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Filing # 134686045 E-Filed 09/15/2021 04:32:46 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR CITRUS
COUNTY, FLORIDA
CASE NO.: 2021 CA 000537 A
NORMAN L. CARTWRIGHT, III,
Plaintiff,
vs.
R. T. BROWN, INC., d/b/a BROWN
FUNERAL HOME AND CREMATORY,
and CITRUS MEMORIAL HOSPITAL, INC.,
Defendants.
NOTICE OF SERVICE OF PLAINTIFF’S AFFIRMATIVE DEFENSE
INTERROGATORIES TO DEFENDANT, CITRUS MEMORIAL HOSPITAL, INC.
Plaintiff, NORMAN L. CARTWRIGHT, Ill, gives Notice of Service of Affirmative Defense
Interrogatories numbered 1 through 2 directed to Defendant, CITRUS MEMORIAL HOSPITAL, INC., to be
answered in writing on or before thirty (30) days from the date of service of the Certificate of Service, at the
Law Offices of Brent C. Miller, P.A., 205 East Burleigh Boulevard, Tavares, Florida 32778.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this [s* day of September, 2021, the undersigned electronically
filed the foregoing with the Citrus County Clerk of the Court by using the e-Filing Portal and that a true and
correct copy of the foregoing has been furnished to Joseph T. Metzger, Esquire, Metzger Law Group, P.A.,
3018 W Horatio St, Tampa, FL 33609, at the following designated E-Mail: service@metzgerlaw.net; and to
Joseph Kinman, Jr., Esquire, Beytin, McLaughlin, McLaughlin, O'Hara, Kinman & Bocchino, 1706 E
Eleventh Ave, Tampa, FL 33605, af the following designated E-Mail: jfk@law-fla.com, jlb@law-fla.com.
Z
AOMASD. HIPPELHEUSER
éfida Bar No.: 0784559
tom@pbcemillerlaw.com
LAW OFFICES OF BRENT C. MILLER, P.A.
205 East Burleigh Boulevard
Tavares, FL 32778
(352) 343-7400
Fax: (352) 343-9152
litigation@bcmillerlaw.com
melisa@bcmillerlaw.com
Attorney for PlaintiffAFFIRMATIVE DEFENSE INTERROGATORIES
TO DEFENDANT, CITRUS MEMORIAL HOSPITAL, INC.
1. Please state the name and address of the person answering these Interrogatories, as well as the
name and address of any person who provided any assistance in answering these Interrogatories.
ANSWER:
2. Please state the factual basis for each and every Affirmative Defense raised by Defendant.
ANSWER:
CITRUS MEMORIAL HOSPITAL, INC.
STATE OF FLORIDA)
)ss
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared
As the of CITRUS MEMORIAL HOSPITAL, INC., who is personally
known to me or who produced as identification, and who did/did not take an
oath, and states that the foregoing answers to interrogatories are true and correct to the best of his/her
knowledge.
SWORN TO AND SUBSCRIBED before me in the State and County aforesaid this day
of 2021.
NOTARY PUBLIC
My Commission Expires:
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Filing # 134686045 E-Filed 09/15/2021 04:32:46 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR CITRUS COUNTY, FLORIDA CASE NO.: 2021 CA 000537 A NORMAN L. CARTWRIGHT, III, Plaintiff, vs. R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants. NOTICE OF SERVICE OF PLAINTIFF’S AFFIRMATIVE DEFENSE INTERROGATORIES TO DEFENDANT, CITRUS MEMORIAL HOSPITAL, INC. Plaintiff, NORMAN L. CARTWRIGHT, Ill, gives Notice of Service of Affirmative Defense Interrogatories numbered 1 through 2 directed to Defendant, CITRUS MEMORIAL HOSPITAL, INC., to be answered in writing on or before thirty (30) days from the date of service of the Certificate of Service, at the Law Offices of Brent C. Miller, P.A., 205 East Burleigh Boulevard, Tavares, Florida 32778. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this [s* day of September, 2021, the undersigned electronically filed the foregoing with the Citrus County Clerk of the Court by using the e-Filing Portal and that a true and correct copy of the foregoing has been furnished to Joseph T. Metzger, Esquire, Metzger Law Group, P.A., 3018 W Horatio St, Tampa, FL 33609, at the following designated E-Mail: service@metzgerlaw.net; and to Joseph Kinman, Jr., Esquire, Beytin, McLaughlin, McLaughlin, O'Hara, Kinman & Bocchino, 1706 E Eleventh Ave, Tampa, FL 33605, af the following designated E-Mail: jfk@law-fla.com, jlb@law-fla.com. Z AOMASD. HIPPELHEUSER éfida Bar No.: 0784559 tom@pbcemillerlaw.com LAW OFFICES OF BRENT C. MILLER, P.A. 205 East Burleigh Boulevard Tavares, FL 32778 (352) 343-7400 Fax: (352) 343-9152 litigation@bcmillerlaw.com melisa@bcmillerlaw.com Attorney for PlaintiffAFFIRMATIVE DEFENSE INTERROGATORIES TO DEFENDANT, CITRUS MEMORIAL HOSPITAL, INC. 1. Please state the name and address of the person answering these Interrogatories, as well as the name and address of any person who provided any assistance in answering these Interrogatories. ANSWER: 2. Please state the factual basis for each and every Affirmative Defense raised by Defendant. ANSWER: CITRUS MEMORIAL HOSPITAL, INC. STATE OF FLORIDA) )ss COUNTY OF ) BEFORE ME, the undersigned authority, personally appeared As the of CITRUS MEMORIAL HOSPITAL, INC., who is personally known to me or who produced as identification, and who did/did not take an oath, and states that the foregoing answers to interrogatories are true and correct to the best of his/her knowledge. SWORN TO AND SUBSCRIBED before me in the State and County aforesaid this day of 2021. NOTARY PUBLIC My Commission Expires: