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Filing # 125648556 E-Filed 04/27/2021 09:31:48 AM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT,
IN AND FOR FLAGLER COUNTY, FLORIDA
MICHAEL RUDY, CASE NO.: 2021 CA 000024
Plaintiff,
Vv.
THE STANDARD FIRE
INSURANCE COMPANY,
Defendant.
/
NOTICE OF SERVICE OF PLAINTIFF’S FIRST SET OF
INTERROGATORIES TO DEFENDANT
The Plaintiff, MICHAEL RUDY, by and through his undersigned counsel and pursuant to
Fla. R. Civ. P. 1.340, hereby give notice of service of his Interrogatories numbered 1 through 14 to
the Defendant, THE STANDARD FIRE INSURANCE COMPANY.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
electronic mail to: Abby R. Dyal, Esq., Law Offices of Jack D. Evans, 4600 Touchton Rd., East,
Bldg 100, Ste 140, Jacksonville, FL 32246 (ADyal@travelers.com JDEorlan@travelers.com and
com) Attorney for Defendants, this 27" day of April, 2021.
GZapata@traveler
CHANFRAU & CHANFRAU
/s/ Greg A. Olsen
William M. Chanfrau, Jr., Esq.
FL Bar No. 0115339
Gregory A. Olsen, Esq.
FL Bar No. 1025866
701 N. Peninsula Dr.
Daytona Beach, FL 32118
P: 386-258-7313; F: 386-238-1464
Attorney for Plaintiff
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 04/27/2021 02:22 PMIN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT,
IN AND FOR FLAGLER COUNTY, FLORIDA
MICHAEL RUDY, CASE NO.: 2021 CA 000024
Plaintiff,
Vv.
THE STANDARD FIRE
INSURANCE COMPANY,
Defendant.
PLAINTIFF’S FIRST INTERROGATORIES TO DEFENDANT
Pursuant to Fla. R. Civ. P. 1.340, the Defendant, THE STANDARD FIRE INSURANCE
COMPANY, is hereby required to serve upon the Plaintiff, under oath and in writing, within thirty
(30) days from the date of service hereof, answers to the following Interrogatories in the space
provided after each. Please be advised that these Interrogatories are being submitted for the purpose
of discovery and for use as evidence at the trial of this cause. Your responses to the following
Interrogatories must be truthful and, as much as is possible, based on your personal knowledge. You
are encouraged not to speculate or guess at any response. In the event the space provided for
response to any question is insufficient to completely answer that question, and then please attach
additional pages to these Interrogatories as necessary to respond fully and completely. Incomplete
or evasive answers shall be deemed an incomplete response to the question or questions so
answered and will result in an application to the Court by the Plaintiff, for an order compelling a
more complete and more definite answer.INTERROGATORIES
1. List the full name, position/title and business address of the person answering these
interrogatories on behalf of the Defendant.
2. Describe any and all policies of insurance, including umbrella policies, which may
provide coverage to the Plaintiff for the allegations set forth in the Complaint, detailing as to
such policies; the name of the insurer, policy number, effective dates of the policy, limits of
liability coverage, and the name and address of the custodian of the policy.
3. Explain your understanding of how the motor vehicle crash described in the Complaint
happened.
4. Describe in detail each act or omission on the part of any individual or entity that you
contend constituted negligence that was a contributing legal cause of the incident in question.
5. Describe those acts which the Plaintiff, MICHAEL RUDY, either did or failed to do which
you contend constituted negligence that was a contributing legal cause of the incident in question.6. State the facts upon which you rely for each affirmative defense in your Answer.
7. List the names and addresses of all persons who are believed or known by you, your
agents or attorneys to have any knowledge or information concerning any of the issues in this
lawsuit and specify the subject matter about which the witness has knowledge.
8. Have you heard or do you know about any statement or remark made by or on behalf of
any party to this lawsuit 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.
9. State the name and address of every person known to you, your agents or 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 such person has, the name and address of the person who took or
prepared it, and the date it was taken or prepared.
10. 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’ 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.11. If you contend that any person or entity is liable in whole or part for the claims asserted
against you in this lawsuit, 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.
12. Did any mechanical defect in the motor vehicle driven by Leonard J. Tadeo contribute to
the motor vehicle crash at issue? If so, describe the nature of the defect and how it contributed to
the incident.
13. If you paid property damage claims on either vehicle involved in the subject motor
vehicle crash, list the total dollar amount you paid for each.
14. List the name, address and telephone number of each appraiser of property damage for
the vehicles involved in the subject motor vehicle crash, the date of each appraisal and the
amount of each appraisal.VERIFICATION OF ANSWERS TO INTERROGATORIES
Date:
Representative - THE STANDARD FIRE
INSURANCE COMPANY
STATE OF
COUNTY OF
I HEREBY CERTIFY that on this day of ; 2020, before me,
an officer duly authorized in the State and County aforesaid, personally appeared
, known to me personally or identified by or through
» who under oath acknowledged execution of the
foregoing interrogatories.
WITNESS my hand and official seal this day of , 2020.
Print Name:
Notary Public, State of Florida
My commission expires
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Filing # 125648556 E-Filed 04/27/2021 09:31:48 AM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA MICHAEL RUDY, CASE NO.: 2021 CA 000024 Plaintiff, Vv. THE STANDARD FIRE INSURANCE COMPANY, Defendant. / NOTICE OF SERVICE OF PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT The Plaintiff, MICHAEL RUDY, by and through his undersigned counsel and pursuant to Fla. R. Civ. P. 1.340, hereby give notice of service of his Interrogatories numbered 1 through 14 to the Defendant, THE STANDARD FIRE INSURANCE COMPANY. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic mail to: Abby R. Dyal, Esq., Law Offices of Jack D. Evans, 4600 Touchton Rd., East, Bldg 100, Ste 140, Jacksonville, FL 32246 (ADyal@travelers.com JDEorlan@travelers.com and com) Attorney for Defendants, this 27" day of April, 2021. GZapata@traveler CHANFRAU & CHANFRAU /s/ Greg A. Olsen William M. Chanfrau, Jr., Esq. FL Bar No. 0115339 Gregory A. Olsen, Esq. FL Bar No. 1025866 701 N. Peninsula Dr. Daytona Beach, FL 32118 P: 386-258-7313; F: 386-238-1464 Attorney for Plaintiff Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 04/27/2021 02:22 PMIN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA MICHAEL RUDY, CASE NO.: 2021 CA 000024 Plaintiff, Vv. THE STANDARD FIRE INSURANCE COMPANY, Defendant. PLAINTIFF’S FIRST INTERROGATORIES TO DEFENDANT Pursuant to Fla. R. Civ. P. 1.340, the Defendant, THE STANDARD FIRE INSURANCE COMPANY, is hereby required to serve upon the Plaintiff, under oath and in writing, within thirty (30) days from the date of service hereof, answers to the following Interrogatories in the space provided after each. Please be advised that these Interrogatories are being submitted for the purpose of discovery and for use as evidence at the trial of this cause. Your responses to the following Interrogatories must be truthful and, as much as is possible, based on your personal knowledge. You are encouraged not to speculate or guess at any response. In the event the space provided for response to any question is insufficient to completely answer that question, and then please attach additional pages to these Interrogatories as necessary to respond fully and completely. Incomplete or evasive answers shall be deemed an incomplete response to the question or questions so answered and will result in an application to the Court by the Plaintiff, for an order compelling a more complete and more definite answer.INTERROGATORIES 1. List the full name, position/title and business address of the person answering these interrogatories on behalf of the Defendant. 2. Describe any and all policies of insurance, including umbrella policies, which may provide coverage to the Plaintiff for the allegations set forth in the Complaint, detailing as to such policies; the name of the insurer, policy number, effective dates of the policy, limits of liability coverage, and the name and address of the custodian of the policy. 3. Explain your understanding of how the motor vehicle crash described in the Complaint happened. 4. Describe in detail each act or omission on the part of any individual or entity that you contend constituted negligence that was a contributing legal cause of the incident in question. 5. Describe those acts which the Plaintiff, MICHAEL RUDY, either did or failed to do which you contend constituted negligence that was a contributing legal cause of the incident in question.6. State the facts upon which you rely for each affirmative defense in your Answer. 7. List the names and addresses of all persons who are believed or known by you, your agents or attorneys to have any knowledge or information concerning any of the issues in this lawsuit and specify the subject matter about which the witness has knowledge. 8. Have you heard or do you know about any statement or remark made by or on behalf of any party to this lawsuit 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. 9. State the name and address of every person known to you, your agents or 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 such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. 10. 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’ 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.11. If you contend that any person or entity is liable in whole or part for the claims asserted against you in this lawsuit, 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. 12. Did any mechanical defect in the motor vehicle driven by Leonard J. Tadeo contribute to the motor vehicle crash at issue? If so, describe the nature of the defect and how it contributed to the incident. 13. If you paid property damage claims on either vehicle involved in the subject motor vehicle crash, list the total dollar amount you paid for each. 14. List the name, address and telephone number of each appraiser of property damage for the vehicles involved in the subject motor vehicle crash, the date of each appraisal and the amount of each appraisal.VERIFICATION OF ANSWERS TO INTERROGATORIES Date: Representative - THE STANDARD FIRE INSURANCE COMPANY STATE OF COUNTY OF I HEREBY CERTIFY that on this day of ; 2020, before me, an officer duly authorized in the State and County aforesaid, personally appeared , known to me personally or identified by or through » who under oath acknowledged execution of the foregoing interrogatories. WITNESS my hand and official seal this day of , 2020. Print Name: Notary Public, State of Florida My commission expires