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Filing # 201060340 E-Filed 06/21/2024 11:02:35 AM
BURTON PRINGLE, IN THE CIRCUIT COURT OF THE 9TH
JUDICIAL CIRCUIT IN AND FOR
Plaintiff, ORANGE COUNTY, FLORIDA
vs. CASE NO.:
COASTAL RIDGE MANAGEMENT, LLC,
and 11841 JEFFERSON COMMONS CIRCLE,
ORLANDO, LLC, Foreign Limited Liability
Company,
Defendants.
___________________________________/
PLAINTIFF’S NOTICE OF SERVICE OF INITIAL
INTERROGATORIES TO DEFENDANT COASTAL RIDGE MANAGEMENT, LLC
COMES NOW the Plaintiff, BURTON PRINGLE, by and through his undersigned attorneys, and
propound the attached set of Interrogatories numbered 1 through 17 to the Defendant, COASTAL RIDGE
MANAGEMENT, LLC, to be answered in writing, under oath, or objected to within forty five (45) days
pursuant to the applicable Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served with the complaint
in this matter upon the Defendant, COASTAL RIDGE MANAGEMENT, LLC, Dated this 21st day of June
2024.
Respectfully submitted,
MORGAN LAW GROUP, P.A.
220 Alhambra Circle, Suite 500
Coral Gables, Florida 33134
Phone: (305) 569-9900
Fax: (305) 443-6828
E-Service: mlg.eservice@morganlawgroup.net
By: /s/ Melodie Rivero___________
Michael Cohen, Esq.,
Florida Bar No.: 146358
Melodie Rivero, Esq.
Florida Bar No.: 1018138
Emails: mcohen@morganlawgroup.net;
mrivero@morganlawgroup.net
Secondary Email: eyaya@morganlawgroup.net
PLAINTIFF’S 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 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.
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 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 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 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.
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. 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.
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 a summary of the grounds for
each opinion.
11. 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.
12. List the names and addresses of all employees, agents, or independent contractors of the
Defendant, 11841 JEFFERSON COMMONS CIRCLE, ORLANDO, LLC, who were
responsible for maintaining the subject premises on January 17, 2023.
13. Please indicate whether or not any markings or warning signs were placed in the area in
which the Plaintiff was injured indicating that the gym premises was unmaintained and/or
dangerous. If so, please describe the markings or signs in detail, and list their location in the
room as well as their proximity to where the Plaintiff was injured.
14. Please state the title of any manual or other such document that discusses the policy and
procedures to be followed by the Defendant and its employees, agents, or independent
contractors when cleaning and/or maintaining the gym and its equipment at the subject
premises for January 17, 2023. In addition, please list the names and addresses of the person
or entity that currently possesses said manual or other such document.
15. Please state whether or not any claims have been made against the Defendant 11841
JEFFERSON COMMONS CIRCLE, ORLANDO, LLC, as a result of any persons being injured
at the subject premises prior to January 17, 2023. If so, please state the following:
A. A brief description of the incident.
B. The names and addresses of the persons who were involved.
C. The dates of the incident.
D. Description of how the claim was resolved. If a lawsuit was filed, please state the
name of the Plaintiff, the case number, and the county in which the suit was filed.
16. Regarding your investigation of the subject incident, please state the following:
A. The names of all persons who investigated the cause and circumstances of the
occurrence for you or your insurance carrier.
B. The names of all persons who investigated Plaintiff’s alleged injuries and damages
for you or your insurance carrier.
C. The names of all persons who have given you signed statements concerning the
incident.
D. The names and addresses of any persons who prepared any reports regarding the
Plaintiff’s incident, which were made in the ordinary course of business.
17. List the names, addresses, and duties of all employees of 11841 JEFFERSON COMMONS
CIRCLE, ORLANDO, LLC, at the subject premises on January 17, 2023.
JURAT SHEET
____________________________
AFFIANT
STATE OF __________________:
: SS
COUNTY OF ________________:
BEFORE ME, the undersigned authority, personally appeared,
_________________________, who is personally known to me to be the person described and/or
produced _____________________ as identification and who executed the foregoing instrument
and before me acknowledged his/her execution of same.
WITNESS my hand and official seal in the County and State last aforesaid, this day
of , 2024.
__________________________________
NOTARY PUBLIC
My Commission Expires:
Preview
Filing # 201060340 E-Filed 06/21/2024 11:02:35 AM BURTON PRINGLE, IN THE CIRCUIT COURT OF THE 9TH JUDICIAL CIRCUIT IN AND FOR Plaintiff, ORANGE COUNTY, FLORIDA vs. CASE NO.: COASTAL RIDGE MANAGEMENT, LLC, and 11841 JEFFERSON COMMONS CIRCLE, ORLANDO, LLC, Foreign Limited Liability Company, Defendants. ___________________________________/ PLAINTIFF’S NOTICE OF SERVICE OF INITIAL INTERROGATORIES TO DEFENDANT COASTAL RIDGE MANAGEMENT, LLC COMES NOW the Plaintiff, BURTON PRINGLE, by and through his undersigned attorneys, and propound the attached set of Interrogatories numbered 1 through 17 to the Defendant, COASTAL RIDGE MANAGEMENT, LLC, to be answered in writing, under oath, or objected to within forty five (45) days pursuant to the applicable Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served with the complaint in this matter upon the Defendant, COASTAL RIDGE MANAGEMENT, LLC, Dated this 21st day of June 2024. Respectfully submitted, MORGAN LAW GROUP, P.A. 220 Alhambra Circle, Suite 500 Coral Gables, Florida 33134 Phone: (305) 569-9900 Fax: (305) 443-6828 E-Service: mlg.eservice@morganlawgroup.net By: /s/ Melodie Rivero___________ Michael Cohen, Esq., Florida Bar No.: 146358 Melodie Rivero, Esq. Florida Bar No.: 1018138 Emails: mcohen@morganlawgroup.net; mrivero@morganlawgroup.net Secondary Email: eyaya@morganlawgroup.net PLAINTIFF’S 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 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. 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 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 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 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. 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. 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. 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 a summary of the grounds for each opinion. 11. 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. 12. List the names and addresses of all employees, agents, or independent contractors of the Defendant, 11841 JEFFERSON COMMONS CIRCLE, ORLANDO, LLC, who were responsible for maintaining the subject premises on January 17, 2023. 13. Please indicate whether or not any markings or warning signs were placed in the area in which the Plaintiff was injured indicating that the gym premises was unmaintained and/or dangerous. If so, please describe the markings or signs in detail, and list their location in the room as well as their proximity to where the Plaintiff was injured. 14. Please state the title of any manual or other such document that discusses the policy and procedures to be followed by the Defendant and its employees, agents, or independent contractors when cleaning and/or maintaining the gym and its equipment at the subject premises for January 17, 2023. In addition, please list the names and addresses of the person or entity that currently possesses said manual or other such document. 15. Please state whether or not any claims have been made against the Defendant 11841 JEFFERSON COMMONS CIRCLE, ORLANDO, LLC, as a result of any persons being injured at the subject premises prior to January 17, 2023. If so, please state the following: A. A brief description of the incident. B. The names and addresses of the persons who were involved. C. The dates of the incident. D. Description of how the claim was resolved. If a lawsuit was filed, please state the name of the Plaintiff, the case number, and the county in which the suit was filed. 16. Regarding your investigation of the subject incident, please state the following: A. The names of all persons who investigated the cause and circumstances of the occurrence for you or your insurance carrier. B. The names of all persons who investigated Plaintiff’s alleged injuries and damages for you or your insurance carrier. C. The names of all persons who have given you signed statements concerning the incident. D. The names and addresses of any persons who prepared any reports regarding the Plaintiff’s incident, which were made in the ordinary course of business. 17. List the names, addresses, and duties of all employees of 11841 JEFFERSON COMMONS CIRCLE, ORLANDO, LLC, at the subject premises on January 17, 2023. JURAT SHEET ____________________________ AFFIANT STATE OF __________________: : SS COUNTY OF ________________: BEFORE ME, the undersigned authority, personally appeared, _________________________, who is personally known to me to be the person described and/or produced _____________________ as identification and who executed the foregoing instrument and before me acknowledged his/her execution of same. WITNESS my hand and official seal in the County and State last aforesaid, this day of , 2024. __________________________________ NOTARY PUBLIC My Commission Expires: