC., the attached surveillance interrogatories, answers to which

        will be due within thirty (30) days from the date of service hereof.

                                          CERTIFICATE OF SERVICE

                I HEREBY CERTIFY that on January 5, 2023, I electronically filed the foregoing with
        the Clerk of the Courts by using the Florida Courts eFiling Portal. I further certify that Pursuant
        to Rule 2.516(b)(1) I forwarded the foregoing this same day via Email to: Scott Shelton, Esq. of
        Cole,   Scott   &    Kissane,    P.A.,   Scott.Shelton@csklegal.com;    gary.lewis@csklegal.com;
        Sandra.mcintosh@csklegal.com.

                                                       /s/ Melissa Alzate
                                                       Melissa Alzate, Esquire
                                                       FBN 1013530
                                                       Morgan & Morgan Orlando P.A.
                                                       198 Broadway Avenue
                                                       Kissimmee, Florida 34741
                                                       Telephone: (407) 452-1597
                                                       Facsimile: (407) 452-1623
                                                       Primary Email: MAlzate@forthepeople.com
                                                       Secondary Email: MCorianoLopez@forthepeople.com
                                                       Tertiary Email: VPagan@forthepeople.com
                                                       Attorney for Plaintiff
             SURVEILLANCE INTERROGATORIES TO DEFENDANT

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.   Please advise as to whether or not surveillance of any kind has been conducted of the
     plaintiff(s) in this case by any individual or entity. If so, please describe the following:

        a)      The nature of such surveillance (i.e., photographic, video, etc.)




        b)      The date(s) of the subject surveillance.




        c)      The time(s) of such surveillance.




        d)      The location(s) of such surveillance.




        e)      The name(s), address(es), employer(s), and phone number(s) of the
                individual(s) conducting such surveillance.




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f)   The fee(s) and/or hourly rate paid to each surveillance company for each date(s)
     of surveillance




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                                       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 Defendants



SWORN TO AND SUBSCRIBED before me this
     day of                      , 2023.



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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