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Filing # 128919377 E-Filed 06/17/2021 12:31:53 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
Case No.:
CACE21-010539
Division:
LOLA BASTIANELLI AND
STEPHANIE BERRABI,
Plaintiffs,
V
JASON R. RUDDER,
Defendant.
i
DEFENDANT'SNOTICE OF SERVING INTERROGATORIES TO
PLAINTIFF, LOLA BASTIANELLI
Lola Bastianellic/o Leeder Law
8551 West Sunrise Boulevard
Suite 202
Plantation, Florida33322
The Defendant, Jason Rudder, by and through the undersigned attorney, propounds the
attached Interrogatoriesnumbered 1 through 29 to be answered under oath in writing, within thirty
(30) days from the rece*t hereofin accordancewith the applicable Rules ofCivil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Electronic Mail on this, the 15th day of June, 2021 to the following designated service email
address(est Thomas H. Leeder, Esq.,
The Law Office of George L. Cimballa, III
Sonia Mardarewich,Esq.
Sonia Mardarewich,Esq.
(Employees of GEICO General Insurance Company)
FloridaBar No.. 108358
600 N. Pine Island Road, STE 400
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/17/2021 12:31:52 AM.****
Plantation,Florida 33324
Phone: 954-472-6585
Facsimile: 954-472-6586
Attorney for Defendant(s) Jason Rudder
Service Email:
DEFINITIONS
A. Reference in these interrogatoriesto "you" or "your" is intended to include the Plaintiff,
and all corporations, firms and other entities owned or controlled by the Plaintiff, togetherwith the
officers, directors, agents, employers and attorneys,and other representatives of such entities now,
or any time in the past.
B.
As used herein, "document" shall mean: Every writing or record of every type and
description that is or has been in your possession, control or custody or of which you have
knowledge, including without limitation on the generality of the foregoing, correspondence,
memoranda, tapes, stenographic or hand-written notes, computer records, including e-mail, studies,
publications, books, pamphlets, pictures, films, voice records, maps, reports, surveys, minutes or
statistical complications; every copy of such writing or record, where the original is not in your
possession, custody or control; and every copy of any original or where such copy contains any
commentary or notationwhatsoever that does appear in the original.
C. As used herein, "date" shall mean: the exact day, month, and year if ascertainable,or if
not, the best approximation (including relationshipin time to other events).
D. As used herein, "identify"when used in referenceto:
(1) An individual, shall mean to state his full name, present or last known address
(designating which) and present or last known employment, position or business
which) includingjob title and employment address.
(2) A firm, partnership, corporation, proprietorship, association or other organization or
Mtitx, shall mean to state its full name and present or last known address (designating
which), the legal form of such entity or organizationand the residence address,job title and
business address for the chief executive officer.
(3) Data, shall mean to state: In the case of a document, the title (if any), date, author,
sender recipient, type of document(i.e. letter, memorandum, book, telegram, chart, etc.), or
some other means of identifying it, a summary of its contents and its present location or
custodian; in the case of an oral communication, the date, the communicator,
communicatee, and a sufficient summary of the contents of such oral communication to
indicate its nature and substance.
The identification of documents covered by these Interrogatories is not required for any
such documents which you are willing to produce voluntarily for inspection and copying by the
undersigned attorney with the time period specified for your answers or such other time as may be
mutually agreedupon.
INTERROGATORIES TO PLAINTIFF
1.
What is the name, address, telephone number, date of birth, driver's license number and
social security number of the person answering these interrogatories, and if applicable, the
person's official position or relationsh* with the party to whom the interrogatories are
directed?
2.
List the names, business addresses, dates of employment and rates of pay regarding all
employers, includingself-employment, for whom you have worked in the past ten years.
3
List all former names and when you were known by those names. State all addresses where
you have lived for the past ten years, the dates you lived at each address, and if you are or
have ever been married, the name ofyour spouse or spouses.
4.
Do you wear glasses, contact lenses or hearing aids? If so, state who prescribedthem; when
they were prescribed; when your eyes or ears were last examined; and the name and address
ofthe examiner?
5.
Have you ever been convicted of a crime, other than any juvenile adjudication,which was a
felony or was punishable by death or imprisonment in excess of one year, or a crime that
involved dishonesty or a false statementregardless ofthe punishment? If so, state as to each
convictionthe specific crime, the date and the place of conviction.
6.
Have you applied at any time for short or long term disability benefits including Social
Security Disabilitybenefits? If so, please state the name of any company or governmental
agency to whom you have applied for disability benefits; when you first applied for
disabilitybenefits and the nature of all disabilities that you claimed in your application.
7.
Did you consume any alcoholic beverages or take any drugs or medication 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.
8
Describe in detail how the incident described in the Complaint happened, including all
actions taken by you to prevent the incident.
9-
Describe in detail each act or omission on the part of any party to this lawsuit that you
contend constituted negligence that was a contributing legal cause of the incident in
question.
10.
At the time of the accident that is the subject of your Complaint, were you prescribed
prescr*tion medication for any disease or illness? If so, and for each such prescr*tion,
state the name of the physician prescribing the medication, the name of the medication and
the disease or illness for which the medicationwas prescribed.
11.
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 any injuries you contend are
permanent,the effects on you that you claim are permanent.
12.
List each medical bill or other 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 to whom
each was paid or is owed, and the goods or services for which each was incurred. Include
all medical bills and any other damages.
13.
Do you contend that you have lost any income, benefits, or earning capacity in the past or
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.
14.
Has anything been paid or is anything payable from any third party (including any PIP or
Med Pay insurer) for the damages listed in your answers to these interrogatories? If so, state
the amounts paid or payable,the name and business address ofthe person or entity who paid
or owes said amounts, and which of those third parties have or claim a right of subrogation.
15.
List the names and business addresses of each physician, clinic or medical facility where
you have received any treatment or examination for the injuries for which you seek damages
in this case. State, as to each physician, clinic or medical facility, the date of treatment or
examination and the injury or conditionfor which you were examined or treated.
16.
List the names and business addresses of all other physicians, medical facilities or other
health care providers where you have been examined or treated in the past ten years, and
state as to each the dates of examination or treatment and the condition or injury for which
you were examined or treated.
17.
List the names and addresses of all persons who are believed or known by you, your agents
or attorneys to have any knowledgeconcerningany of the issues in this lawsuit; and specify
the subject matter about which the witness has knowledge.
18.
Have you heard or do you know about any statement or remark relating to the accidentmade
by anyone at the scene of the accident including the drivers of the vehicles involved in the
accident and the passengers in the vehicles and any witnesses to the accident? If so, state
the name and address of each person who made the statement or remark, the name and
address of each person who heard it, and the date, time, place and substance of each
statement.
19.
State the name and address of every person known to you, your agents, or attorneys, to have
knowledgeabout, or possession, custody or control of any photographs or video pertaining
to any fact or issue involvedin this controversy includingany photographs or video taken at
the scene of the accident and any vehicle photographs. As to each such person describe
what such person has, the name and address of the person who took or prepared it, and the
date it was taken or prepared.
20.
With regard to any recommendation for surgery you have received, state: the name and
address ofthe surgeon who made the recommendation;the surgery recommendedincluding
the part ofthe body; whether surgery is scheduled; and whetheryou presently intend to have
the surgery.
21.
Please state if you have ever been a party, either plaintiff or defendant, in a lawsuit other
than the presentmatter and if so, state whetheryou were Plaintiffor Defendant,the nature of
the action, and the date and court in which such suit was filed.
22.
At the time ofthe incident described in the Complaint,were you wearing a seat belt? Ifnot,
please state why not; where you were seated in the vehicle; and whether the vehicle was
equ*pedwith a seat belt that was operational and available for youruse.
23.
Please list by name and address every entity, includingwithout limitation medical providers,
to whom you or your attorney has issued a letter ofprotection or lien in connection with this
action.
24.
Have you belonged to or been a member of health clubs, gyms, athletic or fitness clubs or
organizations within the past five (5) years? If so, state the name and address of each such
facility and your dates ofmemberships.
25.
Please state the name and address of any health care provider from whom you have sought
treatment for any psychological,psychiatric or emotional illness.
26.
If the alleged injury or injuries sustained in the accident prevent you or make it more
difficult for you to perform your work or occupationor in any way inhibit you or interfere
with your daily activities (including recreationalactivities),please state specifically in what
manner you are affected.
27.
Please state what diagnostic studies including MRIs, CT scans and x-rays, that you or your
attorney possess and list the date of the study, the type of study, the part of the body
involved and the name and address ofthe facility the film was taken.
28.
Have you ever suffered any injuries in any accident, including but is not limited to, motor
vehicle accidents (whetheryou were a driver, passengeror a pedestrian),sl* and falls, or on
the job injuries) either RIjQI to or subsequentto the accidentreferred to in the complaint? If
so, for each such accident state: the date and place of such injury; a detailed descr*tion of
all the injuries you received; the names and addresses of all health care providers and
hospitalsrendering treatmentto you as a result of your injuries; and whether you made any
claim for bodily injury includingworkers compensation claims and the name and address of
each attorney retained to represent you for such claims.
29.
As to each body part you claim to have injured as a result of the subject accident, please
state whether, prior to the subject accident, you ever treated with any medical provider
concerning such body parts? If so, please identify the name and address of any such
medical providers with whom you treated, the approximate dates of treatment and the
specific reason for the treatment.
VERIFICATION OF ANSWERS TO INTERROGATORIES
(Signature)
STATE OF FLORIDA
COUNTY OF
The foregoing instrument was sworn to (or affirmed)and subscribed before me, by means
of 0 physical presence or O online notarization,this
dayor
,2021, by
Before
.
me, the undersigned authority, personallyappeared
who after being duly
,
sworn, deposes and says that he/she is
the personnamed in the foregoing Answers to Interrogatories, that he/she has read the same, knows
the contents thereofand the same are true as stated, who is personallyknown to me or who has
produced
as identification.
DATE
NOTARY PUBLIC
CSEAL)