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**** CASE NUMBER: 502024CA003243XXXAMB Div: AO ****
Filing # 195607795 E-Filed 04/05/2024 03:56:00 PM
IN THE CIRCUIT COURT OF THE 15th
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO:
TWANE FORRESTER,
Plaintiff,
vs.
MARCOS RAMIREZ, and
PROGRESSIVE SELECT INSURANCE
CO.,
Defendants.
___________________________/
NOTICE OF SERVICE OF PLAINTIFF’S
FIRST SET OF INTERROGATORIES TO DEFENDANT
Plaintiff, by and through his undersigned counsel, files this Notice of Service of Plaintiff’s
First Set of Interrogatories together with the Complaint, to be answered by Defendant, MARCOS
RAMIREZ, in writing and under oath, within 45 days of service of same.
CERTIFICATE OF SERVICE
A true and correct copy of these Interrogatories were served together with a copy of the
Summons, Complaint, Request for Admissions and Request for Production.
WOLFSON & LEON
ATTORNEYS FOR PLAINTIFF
3399 Southwest 3rd Avenue
Miami, Florida 33145
(305) 285-1115 - Telephone
(305) 285-1608 – Facsimile
eservice@wolfsonlawfirm.com
CSoret@wolfsonlawfirm.com
/s/ Caroline Soret
By: __________________________
CAROLINE SORET, ESQ
FLA BAR NO: 183430
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 04/05/2024 03:56:00 PM
INTERROGATORIES TO DEFENDANT
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. Describe any and all policies of insurance which you contend cover or may cover you, your
company and/or organization named as the Defendant for the allegations set forth in Plaintiff's
Complaint, providing:
a. the name of the insurer and policy number
b. the effective dates of the policy;
c. the available limits of liability;
d. Self-insured retention and/or deductible, if any, and
e. the name and address of the custodian of the policy.
3. Describe in detail how the incident described in the Complaint happened, including all actions
taken by you to prevent the incident.
4. Describe in detail each act or omission on the part of any party to this lawsuit or any other
person or entity that you contend constituted negligence that was a contributing legal cause of
the incident in question.
5. State the facts upon which you rely for each Affirmative Defense in your Answer.
6. Do you contend any person or entity other than you is, or may be, liable in whole or in 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.
7. 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 issued in this lawsuit, and specify
the subject matter about which the witness has knowledge.
8. Have you heard or do you know about any statement or remark made by or on behalf of any
party of this lawsuit, other than yourself, concerning any issue in this lawsuit? If so, state the
name and address of each such 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. 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.
10. 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' 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 summary of all grounds for each
opinion.
10. 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.
11. 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.
12. Has this Defendant been sued under its correct name? If not, please state the correct name
and explain your answer so that service may be properly obtained.
13. Please state whether or not you have a copy of any statement which the Plaintiff has previously
made concerning this action or its subject matter and which is in your possession, custody, or
control. If so, please provide a copy of that statement to Plaintiff's counsel.
(For the purpose of this question, statement previously made includes: [1] written statement
signed or otherwise adopted or proved by the person making it, [2] stenographic, mechanical,
electrical or other recording, or a transcription thereof, which is a substantially verbatim recital
of an oral statement by the person making it and contemporaneously recorded.)
15. 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.
16. List the name and address of all persons, corporations, or entities who are registered title
owners or who had ownership interest in, or right to control, the motor vehicle that the
defendant driver was 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.
17. At the time of the incident described in the complaint, did the driver of the vehicle described
in your answer to the preceding interrogatory have permission to drive the vehicle? If so, state
the names and addresses of all persons who have such permission.
18. At the time of the incident described in the complaint, was the defendant driver engaged in
any mission or activity for any other person or entity, including any employer? If so, state the
name and address of the person or entity and the nature of the mission or activity.
19. Was the motor vehicle that the defendant driver was driving at the time of the incident in the
complaint damaged in the incident and if so, what was the cost to repair the damage? If a
total loss, what were the estimated damages to the vehicle?
20. List all former names and when you were known by those names. State all addresses where
you have lived for the past 10 years, the dates you lived at each address, your Social Security
number, and your date of birth.
21. 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 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.
22. 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?
23. Did you or did anyone on your behalf perform any type of surveillance on the Plaintiff? If so,
when and where?
__________________________________
STATE OF FLORIDA )
) SS:
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared, who is well known to
me or who has produced ____________________________ as identification, deposes and states that
the foregoing matters are truthful and correct to the best of her knowledge and belief.
___________________________
SWORN TO AND SUBSCRIBED
before me this _________ day
of ________________, 20___.
________________________
Notary Public
My Commission Expires:
_________________________
Commission Number
Preview
**** CASE NUMBER: 502024CA003243XXXAMB Div: AO **** Filing # 195607795 E-Filed 04/05/2024 03:56:00 PM IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: TWANE FORRESTER, Plaintiff, vs. MARCOS RAMIREZ, and PROGRESSIVE SELECT INSURANCE CO., Defendants. ___________________________/ NOTICE OF SERVICE OF PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT Plaintiff, by and through his undersigned counsel, files this Notice of Service of Plaintiff’s First Set of Interrogatories together with the Complaint, to be answered by Defendant, MARCOS RAMIREZ, in writing and under oath, within 45 days of service of same. CERTIFICATE OF SERVICE A true and correct copy of these Interrogatories were served together with a copy of the Summons, Complaint, Request for Admissions and Request for Production. WOLFSON & LEON ATTORNEYS FOR PLAINTIFF 3399 Southwest 3rd Avenue Miami, Florida 33145 (305) 285-1115 - Telephone (305) 285-1608 – Facsimile eservice@wolfsonlawfirm.com CSoret@wolfsonlawfirm.com /s/ Caroline Soret By: __________________________ CAROLINE SORET, ESQ FLA BAR NO: 183430 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 04/05/2024 03:56:00 PM INTERROGATORIES TO DEFENDANT 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. Describe any and all policies of insurance which you contend cover or may cover you, your company and/or organization named as the Defendant for the allegations set forth in Plaintiff's Complaint, providing: a. the name of the insurer and policy number b. the effective dates of the policy; c. the available limits of liability; d. Self-insured retention and/or deductible, if any, and e. the name and address of the custodian of the policy. 3. Describe in detail how the incident described in the Complaint happened, including all actions taken by you to prevent the incident. 4. Describe in detail each act or omission on the part of any party to this lawsuit or any other person or entity that you contend constituted negligence that was a contributing legal cause of the incident in question. 5. State the facts upon which you rely for each Affirmative Defense in your Answer. 6. Do you contend any person or entity other than you is, or may be, liable in whole or in 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. 7. 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 issued in this lawsuit, and specify the subject matter about which the witness has knowledge. 8. Have you heard or do you know about any statement or remark made by or on behalf of any party of this lawsuit, other than yourself, concerning any issue in this lawsuit? If so, state the name and address of each such 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. 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. 10. 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' 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 summary of all grounds for each opinion. 10. 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. 11. 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. 12. Has this Defendant been sued under its correct name? If not, please state the correct name and explain your answer so that service may be properly obtained. 13. Please state whether or not you have a copy of any statement which the Plaintiff has previously made concerning this action or its subject matter and which is in your possession, custody, or control. If so, please provide a copy of that statement to Plaintiff's counsel. (For the purpose of this question, statement previously made includes: [1] written statement signed or otherwise adopted or proved by the person making it, [2] stenographic, mechanical, electrical or other recording, or a transcription thereof, which is a substantially verbatim recital of an oral statement by the person making it and contemporaneously recorded.) 15. 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. 16. List the name and address of all persons, corporations, or entities who are registered title owners or who had ownership interest in, or right to control, the motor vehicle that the defendant driver was 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. 17. At the time of the incident described in the complaint, did the driver of the vehicle described in your answer to the preceding interrogatory have permission to drive the vehicle? If so, state the names and addresses of all persons who have such permission. 18. At the time of the incident described in the complaint, was the defendant driver engaged in any mission or activity for any other person or entity, including any employer? If so, state the name and address of the person or entity and the nature of the mission or activity. 19. Was the motor vehicle that the defendant driver was driving at the time of the incident in the complaint damaged in the incident and if so, what was the cost to repair the damage? If a total loss, what were the estimated damages to the vehicle? 20. List all former names and when you were known by those names. State all addresses where you have lived for the past 10 years, the dates you lived at each address, your Social Security number, and your date of birth. 21. 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 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. 22. 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? 23. Did you or did anyone on your behalf perform any type of surveillance on the Plaintiff? If so, when and where? __________________________________ STATE OF FLORIDA ) ) SS: COUNTY OF ) BEFORE ME, the undersigned authority, personally appeared, who is well known to me or who has produced ____________________________ as identification, deposes and states that the foregoing matters are truthful and correct to the best of her knowledge and belief. ___________________________ SWORN TO AND SUBSCRIBED before me this _________ day of ________________, 20___. ________________________ Notary Public My Commission Expires: _________________________ Commission Number