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Filing # 74577046 E-Filed 07/06/2018 02:56:11 PM
IN. THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
THOMAS ROSS, CASE NO.: CACE18000308 (03)
Plaintiff,
vs.
BRIAN LIEFER AND GEICO
GENERAL INSURANCE COMPANY,
Defendants.
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DEFENDANT'S NOTICE OF SERVICE OF
GENERAL PERSONAL INJURY INTERROGATORIES UPON PLAINTIFF
Defendant, BRIAN W. LIEFER, (hereinafter ““Defendant”), by and through the undersigned
attorneys, files the attached set of Interrogatories numbered 1 through 29 to Plaintiff, THOMAS S.
ROSS (hereinafter “Plaintiff’), to be answered in writing, under oath, or objected to within thirty
(30) days pursuant to the applicable Florida Rules of Civil Procedure.
I HEREBY CERTIFY that on July 6, 2018, the foregoing was electronically filed with the Florida
Courts E-Filing Portal and that as a registered participant of the Portal I have effectuated service through
the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Trelvis D. Randolph, Esq.
trelvis.randolph@csklegal.com, ileana.machado@esklegal.com, alina.gonzalez@csklegal.com, Cole,
Scott & Kissane, P.A., 9150 S. Dadeland Boulevard, Suite 1400, Miami, FL 33256 and Malcolm A.
Purow, Esq. , Steinger, Iscoe & Greene, P.A., 2400 E. Commercial Blvd., Suite 900, Fort Lauderdale, FL
33308.
NICHOLAS J. RYAN & ASSOCIATES
110 S. E. 6th Street, Suite 2100
Fort Lauderdale, FL 33301
Telephone: (954) 627-9401
E-mail for service (FL R. Jud. Admin. 2.516):
flor.law-chuckbenson.295019@statefarm.com
See Eee ee
Charles E. Benson, Esq.
Florida Bar No.: 974056
Attorney for Defendant, Brian Liefer
Attorneys and Staff of Nicholas J. Ryan & Associates are Employees of the
Law Department of State Farm Mutual Automobile Insurance Company
*4* FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/6/2018 2:56:11 PM.****GENERAL PERSONAL INJURY INTERROGATORIES
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 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 ten years.
3. 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.4, 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?
5. Have you ever been convicted of a crime, other than 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.
6. Were you suffering from any 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?7. Did you consume any alcoholic beverages or take any drugs or medications within twelve
(12) hours before the occurrence of the accident described in the Complaint? If so, what
type and amount of alcoholic beverages, drugs or medications were consumed and where
did you consume them?
8. Describe in detail how the incident described in the Complaint happened, including all
actions taken by you to prevent the incident.
9. 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.10. 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 this charge, and if
so, what is the name and address of the person or entity that 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?
11. 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.
12. 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.13. 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.
14. 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 those third parties have or claim a right of subrogation.
15. 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.16. 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.
17. 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.
18. Have you heard or do you know about any statement or remark made by or on behalf of
any part 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.19. 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.
20. Do you intend to call any expert witnesses at the time of 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.
21. Have you made any 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.22. 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.
23. At the time of the incident described in the Complaint, were you wearing a seat belt? If
not, please state why not; where you were seated in the vehicle; and whether the vehicle
was equipped with a seat belt that was operational and available for your use.
24. 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.25. State the names, addresses and telephone numbers of all automobile, medical, health
and/or disability insurance carriers of the Plaintiff for the past ten (10) years, including
the policy number(s), claim number(s) and/or identification number(s) for each insurance
policy.
26. Please state whether you have been involved in any other accidents or incidents, either
preceding or subsequent to the subject accident; if so, please provide the date of any such
accident or incident, the circumstances surrounding said event, describe any injuries you
may have suffered and provide the names, dates and addresses or health care providers
who treated or examined any such injuries.
27. Please state if you have ever made a claim for personal injuries, workmen’s
compensation, or social security benefits. If so, please state with whom the claim was
made, when the claim was made, describe the nature of the claim and the events leading
up to the claim, the claim number, and the status or disposition of any such claim(s).28. Please state the full names, addresses and telephone numbers of any and all pharmacies
where you had prescriptions filled within the past ten (10) years.
29. Please state whether, on the date of the accident sued upon, (a) you personally or
professionally had cellular or other wireless telephone service available to you, and (b)
whether there were any cellular or other wireless telephones in your vehicle at the time of
the accident sued upon (whether for your account or the account of anyone else). If your
answer to (a) and/or (b) is “Yes”, for each telephone, state the telephone number and the
name and address of the service provider.JURAT PAGE
I hereby swear or affirm that I have read the foregoing Answers to Interrogatories and
that said Answers are true and correct and to the best of my knowledge and belief this
day of » 2018.
THOMAS 5. ROSS
STATE OF FLORIDA )
) SS:
COUNTY OF )
Before me, the undersigned authority personally appeared THOMAS S. ROSS, who is
personally known to me or has produced the following identification
and who has signed the foregoing Answers to Interrogatories swearing or affirming that said
answers are true and correct to the best of Plaintiff's knowledge and belief.
Name:
Notary Public, State of Florida
Commission No:
My Commission Expires: