Preview
we" CASE NUMBER: 502020CA007500XXXXMB Div: AK ****
Filing # 110335784 E-Filed 07/16/2020 11:54:21 AM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA.
CASE NO.:
MARIA ALICIA GUZMAN,
Minter
Fai,
VS.
EDWARD JOSEPH PARADISE,
Defendant.
/
STANDARD AUTOMOBILE INTERROGATORIES
TO DEFENDANT
COMES NOW the Plaintiff, MARIA ALICIA GUZMAN, by and through her undersigned
counsel, and propounds the attached Interrogatories to the Defendant EDWARD JOSEPH
PARADISE, to be answered under oath within forty-five (45) days in accordance with the
applicable Rules of Civil Procedure.
I HEREBY CERTIFY that a true and correct copy of the foregoing and original
Interrogatories was served on the Defendant together with the Summons and Complaint.
CARLOS J. JIMENEZ, PL
1880 North Congress Avenue, Suite 315
Boynton Beach, Florida 33426
PH (561) 253-0434
FAX (561) 253-0435
eService@247InjuryLaw.com
(GR
Electronteally Signed
By.
CARLOS J. JIMENEZ, ESQUIRE
Florida Bar No.: 0636746
SCOTT GOLDSTEIN, ESQUIRE
Florida Bar No.: 0540951
CHEN. DAIAARCACU AAIINTY Cl CUADAND ANAY FLEDY —ATMaINNAN 44-64-94 ANA
PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Ur tureuey 1 ite) iveAUTOMOBILE NEGLIGENCE INTERROGATORIES
TO DEFENDANT
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?
List all former names and when 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, and your date of birth.
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 1 year, or that involved dishonesty or a false statement regardless of the
PUNISHING? If SO, SALE AS 16 GACH CONVICLION Whe SPeCifie Tinie aid the Gate aiid Place oF
conviction.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, the 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.
Describe in detail how the incident described in the complaint happened, including all
actions taken by you to prevent the incident.
Describe in detati each act or omission on the part of any party to this iawsutt that you
contend constituted negligence that was a contributing legal cause of the incident in
question.7.
State the facts upon which you rely for each affirmative defense in your answer.
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.
Were you charged with any violation of iaw (including any reguiations or ordinances)
arising out of the incident described in the complaint? If so, what was the nature of the
charge; what plea or answer, if any, did you enter to the charge; what court or agency heard
the charge; was any written report prepared by anyone regarding the charge, and, if so,
what is the name and address of the person or entity who prepared the report; do you have
a copy of the report; and was the testimony at any trial, hearing, or other proceeding on the
charge recorded in any manner, and, if so, what is the name and address of the person who
Aunt aList 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.
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.
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.
Tia wan intand ta nall ani avnart uritnaceas at tha trial af thie nace? Than atata ac ta aach
wO YOu mucina vw Cau ay CApere Witiesoes at ule Ula Or unis Case: 11 50, State as 10 Cac
such witness the name and business address of the witness, the witness' qualifications asan expert, the subject matter upon which the witness is expected to testify, the substance
of the facts and opinions to which the witness is expected to testify, and a summary of the
grounds for each opinion.
14. 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.
i5. Please state 1f you have ever been a party, etther 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.
16. 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 addrace af tha avaminar’
aia Guaress Or wie CAGIOeT +17. 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 the infirmity, disability,
or sickness?
18. Did you consume any alcoholic beverages or take any drugs or medications within 12 hours
before the time of the incident described in the complaint? Ifso, state the type and amount
of alcoholic beverages, drugs, or medication which were consumed, and when and where
you consumed them.
19. Did any mechanical defect in the motor vehicle in which you were riding at the time of the
incident described in the complaint contribute to the incident? If so, describe the nature of
the defect and how it contributed to the incident.20. List the name and address of all persons, corporations, or entities who were registered title
owners or who had ownership interest in, or right to control, the motor vehicle that the
defendant driver was driving at the time of the incident described in the complaint; and
describe both the nature of the ownership interest or right to control the vehicle, and the
vehicle itself, including the make, model, year, and vehicle identification number.
21. At the time of the incident described in the complaint, did the driver of the vehicle
described in your answer to the preceding interrogatory have permission to drive the
vehicle? Ifso, state the names and addresses of all persons who have such permission.
22. At the time of the incident described in the complaint, was the defendant driver engaged in
any mission or activity for any other person or entity, including any employer? If so, state
the name and address of that person or entity and the nature of the mission or activity.23. | Was the motor vehicle that the defendant driver was driving at the time of the incident
described in the complaint damaged in the incident, and, if so, what was the cost to repair
the damage?
24. Prior to the incident described in Plaintiff's complaint, had Defendant's vehicle been
involved in any other automobile accidents while the vehicle was owned by the Defendant?
If so, when did such incident(s) occur? Describe in detail how the incident(s) occurred
including the damage Defendant's vehicle sustained.
25. Please state the dates and locations of any mechanical servicing of the Defendant’s vehicle
for ine GHe (1) Year Period Preceaing ihe licident descrived ti tie Complaint, a Well a8
the nature of the servicing.26. | Were you involved in any prior or subsequent accidents of any nature? If yes, state the
date of the accident, place of accident, injuries sustained and the names of all medical
providers, addresses, telephone numbers and date of treatment for said injuries.
27. What was Defendant’s cell number at the time of the crash?
28. List the name, phone number and address of the cell phone carrier for Defendant relative
to his cell number listed in the answer to question number 27 above.
29. List the name of the person whose name appears on Defendant’s cell phone account
relative to the cell number listed in the answer to question number 27 above.STATE OF FLORIDA }
} ssc
COUNTY OF }
BEFORE ME, the undersigned authority, personally appeared,
who by me being first duly swom, states that (s)he executed the
foregoing Answers to Interrogatories and that they are true to the best of his/her knowledge and
belief.
Notary Public
Sworn to and Subscribed before me this day of 2020.
Notary Public, State of
My Commission Expires:
Preview
we" CASE NUMBER: 502020CA007500XXXXMB Div: AK **** Filing # 110335784 E-Filed 07/16/2020 11:54:21 AM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO.: MARIA ALICIA GUZMAN, Minter Fai, VS. EDWARD JOSEPH PARADISE, Defendant. / STANDARD AUTOMOBILE INTERROGATORIES TO DEFENDANT COMES NOW the Plaintiff, MARIA ALICIA GUZMAN, by and through her undersigned counsel, and propounds the attached Interrogatories to the Defendant EDWARD JOSEPH PARADISE, to be answered under oath within forty-five (45) days in accordance with the applicable Rules of Civil Procedure. I HEREBY CERTIFY that a true and correct copy of the foregoing and original Interrogatories was served on the Defendant together with the Summons and Complaint. CARLOS J. JIMENEZ, PL 1880 North Congress Avenue, Suite 315 Boynton Beach, Florida 33426 PH (561) 253-0434 FAX (561) 253-0435 eService@247InjuryLaw.com (GR Electronteally Signed By. CARLOS J. JIMENEZ, ESQUIRE Florida Bar No.: 0636746 SCOTT GOLDSTEIN, ESQUIRE Florida Bar No.: 0540951 CHEN. DAIAARCACU AAIINTY Cl CUADAND ANAY FLEDY —ATMaINNAN 44-64-94 ANA PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Ur tureuey 1 ite) iveAUTOMOBILE NEGLIGENCE INTERROGATORIES TO DEFENDANT 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? List all former names and when 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, and your date of birth. 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 1 year, or that involved dishonesty or a false statement regardless of the PUNISHING? If SO, SALE AS 16 GACH CONVICLION Whe SPeCifie Tinie aid the Gate aiid Place oF conviction.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, the 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. Describe in detail how the incident described in the complaint happened, including all actions taken by you to prevent the incident. Describe in detati each act or omission on the part of any party to this iawsutt that you contend constituted negligence that was a contributing legal cause of the incident in question.7. State the facts upon which you rely for each affirmative defense in your answer. 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. Were you charged with any violation of iaw (including any reguiations or ordinances) arising out of the incident described in the complaint? If so, what was the nature of the charge; what plea or answer, if any, did you enter to the charge; what court or agency heard the charge; was any written report prepared by anyone regarding the charge, and, if so, what is the name and address of the person or entity who prepared the report; do you have a copy of the report; and was the testimony at any trial, hearing, or other proceeding on the charge recorded in any manner, and, if so, what is the name and address of the person who Aunt aList 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. 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. 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. Tia wan intand ta nall ani avnart uritnaceas at tha trial af thie nace? Than atata ac ta aach wO YOu mucina vw Cau ay CApere Witiesoes at ule Ula Or unis Case: 11 50, State as 10 Cac such witness the name and business address of the witness, the witness' qualifications asan expert, the subject matter upon which the witness is expected to testify, the substance of the facts and opinions to which the witness is expected to testify, and a summary of the grounds for each opinion. 14. 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. i5. Please state 1f you have ever been a party, etther 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. 16. 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 addrace af tha avaminar’ aia Guaress Or wie CAGIOeT +17. 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 the infirmity, disability, or sickness? 18. Did you consume any alcoholic beverages or take any drugs or medications within 12 hours before the time of the incident described in the complaint? Ifso, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when and where you consumed them. 19. Did any mechanical defect in the motor vehicle in which you were riding at the time of the incident described in the complaint contribute to the incident? If so, describe the nature of the defect and how it contributed to the incident.20. List the name and address of all persons, corporations, or entities who were registered title owners or who had ownership interest in, or right to control, the motor vehicle that the defendant driver was driving at the time of the incident described in the complaint; and describe both the nature of the ownership interest or right to control the vehicle, and the vehicle itself, including the make, model, year, and vehicle identification number. 21. At the time of the incident described in the complaint, did the driver of the vehicle described in your answer to the preceding interrogatory have permission to drive the vehicle? Ifso, state the names and addresses of all persons who have such permission. 22. At the time of the incident described in the complaint, was the defendant driver engaged in any mission or activity for any other person or entity, including any employer? If so, state the name and address of that person or entity and the nature of the mission or activity.23. | Was the motor vehicle that the defendant driver was driving at the time of the incident described in the complaint damaged in the incident, and, if so, what was the cost to repair the damage? 24. Prior to the incident described in Plaintiff's complaint, had Defendant's vehicle been involved in any other automobile accidents while the vehicle was owned by the Defendant? If so, when did such incident(s) occur? Describe in detail how the incident(s) occurred including the damage Defendant's vehicle sustained. 25. Please state the dates and locations of any mechanical servicing of the Defendant’s vehicle for ine GHe (1) Year Period Preceaing ihe licident descrived ti tie Complaint, a Well a8 the nature of the servicing.26. | Were you involved in any prior or subsequent accidents of any nature? If yes, state the date of the accident, place of accident, injuries sustained and the names of all medical providers, addresses, telephone numbers and date of treatment for said injuries. 27. What was Defendant’s cell number at the time of the crash? 28. List the name, phone number and address of the cell phone carrier for Defendant relative to his cell number listed in the answer to question number 27 above. 29. List the name of the person whose name appears on Defendant’s cell phone account relative to the cell number listed in the answer to question number 27 above.STATE OF FLORIDA } } ssc COUNTY OF } BEFORE ME, the undersigned authority, personally appeared, who by me being first duly swom, states that (s)he executed the foregoing Answers to Interrogatories and that they are true to the best of his/her knowledge and belief. Notary Public Sworn to and Subscribed before me this day of 2020. Notary Public, State of My Commission Expires: