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Filing # 67978846 E-Filed 02/14/2018 04:18:24 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
LUIS DOMINICIS,
Plaintiff,
vs.
STATE FARM FLORIDA INSURANCE CASE NO.: CACE 18-000997 (12)
COMPANY,
Defendant.
/
PLAINTIFF’S NOTICE OF SERVING INTERROGATORIES TO DEFENDANT
Plaintiff, LUIS DOMINICIS, by and through the undersigned counsel, and pursuant to rule
1.340, Fla. R. Civ. P., hereby files Plaintiff's Notice of Serving Interrogatories to Defendant,
STATE FARM FLORIDA INSURANCE COMPANY.
CERTIFICATE OF SERVICE
I certify that a copy hereof has been furnished via e-mail service or e-portal service to:
Colleen A. Kerins, Esq., Kirwan, Spellacy & Danner, P.A., 200 South Andrews Ave., st Floor, Ft.
Lauderdale, Florida 33301, (pleadings@kirwanspellacy.com), this 14" day of February, 2018.
KAPLAN LAW GROUP, P.A.
Counsel for Plaintiff
6041 Johnson Street
Hollywood, FL 33024
Telephone: (954) 985-0404
Facsimile: (954) 985-0959
Primary email: receptionist@thckaplanlawgroup.com
Secondary email: mkaplan@thekaplanlawgroup.com
By: 4/ Michael Kaplan
Michael D. Kaplan, Esq.
Fla. Bar No.: 149586
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/14/2018 4:18:24 PM.****INTERROGATORIES TO DEFENDANT
(If answering for another person or entity, answer with respect to
that person or entity, unless otherwise stated.)
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. State the facts upon which you rely for each affirmative defense in your Answer.
3. 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.4. 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.
5. 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.
6. List the names, business addresses and telephone numbers of all persons who, on
your behalf or on behalf of your agents or representatives, have any way participated in the
investigation, adjusting or handling of the claim involved herein and specify the date and the nature
of the participation of each such person.7. For any and all policy defenses which you reasonably believe are available with
regard to the claim made by Plaintiff herein, describe in detail the factual and legal basis for any
such defenses and give complete names and business addresses of each and every person believed
or known by you, your agents, representatives, or attorneys, to have knowledge of the facts which
provide the basis for any such defenses.Affiant
STATE OF )
ss.
COUNTY OF )
BEFORE ME in the State and County stated above, the above Affiant personally
appeared who, after being duly sworn, deposes and states that the foregoing Answers to
Interrogatories were answered to the best of his/her knowledge and information.
SWORN TO and SUBSCRIBED before me this day of
by the foregoing Affiant who is:
o personally known to me, or
oO produced , as identification.
Signature of Notary Public
Typed/Printed Name of Notary Public
Notary Public, State of Florida at Large
My commission expires: [Rubber Stamp Required]
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Filing # 67978846 E-Filed 02/14/2018 04:18:24 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA LUIS DOMINICIS, Plaintiff, vs. STATE FARM FLORIDA INSURANCE CASE NO.: CACE 18-000997 (12) COMPANY, Defendant. / PLAINTIFF’S NOTICE OF SERVING INTERROGATORIES TO DEFENDANT Plaintiff, LUIS DOMINICIS, by and through the undersigned counsel, and pursuant to rule 1.340, Fla. R. Civ. P., hereby files Plaintiff's Notice of Serving Interrogatories to Defendant, STATE FARM FLORIDA INSURANCE COMPANY. CERTIFICATE OF SERVICE I certify that a copy hereof has been furnished via e-mail service or e-portal service to: Colleen A. Kerins, Esq., Kirwan, Spellacy & Danner, P.A., 200 South Andrews Ave., st Floor, Ft. Lauderdale, Florida 33301, (pleadings@kirwanspellacy.com), this 14" day of February, 2018. KAPLAN LAW GROUP, P.A. Counsel for Plaintiff 6041 Johnson Street Hollywood, FL 33024 Telephone: (954) 985-0404 Facsimile: (954) 985-0959 Primary email: receptionist@thckaplanlawgroup.com Secondary email: mkaplan@thekaplanlawgroup.com By: 4/ Michael Kaplan Michael D. Kaplan, Esq. Fla. Bar No.: 149586 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/14/2018 4:18:24 PM.****INTERROGATORIES TO DEFENDANT (If answering for another person or entity, answer with respect to that person or entity, unless otherwise stated.) 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. State the facts upon which you rely for each affirmative defense in your Answer. 3. 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.4. 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. 5. 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. 6. List the names, business addresses and telephone numbers of all persons who, on your behalf or on behalf of your agents or representatives, have any way participated in the investigation, adjusting or handling of the claim involved herein and specify the date and the nature of the participation of each such person.7. For any and all policy defenses which you reasonably believe are available with regard to the claim made by Plaintiff herein, describe in detail the factual and legal basis for any such defenses and give complete names and business addresses of each and every person believed or known by you, your agents, representatives, or attorneys, to have knowledge of the facts which provide the basis for any such defenses.Affiant STATE OF ) ss. COUNTY OF ) BEFORE ME in the State and County stated above, the above Affiant personally appeared who, after being duly sworn, deposes and states that the foregoing Answers to Interrogatories were answered to the best of his/her knowledge and information. SWORN TO and SUBSCRIBED before me this day of by the foregoing Affiant who is: o personally known to me, or oO produced , as identification. Signature of Notary Public Typed/Printed Name of Notary Public Notary Public, State of Florida at Large My commission expires: [Rubber Stamp Required]