Preview
#* FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK.***
4% CASE NUMBER: 2014CA012036 DIVISION: AO ****
Filing # 18944447 Electronically Filed 10/02/2014 03:41:58 PM
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO.:
JENNIFER ANNE WOOD,
individually and JENNIFER
ANNE WOOD, as natural parent,
guardian and next friend of
TEIGAN I. WOOD, a minor child,
Plaintiffs,
vs.
GARY GEORGE WOOD, II, and
SUSAN WOOD,
Defendants.
/
PLAINTIFFS’ INTERROGATORIES TO DEFENDANTS, GARY GEORGE WOOD, It
AND SUSAN WOOD
TO: GARY GEORGE WOOD, II
SUSAN WOOD
Plaintiffs, JENNIFER ANNE WOOD, individually and JENNIFER ANNE WOOD, as
natural parent, guardian and next friend of TEIGAN I. WOOD, by and through their
undersigned attorneys, and pursuant to Rule 1.340, Florida Rules of Civil Procedure, hereby
propound the original and one copy of their initial set of Interrogatories numbered 1 through
9 upon the Defendants, GARY GEORGE WOOD, II and SUSAN WOOD, and request that
they furnish their written responses to each of the Interrogatories in writing and under oath
45 days from receipt hereof.
I HEREBY CERTIFY that an original and one true and correct copy of the foregoing
has been furnished to the aboye-addressees by service of process.
JUPITER LEGAL ADVOCATES
6650 West Indiantown Road, Suite 200
Jupiter, Florida 33458
Telephone: (561) 748-8000;
Facsimile: 661) 748- 9000
Florida Bar No.: 370746DEFINITIONS
As used herein, the following terms shall have the meanings indicated below:
A. The term "Plaintiff" refers to "JENNIFER ANNE WOOD".
B. The term "Defendants" refers to "GARY GEORGE WOOD, II” and “SUSAN
WOOD”.
Cc. "Person" means a natural person, corporation, partnership, sole proprietorship,
union, association, federation, or any other kind of entity; and the acts and knowledge of a
persons hall include the acts and knowledge of that person's directors, officers, members,
partners, employees, representative, agents and attorneys.
D. "Document" means any written, recorded, filmed, or graphic matter, whether
produced or reproduced, or on paper, cards, tapes, film, electronic facsimile, computer storage
device, or any other media, including but not limited to, files, personal or intra-office
memoranda, notes, minutes, records, photographs, correspondence, telegrams, diaries,
bookkeeping entries, financial statements, tax returns, checks, check stubs, reports, studies,
charts, graphs, statements, notebooks, intra-company communications, handwritten notes,
applications, agreements, books pamphlets, periodicals, professional manuals, appointment
or other calendars, records or recordings of oral conversations or meetings, work papers, and
also including but not limited to, originals and all copies which are different in any way from
the originals, whether by interlineation, receipt stamp, notation, indication of copies sent or
received and drafts.
E. "Communication" shall mean any contract, oral or written, formal or informal
at any time or place, under any circumstances, in any manner, whereby a statement of anynature is transmitted, disclosed, exchanged or transferred, and shall include, without
limitation, any documents containing, constituting, reflecting, memorializing, referring or
relating to any such contract.
F. "Controlled group or controlled group of corporations" shall haye the meaning
ascribed to such phrase by Section 1563 of the Internal Revenue Code, all of which is
incorporated herein by reference.
G. "Predecessor" means any person, as defined herein, through which you
previously transacted business.
H. "Successor" means any person who has succeeded to your interest in any
business or property (real or personal).
I "Competitor" means any person you have considered or viewed or recognized
as being in competition with you with regard to the sale of product at the airport.
J. “ Affiliate’ means any person in which you or your parent or subsidiary have
an ownership interest, legal or equitable.
K. "Subsidiary" means any person in which you own majority interest or over
which you have control of corporate policy or decisions.
INSTRUCTIONS
A. In each question where you are asked to identify "persons" and/or state a
"name" or "names", state with respect to such person: (1) the name; (2) last known home
address and telephone number; and (3) last known business address and telephone number,
and name of employer.
B. Whenever the response calls for identification of a communication of any type
and such communication was oral, the following information should be furnished:1. By whom it was made and to whom;
2. The date when it was made;
3. Who else was present when it was made;
4, Whether it was recorded or transcribed in any writing of any
type.
Cc. Whenever the response calls for identification of a document or written
communication of any type, the following information should be furnished:
1. Its nature, ¢.g., whether it is a letter, memorandum, etc.;
2. By whom it was made, to whom it was addressed, if copies were
sent to any person, to whom such copies were sent; and;
3. The date when it was made.
In lieu of the above, you may attach a true and correct copy of the document to
your answers.
D. If any document requested to be identified is not in the possession or control of
the aforementioned person, or is no longer in existence, state whether it is: (1) missing or lost;
(2) destroyed; (3) transferred voluntarily or involuntarily to others and, if so, to whom; or (4)
otherwise disposed of; and in each instance explain the circumstances surrounding and
authorization for such disposition thereof and state the approximate date thereof.
E. In answering these interrogatories, furnish all information available to you,
including information in the possession of your attorneys, or their investigators, and all other
persons acting in your behalf, and not merely information of which you have personal
knowledge. If you cannot answer the interrogatories fully after exercising due diligence to
secure the information, so state and answer to the extent possible, specifying your inability toanswer the remainder and stating whatever information or knowledge you have concerning
the unanswered portions, as well as the specific efforts made to obtain the information
necessary to answer fully.
F. If a claim of privilege is asserted as to any oral or written communication for
which identification is requested by these interrogatories, please identify such oral or written
communications and those persons with knowledge regarding any facts contained in or the
substance of said communication so as to allow Defendant to bring this matter before the
Court, Communication shall be deemed to be adequately described for this purpose if the
following information is provided:
1. The nature of the privilege claimed (privilege as used herein shall
include work product);
2. The identity and position of the person(s) supplying the
information on which the communication is based;
3. In the case of written communications, the approximate date the
document was prepared, its title, the type of document (e.g. letter,
memo, efc.), addresses, and the name and position of each person,
including attorneys representing the Plaintiff in connection with
this lawsuit, to whom the contents of the document have been
communicated by copy, exhibition, reading or substantial
summarization.
4. In the case of oral communications, the location and approximate date of each
such communication, the identify of the person who was a party to the communication, and
the identity of each person, including attorneys representing the Plaintiff in connection withthis lawsuit, to whom the content or substance of the communication, or any part thereof, has
been communicated; and
5. A brief description or summary of the contents or substance of the
communication sufficient to explain the basis for the claim of privilege.
Attached are Interrogatories numbered 1 through 9.INTERROGATORIES TO DEFENDANTS, GARY GEORGE WOOD, I
AND SUSAN WOOD
Please identify yourself and identify each and every person with whom you consulted,
upon whom you relied, or who otherwise constituted a source of information for you
in connection with the preparation of your answers to these Interrogatories, listing with
respect to each and every such person the numbers of the Interrogatories for which he
or she was consulted, relied upon, or otherwise constituted a source of information.
Have you made such inquiry of your agents, servants, employees, representatives, and
other persons in your control, and have you made such examination of all documents
relating to this matter so as to enable you to answer the Interrogatories herein as
completely and accurately as you possibly can.
Please provide the name and last known actual address (not a post office box) of each
and every person known or believed by you to have knowledge relevant to the subject
matter of this action and, for each person so listed, please give a short statement of the
issue(s) about which you contend said person has any knowledge.
Served simultaneously with these Interrogatories are certain Request for Admissions
#1 through #38. For each Request for Admission to which a response is not an
unequivocal admission, please state with specificity your reasons, facts, and
circumstances which you contend justify any response other than an unequivocal
admission. If your response is that you do not have sufficient information so as to
enable you to admit or deny a request, then describe with particularity the efforts
undertaken (and by whom) to obtain any information preparatory to your attempt to
respond.Please state the name and address of the person answering these interrogatories and
if applicable, the official position or relationship of the party to whom the
interrogatories are directed.
Please state the name of every insurer, the number of the policy, the effective dates of
the policy, the available limits of liability, the name of each insured and the name and
address of the custodian of any and all policies of insurance which may cover the
Defendant, for the damages sought in Plaintiff's Complaint filed in this proceeding.
Furthermore, if indeed there is a deductible or self-insurance involved, please state the
applicability of said policies for the damages sought in Plaintiff's Complaint.
Please state the names, addresses and phone numbers of any insurance companies or
other entities that are legally obligated or are responsible for any of the damages sought
by the Plaintiff in his Complaint filed in this proceeding.
Please state the names of any individuals, entities, corporations, partnerships or
persons other than the Defendants named in this lawsuit that may be legally obligated
to the Plaintiff in this case or any of the Defendants by way of contribution, contractual
or common law indemnity or contractual, common law or equitable subrogation by
stating the name, address and phone numbers of each.9.
Have you made an agreement with anyone that limited that party or non-party’s
liability to anyone for any of the damages sued upon in this case; if so, please state the
terms of the agreement and the parties to it.I, , being duly sworn, deposes and says that the attached
answers to Interrogatories are true and correct to the best of my knowledge, information and
belief.
GARY GEORGE WOOD, II
STATE OF FLORIDA
COUNTY OF
I HEREBY CERTIFY that on this day, before me, an officer duly authorized in the
State aforesaid and in the County aforesaid to take acknowledgments, personally appeared
, personally known to me, or who produced the following
identification , and he acknowledged before me that he executed
the above-referenced Interrogatories, and did take an oath.
WITNESS my hand and official seal in the County and State last aforesaid this
day of » 2014,
NOTARY PUBLIC
My commission expires:
Preview
#* FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK.*** 4% CASE NUMBER: 2014CA012036 DIVISION: AO **** Filing # 18944447 Electronically Filed 10/02/2014 03:41:58 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: JENNIFER ANNE WOOD, individually and JENNIFER ANNE WOOD, as natural parent, guardian and next friend of TEIGAN I. WOOD, a minor child, Plaintiffs, vs. GARY GEORGE WOOD, II, and SUSAN WOOD, Defendants. / PLAINTIFFS’ INTERROGATORIES TO DEFENDANTS, GARY GEORGE WOOD, It AND SUSAN WOOD TO: GARY GEORGE WOOD, II SUSAN WOOD Plaintiffs, JENNIFER ANNE WOOD, individually and JENNIFER ANNE WOOD, as natural parent, guardian and next friend of TEIGAN I. WOOD, by and through their undersigned attorneys, and pursuant to Rule 1.340, Florida Rules of Civil Procedure, hereby propound the original and one copy of their initial set of Interrogatories numbered 1 through 9 upon the Defendants, GARY GEORGE WOOD, II and SUSAN WOOD, and request that they furnish their written responses to each of the Interrogatories in writing and under oath 45 days from receipt hereof. I HEREBY CERTIFY that an original and one true and correct copy of the foregoing has been furnished to the aboye-addressees by service of process. JUPITER LEGAL ADVOCATES 6650 West Indiantown Road, Suite 200 Jupiter, Florida 33458 Telephone: (561) 748-8000; Facsimile: 661) 748- 9000 Florida Bar No.: 370746DEFINITIONS As used herein, the following terms shall have the meanings indicated below: A. The term "Plaintiff" refers to "JENNIFER ANNE WOOD". B. The term "Defendants" refers to "GARY GEORGE WOOD, II” and “SUSAN WOOD”. Cc. "Person" means a natural person, corporation, partnership, sole proprietorship, union, association, federation, or any other kind of entity; and the acts and knowledge of a persons hall include the acts and knowledge of that person's directors, officers, members, partners, employees, representative, agents and attorneys. D. "Document" means any written, recorded, filmed, or graphic matter, whether produced or reproduced, or on paper, cards, tapes, film, electronic facsimile, computer storage device, or any other media, including but not limited to, files, personal or intra-office memoranda, notes, minutes, records, photographs, correspondence, telegrams, diaries, bookkeeping entries, financial statements, tax returns, checks, check stubs, reports, studies, charts, graphs, statements, notebooks, intra-company communications, handwritten notes, applications, agreements, books pamphlets, periodicals, professional manuals, appointment or other calendars, records or recordings of oral conversations or meetings, work papers, and also including but not limited to, originals and all copies which are different in any way from the originals, whether by interlineation, receipt stamp, notation, indication of copies sent or received and drafts. E. "Communication" shall mean any contract, oral or written, formal or informal at any time or place, under any circumstances, in any manner, whereby a statement of anynature is transmitted, disclosed, exchanged or transferred, and shall include, without limitation, any documents containing, constituting, reflecting, memorializing, referring or relating to any such contract. F. "Controlled group or controlled group of corporations" shall haye the meaning ascribed to such phrase by Section 1563 of the Internal Revenue Code, all of which is incorporated herein by reference. G. "Predecessor" means any person, as defined herein, through which you previously transacted business. H. "Successor" means any person who has succeeded to your interest in any business or property (real or personal). I "Competitor" means any person you have considered or viewed or recognized as being in competition with you with regard to the sale of product at the airport. J. “ Affiliate’ means any person in which you or your parent or subsidiary have an ownership interest, legal or equitable. K. "Subsidiary" means any person in which you own majority interest or over which you have control of corporate policy or decisions. INSTRUCTIONS A. In each question where you are asked to identify "persons" and/or state a "name" or "names", state with respect to such person: (1) the name; (2) last known home address and telephone number; and (3) last known business address and telephone number, and name of employer. B. Whenever the response calls for identification of a communication of any type and such communication was oral, the following information should be furnished:1. By whom it was made and to whom; 2. The date when it was made; 3. Who else was present when it was made; 4, Whether it was recorded or transcribed in any writing of any type. Cc. Whenever the response calls for identification of a document or written communication of any type, the following information should be furnished: 1. Its nature, ¢.g., whether it is a letter, memorandum, etc.; 2. By whom it was made, to whom it was addressed, if copies were sent to any person, to whom such copies were sent; and; 3. The date when it was made. In lieu of the above, you may attach a true and correct copy of the document to your answers. D. If any document requested to be identified is not in the possession or control of the aforementioned person, or is no longer in existence, state whether it is: (1) missing or lost; (2) destroyed; (3) transferred voluntarily or involuntarily to others and, if so, to whom; or (4) otherwise disposed of; and in each instance explain the circumstances surrounding and authorization for such disposition thereof and state the approximate date thereof. E. In answering these interrogatories, furnish all information available to you, including information in the possession of your attorneys, or their investigators, and all other persons acting in your behalf, and not merely information of which you have personal knowledge. If you cannot answer the interrogatories fully after exercising due diligence to secure the information, so state and answer to the extent possible, specifying your inability toanswer the remainder and stating whatever information or knowledge you have concerning the unanswered portions, as well as the specific efforts made to obtain the information necessary to answer fully. F. If a claim of privilege is asserted as to any oral or written communication for which identification is requested by these interrogatories, please identify such oral or written communications and those persons with knowledge regarding any facts contained in or the substance of said communication so as to allow Defendant to bring this matter before the Court, Communication shall be deemed to be adequately described for this purpose if the following information is provided: 1. The nature of the privilege claimed (privilege as used herein shall include work product); 2. The identity and position of the person(s) supplying the information on which the communication is based; 3. In the case of written communications, the approximate date the document was prepared, its title, the type of document (e.g. letter, memo, efc.), addresses, and the name and position of each person, including attorneys representing the Plaintiff in connection with this lawsuit, to whom the contents of the document have been communicated by copy, exhibition, reading or substantial summarization. 4. In the case of oral communications, the location and approximate date of each such communication, the identify of the person who was a party to the communication, and the identity of each person, including attorneys representing the Plaintiff in connection withthis lawsuit, to whom the content or substance of the communication, or any part thereof, has been communicated; and 5. A brief description or summary of the contents or substance of the communication sufficient to explain the basis for the claim of privilege. Attached are Interrogatories numbered 1 through 9.INTERROGATORIES TO DEFENDANTS, GARY GEORGE WOOD, I AND SUSAN WOOD Please identify yourself and identify each and every person with whom you consulted, upon whom you relied, or who otherwise constituted a source of information for you in connection with the preparation of your answers to these Interrogatories, listing with respect to each and every such person the numbers of the Interrogatories for which he or she was consulted, relied upon, or otherwise constituted a source of information. Have you made such inquiry of your agents, servants, employees, representatives, and other persons in your control, and have you made such examination of all documents relating to this matter so as to enable you to answer the Interrogatories herein as completely and accurately as you possibly can. Please provide the name and last known actual address (not a post office box) of each and every person known or believed by you to have knowledge relevant to the subject matter of this action and, for each person so listed, please give a short statement of the issue(s) about which you contend said person has any knowledge. Served simultaneously with these Interrogatories are certain Request for Admissions #1 through #38. For each Request for Admission to which a response is not an unequivocal admission, please state with specificity your reasons, facts, and circumstances which you contend justify any response other than an unequivocal admission. If your response is that you do not have sufficient information so as to enable you to admit or deny a request, then describe with particularity the efforts undertaken (and by whom) to obtain any information preparatory to your attempt to respond.Please state the name and address of the person answering these interrogatories and if applicable, the official position or relationship of the party to whom the interrogatories are directed. Please state the name of every insurer, the number of the policy, the effective dates of the policy, the available limits of liability, the name of each insured and the name and address of the custodian of any and all policies of insurance which may cover the Defendant, for the damages sought in Plaintiff's Complaint filed in this proceeding. Furthermore, if indeed there is a deductible or self-insurance involved, please state the applicability of said policies for the damages sought in Plaintiff's Complaint. Please state the names, addresses and phone numbers of any insurance companies or other entities that are legally obligated or are responsible for any of the damages sought by the Plaintiff in his Complaint filed in this proceeding. Please state the names of any individuals, entities, corporations, partnerships or persons other than the Defendants named in this lawsuit that may be legally obligated to the Plaintiff in this case or any of the Defendants by way of contribution, contractual or common law indemnity or contractual, common law or equitable subrogation by stating the name, address and phone numbers of each.9. Have you made an agreement with anyone that limited that party or non-party’s liability to anyone for any of the damages sued upon in this case; if so, please state the terms of the agreement and the parties to it.I, , being duly sworn, deposes and says that the attached answers to Interrogatories are true and correct to the best of my knowledge, information and belief. GARY GEORGE WOOD, II STATE OF FLORIDA COUNTY OF I HEREBY CERTIFY that on this day, before me, an officer duly authorized in the State aforesaid and in the County aforesaid to take acknowledgments, personally appeared , personally known to me, or who produced the following identification , and he acknowledged before me that he executed the above-referenced Interrogatories, and did take an oath. WITNESS my hand and official seal in the County and State last aforesaid this day of » 2014, NOTARY PUBLIC My commission expires: