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Case Number: CACE-21-010539 Division: 25
Filing # 127573277 E-Filed 05/26/2021 12:17:19 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.:
LOLA BASTIANELLI AND
STEPHANIE BERRABI
Plaintiffs,
vs.
JASON R. RUDDER
Defendant,
/
NOTICE OF SERVICE OF INTERROGATORIES ON DEFENDANT
The Defendant, JASON R. RUDDER, is hereby requested to answer the attached
interrogatories being 24 in number being propounded by the Plaintiff, LOLA
BASTIANELLI and STEPHANIE BERRABI, with the Complaint, within the time allowed
by Rule 1.340, Florida Rules of Civil Procedure.
DATED THIS 26" DAY OF MAY, 2021.
LEEDER LAW
Attomeys for Plaintiff
8551 West Sunrise Blvd. | Ste. 202
Plantation, FL 33322
Telephone (954) 734-2382
Pleadings@leederlaw.com
By/s/ Callas § DebPoreia
THOMAS H. LEEDER, ESQ.
FBN: 746401
COLLINS S. DEPERCIO, ESQ.
FBN: 1014971
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/26/2021 12:17:16 PM.****AUTOMOBILE INTERROGATORIES TO DEFENDANT
(If answering for another person or entity, answer with respect to that person or entity,
unless otherwise stated.)
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. 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.
3. 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 punishment? If so, state as to each conviction the specific crime and
the date and place of conviction.
4. Describe any and all policies of insurance which you contend cover or may cover you
for the allegations set forth in plaintiff's 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.5. Describe in detail how the incident described in the complaint happened, including all
actions taken by you to prevent the incident.
6. 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.
7. State the facts upon which you rely for each affirmative defense in your answer.
8. 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.9. Were you charged with any violation of law (including any regulations 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 recorded the testimony?
10.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.
11.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 per-son 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.12.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.
13.Do you intend to call any expert witnesses at the trial of this case? If so, state as to
each such witness the name and business address of the witness, the witness’s
qualifications as an 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.15.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.
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 address of the examiner?
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? If so, 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 de-scribed 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
21.
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.
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? If so, 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 per-son 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.Please provide the name of all your cellular phone company(s), your cellular phone
number(s), the name(s) on the account(s), the billing address for your account(s), and
your account number(s) for any cellular phone in your possession, custody or control
at the time of the car crash described in the complaint.STATE OF )
COUNTY OF )
BEFORE ME, the undersigned authority, this day personally appeared
, who after first being duly sworn states under oath that
he/she signed the foregoing Answers to Auto Personal Injury Interrogatories and that
they are true and correct to the best of his/her knowledge and belief.
IN WITNESS WHEREOF, I have hereunto set my hand and seal, this day of
, 202_.
Signature of Notary Public, State of Florida
Name of Notary typed, printed or stamped
My Commission Expires:
Personally known to me
Produced identification:
Type of Identification