Preview
Filing # 134478017 E-Filed 09/13/2021 03:15:43 PM
IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 21000968CA.
Plaintiff,
V.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
/
DEFENDANTS, MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC NOTICE OF SERVING FIRST SET OF
INTERROGATORIES TO PLAINTIFF, BARBARA GONZALEZ
Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES,
LLC, by and through undersigned counsel, hereby gives notice of serving the attached
Interrogatories upon the Plaintiff, BARBARA GONZALEZ, pursuant to Rule 1.340(e) of the
Florida Rules of Civil Procedure
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via
e-mail to all counsel of record on the attached Service List on this 13" day of September, 2021.
KUBICKI DRAPER
9100 South Dadeland Blvd.
Suite 1800
Miami, FL 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
Pleadings: FIC-KD@kubickidraper.com
By: /s/ Francesca Ippolito-Craven
FRANCESCA IPPOLITO-CRAVEN
fic@kubickidraper.com
Florida Bar Number: 0145361
LISANDRA GUERRERO
lg@kubickidraper.com
Florida Bar Number: 0098521
SERVICE LIST
Co-counsel for Plaintiff:
Michael J. Rossi, Esq.
MICHAEL J. ROSSI, P.A.
115 South Albany Avenue
Tampa, FL 33606
michael@michaelrossilaw.com
Helen Stratigakos, Esq.
STRATIGAKOS LAW, P.A.
412 East Madison Street, Suite 814
Tampa, FL 33602
helen@stratigakoslaw.com
marty@stratigakoslaw.comn'
FIRST INTERROGATORIES TO PLAINTIFF, BARBARA GONZALEZ
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?
Answer:
List the names, business addresses, dates of employment, and rates of pay regarding all
employers, including self-employment, for whom you have worked in the past 10 years.
Answer:
List all former names and who you were known by those names. State all addresses
where you have lived for the past 10 years, the dates you lived at each address, your
social security number, your date of birth, your driver’s license number, and if you are or
have ever been married, the name of your spouse or spouses.
Answer:
Have you ever been convicted of a crime, other than any juvenile adjudication, which
under the law under which you were convicted was punishable by death or imprisonment
in excess of one year, or that involved dishonesty or a false statement regardless of the
punishment? If so, state as to each conviction the specific crime and the date and place
of conviction.
Answer:
Were you suffering from physical infirmity, disability, or sickness at the time of the
incident described in the Complaint? If so, what was the nature of infirmity, disability, or
sickness.
Answer:
Do you wear glasses, contact lenses, or hearing aids? If so, who prescribed them, when
were they prescribed, when were your eyes or ears last examined, and what is the name
and address of the examiner?
Answer:
Did you consume any alcoholic beverages or take any drugs or medications within twelve
hours before the time of the incident described in the Complaint? If so, state the type
and amount of alcoholic beverages, drugs, or medication which were consumed, and
when and where you consumed them.
Answer:
Describe in detail how the incident described in the Complaint happened, including what
caused the incident and all actions taken by you to prevent the incident.
Answer:
Describe each injury for which you are claiming damages in this case, specifying the part
of your body that was injured, the nature of the injury, and, as to the injuries you contend
are permanent, the effects on you that you claim are permanent.
Answer:
10. List each item of expense or damage, other than loss of income or earning capacity, that
you claim to have incurred as a result of the incident described in the complaint, giving
for each item the date incurred, the name and business address of the person or entity to
whom each was paid or is owed, and the goods or services for which each was incurred.
Answer:
11 Do you contend that you have lost any income, benefits, or earning capacity in the past
and future as a result of the incident described in the Complaint? If so, state the nature
of the income, benefits, or earning capacity, and the amount and the method that you
used in computing the amount.
Answer:
12. Has anything been paid or is anything payable from any third party for the damages listed
in your answers to these interrogatories? If so, state the amounts paid or payable, the
name and business address of the person or entity who paid or owes said amounts, and
which of those third parties have or claim a right of subrogation.
Answer:
13 List the names and business addresses of each physician who has treated or examined
you, and each medical facility where you have received any treatment or examination for
the injuries for which you seek damages in this case; and state as to each the date of
treatment or examination, and the injury or condition for which you were examined or
treated.
Answer:
14. List the names and business addresses of all other physicians, medical facilities,
pharmacies, or other health care providers by whom or at which you have been examined
or treated in the past 10 years; and state as to each the dates of examination or treatment
and the condition or injury for which you were examined or treated.
Answer:
15 List the names and addresses of all persons who are believed or known by you, your
agents, or your attorneys to have any knowledge concerning any of the issues in this
lawsuit; and specify the subject matter about which the witness has knowledge.
Answer:
16. 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.
Answer:
17 State the name and address of every person known to you, your agents, or your attorneys,
who has knowledge about, or possession, custody, or control of, any model, plat, map,
drawing, motion picture, videotape, or photograph pertaining to any fact or issue
involved in this controversy; and describe as to each, what item such person has, the
name and address of the person who took or prepared it, and the date it was taken or
prepared
Answer
18 Have you made an agreement with anyone that would limit that party’s liability to
anyone for any of the damages sued upon in this case? If so, state the terms of the
agreement and the parties to it.
Answer:
19. Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other
than the present matter, and if, so, state whether you were plaintiff or defendant, the
nature of the action, and the date and court in which such suit was filed.
Answer:
20. As to each condition or defect which you contend caused the incident, state:
a. A description of the condition which made the premises dangerous.
b Each fact which indicates the length of time the condition had existed
prior to the incident.
Whether you allege that the Defendant knew of the condition which you
alleged caused the incident herein.
Each fact which tends to show that the Defendant knew, or should have
known, of the condition and from whom did you obtain such information.
Each act which the Defendant failed to perform to make premises
reasonably safe for use and from whom did you obtain such information.
State whether you knew of the condition before the incident, and if so,
The manner in which you acquired such knowledge.
i The time you acquired such knowledge.
i Any act performed by you to avoid the incident after you acquired such
knowledge.
Answer:
21 Please describe what activities you engaged in or what you did in the two hours
immediately prior to the alleged incident.
Answer:
22. Please state whether or not the Plaintiff has received any payments, medical expense,
disability, lost income or wages, as a result of the injuries received in this
accident/incident, said payments being made by or pursuant to:
a) United States Social Security Act.
b) Any federal, state or local income disability act.
c) Any other public programs providing medical expenses, disability payments or
other similar benefits.
4) Any health, sickness or income disability income.
e) Any automobile accident insurance that provides health benefits or income
disability coverage.
Any other similar insurance benefits except life insurance benefits available to the
Claimant.
8) Any contract or agreement of any group, organization, partnership, or corporation
to provide, pay for or reimburse the costs of hospital, medical, dental or other
health care services.
h) Any contractual or voluntary wage continuation plan provided by employers or
any other system intended to provide wages during a period of disability.
Answer:
23 If the answer to the above Interrogatory is in the affirmative:
a) Please state the name of the insurance company, agency, corporation, or person
making said payments.
b) Please state the amount of payments made by each said entity as well as the dates
of payment.
Answer:
STATE OF FLORIDA )
ss
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared ,
who, being by me first duly sworn, and who is personally known to me or produced a valid
driver's license as identification, and who did/did not take an oath, deposes and says that the
foregoing is true and correct to the best of her knowledge, and that she has read the foregoing
and knows the contents thereof.
BARBARA GONZALEZ
SWORN TO AND SUBSCRIBED before me on
Notary Public
State of Florida at Large
My Commission Expires:
Preview
Filing # 134478017 E-Filed 09/13/2021 03:15:43 PM IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 21000968CA. Plaintiff, V. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / DEFENDANTS, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC NOTICE OF SERVING FIRST SET OF INTERROGATORIES TO PLAINTIFF, BARBARA GONZALEZ Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC, by and through undersigned counsel, hereby gives notice of serving the attached Interrogatories upon the Plaintiff, BARBARA GONZALEZ, pursuant to Rule 1.340(e) of the Florida Rules of Civil Procedure CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via e-mail to all counsel of record on the attached Service List on this 13" day of September, 2021. KUBICKI DRAPER 9100 South Dadeland Blvd. Suite 1800 Miami, FL 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 Pleadings: FIC-KD@kubickidraper.com By: /s/ Francesca Ippolito-Craven FRANCESCA IPPOLITO-CRAVEN fic@kubickidraper.com Florida Bar Number: 0145361 LISANDRA GUERRERO lg@kubickidraper.com Florida Bar Number: 0098521 SERVICE LIST Co-counsel for Plaintiff: Michael J. Rossi, Esq. MICHAEL J. ROSSI, P.A. 115 South Albany Avenue Tampa, FL 33606 michael@michaelrossilaw.com Helen Stratigakos, Esq. STRATIGAKOS LAW, P.A. 412 East Madison Street, Suite 814 Tampa, FL 33602 helen@stratigakoslaw.com marty@stratigakoslaw.comn' FIRST INTERROGATORIES TO PLAINTIFF, BARBARA GONZALEZ 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? Answer: List the names, business addresses, dates of employment, and rates of pay regarding all employers, including self-employment, for whom you have worked in the past 10 years. Answer: List all former names and who you were known by those names. State all addresses where you have lived for the past 10 years, the dates you lived at each address, your social security number, your date of birth, your driver’s license number, and if you are or have ever been married, the name of your spouse or spouses. Answer: Have you ever been convicted of a crime, other than any juvenile adjudication, which under the law under which you were convicted was punishable by death or imprisonment in excess of one year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction the specific crime and the date and place of conviction. Answer: Were you suffering from physical infirmity, disability, or sickness at the time of the incident described in the Complaint? If so, what was the nature of infirmity, disability, or sickness. Answer: Do you wear glasses, contact lenses, or hearing aids? If so, who prescribed them, when were they prescribed, when were your eyes or ears last examined, and what is the name and address of the examiner? Answer: Did you consume any alcoholic beverages or take any drugs or medications within twelve hours before the time of the incident described in the Complaint? If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when and where you consumed them. Answer: Describe in detail how the incident described in the Complaint happened, including what caused the incident and all actions taken by you to prevent the incident. Answer: Describe each injury for which you are claiming damages in this case, specifying the part of your body that was injured, the nature of the injury, and, as to the injuries you contend are permanent, the effects on you that you claim are permanent. Answer: 10. List each item of expense or damage, other than loss of income or earning capacity, that you claim to have incurred as a result of the incident described in the complaint, giving for each item the date incurred, the name and business address of the person or entity to whom each was paid or is owed, and the goods or services for which each was incurred. Answer: 11 Do you contend that you have lost any income, benefits, or earning capacity in the past and future as a result of the incident described in the Complaint? If so, state the nature of the income, benefits, or earning capacity, and the amount and the method that you used in computing the amount. Answer: 12. Has anything been paid or is anything payable from any third party for the damages listed in your answers to these interrogatories? If so, state the amounts paid or payable, the name and business address of the person or entity who paid or owes said amounts, and which of those third parties have or claim a right of subrogation. Answer: 13 List the names and business addresses of each physician who has treated or examined you, and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this case; and state as to each the date of treatment or examination, and the injury or condition for which you were examined or treated. Answer: 14. List the names and business addresses of all other physicians, medical facilities, pharmacies, or other health care providers by whom or at which you have been examined or treated in the past 10 years; and state as to each the dates of examination or treatment and the condition or injury for which you were examined or treated. Answer: 15 List the names and addresses of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. Answer: 16. 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. Answer: 17 State the name and address of every person known to you, your agents, or your attorneys, who has knowledge about, or possession, custody, or control of, any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared Answer 18 Have you made an agreement with anyone that would limit that party’s liability to anyone for any of the damages sued upon in this case? If so, state the terms of the agreement and the parties to it. Answer: 19. Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other than the present matter, and if, so, state whether you were plaintiff or defendant, the nature of the action, and the date and court in which such suit was filed. Answer: 20. As to each condition or defect which you contend caused the incident, state: a. A description of the condition which made the premises dangerous. b Each fact which indicates the length of time the condition had existed prior to the incident. Whether you allege that the Defendant knew of the condition which you alleged caused the incident herein. Each fact which tends to show that the Defendant knew, or should have known, of the condition and from whom did you obtain such information. Each act which the Defendant failed to perform to make premises reasonably safe for use and from whom did you obtain such information. State whether you knew of the condition before the incident, and if so, The manner in which you acquired such knowledge. i The time you acquired such knowledge. i Any act performed by you to avoid the incident after you acquired such knowledge. Answer: 21 Please describe what activities you engaged in or what you did in the two hours immediately prior to the alleged incident. Answer: 22. Please state whether or not the Plaintiff has received any payments, medical expense, disability, lost income or wages, as a result of the injuries received in this accident/incident, said payments being made by or pursuant to: a) United States Social Security Act. b) Any federal, state or local income disability act. c) Any other public programs providing medical expenses, disability payments or other similar benefits. 4) Any health, sickness or income disability income. e) Any automobile accident insurance that provides health benefits or income disability coverage. Any other similar insurance benefits except life insurance benefits available to the Claimant. 8) Any contract or agreement of any group, organization, partnership, or corporation to provide, pay for or reimburse the costs of hospital, medical, dental or other health care services. h) Any contractual or voluntary wage continuation plan provided by employers or any other system intended to provide wages during a period of disability. Answer: 23 If the answer to the above Interrogatory is in the affirmative: a) Please state the name of the insurance company, agency, corporation, or person making said payments. b) Please state the amount of payments made by each said entity as well as the dates of payment. Answer: STATE OF FLORIDA ) ss COUNTY OF BEFORE ME, the undersigned authority, personally appeared , who, being by me first duly sworn, and who is personally known to me or produced a valid driver's license as identification, and who did/did not take an oath, deposes and says that the foregoing is true and correct to the best of her knowledge, and that she has read the foregoing and knows the contents thereof. BARBARA GONZALEZ SWORN TO AND SUBSCRIBED before me on Notary Public State of Florida at Large My Commission Expires: