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Filing # 77070522 E-Filed 08/27/2018 04:42:48 PM
IN THE CIRCUIT COURT FOR THE SEVENTEENTH JUDICIAL
CIRCUIT OF AND FOR BROWARD COUNTY, FLORIDA
JETINIA BERNARD LITTLES
PLAINTIFF
VS. CASE NO.: 18-005151-05
BRINKS INCORPORATED foreign for profit
Corporation
DEFENDANT
/
PLAINTIFF NOTICE OF FILING ANSWERS TO DEFENDANTS’
INTERROGATORIES
COMES NOW, the Plaintiff, Jentina Bernard Littles, by and through his
undersigned counsel and hereby files this his Notice of Filing Answers to Defendants’
Interrogatories pursuant to the Florida Rules for Civil Procedure:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy ofthe above was furnished to
Attorneys for Defendant Kelly R. High BUSH ROSS, P.A. P.O. Box 3913 Tampa. FL 33601
(813) 224-9255 khigh@bushross.com tcollins@bushross.com, this 27 day of August 2018.
/s! David L. Hirsch
David L. Hirsch Esq.
Brawer, Hirsch and Associates, P.A.
650C. S.E. Third Ave.
Ft. Lauderdale, FL.33301
FBN 0610291
(954)522-1922/ FAX (877)876-2420
Designated email: pleadings(@bhapa.law
Alternate Email: david@bhapa.law
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 8/27/2018 4:42:48 PM.****IN THE CIRCUIT COURT FOR THE SEVENTEENTH JUDICIAL
CIRCUIT OF AND FOR BROWARD COUNTY, FLORIDA
JETINIA BERNARD LITTLES
PLAINTIFF
VS. CASE NO.: 18-005151-05
BRINKS INCORPORATED foreign for profit
; Corporation
DEFENDANT
iH
PLAINTIFFS’ ANSWERS TO DEFENDANTS’ REQUEST FOR INTERROGATORIES
COMES NOW THE PLAINTIFF and files these sworn answers to the Defendant’s
Interrogatories:
1. Jentina B. Littles 1408 NW 24th Terrace Fort Lauderdale, FL 33311 (954) 214-4212
2 From 2017 - present: Action Excavation Inc. 16700 SW Sist CT Southwest Ranches,
33331 (954) 520-0759 $10 per hour for 30 -35 hours weekly from 2012-2017
Bekins Van Lines Bekins of South Florida 5300 North Powerline Road, Unit 100 Fort
Lauderdale, FL 33309 Toll Free: (888) 919-3264 Local: (954) 228-8637 $12 per hour for36
hours from 2012-2012 ( 6 months)
Roscioli Yachting Center Address: 3201 W State Rd 84, Fort Lauderdale, FL 33312 $12 per hr.
(954) 581-9200 from 200-2011
Beltman Relocation Group 3039 N Andrews Ave, Pompano Beach, FL 33064 (954) 951-5415
$10 per hr. from 2009-2008
Apex Marine 2764, 2051 NW 11th St, Miami, FL 33125 (305) 644-4456 $12 per hr.
3. Jentina B. Littles Single DOB ZZ! = (vill supply by telephone)
Present from 2008 1408 NW 24th Terrace Fort Lauderdale, FL 33311
4, Reading glasses (125). No prescription No examination5. 2010 Selling Cocaine Okeechobee CI for 1.5 years ; 2008 Century CI Pensacola, FL
Strong Arm Robbery lyear | day;
8. On or about September 15, 2016 the Plaintiff was on Davie Blvd. heading west when
Defendant’s large Brinks truck which was at the red light by the Publix Supermarket parking lot
ran the red light thereby failing to yield the right of way to Plaintiff on his bicycle placing its
large Brinks truck in the actual roadway in the immediate path of the Plaintiff's on coming
bicycle and causing the front grill of the large Brinks truck collide with the Plaintiff. Plaintiff
could only brace himself for the impact as he barely had time to swerve. The bicycle T-boned
into the front of the Brinks truck grill.
19. Defendant was guilty of negligence per se. in that its driver was in violation of FL Stat
§316.075 Traffic control signal devices. —
The Defendant further failed in its duty to operate its large Brinks truck with proper
due care and due caution for other persons and bicyclists lawfully and properly operating on the
roadway under all the prevailing circumstances and was guilty of general negligence.
10. No
Il. Asa proximate cause of the aforesaid negligence of the Defendant, your Plaintiff was caused
to suffer serious physical injuries and permanent damage and impairment to wit, an orthopedic
condition known as a Grade | Anterolisthesis together with a bulging disc and annular tearing of
the L5-S1 lumbar disc. This injury was accompanied by a flattening of the ventral thecal sac witha mild central dise canal stenosis and moderate to severe foraminal stenosis bilaterally at that L5-
S1 lumbar spinal disc level. Plaintiff shows that in such an L5-S1 annular tear injury, the annulus
fibrosis of the spinal disc ruptures or rips and the material that it encases leaks out into the spinal
column coming into contact with nearby spinal nerves producing extreme pain around the back
from a condition known as “Internal Dise Disruption”. Additionally. Plaintiff continues to suffer
severe neck pain caused by a traumatically induced bulging annulus at the multiple cervical disc
levels of C3-4, C-4-5, C-5, C 5- 6 and C6-7, each such bulging disc abutting the ventral thecal sac
and all of which was accompanied by a straightening of Plaintiffs normal cervical lordosis
curvature. Plaintiff has pain in his right hip when going up stairs, The Plaintiff sought medical
care at the Emergency Room of the Broward General Hospital where he was transported from the
scene of the accident. The Plaintiff also sought medical treatment from an orthopedic surgeon at
CitiMed in Hollywood FL who has recommended arthroscopic surgery for his horn tear injury to
the ligaments of his right knee as was clearly demonstrated on the Plaintiff's MRI costing in the
approximate range of $2,700.00 and $7,400.00. The surgical cost for the repairs to the Plaintiff's
cervical and lumbar disc have not fully been determined.
12. The Plaintiff sought medical care at the Emergency Room of the Broward General Hospital (
$767.00 plus $2692.01) where he was transported from the scene of the accident. The Plaintiff
also sought medical treatment from an orthopedic surgeon at CitiMed in Hollywood FL
($29,210.00) who gave him steroidal injections and have recommended arthroscopic surgery for
his horn tear injury to the ligaments of his right knee as was clearly demonstrated on the Plaintiff's
MRI costing in the approximate range of $2,700.00 and $7,400.00, The surgical cost for the repairs
to the Plaintiff's cervical and lumbar disc have not fully been determined. Plaintiff is due to returnfor an additional series of injections at Citimed for on-going problems with his right hip, back and
neck,
13. Lost Wages $864.00; Future lost earning capacity underdetermined.
14. No as acommercial policy no No-fault PIP benefits were paid to Plaintiff, to Broward General
or to Citimed to date.
15. Broward Medical Center, c/o Broward Health 1600 S Andrews Ave, Fort Lauderdale, FL
33316; CitiMed Dr. Wilkerson MD, Dr. Nickerson MD 5901 Hollywood Blvd. Hollywood. FL
33021
16. Slip and Fall Injury for back injury 2015 at Publix treated with Goldson Spine Rehabilitation
Center 734 North State Road 7, Plantation, FL 33317 and Broward General ER; Dermatological
rash on back April 2018 Broward Medical Center, c/o Broward Health 1600 S Andrews Ave, Fort
Lauderdale, FL 33316; 2018 January-Feb. Plantation General Medical Center heat related
respiratory issues. 2008 Work related injury to ribs- Broward Medical Center, c/o Broward Health
1600 $ Andrews Ave, Fort Lauderdale, FL; to be supplemented. No primary physician, No
Surgery, No chronic illnesses. General Medical issues were treated at Broward Medical Center,
c/o Broward Health 1600 S Andrews Ave, Fort Lauderdale, FL through the years.
17. Plaintiff, Defendant, Defendant’s agents and Defendant Driver, Officer Koch #6401 Fort
Lauderdale Police Dept. 1300 W Broward Blvd, Fort Lauderdale, FL 33312, Fort Lauderdale FireRescue personnel names to be supplemented. Dr. Wilkerson, MD, Dr. Nickerson and Staff of
Citimed. ER MD’s and ER Staff and personnel at Broward Medical Center, c/o Broward Health
1600 S Andrews Ave, Fort Lauderdale, FL; Vincent___ supervisor Bekins of South Florida.
Robert___ Co-worker Bekins of South Florida, Steven____ Davie Road Publix employee
,
18. Fire Rescue Personnel warned Plaintiff against making a claim. Koch FLPD said he would be
charging Brinks Driver for red light or failure to yield. Brinks truck passenger asked “Are You
Alright?”
19. Officer Koch #6401 Fort Lauderdale Police Dept. 1300 W Broward Blvd, Fort Lauderdale,
FL 33312, Medical X-rays and MRIs with various providers
20. None other than medical experts
21.No.
22. Workers Compensation 2011 settlement without suit, No other litigation other than criminal
records attached. Slip and Fall Injury settled with Publix 2015 no suit filed.
23. Not Applicable for bicycle.
24. No defects to bicycle.
uw24. 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.
AINTIFF
STATE OF FLORIDA
COUNTY OF ‘
THE FOREGOING INSTRUMENT was acknowledged by me on AMMUSL 27,02 %
by 4 font eA b eS , who is personally known to me or who has froduced
“Dhak 2313.43 -77.__as identification. j
47.0 /
Siemanrel ac Uerlr2a
Commission # FF 993329 Printed Name i
ly Comm. Expires May 17, 2020 e é 32)
Bondad thraugh Nalional Notary Asso C 43 = 1 2 .2bdO
Notary’s Serial Number/&xpiration Date
MASSIEL MENOOZA
Notary Public - State of Florida
899365.D0C
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Filing # 77070522 E-Filed 08/27/2018 04:42:48 PM IN THE CIRCUIT COURT FOR THE SEVENTEENTH JUDICIAL CIRCUIT OF AND FOR BROWARD COUNTY, FLORIDA JETINIA BERNARD LITTLES PLAINTIFF VS. CASE NO.: 18-005151-05 BRINKS INCORPORATED foreign for profit Corporation DEFENDANT / PLAINTIFF NOTICE OF FILING ANSWERS TO DEFENDANTS’ INTERROGATORIES COMES NOW, the Plaintiff, Jentina Bernard Littles, by and through his undersigned counsel and hereby files this his Notice of Filing Answers to Defendants’ Interrogatories pursuant to the Florida Rules for Civil Procedure: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy ofthe above was furnished to Attorneys for Defendant Kelly R. High BUSH ROSS, P.A. P.O. Box 3913 Tampa. FL 33601 (813) 224-9255 khigh@bushross.com tcollins@bushross.com, this 27 day of August 2018. /s! David L. Hirsch David L. Hirsch Esq. Brawer, Hirsch and Associates, P.A. 650C. S.E. Third Ave. Ft. Lauderdale, FL.33301 FBN 0610291 (954)522-1922/ FAX (877)876-2420 Designated email: pleadings(@bhapa.law Alternate Email: david@bhapa.law *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 8/27/2018 4:42:48 PM.****IN THE CIRCUIT COURT FOR THE SEVENTEENTH JUDICIAL CIRCUIT OF AND FOR BROWARD COUNTY, FLORIDA JETINIA BERNARD LITTLES PLAINTIFF VS. CASE NO.: 18-005151-05 BRINKS INCORPORATED foreign for profit ; Corporation DEFENDANT iH PLAINTIFFS’ ANSWERS TO DEFENDANTS’ REQUEST FOR INTERROGATORIES COMES NOW THE PLAINTIFF and files these sworn answers to the Defendant’s Interrogatories: 1. Jentina B. Littles 1408 NW 24th Terrace Fort Lauderdale, FL 33311 (954) 214-4212 2 From 2017 - present: Action Excavation Inc. 16700 SW Sist CT Southwest Ranches, 33331 (954) 520-0759 $10 per hour for 30 -35 hours weekly from 2012-2017 Bekins Van Lines Bekins of South Florida 5300 North Powerline Road, Unit 100 Fort Lauderdale, FL 33309 Toll Free: (888) 919-3264 Local: (954) 228-8637 $12 per hour for36 hours from 2012-2012 ( 6 months) Roscioli Yachting Center Address: 3201 W State Rd 84, Fort Lauderdale, FL 33312 $12 per hr. (954) 581-9200 from 200-2011 Beltman Relocation Group 3039 N Andrews Ave, Pompano Beach, FL 33064 (954) 951-5415 $10 per hr. from 2009-2008 Apex Marine 2764, 2051 NW 11th St, Miami, FL 33125 (305) 644-4456 $12 per hr. 3. Jentina B. Littles Single DOB ZZ! = (vill supply by telephone) Present from 2008 1408 NW 24th Terrace Fort Lauderdale, FL 33311 4, Reading glasses (125). No prescription No examination5. 2010 Selling Cocaine Okeechobee CI for 1.5 years ; 2008 Century CI Pensacola, FL Strong Arm Robbery lyear | day; 8. On or about September 15, 2016 the Plaintiff was on Davie Blvd. heading west when Defendant’s large Brinks truck which was at the red light by the Publix Supermarket parking lot ran the red light thereby failing to yield the right of way to Plaintiff on his bicycle placing its large Brinks truck in the actual roadway in the immediate path of the Plaintiff's on coming bicycle and causing the front grill of the large Brinks truck collide with the Plaintiff. Plaintiff could only brace himself for the impact as he barely had time to swerve. The bicycle T-boned into the front of the Brinks truck grill. 19. Defendant was guilty of negligence per se. in that its driver was in violation of FL Stat §316.075 Traffic control signal devices. — The Defendant further failed in its duty to operate its large Brinks truck with proper due care and due caution for other persons and bicyclists lawfully and properly operating on the roadway under all the prevailing circumstances and was guilty of general negligence. 10. No Il. Asa proximate cause of the aforesaid negligence of the Defendant, your Plaintiff was caused to suffer serious physical injuries and permanent damage and impairment to wit, an orthopedic condition known as a Grade | Anterolisthesis together with a bulging disc and annular tearing of the L5-S1 lumbar disc. This injury was accompanied by a flattening of the ventral thecal sac witha mild central dise canal stenosis and moderate to severe foraminal stenosis bilaterally at that L5- S1 lumbar spinal disc level. Plaintiff shows that in such an L5-S1 annular tear injury, the annulus fibrosis of the spinal disc ruptures or rips and the material that it encases leaks out into the spinal column coming into contact with nearby spinal nerves producing extreme pain around the back from a condition known as “Internal Dise Disruption”. Additionally. Plaintiff continues to suffer severe neck pain caused by a traumatically induced bulging annulus at the multiple cervical disc levels of C3-4, C-4-5, C-5, C 5- 6 and C6-7, each such bulging disc abutting the ventral thecal sac and all of which was accompanied by a straightening of Plaintiffs normal cervical lordosis curvature. Plaintiff has pain in his right hip when going up stairs, The Plaintiff sought medical care at the Emergency Room of the Broward General Hospital where he was transported from the scene of the accident. The Plaintiff also sought medical treatment from an orthopedic surgeon at CitiMed in Hollywood FL who has recommended arthroscopic surgery for his horn tear injury to the ligaments of his right knee as was clearly demonstrated on the Plaintiff's MRI costing in the approximate range of $2,700.00 and $7,400.00. The surgical cost for the repairs to the Plaintiff's cervical and lumbar disc have not fully been determined. 12. The Plaintiff sought medical care at the Emergency Room of the Broward General Hospital ( $767.00 plus $2692.01) where he was transported from the scene of the accident. The Plaintiff also sought medical treatment from an orthopedic surgeon at CitiMed in Hollywood FL ($29,210.00) who gave him steroidal injections and have recommended arthroscopic surgery for his horn tear injury to the ligaments of his right knee as was clearly demonstrated on the Plaintiff's MRI costing in the approximate range of $2,700.00 and $7,400.00, The surgical cost for the repairs to the Plaintiff's cervical and lumbar disc have not fully been determined. Plaintiff is due to returnfor an additional series of injections at Citimed for on-going problems with his right hip, back and neck, 13. Lost Wages $864.00; Future lost earning capacity underdetermined. 14. No as acommercial policy no No-fault PIP benefits were paid to Plaintiff, to Broward General or to Citimed to date. 15. Broward Medical Center, c/o Broward Health 1600 S Andrews Ave, Fort Lauderdale, FL 33316; CitiMed Dr. Wilkerson MD, Dr. Nickerson MD 5901 Hollywood Blvd. Hollywood. FL 33021 16. Slip and Fall Injury for back injury 2015 at Publix treated with Goldson Spine Rehabilitation Center 734 North State Road 7, Plantation, FL 33317 and Broward General ER; Dermatological rash on back April 2018 Broward Medical Center, c/o Broward Health 1600 S Andrews Ave, Fort Lauderdale, FL 33316; 2018 January-Feb. Plantation General Medical Center heat related respiratory issues. 2008 Work related injury to ribs- Broward Medical Center, c/o Broward Health 1600 $ Andrews Ave, Fort Lauderdale, FL; to be supplemented. No primary physician, No Surgery, No chronic illnesses. General Medical issues were treated at Broward Medical Center, c/o Broward Health 1600 S Andrews Ave, Fort Lauderdale, FL through the years. 17. Plaintiff, Defendant, Defendant’s agents and Defendant Driver, Officer Koch #6401 Fort Lauderdale Police Dept. 1300 W Broward Blvd, Fort Lauderdale, FL 33312, Fort Lauderdale FireRescue personnel names to be supplemented. Dr. Wilkerson, MD, Dr. Nickerson and Staff of Citimed. ER MD’s and ER Staff and personnel at Broward Medical Center, c/o Broward Health 1600 S Andrews Ave, Fort Lauderdale, FL; Vincent___ supervisor Bekins of South Florida. Robert___ Co-worker Bekins of South Florida, Steven____ Davie Road Publix employee , 18. Fire Rescue Personnel warned Plaintiff against making a claim. Koch FLPD said he would be charging Brinks Driver for red light or failure to yield. Brinks truck passenger asked “Are You Alright?” 19. Officer Koch #6401 Fort Lauderdale Police Dept. 1300 W Broward Blvd, Fort Lauderdale, FL 33312, Medical X-rays and MRIs with various providers 20. None other than medical experts 21.No. 22. Workers Compensation 2011 settlement without suit, No other litigation other than criminal records attached. Slip and Fall Injury settled with Publix 2015 no suit filed. 23. Not Applicable for bicycle. 24. No defects to bicycle. uw24. 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. AINTIFF STATE OF FLORIDA COUNTY OF ‘ THE FOREGOING INSTRUMENT was acknowledged by me on AMMUSL 27,02 % by 4 font eA b eS , who is personally known to me or who has froduced “Dhak 2313.43 -77.__as identification. j 47.0 / Siemanrel ac Uerlr2a Commission # FF 993329 Printed Name i ly Comm. Expires May 17, 2020 e é 32) Bondad thraugh Nalional Notary Asso C 43 = 1 2 .2bdO Notary’s Serial Number/&xpiration Date MASSIEL MENOOZA Notary Public - State of Florida 899365.D0C