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Case Number:21-004236-CI
Filing # 134086976 E-Filed 09/07/2021 10:14:16 AM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR THE COUNTY OF PINELLAS, STATE OF FLORIDA
CIVIL DIVISION
YAJAIRA MONTES,
Plaintiff,
CASE NO.:
DIVISION:
DONNA DOUGLAS; DENNIS
DOUGLAS; and GEICO GENERAL
INSURANCE COMPANY,
Defendants.
NOTICE OF SERVING UNINSURED/UNDERINSURED INTERROGATORIES TO
DEFENDANT, GEICO GENERAL INSURANCE COMPANY
COMES NOW the Plaintiff, YAJAIRA MONTES, by and through her undersigned
attorney, and who hereby propounds the attached written interrogatories to the Defendant,
GEICO GENERAL INSURANCE COMPANY, and request answers thereto within forty-five
(45) days of service of said interrogatories, pursuant to Florida Rules of Civil Procedure, Rule
1.340.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to the
Defendant via service of process.
CATANIA & CATANIA, P.A.
MARC B. PARISH, ESQUIRE
FBN: 0056714
efiling@cataniaandcatania.com
Bank of America Plaza, Suite 2400
101 E. Kennedy Boulevard
Tampa, FL 33602
813/222-8545
Attorney for Plaintiff
***ELECTRONICALLY FILED 09/07/2021 10:14:13 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
INTERROGATORIES TO DEFENDANT, GEICO GENERAL INSURANCE COMPANY
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?
2. Describe any and all policies of insurance which you contend cover or may cover you for
the allegations set forth in Plaintiffs complaint, detailing as to such policies: the name of
the insurer, number of the policy, the effective dates of the policy, the available limits of
liability, and the name and address of the custodian of the policy.
3. Do you claim or intend to claim that you have grounds for denying coverage to Plaintiff
under the policy? If so, please state each and every ground for denial, and the facts in
support there of.
4. State the facts upon which you rely for each affirmative defense in your answer.
5. 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.
6. List the names and addresses of all persons who are believed or known by you, your
agents or attorneys to have any knowledge concerning any of the issues in this lawsuit;
and specify the subject matter about which the witness has knowledge.
7. 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. Wal-Mart Stores, Inc, v. Weeks, 696 So2d. 855 (2nd DCA 1997).
8. 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, video tape, or photograph pertaining to any fact or issue involved in this
controversy; and describe as to each, what such person has, the name and address of the
person who took or prepared it, and the date it was taken or prepared.
9. Do you contend that the medical care and treatment received by the Plaintiff was
excessive? If so, please state each and every fact in support of such contention, and the
name, address and telephone number of each person whose opinion you have relied upon
to support such facts.
10. State the nature of any investigation which you have conducted upon the claimant since
the date of the subject accident, including photographing Plaintiff, surveillance, or other
observations. Please state the dates and place conducted.
11. Do you contend that the Plaintiff suffered injuries or illness subsequent to the date of the
subject accident? If so, please state the nature and description of each such illness and/or
condition contended.
On behalf of GEICO GENERAL INSURANCE
COMPANY,
Printed Name
STATE OF FLORIDA
COUNTY OF
SWORN TO AND SUBSCRIBED before me, personally appeared
, who, after being first duly sworn, deposes and says that
he/she/it executed the foregoing Interrogatories on this the day of ,
2021.
NOTARY PUBLIC
My Commission Expires:
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Case Number:21-004236-CI Filing # 134086976 E-Filed 09/07/2021 10:14:16 AM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR THE COUNTY OF PINELLAS, STATE OF FLORIDA CIVIL DIVISION YAJAIRA MONTES, Plaintiff, CASE NO.: DIVISION: DONNA DOUGLAS; DENNIS DOUGLAS; and GEICO GENERAL INSURANCE COMPANY, Defendants. NOTICE OF SERVING UNINSURED/UNDERINSURED INTERROGATORIES TO DEFENDANT, GEICO GENERAL INSURANCE COMPANY COMES NOW the Plaintiff, YAJAIRA MONTES, by and through her undersigned attorney, and who hereby propounds the attached written interrogatories to the Defendant, GEICO GENERAL INSURANCE COMPANY, and request answers thereto within forty-five (45) days of service of said interrogatories, pursuant to Florida Rules of Civil Procedure, Rule 1.340. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished to the Defendant via service of process. CATANIA & CATANIA, P.A. MARC B. PARISH, ESQUIRE FBN: 0056714 efiling@cataniaandcatania.com Bank of America Plaza, Suite 2400 101 E. Kennedy Boulevard Tampa, FL 33602 813/222-8545 Attorney for Plaintiff ***ELECTRONICALLY FILED 09/07/2021 10:14:13 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** INTERROGATORIES TO DEFENDANT, GEICO GENERAL INSURANCE COMPANY 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? 2. Describe any and all policies of insurance which you contend cover or may cover you for the allegations set forth in Plaintiffs complaint, detailing as to such policies: the name of the insurer, number of the policy, the effective dates of the policy, the available limits of liability, and the name and address of the custodian of the policy. 3. Do you claim or intend to claim that you have grounds for denying coverage to Plaintiff under the policy? If so, please state each and every ground for denial, and the facts in support there of. 4. State the facts upon which you rely for each affirmative defense in your answer. 5. 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. 6. List the names and addresses of all persons who are believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. 7. 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. Wal-Mart Stores, Inc, v. Weeks, 696 So2d. 855 (2nd DCA 1997). 8. 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, video tape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. 9. Do you contend that the medical care and treatment received by the Plaintiff was excessive? If so, please state each and every fact in support of such contention, and the name, address and telephone number of each person whose opinion you have relied upon to support such facts. 10. State the nature of any investigation which you have conducted upon the claimant since the date of the subject accident, including photographing Plaintiff, surveillance, or other observations. Please state the dates and place conducted. 11. Do you contend that the Plaintiff suffered injuries or illness subsequent to the date of the subject accident? If so, please state the nature and description of each such illness and/or condition contended. On behalf of GEICO GENERAL INSURANCE COMPANY, Printed Name STATE OF FLORIDA COUNTY OF SWORN TO AND SUBSCRIBED before me, personally appeared , who, after being first duly sworn, deposes and says that he/she/it executed the foregoing Interrogatories on this the day of , 2021. NOTARY PUBLIC My Commission Expires: