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Filing # 60296529 E-Filed 08/11/2017 02:28:33 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN
AND FOR ORANGE COUNTY,
FLORIDA
CASE NO:
RUSTAM IMANGULOV
Plaintiff,
vs.
ILIAS DIMOPOULOS
Defendant.
____________________________________/
NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT
COMES NOW Plaintiff, RUSTAM IMANGULOV, by and through the undersigned
counsel and hereby notifies this Court and counsel of record that it has served its first set of
Interrogatories upon Defendant, to be answered under oath in writing within forty-five (45) days,
in accordance with the Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon
the Defendant with a copy of the Complaint, Request for Admissions and Request to Produce.
/s/ Andres I. Beregovich
___________________________________
ANDRES I. BEREGOVICH, ESQUIRE
Florida Bar No.: 0097812
The Beregovich Law Firm, P.A.
210 N. Mills Avenue
Orlando, FL 32801
Telephone: (407) 809-9000
Facsimile: (407) 809-9001
Service Email: eservice@beregovichlaw.com
Attorney for Plaintiff
DEFINITIONS AND INSTRUCTIONS
Please refer to these definitions and instructions in providing your answers. Unless otherwise
clearly indicated by the context thereof, the following definitions and instructions shall apply to
each of the interrogatories set forth below:
Definitions
1. Defendant means ILIAS DIMOPOULOS.
2. "You" and/or "Your" and “Their” means Plaintiffs, unless otherwise so stated.
3. "Communication" means, without limitation, any oral, written, telephonic, radio, video or
electronic transmission of information, demands or questions, including but not limited to
conversations, meetings, discussions, telephone calls, telegrams, telecopies, telexes, seminars,
conferences, writings, letters, messages, notes, or memoranda.
4. "Document" or "Documents" means all "writings and recordings". The definition is intended
to include all documents, agreements, correspondence, records, ledgers, contracts, bills, invoices,
bills of lading, inventories, financial data, memoranda, notes, or other writings, formal or
informal in nature, accounting and financial records, diaries, statements, telegrams, draft, work
papers, paper and magnetic tapes, charts, computer cards and print outs, electronically or
magnetically stored information or data, minutes, publications, calendars, telephone pads,
bulletins, directives, logs and listings, in your actual or constructive possession, custody or
control, or of which you have knowledge of the existence, and whether prepared, published or
released by you or by any other person or entity. Without limitation on the foregoing, the term
"documents" shall include any copy which differs in any respect from the original or other
versions of the documents, such as copies containing notations, insertions, corrections, marginal
notes or any variations.
5. "Identify" means, when used in reference to:
A. An individual, to state his or her (I) full name; (ii) present or last known home and
business address, including street name and number, city or town and zip code; (iii) present or
last known position, job title and job description;
B. A person other than an individual, to state its (I) full name and type of organization or
entity; (ii) address or principal place of business; and (iii) jurisdiction and date of incorporation
or organization, if known.
C. Documents, to state (I) the name and date of the document, the name and address of
the person(s) originating the document, the name and address, if any, of the person(s) to whom
the document is addressed, the names and addresses of all persons to whom copies of the
documents were to have been sent; and the organization, firm or agency with which any such
persons were connected as of the date of the document; and (ii) whether Plaintiff is in possession
of or have under their control the original or a copy of the document, and, if not in possession of
an original or copy, the name and address of the custodian of each original copy, and the name
and address of each person who Defendant believes presently is in possession of the original or
copy of such document. In lieu of identifying particular documents, when such identification is
requested, the document may, at Defendant’s option, be attached to the response to these
interrogatories, bearing an indication to which interrogatory or interrogatories each document
relates.
D. Conversations, to state the date and place and approximate time of day of the
conversation, the identity of all persons in attendance, the subject matter and reasons for the
conversation, the statements made by each person, including the context in which they were
made and the identity of any writings or recordations which exist relating thereto.
E. A claim, the name of the claimant, the nature of the claim, the names of all parties to
any lawsuit, the court number, if any, the date of the claim, the date upon which Defendant first
became aware of the claim, the relief sought, and the present status or final disposition of the
claim.
F. Any other item or information, to provide a particular description of the same.
6. "Notice" shall include formal and informal notification and is not limited to "notice" as that
term is used in any policy issued to the Plaintiffs.
7. The plural shall include the singular and the singular shall include the plural.
Instructions
1. Privilege. If you contend that you are entitled to withhold information falling within the
purview of this First Set of Interrogatories on the basis of the attorney-client privilege, the work-
product doctrine, or any other ground, such information should be identified by providing a
description of the following:
A. Describe the subject matter of the information in enough detail to determine the
validity of the claimed privilege;
B. Identify the person(s) who have knowledge or who have transmitted said information;
C. State the nature and basis of the privilege or other ground claimed for withholding the
information and;
D. The date such information was transmitted to or by you.
2. Documents. If a document, or documents will provide the requested information, attach the
document(s) to your responses and indicate the Interrogatory to which the document(s) is/are
responsive.
AUTOMOBILE NEGLIGENCE INTERROGATORIES TO DEFENDANT ILIAS
DIMOPOULOS
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 ten 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 one year, or that involved dishonesty or a false statement regardless of the
punishment? If so, state as to each conviction the specific crime, the date and the 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, 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 was 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 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 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.
12. 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.
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 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
occurrence of the accident 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 medication within 12
hours before the incident described in the complaint? If so, state the type and amount of
alcoholic beverages, drugs, or medications 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 described 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 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.
21. At the time of the incident described in the complaint, did you have permission to drive
the vehicle?
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 person 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. At the time of the accident, did you have in your possession a cellular phone(s)? If so,
please provide the name of your cellular phones’ carrier, the cellular phone numbers of
the cellular phone(s) in your possession
25. Please list in chronological order the dates in which you have been involved in a motor
vehicle crash over the last five (5) years regardless of who was at-fault.
I HEREBY affirm that the answers to the above and foregoing Interrogatories are true
and correct to the best of my knowledge and belief.
_________________________________
ILIAS DIMOPOULOS
STATE OF FLORIDA
COUNTY OF _________
THE FOREGOING instrument was acknowledged before me this _____ day of
_____________, 2017, by ________________________________________________________,
who is personally known to me or who has produced identification in the form of
_____________________________________.
___________________________
NOTARY PUBLIC
(Notary Seal)
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Filing # 60296529 E-Filed 08/11/2017 02:28:33 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO: RUSTAM IMANGULOV Plaintiff, vs. ILIAS DIMOPOULOS Defendant. ____________________________________/ NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT COMES NOW Plaintiff, RUSTAM IMANGULOV, by and through the undersigned counsel and hereby notifies this Court and counsel of record that it has served its first set of Interrogatories upon Defendant, to be answered under oath in writing within forty-five (45) days, in accordance with the Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served upon the Defendant with a copy of the Complaint, Request for Admissions and Request to Produce. /s/ Andres I. Beregovich ___________________________________ ANDRES I. BEREGOVICH, ESQUIRE Florida Bar No.: 0097812 The Beregovich Law Firm, P.A. 210 N. Mills Avenue Orlando, FL 32801 Telephone: (407) 809-9000 Facsimile: (407) 809-9001 Service Email: eservice@beregovichlaw.com Attorney for Plaintiff DEFINITIONS AND INSTRUCTIONS Please refer to these definitions and instructions in providing your answers. Unless otherwise clearly indicated by the context thereof, the following definitions and instructions shall apply to each of the interrogatories set forth below: Definitions 1. Defendant means ILIAS DIMOPOULOS. 2. "You" and/or "Your" and “Their” means Plaintiffs, unless otherwise so stated. 3. "Communication" means, without limitation, any oral, written, telephonic, radio, video or electronic transmission of information, demands or questions, including but not limited to conversations, meetings, discussions, telephone calls, telegrams, telecopies, telexes, seminars, conferences, writings, letters, messages, notes, or memoranda. 4. "Document" or "Documents" means all "writings and recordings". The definition is intended to include all documents, agreements, correspondence, records, ledgers, contracts, bills, invoices, bills of lading, inventories, financial data, memoranda, notes, or other writings, formal or informal in nature, accounting and financial records, diaries, statements, telegrams, draft, work papers, paper and magnetic tapes, charts, computer cards and print outs, electronically or magnetically stored information or data, minutes, publications, calendars, telephone pads, bulletins, directives, logs and listings, in your actual or constructive possession, custody or control, or of which you have knowledge of the existence, and whether prepared, published or released by you or by any other person or entity. Without limitation on the foregoing, the term "documents" shall include any copy which differs in any respect from the original or other versions of the documents, such as copies containing notations, insertions, corrections, marginal notes or any variations. 5. "Identify" means, when used in reference to: A. An individual, to state his or her (I) full name; (ii) present or last known home and business address, including street name and number, city or town and zip code; (iii) present or last known position, job title and job description; B. A person other than an individual, to state its (I) full name and type of organization or entity; (ii) address or principal place of business; and (iii) jurisdiction and date of incorporation or organization, if known. C. Documents, to state (I) the name and date of the document, the name and address of the person(s) originating the document, the name and address, if any, of the person(s) to whom the document is addressed, the names and addresses of all persons to whom copies of the documents were to have been sent; and the organization, firm or agency with which any such persons were connected as of the date of the document; and (ii) whether Plaintiff is in possession of or have under their control the original or a copy of the document, and, if not in possession of an original or copy, the name and address of the custodian of each original copy, and the name and address of each person who Defendant believes presently is in possession of the original or copy of such document. In lieu of identifying particular documents, when such identification is requested, the document may, at Defendant’s option, be attached to the response to these interrogatories, bearing an indication to which interrogatory or interrogatories each document relates. D. Conversations, to state the date and place and approximate time of day of the conversation, the identity of all persons in attendance, the subject matter and reasons for the conversation, the statements made by each person, including the context in which they were made and the identity of any writings or recordations which exist relating thereto. E. A claim, the name of the claimant, the nature of the claim, the names of all parties to any lawsuit, the court number, if any, the date of the claim, the date upon which Defendant first became aware of the claim, the relief sought, and the present status or final disposition of the claim. F. Any other item or information, to provide a particular description of the same. 6. "Notice" shall include formal and informal notification and is not limited to "notice" as that term is used in any policy issued to the Plaintiffs. 7. The plural shall include the singular and the singular shall include the plural. Instructions 1. Privilege. If you contend that you are entitled to withhold information falling within the purview of this First Set of Interrogatories on the basis of the attorney-client privilege, the work- product doctrine, or any other ground, such information should be identified by providing a description of the following: A. Describe the subject matter of the information in enough detail to determine the validity of the claimed privilege; B. Identify the person(s) who have knowledge or who have transmitted said information; C. State the nature and basis of the privilege or other ground claimed for withholding the information and; D. The date such information was transmitted to or by you. 2. Documents. If a document, or documents will provide the requested information, attach the document(s) to your responses and indicate the Interrogatory to which the document(s) is/are responsive. AUTOMOBILE NEGLIGENCE INTERROGATORIES TO DEFENDANT ILIAS DIMOPOULOS 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 ten 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 one year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction the specific crime, the date and the 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, 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 was 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 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 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. 12. 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. 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 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 occurrence of the accident 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 medication within 12 hours before the incident described in the complaint? If so, state the type and amount of alcoholic beverages, drugs, or medications 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 described 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 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. 21. At the time of the incident described in the complaint, did you have permission to drive the vehicle? 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 person 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. At the time of the accident, did you have in your possession a cellular phone(s)? If so, please provide the name of your cellular phones’ carrier, the cellular phone numbers of the cellular phone(s) in your possession 25. Please list in chronological order the dates in which you have been involved in a motor vehicle crash over the last five (5) years regardless of who was at-fault. I HEREBY affirm that the answers to the above and foregoing Interrogatories are true and correct to the best of my knowledge and belief. _________________________________ ILIAS DIMOPOULOS STATE OF FLORIDA COUNTY OF _________ THE FOREGOING instrument was acknowledged before me this _____ day of _____________, 2017, by ________________________________________________________, who is personally known to me or who has produced identification in the form of _____________________________________. ___________________________ NOTARY PUBLIC (Notary Seal)