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Filing # 196953054 E-Filed 04/25/2024 09:41:04 AM
IN THE CIRCUIT COURT OF THE
9th JUDICIAL CIRCUIT, IN AND FOR
OSCEOLA COUNTY, FLORIDA
JIMANEZ FIFI,
CASE NO.
Plaintiff,
vs.
CARTER NICHOLSON,
Defendant.
___________________________/
NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT
Plaintiff, JIMANEZ FIFI, by and through undersigned counsel, hereby files this Notice of
Service of Interrogatories directed to Defendant, CARTER NICHOLSON, pursuant to Florida Rules
of Civil Procedure, Rule 1.340, and requests Defendant to file answers to the interrogatories, under
oath, in accordance with Rule 1.340.
Dated this 25th day of April, 2024.
THE LAW OFFICES OF
BERMAN & BERMAN, P.A.
Attorneys for Plaintiff
Post Office Box 272789
Boca Raton, Florida 33427
Telephone: (561) 826 5200
Facsimile: (561) 826 5201
By: /s/ Daniel C. Meyl
Daniel Christopher Meyl, Esq.
Florida Bar No.: 1018336
service@thebermanlawgroup.com
INTRODUCTION & DEFINITIONS
A. These interrogatories are directed toward all information known or available to
Defendant, including information contained in the records and documents in Defendant's custody or
control or available to Defendant upon reasonable inquiry. Where interrogatories cannot be answered
in full, they shall be answered as completely as possible and incomplete answers shall be accompanied
by a specification of the reasons for the incompleteness of the answer and of whatever actual
knowledge is possessed with respect to each unanswered or incompletely answered interrogatory.
If sufficient space for your answer is not provided herein, you may attach additional papers with your
answers and refer to your attached answers in the space provided herein.
B. Each interrogatory is to be deemed a continuing one. If, after serving an answer to any
interrogatory, Defendant, or an authorized officer for Defendant, obtains or becomes aware of any
further information pertaining to that interrogatory, Defendant or its authorized officer is requested
to serve a supplemental answer setting forth such information.
C. "You" or "Your" refers to the Person (as defined below) to whom this request is
addressed, including his/her/its employees, agents, servants, subsidiaries, parent company, affiliated
company, and other persons acting for or in concert with or purporting to act on the Defendant's
behalf, including your Representative (as defined below).
D. ""Defendant" shall mean CARTER NICHOLSON and includes all nicknames,
pseudonyms and/or misnomers in any papers or documents referencing the defendant or any liability
or obligation attributable to them.
E. "Plaintiff" shall mean JIMANEZ FIFI.
F. "Person" means any natural individual in any capacity whatsoever or any entity or
organization, including divisions, departments, and other units herein, and shall include, but not be
limited to, public or private corporations, partnerships, joint ventures, voluntary or unincorporated
associations, organizations, proprietorships, trusts, estates, governmental agencies, commissions,
bureaus, or departments, and the agents, servants, and employees of same.
G. "Representative" means any and all agents, employees, servants, officers, directors,
attorneys, or other persons acting or purporting to act on behalf of the person in question, including
insurance company employees.
H. If you object to providing any response on the grounds of privilege or protection of
trial preparation material, please state the specific basis of your privilege claim.
I. When appropriate, the singular form of a word should be interpreted in the plural as
may be necessary to bring within the scope hereof any documents which might otherwise be
construed to be outside the scope thereof
J. "Document(s)" or "Writing(s)" shall be deemed to include every record of every type,
and is used in the broadest sense and includes any medium upon which intelligence or information can
be recorded and further includes, but is not limited to, all originals, nonidentical copies and drafts of
the following items, whether printed, handwritten, typed, recorded, sent, received or stored via
electronic or digital means or device, or reproduced by hand, including without limitation
correspondence, memoranda, e-mails, texts, invoices, receipts, records, ledger cards or other
accounting records, voucher, check, shop order, diary, calendar, instruction, summaries of personal
conversations or interviews, minutes or records of meetings or conferences, transcripts, opinions or
reports of consultants, projections, drafts, contracts, agreements, confirmations, statistical statements,
studies, telegrams, telexes, books, notes, reports, logs, diaries, audio and /or video recordings, data
compilations from which information can be obtained, charts, photographs, notebooks, drawings,
plan, printed materials or any kind, charts and interoffice communications, and any other writing of
whatever description, including but not limited to any information contained in any computer
(whether stored on a physical drive or in a cloud or virtual storage space), signed or unsigned,
regardless of whether approved, signed, sent received, redrafted, or executed, study, work paper,
handwritten note, draft, chart, paper, print, laboratory record, drawing sketch, diagram, form graph,
index, list, tape, photograph, microfilm, data sheet, data processing card, or any other written,
recorded, transcribed, punched, taped, filmed, or graphic matter, however produced and reproduced.
K. "Communication", "communications", or "correspondence" includes every manner or
means of disclosure, transfer, or exchange of information, and every disclosure, transfer or exchange
of information or opinion, whether orally or by document or whether face-to-face, by telephone, mail,
personal delivery, text message, email, or otherwise.
L. As used in these requests, any references indicating the use of masculine or feminine
and any references indicating the use of singular or plural, shall be used interchangeably.
M. The words "and" and "or" as used herein shall be construed either disjunctively or
conjunctively as required by the context to bring within the scope of these interrogatories any answer
that might be deemed outside their scope by another construction.
N. "Relating to" means containing, constituting, considering, comprising, concerning,
discussing, regarding, describing, reflecting, studying, commenting or reporting on, mentioning,
analyzing, or referring, alluding, or pertaining to, in whole or in part.
O. "Identify" or "identity" means to state or a statement of:
a) in the case of a person other than a natural person, its name, the address of its
principal place of business (including zip code), its telephone number, and the name of its chief
executive officer, as well as, if it has a person other than a natural person that ultimately controls it,
that other person's name, the address of that person's principal place of business (including zip code),
that other person's telephone number, and the name of that other person's chief executive officer;
b) in the case of a natural person, his or her name, business address and telephone
number, employer, and title or position;
c) in the case of a communication, its date, type (e.g., telephone conversation or
discussion), the place where it occurred, the identity of the person who made the communication, the
identity of the person who received the communication, the identity of each other person when it was
made, and the subject matter discussed;
d) in the case of a document, the title of the document, the author, the title or
position of the author, the addressee, each recipient, the type of document, the subject matter, the
date of preparation, and its number of pages; and
e) in the case of an agreement, its date, the place where it occurred, the identity
of all persons who were parties to the agreement, the identity of each person who has knowledge of
the agreement and all other persons present when it was made, and the subject matter of the
agreement.
P. "Including" shall have its ordinary meaning and shall mean "including but not limited
to" and shall not indicate limitation to the examples or items mentioned.
Q. The term "subject accident" as used herein, refers to the motor vehicle accident giving
rise to this Complaint and described in Plaintiff's Complaint.
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. 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.
3. 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.
4. 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, 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 subject accident 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 subject accident.
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 subject accident? 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 knowledge.
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 every 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.
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.
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?
17. Were you suffering from physical infirmity, disability, or sickness at the time of the subject
accident? If so, what was the nature of the infirmity, disability, or sickness?
18. Did you consume any alcoholic beverages or take any drugs or medications within 12 hours
before the time of the subject accident? 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 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.
20. List the name and address of all persons, corporations, or entities who were registered title
owners or who had ownership interest in, or right to control, the motor vehicle that the
defendant was driving at the time of the subject accident; 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 subject accident, was the defendant 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. Was the motor vehicle that the defendant was 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?
23. Has any surveillance material including, but not limited to, videotape, movies, photographs
or reports been compiled, taken or prepared of the Plaintiff in this action?
24. If your answer to the preceding question is yes, please state the date that the information was
prepared; who prepared the information, including his/her business address; what the
information depicts or describes and the location at which the information was obtained.
25. List in detail any intervening acts, events or causes, including third parties, which may have
contributed to the subject accident which resulted in the damages alleged by Plaintiff.
26. Please state whether or not you were on or using a cell phone at the time of the subject
accident.
27. Please identify the telephone number, provider and account holder's name and address for any
cell phone that was in your possession at the time of the subject accident.
28. Please state whether or not the motor vehicle that Defendant operated at the time of the
subject accident was equipped with an event data recorder ("EDR"), also referred to as the
"black box," dash cam, or any other recording device, and if so, list each device, and state
whether you or anyone on your behalf retrieved the data from the device and the present
custodian of said data.
______________________________
Signature
STATE OF ________________________
COUNTY OF ______________________
BEFORE ME, this ____ day of _________, 2024, the undersigned authority, personally
appeared ___________________, who _______ is personally known to me or produced
_______________________ as identification and who, having been duly sworn, deposes and says
that the foregoing answers to these interrogatories are true and correct.
______________________________
Notary
(Affix Seal)
Preview
Filing # 196953054 E-Filed 04/25/2024 09:41:04 AM IN THE CIRCUIT COURT OF THE 9th JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA JIMANEZ FIFI, CASE NO. Plaintiff, vs. CARTER NICHOLSON, Defendant. ___________________________/ NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT Plaintiff, JIMANEZ FIFI, by and through undersigned counsel, hereby files this Notice of Service of Interrogatories directed to Defendant, CARTER NICHOLSON, pursuant to Florida Rules of Civil Procedure, Rule 1.340, and requests Defendant to file answers to the interrogatories, under oath, in accordance with Rule 1.340. Dated this 25th day of April, 2024. THE LAW OFFICES OF BERMAN & BERMAN, P.A. Attorneys for Plaintiff Post Office Box 272789 Boca Raton, Florida 33427 Telephone: (561) 826 5200 Facsimile: (561) 826 5201 By: /s/ Daniel C. Meyl Daniel Christopher Meyl, Esq. Florida Bar No.: 1018336 service@thebermanlawgroup.com INTRODUCTION & DEFINITIONS A. These interrogatories are directed toward all information known or available to Defendant, including information contained in the records and documents in Defendant's custody or control or available to Defendant upon reasonable inquiry. Where interrogatories cannot be answered in full, they shall be answered as completely as possible and incomplete answers shall be accompanied by a specification of the reasons for the incompleteness of the answer and of whatever actual knowledge is possessed with respect to each unanswered or incompletely answered interrogatory. If sufficient space for your answer is not provided herein, you may attach additional papers with your answers and refer to your attached answers in the space provided herein. B. Each interrogatory is to be deemed a continuing one. If, after serving an answer to any interrogatory, Defendant, or an authorized officer for Defendant, obtains or becomes aware of any further information pertaining to that interrogatory, Defendant or its authorized officer is requested to serve a supplemental answer setting forth such information. C. "You" or "Your" refers to the Person (as defined below) to whom this request is addressed, including his/her/its employees, agents, servants, subsidiaries, parent company, affiliated company, and other persons acting for or in concert with or purporting to act on the Defendant's behalf, including your Representative (as defined below). D. ""Defendant" shall mean CARTER NICHOLSON and includes all nicknames, pseudonyms and/or misnomers in any papers or documents referencing the defendant or any liability or obligation attributable to them. E. "Plaintiff" shall mean JIMANEZ FIFI. F. "Person" means any natural individual in any capacity whatsoever or any entity or organization, including divisions, departments, and other units herein, and shall include, but not be limited to, public or private corporations, partnerships, joint ventures, voluntary or unincorporated associations, organizations, proprietorships, trusts, estates, governmental agencies, commissions, bureaus, or departments, and the agents, servants, and employees of same. G. "Representative" means any and all agents, employees, servants, officers, directors, attorneys, or other persons acting or purporting to act on behalf of the person in question, including insurance company employees. H. If you object to providing any response on the grounds of privilege or protection of trial preparation material, please state the specific basis of your privilege claim. I. When appropriate, the singular form of a word should be interpreted in the plural as may be necessary to bring within the scope hereof any documents which might otherwise be construed to be outside the scope thereof J. "Document(s)" or "Writing(s)" shall be deemed to include every record of every type, and is used in the broadest sense and includes any medium upon which intelligence or information can be recorded and further includes, but is not limited to, all originals, nonidentical copies and drafts of the following items, whether printed, handwritten, typed, recorded, sent, received or stored via electronic or digital means or device, or reproduced by hand, including without limitation correspondence, memoranda, e-mails, texts, invoices, receipts, records, ledger cards or other accounting records, voucher, check, shop order, diary, calendar, instruction, summaries of personal conversations or interviews, minutes or records of meetings or conferences, transcripts, opinions or reports of consultants, projections, drafts, contracts, agreements, confirmations, statistical statements, studies, telegrams, telexes, books, notes, reports, logs, diaries, audio and /or video recordings, data compilations from which information can be obtained, charts, photographs, notebooks, drawings, plan, printed materials or any kind, charts and interoffice communications, and any other writing of whatever description, including but not limited to any information contained in any computer (whether stored on a physical drive or in a cloud or virtual storage space), signed or unsigned, regardless of whether approved, signed, sent received, redrafted, or executed, study, work paper, handwritten note, draft, chart, paper, print, laboratory record, drawing sketch, diagram, form graph, index, list, tape, photograph, microfilm, data sheet, data processing card, or any other written, recorded, transcribed, punched, taped, filmed, or graphic matter, however produced and reproduced. K. "Communication", "communications", or "correspondence" includes every manner or means of disclosure, transfer, or exchange of information, and every disclosure, transfer or exchange of information or opinion, whether orally or by document or whether face-to-face, by telephone, mail, personal delivery, text message, email, or otherwise. L. As used in these requests, any references indicating the use of masculine or feminine and any references indicating the use of singular or plural, shall be used interchangeably. M. The words "and" and "or" as used herein shall be construed either disjunctively or conjunctively as required by the context to bring within the scope of these interrogatories any answer that might be deemed outside their scope by another construction. N. "Relating to" means containing, constituting, considering, comprising, concerning, discussing, regarding, describing, reflecting, studying, commenting or reporting on, mentioning, analyzing, or referring, alluding, or pertaining to, in whole or in part. O. "Identify" or "identity" means to state or a statement of: a) in the case of a person other than a natural person, its name, the address of its principal place of business (including zip code), its telephone number, and the name of its chief executive officer, as well as, if it has a person other than a natural person that ultimately controls it, that other person's name, the address of that person's principal place of business (including zip code), that other person's telephone number, and the name of that other person's chief executive officer; b) in the case of a natural person, his or her name, business address and telephone number, employer, and title or position; c) in the case of a communication, its date, type (e.g., telephone conversation or discussion), the place where it occurred, the identity of the person who made the communication, the identity of the person who received the communication, the identity of each other person when it was made, and the subject matter discussed; d) in the case of a document, the title of the document, the author, the title or position of the author, the addressee, each recipient, the type of document, the subject matter, the date of preparation, and its number of pages; and e) in the case of an agreement, its date, the place where it occurred, the identity of all persons who were parties to the agreement, the identity of each person who has knowledge of the agreement and all other persons present when it was made, and the subject matter of the agreement. P. "Including" shall have its ordinary meaning and shall mean "including but not limited to" and shall not indicate limitation to the examples or items mentioned. Q. The term "subject accident" as used herein, refers to the motor vehicle accident giving rise to this Complaint and described in Plaintiff's Complaint. 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. 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. 3. 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. 4. 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, 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 subject accident 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 subject accident. 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 subject accident? 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 knowledge. 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 every 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. 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. 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? 17. Were you suffering from physical infirmity, disability, or sickness at the time of the subject accident? If so, what was the nature of the infirmity, disability, or sickness? 18. Did you consume any alcoholic beverages or take any drugs or medications within 12 hours before the time of the subject accident? 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 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. 20. List the name and address of all persons, corporations, or entities who were registered title owners or who had ownership interest in, or right to control, the motor vehicle that the defendant was driving at the time of the subject accident; 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 subject accident, was the defendant 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. Was the motor vehicle that the defendant was 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? 23. Has any surveillance material including, but not limited to, videotape, movies, photographs or reports been compiled, taken or prepared of the Plaintiff in this action? 24. If your answer to the preceding question is yes, please state the date that the information was prepared; who prepared the information, including his/her business address; what the information depicts or describes and the location at which the information was obtained. 25. List in detail any intervening acts, events or causes, including third parties, which may have contributed to the subject accident which resulted in the damages alleged by Plaintiff. 26. Please state whether or not you were on or using a cell phone at the time of the subject accident. 27. Please identify the telephone number, provider and account holder's name and address for any cell phone that was in your possession at the time of the subject accident. 28. Please state whether or not the motor vehicle that Defendant operated at the time of the subject accident was equipped with an event data recorder ("EDR"), also referred to as the "black box," dash cam, or any other recording device, and if so, list each device, and state whether you or anyone on your behalf retrieved the data from the device and the present custodian of said data. ______________________________ Signature STATE OF ________________________ COUNTY OF ______________________ BEFORE ME, this ____ day of _________, 2024, the undersigned authority, personally appeared ___________________, who _______ is personally known to me or produced _______________________ as identification and who, having been duly sworn, deposes and says that the foregoing answers to these interrogatories are true and correct. ______________________________ Notary (Affix Seal)