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Filing # 58392184 E-Filed 06/28/2017 03:46:56 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
BORIS MILAN AND KAREN KROBOTH
Plaintiff(s),
Vv.
OLYMPUS INSURANCE COMPANY
Defendant. Case No.: 2016-022783 CACE 12
NOTICE OF PLAINTIFFS’ VERIFIED RESPONSE TO DEFENDANT’S
EXPERT INTERROGATORIES
Plaintiff, BORIS MILAN AND KAREN KROBOTH, by and through the undersigned attorneys,
pursuant to Fla. R. Civ. P. 1.340, hereby responds to Defendant’s Expert Interrogatories (the “Interrogatories”)
and state as follows:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 28, 2017, a true and correct copy of the foregoing has been served
via e-service upon Marc J. Gutterman, Esq., Gutterman Trial Group at the following e-mail address(es):
mgutterman@guttermangroup.com; eservice@guttermangroup.com; Iflores@guttermangroup.com;
mewman@gutt.
Respectfully submitted,
MILITZOK & LEVY, P.A.
Attorneys for Plaintiff
The Yankee Clipper Law Center
3230 Stirling Road, Suite 1
Hollywood, Florida 33021
(954) 727-8570 - Telephone
jack@mllawfl.com - E-Mail
michelle@mllawfl.com - Secondary Service
FLService@mllawfl.com - E-Service
By: /s/ Jack Benmeleh
JACK BENMELEH, ESQ.
Florida Bar No.: 62179
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/28/2017 3:46:55 PM.****Milan and Kroboth v. Olympus
Case No.: 2016-022783 CACE 12
FENERAL OB, INS
The following are general objections to each and every interrogatory:
1. Plaintiffs object to each interrogatory to the extent, if at all, it seeks information representing
communications between Plaintiffs’ counsel and Plaintiffs. Plaintiffs will not provide any information which is
privileged from disclosure based on the attorney-client privilege.
2. Plaintiffs object to each interrogatory to the extent, if at all, it seeks information representing
attorney work product. Plaintiffs will not provide any information which is privileged from disclosure based on
the work product privilege.
3. Plaintiffs object generally to each and every Interrogatory to the extent the response thereto
would cause undue burden, undue expense, and/or oppression.
4, Plaintiffs object generally to the Interrogatories to the extent that they purport to require
Plaintiffs to search the files of third parties, on the grounds that such Interrogatories are overly broad or unduly
burdensome.
5. Plaintiffs object to the Interrogatories to the extent they are overbroad and unduly burdensome,
do not seek information or documents relevant to the subject matter of the pending action, or are not reasonably
calculated to lead to the discovery of admissible evidence.
6. Plaintiffs object to each Interrogatory to the extent that it calls for information that already is in
the possession, custody and control of Defendant.
7. Plaintiffs specifically reserve the right to object, as appropriate, to the admission of these
responses as evidence at trial or for any other purposes.
8. Plaintiffs object to each Interrogatory to the extent that it seeks to impose upon Plaintiffs any
obligation beyond those required by the Florida Rules of Civil Procedure and applicable case law.Milan and Kroboth v. Olympus
Case No.: 2016-022783 CACE 12
9. Plaintiffs object to each Interrogatory to the extent it calls for information that may be derived or
ascertained from the documents produced by Plaintiffs pursuant to Defendant’s Requests for Production, and as
to those, Plaintiffs reserve the right to produce documents in lieu of stating a response.
10. These General Objections shall be deemed to be applicable and continuing with respect to any
specific Interrogatory answered below. The General objections asserted above are hereby incorporated in each
of the specific answers and/or objections set forth herein. Such General Objections are not waived or limited in
any way by any answer to any specified numbered Interrogatory.
11. _ As Plaintiffs has not had the opportunity to complete and/or conduct discovery and discovery is
ongoing, it reserves the right to supplement, amend or correct all or part of these responses provided herein.
SPECIFIC ANSWERS AND OBJECTIONS TO FIRST SET OF INTERROGATORIES
1. It is unknown at this time whether any experts will be testifying in this case as discovery is
ongoing. Plaintiffs will timely comply with any orders requiring such disclosure.
2. It is unknown at this time whether any experts will be testifying in this case as discovery is
ongoing. Plaintiffs will timely comply with any orders requiring such disclosure.
[Remainder of Page Left Intentionally Blank]STATE OF FLORIDA )
)ss
COUNTY OF )
Karen Kroboth, being duly sworn, deposes and says that the attached Answers to First Set of
Interrogatories Propounded to Plaintiff are true and correct to the best of his/her knowledge,
information and belief.
(Print, Type or Stamp Commissioned Name of
Notary Public)
Personally Known (_] OR Produced Identification we
¥ | |
Type of Identification Produced: — ju
SWORN TO AND SUL IBSCRIBED
before me this“) \""* day of
nen OE. 2011 MICHELLE E PAREDES
Commission # GG 104282
o! = Explros May 14,2021
Hee ‘Bonded They Budget Notary Serviced
My commission expires:STATE OF FLORIDA )
)Ss
COUNTY OF )
Boris Milan, being duly sworn, deposes and says that the attached Answers to First Set of
Interrogatories Propounded to Plaintiff are true and correct to the best of his/her knowledge,
information and belief.
[|
NOTARY PUBLIC’ |
, : D
Milnelle Eo Piceles
(Print, Type or Stamp Commissioned Name of
Notary Public)
Personally Known (J OR Produced Identification Z
Type of Identification Produced: EL
SWORN TO AND SUBSCRIBED
before me this aS day of
une 204,
My commission expires:
rug, MICHELLE E PAREDES
See commlaslon# GS 104282
ss i Expires May 14,2024
ONS se Bonded The Bye NAY BMS
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Filing # 58392184 E-Filed 06/28/2017 03:46:56 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA BORIS MILAN AND KAREN KROBOTH Plaintiff(s), Vv. OLYMPUS INSURANCE COMPANY Defendant. Case No.: 2016-022783 CACE 12 NOTICE OF PLAINTIFFS’ VERIFIED RESPONSE TO DEFENDANT’S EXPERT INTERROGATORIES Plaintiff, BORIS MILAN AND KAREN KROBOTH, by and through the undersigned attorneys, pursuant to Fla. R. Civ. P. 1.340, hereby responds to Defendant’s Expert Interrogatories (the “Interrogatories”) and state as follows: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 28, 2017, a true and correct copy of the foregoing has been served via e-service upon Marc J. Gutterman, Esq., Gutterman Trial Group at the following e-mail address(es): mgutterman@guttermangroup.com; eservice@guttermangroup.com; Iflores@guttermangroup.com; mewman@gutt. Respectfully submitted, MILITZOK & LEVY, P.A. Attorneys for Plaintiff The Yankee Clipper Law Center 3230 Stirling Road, Suite 1 Hollywood, Florida 33021 (954) 727-8570 - Telephone jack@mllawfl.com - E-Mail michelle@mllawfl.com - Secondary Service FLService@mllawfl.com - E-Service By: /s/ Jack Benmeleh JACK BENMELEH, ESQ. Florida Bar No.: 62179 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/28/2017 3:46:55 PM.****Milan and Kroboth v. Olympus Case No.: 2016-022783 CACE 12 FENERAL OB, INS The following are general objections to each and every interrogatory: 1. Plaintiffs object to each interrogatory to the extent, if at all, it seeks information representing communications between Plaintiffs’ counsel and Plaintiffs. Plaintiffs will not provide any information which is privileged from disclosure based on the attorney-client privilege. 2. Plaintiffs object to each interrogatory to the extent, if at all, it seeks information representing attorney work product. Plaintiffs will not provide any information which is privileged from disclosure based on the work product privilege. 3. Plaintiffs object generally to each and every Interrogatory to the extent the response thereto would cause undue burden, undue expense, and/or oppression. 4, Plaintiffs object generally to the Interrogatories to the extent that they purport to require Plaintiffs to search the files of third parties, on the grounds that such Interrogatories are overly broad or unduly burdensome. 5. Plaintiffs object to the Interrogatories to the extent they are overbroad and unduly burdensome, do not seek information or documents relevant to the subject matter of the pending action, or are not reasonably calculated to lead to the discovery of admissible evidence. 6. Plaintiffs object to each Interrogatory to the extent that it calls for information that already is in the possession, custody and control of Defendant. 7. Plaintiffs specifically reserve the right to object, as appropriate, to the admission of these responses as evidence at trial or for any other purposes. 8. Plaintiffs object to each Interrogatory to the extent that it seeks to impose upon Plaintiffs any obligation beyond those required by the Florida Rules of Civil Procedure and applicable case law.Milan and Kroboth v. Olympus Case No.: 2016-022783 CACE 12 9. Plaintiffs object to each Interrogatory to the extent it calls for information that may be derived or ascertained from the documents produced by Plaintiffs pursuant to Defendant’s Requests for Production, and as to those, Plaintiffs reserve the right to produce documents in lieu of stating a response. 10. These General Objections shall be deemed to be applicable and continuing with respect to any specific Interrogatory answered below. The General objections asserted above are hereby incorporated in each of the specific answers and/or objections set forth herein. Such General Objections are not waived or limited in any way by any answer to any specified numbered Interrogatory. 11. _ As Plaintiffs has not had the opportunity to complete and/or conduct discovery and discovery is ongoing, it reserves the right to supplement, amend or correct all or part of these responses provided herein. SPECIFIC ANSWERS AND OBJECTIONS TO FIRST SET OF INTERROGATORIES 1. It is unknown at this time whether any experts will be testifying in this case as discovery is ongoing. Plaintiffs will timely comply with any orders requiring such disclosure. 2. It is unknown at this time whether any experts will be testifying in this case as discovery is ongoing. Plaintiffs will timely comply with any orders requiring such disclosure. [Remainder of Page Left Intentionally Blank]STATE OF FLORIDA ) )ss COUNTY OF ) Karen Kroboth, being duly sworn, deposes and says that the attached Answers to First Set of Interrogatories Propounded to Plaintiff are true and correct to the best of his/her knowledge, information and belief. (Print, Type or Stamp Commissioned Name of Notary Public) Personally Known (_] OR Produced Identification we ¥ | | Type of Identification Produced: — ju SWORN TO AND SUL IBSCRIBED before me this“) \""* day of nen OE. 2011 MICHELLE E PAREDES Commission # GG 104282 o! = Explros May 14,2021 Hee ‘Bonded They Budget Notary Serviced My commission expires:STATE OF FLORIDA ) )Ss COUNTY OF ) Boris Milan, being duly sworn, deposes and says that the attached Answers to First Set of Interrogatories Propounded to Plaintiff are true and correct to the best of his/her knowledge, information and belief. [| NOTARY PUBLIC’ | , : D Milnelle Eo Piceles (Print, Type or Stamp Commissioned Name of Notary Public) Personally Known (J OR Produced Identification Z Type of Identification Produced: EL SWORN TO AND SUBSCRIBED before me this aS day of une 204, My commission expires: rug, MICHELLE E PAREDES See commlaslon# GS 104282 ss i Expires May 14,2024 ONS se Bonded The Bye NAY BMS