Preview
Filing # 196211217 E-Filed 04/15/2024 02:58:48 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
DELANEY JAROSIK, CASE NO.:
Plaintiff,
vs.
NICHOLAS M. VALDALEZ, GLORY LIZ
VALDALEZ and PROGRESSIVE AMERICAN
INSURANCE COMPANY,
Defendants.
PLAINTIFF’S NOTICE OF SERVING INITIAL INTERROGATORIES
TO DEFENDANT, GLORY LIZ VALDALEZ
Plaintiff, DELANEY JAROSIK, by and through the undersigned attorney, hereby
propounds Interrogatories upon the Defendant, GLORY LIZ VALDALEZ, together with a copy
of this Notice pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, answers to which
will be due within forty-five (45) days from the date of service.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
Defendant by serving same along with the Summons and Complaint.
/s/ Howard P. Markowitz
Howard P. Markowitz, Esquire
Florida Bar No.: 978078
J.D. Dowell, Esquire
Florida Bar No.: 789720
PITISCI, DOWELL & MARKOWITZ
101 S. Moody Avenue, Suite 200
Tampa, Florida 33609
Phone: (813) 228-9233
Fax: (813) 229-5979
hmarkowitz@pdmmlaw.com;
jdowell@pdmmlaw.com
Ipadovano@pdmmlaw.com
Attorneys for Plaintiff
4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
— INITIAL
PLAINTIFF RL U INTERR OGATOR
ERRUGA IES TO
TORIES TO
DEFENDANT, GLORY LIZ VALDALEZ
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?
List all former names and when you were known by those names. State all addresse
s
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.
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 imprison
ment
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 s pecific crime and the date and
place of
conviction.
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 policie
s 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.
Describe in detail how the incident described in the com plaint
happened, including all
actions taken by you to prevent the incident.
Describe in detail each act or omission on the part of any party to
this lawsuit that you
content constituted negligence that was a contributing legal cause
of the incident in
question.
2.
4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
State the facts upon which you rely for each affirmative defense in your answer.
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.
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 knowled
ge.
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 ever y 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.
3
4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
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' qualifications
as
an expert, the subject matter upon which the witness is expected to testify, the substanc
e
of the facts and opinions to which the witness is expected to testify, and a summary of the
grounds for each opinion.
14 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 Defendan
t, the
nature of the action, and the date and court in which such suit was filed.
15 List the names, business address and business telephone numbers of all medical
doctors
by whom, and all hospitals at which you have been examined and/or treated
in the past
five (5) years.
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?
IF, 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 medicat
ions 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
driving 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.
4
4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4
20. List the name and address of all person, 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 At the time of the incident described in the complaint, were you engaged in any mission
or activity for any other person or entity including any employer? If so, state the
name
and address of that person or entity and the nature of the mission or activity.
22) Did you have Nicholas M. Valdalez’ permission to drive his vehicle at the time
of the
crash complained of herein.
23 Please provide the full carrier’s name, address, account number and phone number(s
) for
each and every cell phone activated in your name on in your possession on the date
of the
incident.
24. List the name, business address and dates of employment regarding
all employees,
including self-employment, for whom you have worked in the past ten (10)
years.
25 Who were you employed by and workin, g for on the date of the accident,
November Ts
2022?
26. Was the motor vehicle that you were driving at the time of the incident
described in the
complaint damaged in the incident, and, if so, what was the cost to repair the
damage?
4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5
BY:
Name: GLORY LIZ VALDALEZ
STATE OF }
}ss
COUNTY OF }
The foregoing instrument was acknowledged before me _ this day of
. 2024 by who is personally known to
me (or has produced as identification) and did/did not take an
oath.
BY:
Name:
NOTARY PUBLIC STATE OF
Commission Expires/Serial No./Seal
6
4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6
Preview
Filing # 196211217 E-Filed 04/15/2024 02:58:48 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION DELANEY JAROSIK, CASE NO.: Plaintiff, vs. NICHOLAS M. VALDALEZ, GLORY LIZ VALDALEZ and PROGRESSIVE AMERICAN INSURANCE COMPANY, Defendants. PLAINTIFF’S NOTICE OF SERVING INITIAL INTERROGATORIES TO DEFENDANT, GLORY LIZ VALDALEZ Plaintiff, DELANEY JAROSIK, by and through the undersigned attorney, hereby propounds Interrogatories upon the Defendant, GLORY LIZ VALDALEZ, together with a copy of this Notice pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, answers to which will be due within forty-five (45) days from the date of service. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to Defendant by serving same along with the Summons and Complaint. /s/ Howard P. Markowitz Howard P. Markowitz, Esquire Florida Bar No.: 978078 J.D. Dowell, Esquire Florida Bar No.: 789720 PITISCI, DOWELL & MARKOWITZ 101 S. Moody Avenue, Suite 200 Tampa, Florida 33609 Phone: (813) 228-9233 Fax: (813) 229-5979 hmarkowitz@pdmmlaw.com; jdowell@pdmmlaw.com Ipadovano@pdmmlaw.com Attorneys for Plaintiff 4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 — INITIAL PLAINTIFF RL U INTERR OGATOR ERRUGA IES TO TORIES TO DEFENDANT, GLORY LIZ VALDALEZ 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? List all former names and when you were known by those names. State all addresse s 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. 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 imprison ment 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 s pecific crime and the date and place of conviction. 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 policie s 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. Describe in detail how the incident described in the com plaint happened, including all actions taken by you to prevent the incident. Describe in detail each act or omission on the part of any party to this lawsuit that you content constituted negligence that was a contributing legal cause of the incident in question. 2. 4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 State the facts upon which you rely for each affirmative defense in your answer. 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. 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 knowled ge. 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 ever y 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. 3 4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 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' qualifications as an expert, the subject matter upon which the witness is expected to testify, the substanc e of the facts and opinions to which the witness is expected to testify, and a summary of the grounds for each opinion. 14 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 Defendan t, the nature of the action, and the date and court in which such suit was filed. 15 List the names, business address and business telephone numbers of all medical doctors by whom, and all hospitals at which you have been examined and/or treated in the past five (5) years. 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? IF, 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 medicat ions 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 driving 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. 4 4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4 20. List the name and address of all person, 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 At the time of the incident described in the complaint, were you engaged in any mission or activity for any other person or entity including any employer? If so, state the name and address of that person or entity and the nature of the mission or activity. 22) Did you have Nicholas M. Valdalez’ permission to drive his vehicle at the time of the crash complained of herein. 23 Please provide the full carrier’s name, address, account number and phone number(s ) for each and every cell phone activated in your name on in your possession on the date of the incident. 24. List the name, business address and dates of employment regarding all employees, including self-employment, for whom you have worked in the past ten (10) years. 25 Who were you employed by and workin, g for on the date of the accident, November Ts 2022? 26. Was the motor vehicle that you were driving at the time of the incident described in the complaint damaged in the incident, and, if so, what was the cost to repair the damage? 4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5 BY: Name: GLORY LIZ VALDALEZ STATE OF } }ss COUNTY OF } The foregoing instrument was acknowledged before me _ this day of . 2024 by who is personally known to me (or has produced as identification) and did/did not take an oath. BY: Name: NOTARY PUBLIC STATE OF Commission Expires/Serial No./Seal 6 4/15/2024 2:58 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6