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Case Number: CACE-14-015935 Division: 14
Filing # 17171330 Electronically Filed 08/15/2014 04:58:25 PM
IN THE 17" JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.
FLA. BAR NO. 305553
WILLIE JOHNSON,
Plaintiff,
vs.
WAYNE MUCCI, D.O.;
SCIENTIFIC IMAGE CENTER
MANAGEMENT, INC.;
LIFESTYLE LIFT FLORIDA EAST, P.A.
d/b/a LIFESTYLE LIFT; and LIFESTYLE
LIFT FLORIDA EAST, P.A. a/k/a
LIFESTYLE LIFT SKINCARE, LLC,
Defendants.
SoensESennSnsneeeeeeeaseseaeeneeonae’
PLAINTIFF'S INSURANCE INTERROGATORIES
TO DEFENDANT, LIFESTYLE LIFT FLORIDA EAST, P.A.
D/B/A LIFESTYLE LIFT
COMES NOW, the Plaintiff, WILLIE JOHNSON, by and through undersigned
counsel, propounds the attached Insurance Interrogatories to the Defendant,
LIFESTYLE LIFT FLORIDA EAST, P.A. D/B/A LIFESTYLE LIFT to be answered under oath
in accordance with Florida Rule of Civil Procedure 1.340.
/
iy
DATED this 5 day of August, 2014, and was served to all Defendants with
the Summons and Complaint.
MALOVE HENRATTY, P.A.
Attorneys for Plaintiff
14 Rose Drive
Fort Lauderdale, FL 33316
Telephone: (954) 767-1000
Facsimile: (954) 767-1001
By: Fihte
STEPHEN L. MALOVE
Fla, Bar No, 305553
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/15/2014 4:58:23 PM.****INSURANCE INTERROGATORIES TO DEFENDANT,
LIFESTYLE LIFT FLORIDA EAST, P.A.
D/B/A LIFESTYLE LIFT
At the time of the incident involved herein, were you covered by
any policy of liability insurance?
If so, for EACH such policy providing primary coverage, please state:
a) The name of the insurer.
b) The name of named insured.
c) The policy number.
d) The effective date of coverage.
e) The amount of coverage.
f) The name, address, and occupation of the person who
has present custody of the policy.
g) Whether you have given notice to such insurance
company with respect to this incident..
h) If you have given notice to such insurance company
with respect to this incident, please state the name,
address and job title or capacity of the insurance
company representative to whom the notice was given.
weAt the time of the incident involved herein, were you covered by
any policy of excess liability insurance?
If so, for EACH such policy providing excess coverage, please state:
a)
b)
c)
d)
e)
f)
9)
h)
The name of the insurer.
The name of named insured.
The policy number.
The effective date of coverage.
The amount of coverage.
The name, address, and occupation of the person who has present
custody of the policy.
Whether you have given notice to such insurance
company with respect to this incident.
If you have given notice with respect to this incident,
please state the name, address and job title or capacity
of the insurance representative to whom notice was
given.
wa5. Has any insurance company which you believe provides liability
coverage to you for the incident described in the Complaint:
a) Denied coverage, or
b) Stated that it will defend you in this matter under a
reservation of its rights to later deny coverage.
6. Have any of the insurance companies referred to in your answers
to questions 2 and 4 above re-insured any part of the risk? If so,
state:
a) The name of the re-insured.
b) The amount re-insured.
rp As to any of the coverage mentioned above, do you have a
deductible amount which must be paid or tendered before the
insurance company is obligated to pay a judgment against you?
If so, state:
a) The amount of the deductible.
b) Whether you have offered to pay it.
Please attach a separate sheet supplying the above requested information for
each insurance policy; and if there is more than one policy, please check ( )
here.STATE OF FLORIDA )
COUNTY OF )
BEFORE ME, the undersigned authority, this day personally appeared
, who being personally known to me or
has produced . as identification, who being
by me first duly sworn, deposes and says that executed the foregoing
Answers to Interrogatories and that they are true and correct to the best of
knowledge and belief.
WITNESS my hand and official seal at
this day of , 2014.
NOTARY PUBLIC, State of Florida at Large
Printed Name:
My Commission Expires:
Preview
Case Number: CACE-14-015935 Division: 14 Filing # 17171330 Electronically Filed 08/15/2014 04:58:25 PM IN THE 17" JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. FLA. BAR NO. 305553 WILLIE JOHNSON, Plaintiff, vs. WAYNE MUCCI, D.O.; SCIENTIFIC IMAGE CENTER MANAGEMENT, INC.; LIFESTYLE LIFT FLORIDA EAST, P.A. d/b/a LIFESTYLE LIFT; and LIFESTYLE LIFT FLORIDA EAST, P.A. a/k/a LIFESTYLE LIFT SKINCARE, LLC, Defendants. SoensESennSnsneeeeeeeaseseaeeneeonae’ PLAINTIFF'S INSURANCE INTERROGATORIES TO DEFENDANT, LIFESTYLE LIFT FLORIDA EAST, P.A. D/B/A LIFESTYLE LIFT COMES NOW, the Plaintiff, WILLIE JOHNSON, by and through undersigned counsel, propounds the attached Insurance Interrogatories to the Defendant, LIFESTYLE LIFT FLORIDA EAST, P.A. D/B/A LIFESTYLE LIFT to be answered under oath in accordance with Florida Rule of Civil Procedure 1.340. / iy DATED this 5 day of August, 2014, and was served to all Defendants with the Summons and Complaint. MALOVE HENRATTY, P.A. Attorneys for Plaintiff 14 Rose Drive Fort Lauderdale, FL 33316 Telephone: (954) 767-1000 Facsimile: (954) 767-1001 By: Fihte STEPHEN L. MALOVE Fla, Bar No, 305553 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/15/2014 4:58:23 PM.****INSURANCE INTERROGATORIES TO DEFENDANT, LIFESTYLE LIFT FLORIDA EAST, P.A. D/B/A LIFESTYLE LIFT At the time of the incident involved herein, were you covered by any policy of liability insurance? If so, for EACH such policy providing primary coverage, please state: a) The name of the insurer. b) The name of named insured. c) The policy number. d) The effective date of coverage. e) The amount of coverage. f) The name, address, and occupation of the person who has present custody of the policy. g) Whether you have given notice to such insurance company with respect to this incident.. h) If you have given notice to such insurance company with respect to this incident, please state the name, address and job title or capacity of the insurance company representative to whom the notice was given. weAt the time of the incident involved herein, were you covered by any policy of excess liability insurance? If so, for EACH such policy providing excess coverage, please state: a) b) c) d) e) f) 9) h) The name of the insurer. The name of named insured. The policy number. The effective date of coverage. The amount of coverage. The name, address, and occupation of the person who has present custody of the policy. Whether you have given notice to such insurance company with respect to this incident. If you have given notice with respect to this incident, please state the name, address and job title or capacity of the insurance representative to whom notice was given. wa5. Has any insurance company which you believe provides liability coverage to you for the incident described in the Complaint: a) Denied coverage, or b) Stated that it will defend you in this matter under a reservation of its rights to later deny coverage. 6. Have any of the insurance companies referred to in your answers to questions 2 and 4 above re-insured any part of the risk? If so, state: a) The name of the re-insured. b) The amount re-insured. rp As to any of the coverage mentioned above, do you have a deductible amount which must be paid or tendered before the insurance company is obligated to pay a judgment against you? If so, state: a) The amount of the deductible. b) Whether you have offered to pay it. Please attach a separate sheet supplying the above requested information for each insurance policy; and if there is more than one policy, please check ( ) here.STATE OF FLORIDA ) COUNTY OF ) BEFORE ME, the undersigned authority, this day personally appeared , who being personally known to me or has produced . as identification, who being by me first duly sworn, deposes and says that executed the foregoing Answers to Interrogatories and that they are true and correct to the best of knowledge and belief. WITNESS my hand and official seal at this day of , 2014. NOTARY PUBLIC, State of Florida at Large Printed Name: My Commission Expires: