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Filing # 126234863 E-Filed 05/05/2021 03:18:06 PM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT,
IN AND FOR FLAGLER COUNTY, FLORIDA
CASE NO: 2021-CA-000024
MICHAEL RUDY,
Plaintiff,
v.
THE STANDARD FIRE
INSURANCE COMPANY,
Defendant.
/
NOTICE OF SERVICE OF INTERROGATORIES TO PLAINTIFF,
MICHAEL RUDY
PLEASE TAKE NOTICE that Interrogatories have been propounded to Plaintiff,
MICHAEL RUDY, in the above-captioned matter by e-mail this Sth day of May, 2021.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document has been
served through the Florida courts E-Portal system, which will provide the foregoing by e-mail to:
WILLIAM M. CHANFRAU, IR., ESQ. at williamjr@chanfraulaw.com,
jessica@chanfraulaw.com, Johanna@chanfraulaw.com and GREGORY A. OLSEN, ESQ. at
greg@chanfraulaw.com on this 5th day of May, 2021.
4s/ Abby R. Dyal, Esq.
Abby R. Dyal, Esquire
Florida Bar No.: 84614
LAW OFFICES OF JACK D. EVANS
4600 Touchton Road East
Building 100, Suite 140
Jacksonville, FL 32246-8299
Ph: (904) 928-2947
Fax: (888) 896-5620
Primary: ADyal@travelers.com
Secondary: JDEorlan@travelers.com
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 05/06/2021 01:58 PMIN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT,
IN AND FOR FLAGLER COUNTY, FLORIDA
CASE NO: 2021-CA-000024
MICHAEL RUDY,
Plaintiff,
v.
THE STANDARD FIRE
INSURANCE COMPANY,
Defendants.
/
INTERROGATORIES TO PLAINTIFF, MICHAEL RUDY
Pursuant to Fla. R. Civ. P. 1.340, Defendant, The Standard Fire Insurance Company,
propounds the following Interrogatories to the Plaintiff, MICHAEL RUDY, to be answered fully, in
writing and under oath, within thirty (30) days from the date of service hereof.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document has been
served through the Florida courts E-Portal system, which will provide the foregoing by e-mail to:
WILLIAM M. CHANFRAU, JR., ESQ. at williamjr@chanfraulaw.com,
jessica@chanfraulaw.com, Johanna@chanfraulaw.com and GREGORY A. OLSEN, ESQ. at
greg(@chanfraulaw.com on this Sth day of May, 2021.
4s/ Abby R. Dyal, Esq.
Abby R. Dyal, Esquire
Florida Bar No.: 84614
LAW OFFICES OF JACK D. EVANS
4600 Touchton Road East
Building 100, Suite 140
Jacksonville, FL 32246-8299
Ph: (904) 928-2947
Fax: (888) 896-5620
Primary: ADyal@travelers.com
Secondary: JDEorlan@travelers.comINTERROGATORIES
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 the names, business addresses, dates of employment, and rates of pay regarding all
employers, including self-employment, for whom you have worked in the past 10 years.
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, your social security
number, your date of birth, and, if you are or have ever been married, the name of your
spouse or spouses.
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?
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.
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?10.
ll.
12.
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.
Describe in detail how the incident described in the complaint happened.
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.
List each 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.
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.
Has anything been paid or is anything payable from any third party for the damages listed in
your answers to these interrogatories? If so, state the amounts paid or payable, the name and
business address of the person or entity who paid or owes said amounts, and which of these
third parties have or claim a right of subrogation.13.
14,
15.
16.
17.
List the names and business addresses of each physician who has treated or examined you,
and each medical facility where you have received any treatment or examination for the
injuries for which you seek damages in this case; and state as to each, the date of treatment
or examination, and the injury or condition for which you were examined or treated.
List the names and business addresses of all other physicians, medical facilities or other
health care providers by whom or at which 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.
List the names and addresses of all persons who are believed or known by you, your agents
or 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, or any witness 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 date, time, place, and substance of each
statement.
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, video tape, 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.18.
19,
20.
21.
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.
Please state if you have ever made a prior and/or subsequent personal injury claim or have
been a party, either plaintiff or defendant, in a lawsuit other than the present matter and if so,
state the date and nature of the personal injury claim and the parties to the lawsuit, the court
in which the lawsuit was maintained and the ultimate resolution of it.
Please state whether you, your attorney(s), or anyone on the behalf of you of your
attorney(s) has entered into an agreement, contract, contingency or loan with a lender,
litigation funding company, litigation lending company, medical funding company or
other similar entity, company, corporation, partnership or person that is engaged in
loaning money, advancing money or financially assisting you or your attorney in any
aspect of this case, whether it be for payment of medical bills, litigation expenses,
witness expenses, lost wages or an advancement against a portion or all of any potential
recovery you may receive.
If the preceding interrogatory is applicable, please identify fully the following:
(a) The complete name and address of the lender, litigation funding company,
litigation lending company, medical funding company or similar entity as
described above.
(b) The date on which agreement, advance or loan was made.
(c) The amount of such agreement, advance or loan.
(d) All information, including documents of any kind provided to the lender,
litigation funding company, litigation lending company, either pursuant to the
request of the litigation funding company, litigation lending company, or
voluntarily.22. Identify the user name and email address for any and all social networking sites,
including, but not limited to Facebook, Instagram, Twitter, SnapChat, Tik Tok, etc.,
account maintained by you or on your behalf from February 1, 2014 to present.
23. Please state whether between the period beginning 24 months before the incident that is
the subject of this litigation and the date on which you answer these interrogatories you
have worn at any time a mobile tracking device (such as but not limited to a cell phone, a
“Fitbit” or “Apple Tracking Watch”). If so, please identify all such devices that you have
worn and the dates that you have worn them.
UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING
AND THAT THE FACTS STATED IN IT ARE TRUE.
MICHAEL RUDY
STATE OF FLORIDA,
COUNTY OF »SS:
The foregoing instrument was acknowledged before me_ this day of
; , by MICHAEL RUDY, who is personally known to me or who
has produced as identification.
NOTARY PUBLIC
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Filing # 126234863 E-Filed 05/05/2021 03:18:06 PM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO: 2021-CA-000024 MICHAEL RUDY, Plaintiff, v. THE STANDARD FIRE INSURANCE COMPANY, Defendant. / NOTICE OF SERVICE OF INTERROGATORIES TO PLAINTIFF, MICHAEL RUDY PLEASE TAKE NOTICE that Interrogatories have been propounded to Plaintiff, MICHAEL RUDY, in the above-captioned matter by e-mail this Sth day of May, 2021. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document has been served through the Florida courts E-Portal system, which will provide the foregoing by e-mail to: WILLIAM M. CHANFRAU, IR., ESQ. at williamjr@chanfraulaw.com, jessica@chanfraulaw.com, Johanna@chanfraulaw.com and GREGORY A. OLSEN, ESQ. at greg@chanfraulaw.com on this 5th day of May, 2021. 4s/ Abby R. Dyal, Esq. Abby R. Dyal, Esquire Florida Bar No.: 84614 LAW OFFICES OF JACK D. EVANS 4600 Touchton Road East Building 100, Suite 140 Jacksonville, FL 32246-8299 Ph: (904) 928-2947 Fax: (888) 896-5620 Primary: ADyal@travelers.com Secondary: JDEorlan@travelers.com Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 05/06/2021 01:58 PMIN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CASE NO: 2021-CA-000024 MICHAEL RUDY, Plaintiff, v. THE STANDARD FIRE INSURANCE COMPANY, Defendants. / INTERROGATORIES TO PLAINTIFF, MICHAEL RUDY Pursuant to Fla. R. Civ. P. 1.340, Defendant, The Standard Fire Insurance Company, propounds the following Interrogatories to the Plaintiff, MICHAEL RUDY, to be answered fully, in writing and under oath, within thirty (30) days from the date of service hereof. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document has been served through the Florida courts E-Portal system, which will provide the foregoing by e-mail to: WILLIAM M. CHANFRAU, JR., ESQ. at williamjr@chanfraulaw.com, jessica@chanfraulaw.com, Johanna@chanfraulaw.com and GREGORY A. OLSEN, ESQ. at greg(@chanfraulaw.com on this Sth day of May, 2021. 4s/ Abby R. Dyal, Esq. Abby R. Dyal, Esquire Florida Bar No.: 84614 LAW OFFICES OF JACK D. EVANS 4600 Touchton Road East Building 100, Suite 140 Jacksonville, FL 32246-8299 Ph: (904) 928-2947 Fax: (888) 896-5620 Primary: ADyal@travelers.com Secondary: JDEorlan@travelers.comINTERROGATORIES 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 the names, business addresses, dates of employment, and rates of pay regarding all employers, including self-employment, for whom you have worked in the past 10 years. 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, your social security number, your date of birth, and, if you are or have ever been married, the name of your spouse or spouses. 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? 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. 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?10. ll. 12. 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. Describe in detail how the incident described in the complaint happened. 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. List each 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. 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. Has anything been paid or is anything payable from any third party for the damages listed in your answers to these interrogatories? If so, state the amounts paid or payable, the name and business address of the person or entity who paid or owes said amounts, and which of these third parties have or claim a right of subrogation.13. 14, 15. 16. 17. List the names and business addresses of each physician who has treated or examined you, and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this case; and state as to each, the date of treatment or examination, and the injury or condition for which you were examined or treated. List the names and business addresses of all other physicians, medical facilities or other health care providers by whom or at which 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. List the names and addresses of all persons who are believed or known by you, your agents or 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, or any witness 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 date, time, place, and substance of each statement. 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, video tape, 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.18. 19, 20. 21. 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. Please state if you have ever made a prior and/or subsequent personal injury claim or have been a party, either plaintiff or defendant, in a lawsuit other than the present matter and if so, state the date and nature of the personal injury claim and the parties to the lawsuit, the court in which the lawsuit was maintained and the ultimate resolution of it. Please state whether you, your attorney(s), or anyone on the behalf of you of your attorney(s) has entered into an agreement, contract, contingency or loan with a lender, litigation funding company, litigation lending company, medical funding company or other similar entity, company, corporation, partnership or person that is engaged in loaning money, advancing money or financially assisting you or your attorney in any aspect of this case, whether it be for payment of medical bills, litigation expenses, witness expenses, lost wages or an advancement against a portion or all of any potential recovery you may receive. If the preceding interrogatory is applicable, please identify fully the following: (a) The complete name and address of the lender, litigation funding company, litigation lending company, medical funding company or similar entity as described above. (b) The date on which agreement, advance or loan was made. (c) The amount of such agreement, advance or loan. (d) All information, including documents of any kind provided to the lender, litigation funding company, litigation lending company, either pursuant to the request of the litigation funding company, litigation lending company, or voluntarily.22. Identify the user name and email address for any and all social networking sites, including, but not limited to Facebook, Instagram, Twitter, SnapChat, Tik Tok, etc., account maintained by you or on your behalf from February 1, 2014 to present. 23. Please state whether between the period beginning 24 months before the incident that is the subject of this litigation and the date on which you answer these interrogatories you have worn at any time a mobile tracking device (such as but not limited to a cell phone, a “Fitbit” or “Apple Tracking Watch”). If so, please identify all such devices that you have worn and the dates that you have worn them. UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING AND THAT THE FACTS STATED IN IT ARE TRUE. MICHAEL RUDY STATE OF FLORIDA, COUNTY OF »SS: The foregoing instrument was acknowledged before me_ this day of ; , by MICHAEL RUDY, who is personally known to me or who has produced as identification. NOTARY PUBLIC