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Filing # 83946745 E-Filed 01/25/2019 07:20:44 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. 18-001322 (12)
KARMEL RUNCIE,
Plaintiff,
INTERNATIONAL VILLAGE
ASSOCIATION, INC. and
DOREEN SYRLIK
Defendants.
PLAINTIFF’ TICE OF SERVING FOURTH SET OF INTERROGATORIES T
DEFENDANT INTERNATIONAL VILLAGE A‘ TATION, IN
Plaintiff, KARMEL RUNCIE, by and through undersigned counsel, and pursuant to Rule
1.340 of the Florida Rules of Civil Procedure, hereby gives notice of the service of the attached
Fourth Set of Interrogatories on Defendant, International Village Association, Inc. to answer said
Interrogatories under oath and in writing within thirty (30) days.
Respectfully submitted,
By: Chelsea Lewis, Esq.
Chelsea Lewis, Esq.
Fla. Bar No. 111607
Lewis Law LLC
151 N. Nob Hill Rd., Suite 348
Plantation, FL 33324
chelsealewispa@ gmail.com
Tel. 954-870-9734
Fax 1-888-388-7360
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/25/2019 7:20:45 PM.****IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. 18-001322 (12)
KARMEL RUNCIE,
Plaintiff,
INTERNATIONAL VILLAGE
ASSOCIATION, INC. and
DOREEN SYRLIK
Defendants.
/
PLAINTIFF’S FOURTH SET OF INTERROGATORIES TO
DEFENDANT, INTERNATIONAL VILLAGE ASSOCIATION, INC.
Pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, Plaintiff propounds the
following interrogatories to Defendant, INTERNATIONAL VILLAGE ASSOCIATION, INC, to
be answered fully and completely in accordance with that rule. Each of the following interrogatories
is continuing in nature. If at any time prior to the conclusion of the trial, Defendant, or its agents or
attorneys, acquire supplemental or additional information relating to any of the subjects addressed
herein, Defendant is requested to supplement its answers to these interrogatories to reflect such
information.
INSTRUCTIONS
In answering these interrogatories, the following instructions and definitions apply:A. You are required to furnish all information which is available to you, including
information in the possession of your agents or representatives, or any other person or organization
acting on your behalf, and not merely such information known personally to you.
B. If you cannot answer any of the following interrogatories in full, after exercising due
diligence to secure the information to do so, state and answer to the extent possible and state
whatever information or knowledge you have concerning the unanswered portions.
C. Each interrogatory not only calls for information known to Defendant but also for all
information available to Defendant through reasonable inquiry.
D. Ineach case where Defendant identifies a person, state with respect to each such person:
a. in the case of a person other than a natural person, its name, the address of its principal
place of business (including zipcode), its telephone number, and the name of its chief executive
officer, as well as, if it has a person other than a natural person that ultimately controls it, that other
person's name, the address of that person's principal place of business (including zipcode), that other
person's telephone number, and the name of that other person's chief executive officer;
b. in the case of a natural person, his or her full name, last known home address, last known
work address and telephone number, employer, and title or position;
E. In each case wherein Defendant is asked to identify a writing or document, or when
the answer to an interrogatory refers to a writing or document, please attach a copy of the document
to your answer, or if the document is not available, state with respect to each such writing or
document:
1. The identity of the person who signed it or over whose name it was
issued;2. The addressee or addressees;
3. The nature and substance of the document or writing with sufficient
particularity to enable the same to be identified;
4. The date of the document or writing; and
5. The identity of each person who has custody of the document or writing
or any copies thereof.
FB For purposes of these Interrogatories, “Defendant” refers to International Village
Association, Inc. and “Plaintiff” refers to Karmel Runcie.
G. Where a claim of privilege is asserted in objecting to any interrogatory or sub-part
thereof, and an answer is not provided on the basis of such assertion, provide the information
required pursuant to the Florida Rules of Civil Procedure.
H. “Including” means including, but not limited to.
I ”Person" means any natural person, corporation, company, partnership, joint
venture, firm, association, proprietorship, agency, board, authority, commission, office or other
business or legal entity, whether private or governmental.
I The singular form of a noun or pronoun shall be considered to include within its
meaning the plural form of the noun or pronoun, and vice versa; and the past tense shall include the
present tense where the clear meaning is not distorted. The term "or" shall mean "and" and vice-
versa, as necessary to bring within the scope of the following discovery request all information and/
or documents that would be excluded absent this definition.INTERROGATORIES
1. Please identify any investigator(s) referenced in Defendant’s privilege log in
response to Plaintiff’s Seventh Request for Production (filed on or about January 23, 2019) and
identify all individuals who review, saw, drafted or sent any “correspondence between Defendant
IVA and its investigator regarding the allegations as contained in Plaintiff's Third Amended
Complaint.”
ANSWER:VERIFICATION
I, , being first duly sworn in accordance with law, do hereby
depose and state that I have read the answers to Plaintiff's Fourth Set of Interrogatories and that
the answers are true and correct to the best of my knowledge and information.
Corporate Representative
STATE OF FLORIDA
COUNTY OF
The foregoing instrument was executed before me this day of 7
2019, by » who is personally known to me or who has produced
as identification and who did take an oath.
NOTARY PUBLIC
My Commission Expires:CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 25, 2019, the foregoing was served on Daniel Klein,
Esq. (daniel. klein@esklegal.com; tania.cabrera@csklegal.com); Samuel Fallk, Esq.
(samucl. fallk@esklegal.com; linda.vitti@esklegal.com) via e-mail and facsimile.
By: Chelsea Lewis, Esq.
Chelsea Lewis, Esq.
Fla. Bar No. 111607
Lewis Law LLC
151 N. Nob Hill Rd., Suite 348
Plantation, FL 33324
chelscalewispa@:gmail.com
Tel. 954-870-9734
Fax 1-888-388-7360
Preview
Filing # 83946745 E-Filed 01/25/2019 07:20:44 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 18-001322 (12) KARMEL RUNCIE, Plaintiff, INTERNATIONAL VILLAGE ASSOCIATION, INC. and DOREEN SYRLIK Defendants. PLAINTIFF’ TICE OF SERVING FOURTH SET OF INTERROGATORIES T DEFENDANT INTERNATIONAL VILLAGE A‘ TATION, IN Plaintiff, KARMEL RUNCIE, by and through undersigned counsel, and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby gives notice of the service of the attached Fourth Set of Interrogatories on Defendant, International Village Association, Inc. to answer said Interrogatories under oath and in writing within thirty (30) days. Respectfully submitted, By: Chelsea Lewis, Esq. Chelsea Lewis, Esq. Fla. Bar No. 111607 Lewis Law LLC 151 N. Nob Hill Rd., Suite 348 Plantation, FL 33324 chelsealewispa@ gmail.com Tel. 954-870-9734 Fax 1-888-388-7360 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/25/2019 7:20:45 PM.****IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 18-001322 (12) KARMEL RUNCIE, Plaintiff, INTERNATIONAL VILLAGE ASSOCIATION, INC. and DOREEN SYRLIK Defendants. / PLAINTIFF’S FOURTH SET OF INTERROGATORIES TO DEFENDANT, INTERNATIONAL VILLAGE ASSOCIATION, INC. Pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, Plaintiff propounds the following interrogatories to Defendant, INTERNATIONAL VILLAGE ASSOCIATION, INC, to be answered fully and completely in accordance with that rule. Each of the following interrogatories is continuing in nature. If at any time prior to the conclusion of the trial, Defendant, or its agents or attorneys, acquire supplemental or additional information relating to any of the subjects addressed herein, Defendant is requested to supplement its answers to these interrogatories to reflect such information. INSTRUCTIONS In answering these interrogatories, the following instructions and definitions apply:A. You are required to furnish all information which is available to you, including information in the possession of your agents or representatives, or any other person or organization acting on your behalf, and not merely such information known personally to you. B. If you cannot answer any of the following interrogatories in full, after exercising due diligence to secure the information to do so, state and answer to the extent possible and state whatever information or knowledge you have concerning the unanswered portions. C. Each interrogatory not only calls for information known to Defendant but also for all information available to Defendant through reasonable inquiry. D. Ineach case where Defendant identifies a person, state with respect to each such person: a. in the case of a person other than a natural person, its name, the address of its principal place of business (including zipcode), its telephone number, and the name of its chief executive officer, as well as, if it has a person other than a natural person that ultimately controls it, that other person's name, the address of that person's principal place of business (including zipcode), that other person's telephone number, and the name of that other person's chief executive officer; b. in the case of a natural person, his or her full name, last known home address, last known work address and telephone number, employer, and title or position; E. In each case wherein Defendant is asked to identify a writing or document, or when the answer to an interrogatory refers to a writing or document, please attach a copy of the document to your answer, or if the document is not available, state with respect to each such writing or document: 1. The identity of the person who signed it or over whose name it was issued;2. The addressee or addressees; 3. The nature and substance of the document or writing with sufficient particularity to enable the same to be identified; 4. The date of the document or writing; and 5. The identity of each person who has custody of the document or writing or any copies thereof. FB For purposes of these Interrogatories, “Defendant” refers to International Village Association, Inc. and “Plaintiff” refers to Karmel Runcie. G. Where a claim of privilege is asserted in objecting to any interrogatory or sub-part thereof, and an answer is not provided on the basis of such assertion, provide the information required pursuant to the Florida Rules of Civil Procedure. H. “Including” means including, but not limited to. I ”Person" means any natural person, corporation, company, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission, office or other business or legal entity, whether private or governmental. I The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun, and vice versa; and the past tense shall include the present tense where the clear meaning is not distorted. The term "or" shall mean "and" and vice- versa, as necessary to bring within the scope of the following discovery request all information and/ or documents that would be excluded absent this definition.INTERROGATORIES 1. Please identify any investigator(s) referenced in Defendant’s privilege log in response to Plaintiff’s Seventh Request for Production (filed on or about January 23, 2019) and identify all individuals who review, saw, drafted or sent any “correspondence between Defendant IVA and its investigator regarding the allegations as contained in Plaintiff's Third Amended Complaint.” ANSWER:VERIFICATION I, , being first duly sworn in accordance with law, do hereby depose and state that I have read the answers to Plaintiff's Fourth Set of Interrogatories and that the answers are true and correct to the best of my knowledge and information. Corporate Representative STATE OF FLORIDA COUNTY OF The foregoing instrument was executed before me this day of 7 2019, by » who is personally known to me or who has produced as identification and who did take an oath. NOTARY PUBLIC My Commission Expires:CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 25, 2019, the foregoing was served on Daniel Klein, Esq. (daniel. klein@esklegal.com; tania.cabrera@csklegal.com); Samuel Fallk, Esq. (samucl. fallk@esklegal.com; linda.vitti@esklegal.com) via e-mail and facsimile. By: Chelsea Lewis, Esq. Chelsea Lewis, Esq. Fla. Bar No. 111607 Lewis Law LLC 151 N. Nob Hill Rd., Suite 348 Plantation, FL 33324 chelscalewispa@:gmail.com Tel. 954-870-9734 Fax 1-888-388-7360