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Filing # 61517662 E-Filed 09/14/2017 08:15:17 AM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
RONALD VOHS, CASE NO.: 17-007673 CACE 05
Plaintiff,
v.
JOSIMAR’S CLEANING SERVICES
CORP., INDUSTRIAL CABLE
COMMUNICATIONS SERVICES, INC.,
AND COMCAST OF COLORADO/FLORIDA/
MICHIGAN/NEW MEXICO/PENNSYLVANIA
/WASHINGTON, LLC.,
Defendants.
/
/
NOTICE OF SERVING DEFENDANT COMCAST’S INTERROGATORIES TO CO-
DEFENDANT CABLE TELEVISION INSTALLATION & SERVICE, LLC
The Defendant, COMCAST OF COLORADO / FLORIDA / MICHIGAN / NEW
MEXICO / PENNSYLVANIA / WASHINGTON, LLC.. by and through the undersigned counsel and
pursuant to Fla. R. Civ. P. 1.340, hereby propounds the attached Interrogatories to Co-Defendant,
INDUSTRIAL CABLE COMMUNICATIONS SERVICES, INC., to be answered in writing, under oath,
or objected within thirty (30) days.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via electronic mail this 14"* day of September , 2017, to: Yeemee Chan, Esq., Steinger, Iscoe &
Greene, P.A., 2400 E. Commercial Blvd., Suite 900, Ft. Lauderdale, FL 33308, Armando P.
Rubio, Esq. and Kevin D. Pardinas, Esq., Fields Howell LLP., 9155 So. Dadeland Blvd., Suite
1012, Miami, FL 33156 and Connoly C. McArthur , Esq., Fudge & McArthur, P.A., 650 16"
Street North, St. Petersburg, FL 33705.
RUDD & DIAMOND, P.A.
Attorneys for Defendant, Comcast
4000 Hollywood Blvd.
Presidential Circle, Suite 120-N
Hollywood, FL 33021
Tel. (954) 961-5059
Fax. (954) 961-8953
service@rudddiamond.com
By: /s/
Michael P. Rudd
FL Bar No.: 782416
And
Peter A. Diamond
17.11718/PAD/sm FL Bar No.: 0180051
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 9/14/2017 8:15:17 AM.****DEFENDANT COMCAST’S INTERROGATORIES TO CO-DEFENDANT
INDUSTRIAL CABLE COMMUNICATIONS SERVICES, INC.
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?
ANSWER:
2) Describe in detail how the incident described in the complaint happened, including all
actions taken by you to prevent the incident.
ANSWER:
3) 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.
ANSWER
4) Describe any and all policies of insurance which you contend to cover or may cover you
for all allegations set forth in Plaintiff 's Complaint, detailing as to such policies the name5)
6)
7)
of the insurer, policy numbers, the effective dates of the policy, the available liability limits,
and the name and address of the custodian of the policy.
ANSWER:
State the facts upon which you rely for each affirmative defense in your answer to the
Claim.
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.
ANSWER:
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.
ANSWER: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.
ANSWER:
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 item such person has, the name and address of
the person who took or prepared it, and the date it was taken or prepared.
ANSWER:
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.
ANSWER: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.
ANSWER:
12) Did Industrial Cable Communications Services, Inc. ever perform any work, and/or service
the property, and/or install cable on or around the property located at or around 11656 SW
11" Street, Davie, Florida, 33325.
ANSWER:13) Did Industrial Cable Communications Services, Inc ever hire a third party to perform any
work, and/or service the property, and/or install cable on or around the property located at
or around 11656 SW 11" Street, Davie, Florida, 33325.
ANSWER:
14) Please state if you 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.
ANSWER:JURAT PAGE
STATE OF FLORIDA )
288
COUNTY OF )
The foregoing was acknowledged before me this __ day of » 2014.
who is personally known to me, or
who has produced as identification, and
who ( ) did (_ ) did not take an oath.
NOTARY PUBLIC, State of Florida
My Commission Expires:
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Filing # 61517662 E-Filed 09/14/2017 08:15:17 AM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA RONALD VOHS, CASE NO.: 17-007673 CACE 05 Plaintiff, v. JOSIMAR’S CLEANING SERVICES CORP., INDUSTRIAL CABLE COMMUNICATIONS SERVICES, INC., AND COMCAST OF COLORADO/FLORIDA/ MICHIGAN/NEW MEXICO/PENNSYLVANIA /WASHINGTON, LLC., Defendants. / / NOTICE OF SERVING DEFENDANT COMCAST’S INTERROGATORIES TO CO- DEFENDANT CABLE TELEVISION INSTALLATION & SERVICE, LLC The Defendant, COMCAST OF COLORADO / FLORIDA / MICHIGAN / NEW MEXICO / PENNSYLVANIA / WASHINGTON, LLC.. by and through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.340, hereby propounds the attached Interrogatories to Co-Defendant, INDUSTRIAL CABLE COMMUNICATIONS SERVICES, INC., to be answered in writing, under oath, or objected within thirty (30) days. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via electronic mail this 14"* day of September , 2017, to: Yeemee Chan, Esq., Steinger, Iscoe & Greene, P.A., 2400 E. Commercial Blvd., Suite 900, Ft. Lauderdale, FL 33308, Armando P. Rubio, Esq. and Kevin D. Pardinas, Esq., Fields Howell LLP., 9155 So. Dadeland Blvd., Suite 1012, Miami, FL 33156 and Connoly C. McArthur , Esq., Fudge & McArthur, P.A., 650 16" Street North, St. Petersburg, FL 33705. RUDD & DIAMOND, P.A. Attorneys for Defendant, Comcast 4000 Hollywood Blvd. Presidential Circle, Suite 120-N Hollywood, FL 33021 Tel. (954) 961-5059 Fax. (954) 961-8953 service@rudddiamond.com By: /s/ Michael P. Rudd FL Bar No.: 782416 And Peter A. Diamond 17.11718/PAD/sm FL Bar No.: 0180051 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 9/14/2017 8:15:17 AM.****DEFENDANT COMCAST’S INTERROGATORIES TO CO-DEFENDANT INDUSTRIAL CABLE COMMUNICATIONS SERVICES, INC. 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? ANSWER: 2) Describe in detail how the incident described in the complaint happened, including all actions taken by you to prevent the incident. ANSWER: 3) 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. ANSWER 4) Describe any and all policies of insurance which you contend to cover or may cover you for all allegations set forth in Plaintiff 's Complaint, detailing as to such policies the name5) 6) 7) of the insurer, policy numbers, the effective dates of the policy, the available liability limits, and the name and address of the custodian of the policy. ANSWER: State the facts upon which you rely for each affirmative defense in your answer to the Claim. 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. ANSWER: 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. ANSWER: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. ANSWER: 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 item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. ANSWER: 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. ANSWER: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. ANSWER: 12) Did Industrial Cable Communications Services, Inc. ever perform any work, and/or service the property, and/or install cable on or around the property located at or around 11656 SW 11" Street, Davie, Florida, 33325. ANSWER:13) Did Industrial Cable Communications Services, Inc ever hire a third party to perform any work, and/or service the property, and/or install cable on or around the property located at or around 11656 SW 11" Street, Davie, Florida, 33325. ANSWER: 14) Please state if you 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. ANSWER:JURAT PAGE STATE OF FLORIDA ) 288 COUNTY OF ) The foregoing was acknowledged before me this __ day of » 2014. who is personally known to me, or who has produced as identification, and who ( ) did (_ ) did not take an oath. NOTARY PUBLIC, State of Florida My Commission Expires: