Preview
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/12/2013 4:01:15 PM.###*
Electronically Filed 04/12/2013 04:04:16 PM ET
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. 062012CA019330AXXXE
MARY JOHNSTON,
Plaintiff,
vs.
VLN DEVELOPMENT, LLC, a Florida
Limited Liability Company,
Defendant, /
DEFENDANT'S NOTICE OF SERVING CONTENTION
INTERROGATORIES TO PLAINTIFF, MARY JOHNSTON
COMES NOW the Defendant, hereby files this, its Notice of Serving Contention
Interrogatories on the Plaintiff, numbered 1 through 3, to be answered under oath, in writing
within thirty (30) days from receipt hereof in accordance with Florida Rules of Civil Procedure
1.340.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing Interrogatories has
been furnished via email Mail this 72.7“ day of April, 2013, to Shyamie Dixit, Jr, Esquire,
respectively: sdixit@dixitlaw.com; shyamiedixit@gmail.com, scampbell@dixitlaw.com.
POWERS MCNALIS TORRES TEEBAGY LUONGO
P.O. Box 21289
West Palm Beach, FL 33416-1289
(561) 588-3000 Telephone
(561) 588-3705 Facsimile
Service Email: eservice@powersmenalis.com
Attorney for Defendant, VLN Development
BY: cee WN Hr
JAMILA V. ALEXANDER, ESQUIRE
Florida Bar No.: 587141
12470/293CONTENTION INTERROGATORIES
1, State the facts, with specificity and detail, which support Plaintiffs contention that in
Paragraphs 8 and 17 of Plaintiff's Complaint that the ramp at the exterior of the grocery store
was “not compliant with the Americans with Disabilities Act or the Florida Building Code.” For
each fact relied upon, please identify all person(s) who have personal knowledge of these facts,
including their names, addresses, telephone numbers and subject of matter of that person(s)’
knowledge; and identify all documents that support or explain the identified facts.
2. Identify, with specificity, each and every section, provision and/or standard of the
Americans with Disabilities Act and/or the Florida Building Code the Plaintiff contends that the
ramp at the exterior of the grocery store violated or was not in compliance with as alleged in
Paragraphs 8 and 17 of the Complaint and, for each section, provision and/or standard identified,
please provide the nature of the violation or non-compliance and the specific facts relied upon by
Plaintiff to support that contention. For each fact relied upon, please identify all person(s) who
have personal knowledge of these facts, including their names, addresses, telephone numbers and
subject matter of that person(s)’ knowledge; and identify all documents that support or explain
the identified facts.
3. State the facts with specificity and detail that the Plaintiff relies upon in support of the
allegation in Paragraph 17 of the Complaint that “the ramp was too steep, there was a large gap
between the bottom of the ramp and the sidewalk, and there was no landing onto the ramp.” For
each fact relied upon, please identify all witnesses who will testify in support of your contention,
including their names, last known address, and telephone number. Also, identify all documents
that support your contention.SIGNATURE AND NOTARY PAGE
STATE OF FLORIDA y
)
COUNTY OF )
, duly sworn upon oath, deposes and says that the
foregoing Answers to Interrogatories are true and correct to the best of my knowledge,
information, and belief at the present time.
By
The foregoing instrument was acknowledged before me this day of April, 2013,
by , who is personally known to me or who has produced
as identification and who did/did not take an oath.
Notary Public State of Commission No:
My commission expires:
Preview
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/12/2013 4:01:15 PM.###* Electronically Filed 04/12/2013 04:04:16 PM ET IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 062012CA019330AXXXE MARY JOHNSTON, Plaintiff, vs. VLN DEVELOPMENT, LLC, a Florida Limited Liability Company, Defendant, / DEFENDANT'S NOTICE OF SERVING CONTENTION INTERROGATORIES TO PLAINTIFF, MARY JOHNSTON COMES NOW the Defendant, hereby files this, its Notice of Serving Contention Interrogatories on the Plaintiff, numbered 1 through 3, to be answered under oath, in writing within thirty (30) days from receipt hereof in accordance with Florida Rules of Civil Procedure 1.340. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing Interrogatories has been furnished via email Mail this 72.7“ day of April, 2013, to Shyamie Dixit, Jr, Esquire, respectively: sdixit@dixitlaw.com; shyamiedixit@gmail.com, scampbell@dixitlaw.com. POWERS MCNALIS TORRES TEEBAGY LUONGO P.O. Box 21289 West Palm Beach, FL 33416-1289 (561) 588-3000 Telephone (561) 588-3705 Facsimile Service Email: eservice@powersmenalis.com Attorney for Defendant, VLN Development BY: cee WN Hr JAMILA V. ALEXANDER, ESQUIRE Florida Bar No.: 587141 12470/293CONTENTION INTERROGATORIES 1, State the facts, with specificity and detail, which support Plaintiffs contention that in Paragraphs 8 and 17 of Plaintiff's Complaint that the ramp at the exterior of the grocery store was “not compliant with the Americans with Disabilities Act or the Florida Building Code.” For each fact relied upon, please identify all person(s) who have personal knowledge of these facts, including their names, addresses, telephone numbers and subject of matter of that person(s)’ knowledge; and identify all documents that support or explain the identified facts. 2. Identify, with specificity, each and every section, provision and/or standard of the Americans with Disabilities Act and/or the Florida Building Code the Plaintiff contends that the ramp at the exterior of the grocery store violated or was not in compliance with as alleged in Paragraphs 8 and 17 of the Complaint and, for each section, provision and/or standard identified, please provide the nature of the violation or non-compliance and the specific facts relied upon by Plaintiff to support that contention. For each fact relied upon, please identify all person(s) who have personal knowledge of these facts, including their names, addresses, telephone numbers and subject matter of that person(s)’ knowledge; and identify all documents that support or explain the identified facts. 3. State the facts with specificity and detail that the Plaintiff relies upon in support of the allegation in Paragraph 17 of the Complaint that “the ramp was too steep, there was a large gap between the bottom of the ramp and the sidewalk, and there was no landing onto the ramp.” For each fact relied upon, please identify all witnesses who will testify in support of your contention, including their names, last known address, and telephone number. Also, identify all documents that support your contention.SIGNATURE AND NOTARY PAGE STATE OF FLORIDA y ) COUNTY OF ) , duly sworn upon oath, deposes and says that the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information, and belief at the present time. By The foregoing instrument was acknowledged before me this day of April, 2013, by , who is personally known to me or who has produced as identification and who did/did not take an oath. Notary Public State of Commission No: My commission expires: