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35-2021-CA-000746-AXXX-XX
Filing # 125955666 E-Filed 04/30/2021 03:10:20 PM
IN THE CIRCUIT COURT OF THE
FIFTH JUDICIAL CIRCUIT, INAND FOR
LAKE COUNTY, FLORIDA
CASE NO.:
KRISH DARMALINGUM,
Plaintiff,
vs.
CLEAR BLUE INSURANCE COMPANY,
Defendant.
/
NOTICE OF SERVICE OF INTERROGATORIES
Plaintiff(s), pursuant to Rules 1.340 and 1.570(e) of the Florida Rules of Civil
Procedure, hereby files Notice of Service of the original and one (1) copy of a set of
Interrogatories to be answered by the Defendant under oath and in writing, within forty-
five (45) days from the date of service hereof.
| HEREBY CERTIFY that | have served a true and correct copy of the foregoing
upon the Defendant's Registered Agent: State of Florida, Chief Financial Officer, 200 E.
Gaines St., Tallahassee, Florida, 32399, contemporaneously with the Summons and
Complaint in this matter.
BOLTZ LEGAL
1221 E. Broadway St., Suite 1011
Oviedo, FL 32765
Telephone: (386) 868-5848
Fax: (386) 868-5847
ATTORNEY FOR PLAINTIFF
Primary: brookeboltz@boltzlegal.com
Secondary: blacy@boltzlegal.com
/s/_ BROOKE BOLTZ
BROOKE BOLTZ, ESQUIRE
Florida Bar No.: 54035
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 05/03/2021 09:09:33 AMIN THE CIRCUIT COURT OF THE
FIFTH JUDICIAL CIRCUIT, INAND FOR
LAKE COUNTY, FLORIDA
CASE NO.:
KRISH DARMALINGUM,
Plaintiff,
vs.
CLEAR BLUE INSURANCE COMPANY,
Defendant.
INTERROGATORIES TO DEFENDANT
TO: CLEAR BLUE INSURANCE COMPANY
clo SERVICE OF PROCESS SECTION
FLORIDA DEPARTMENT OF INSURANCE
P. O. Box 6200
Tallahassee, FL 32314-6200
PURSUANT to Rules 1.280 and 1.570 of the Florida Rules of Civil Procedure,
Plaintiffs) propounds to the Defendant the attached Interrogatories to be answered under
oath and in writing within forty-five (45) days after service hereof.
(Definitions: “You(r) as used in these interrogatories means your corporation, company
or partnership, or any who handles, adjust or investigates claims on its behalf.)
1. State your complete corporate name, nature of your business, whether you are
licensed to do business in the State of Florida, whether you maintain agents for
the transacting of your customary business in LAKE County, Florida, and whether
your name as it appears in the Plaintiffs’ Complaint is correct.
2. List the names, addresses and telephone numbers of all persons believed or
known by you, your agents or attorneys to have any knowledge concerning any of
the issues raised by the pleadings and in each claim described in the Complaint,
specifying the subject matter about which the witnesses have knowledge and state
whether you have obtained any statements (oral, written and/or recorded) from
any of said witnesses, list the dates any such witness statements were taken, by
whom any such witness statements were taken and who has present possession,
custody and control of any such statements.. List the names, residence addresses, business addresses and telephone number
of all persons believed or known by you, your agents, or attorneys, to have heard
Plaintiffs make any statement, remark or comment concerning the loss(-es)
complained of in the Complaint and the substance of any such statement, remark
or comment.
. List the names, residence addresses, business addresses and telephone numbers
of all persons who, on your behalf or on behalf of your agents or representative,
have if any participated in the investigation, adjusting or handling of the claim for
benefits involved herein and specify the date and the nature of the participation of
each such person.
. Describe in detail each fact known to you about the nature of the Plaintiffs’ request
for coverage and what information (from any source) you have indicating that
Defendant has paid Plaintiffs’ damages in full.
. For any and all policy defenses which you reasonably believe are available with
regard to the claim(s) made by the Plaintiffs herein: Describe in detail the factual
and legal basis for any such defenses and give complete names, residence
addresses, business addresses and telephone number of each and every person
believed or known by you, your agents or attorneys, to have knowledge of the facts
which would provide the basis for any such defenses.
. List the names, addresses and official positions of each and every person in your
employ or in the employ of anyone on your behalf who has had any involvement
in the review of the denial or withholding of payment of the Plaintiffs’ claim and
state in what capacity they were involved, the date they were involved and the
nature of their involvement.
. With regard to the Plaintiff's Request to Produce served with the Complaint, for
each item on the Request to Produce of which you are withholding production
claiming any privilege (work product/attorney-client, etc.), please state, with
respect to each such document: The date of the document; the number of pages
of the document; the type of document involved and its general subject matter; the
names of all person who prepared the document; to whom the document was
directed; the privilege upon the Defendant relies on withholding the document: all
facts upon which Defendant relies in support of the privilege; the names, business
addresses, residence addresses, telephone numbers, positions and occupations
of all persons known or believed by Defendant to have knowledge concerning the
factual basis for Defendant's assertion of privilege with regard to the documents;
and any policy provisions, statutory languages or case law which Defendant relies
upon in claiming the privilege.
. Please state how much money Defendant has paid any consultants who examined
Plaintiffs’ property (whether engineers, contractors, meteorologists, scientists,underwriters or adjusters) over the past 3 years for the evaluation of claims
submitted to Defendant by Defendant’s insureds.
10.State the total amount of compensation, fees and costs which have been paid by
or on behalf of the Defendant to any of its experts or consultants for work on this
case in the past three (3) years.Signature of Agent for Defendant
CLEAR BLUE INSURANCE COMPANY
STATE OF
COUNTY OF
BEFORE ME, the undersigned authority, appeared
, who is
personally known to me or who has provided
as identification, and he / she states that the above and foregoing Answers to
Interrogatories are true and correct.
NOTARY PUBLIC-State of
My Commission Expires:
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35-2021-CA-000746-AXXX-XX Filing # 125955666 E-Filed 04/30/2021 03:10:20 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, INAND FOR LAKE COUNTY, FLORIDA CASE NO.: KRISH DARMALINGUM, Plaintiff, vs. CLEAR BLUE INSURANCE COMPANY, Defendant. / NOTICE OF SERVICE OF INTERROGATORIES Plaintiff(s), pursuant to Rules 1.340 and 1.570(e) of the Florida Rules of Civil Procedure, hereby files Notice of Service of the original and one (1) copy of a set of Interrogatories to be answered by the Defendant under oath and in writing, within forty- five (45) days from the date of service hereof. | HEREBY CERTIFY that | have served a true and correct copy of the foregoing upon the Defendant's Registered Agent: State of Florida, Chief Financial Officer, 200 E. Gaines St., Tallahassee, Florida, 32399, contemporaneously with the Summons and Complaint in this matter. BOLTZ LEGAL 1221 E. Broadway St., Suite 1011 Oviedo, FL 32765 Telephone: (386) 868-5848 Fax: (386) 868-5847 ATTORNEY FOR PLAINTIFF Primary: brookeboltz@boltzlegal.com Secondary: blacy@boltzlegal.com /s/_ BROOKE BOLTZ BROOKE BOLTZ, ESQUIRE Florida Bar No.: 54035 FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 05/03/2021 09:09:33 AMIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, INAND FOR LAKE COUNTY, FLORIDA CASE NO.: KRISH DARMALINGUM, Plaintiff, vs. CLEAR BLUE INSURANCE COMPANY, Defendant. INTERROGATORIES TO DEFENDANT TO: CLEAR BLUE INSURANCE COMPANY clo SERVICE OF PROCESS SECTION FLORIDA DEPARTMENT OF INSURANCE P. O. Box 6200 Tallahassee, FL 32314-6200 PURSUANT to Rules 1.280 and 1.570 of the Florida Rules of Civil Procedure, Plaintiffs) propounds to the Defendant the attached Interrogatories to be answered under oath and in writing within forty-five (45) days after service hereof. (Definitions: “You(r) as used in these interrogatories means your corporation, company or partnership, or any who handles, adjust or investigates claims on its behalf.) 1. State your complete corporate name, nature of your business, whether you are licensed to do business in the State of Florida, whether you maintain agents for the transacting of your customary business in LAKE County, Florida, and whether your name as it appears in the Plaintiffs’ Complaint is correct. 2. List the names, addresses and telephone numbers of all persons believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues raised by the pleadings and in each claim described in the Complaint, specifying the subject matter about which the witnesses have knowledge and state whether you have obtained any statements (oral, written and/or recorded) from any of said witnesses, list the dates any such witness statements were taken, by whom any such witness statements were taken and who has present possession, custody and control of any such statements.. List the names, residence addresses, business addresses and telephone number of all persons believed or known by you, your agents, or attorneys, to have heard Plaintiffs make any statement, remark or comment concerning the loss(-es) complained of in the Complaint and the substance of any such statement, remark or comment. . List the names, residence addresses, business addresses and telephone numbers of all persons who, on your behalf or on behalf of your agents or representative, have if any participated in the investigation, adjusting or handling of the claim for benefits involved herein and specify the date and the nature of the participation of each such person. . Describe in detail each fact known to you about the nature of the Plaintiffs’ request for coverage and what information (from any source) you have indicating that Defendant has paid Plaintiffs’ damages in full. . For any and all policy defenses which you reasonably believe are available with regard to the claim(s) made by the Plaintiffs herein: Describe in detail the factual and legal basis for any such defenses and give complete names, residence addresses, business addresses and telephone number of each and every person believed or known by you, your agents or attorneys, to have knowledge of the facts which would provide the basis for any such defenses. . List the names, addresses and official positions of each and every person in your employ or in the employ of anyone on your behalf who has had any involvement in the review of the denial or withholding of payment of the Plaintiffs’ claim and state in what capacity they were involved, the date they were involved and the nature of their involvement. . With regard to the Plaintiff's Request to Produce served with the Complaint, for each item on the Request to Produce of which you are withholding production claiming any privilege (work product/attorney-client, etc.), please state, with respect to each such document: The date of the document; the number of pages of the document; the type of document involved and its general subject matter; the names of all person who prepared the document; to whom the document was directed; the privilege upon the Defendant relies on withholding the document: all facts upon which Defendant relies in support of the privilege; the names, business addresses, residence addresses, telephone numbers, positions and occupations of all persons known or believed by Defendant to have knowledge concerning the factual basis for Defendant's assertion of privilege with regard to the documents; and any policy provisions, statutory languages or case law which Defendant relies upon in claiming the privilege. . Please state how much money Defendant has paid any consultants who examined Plaintiffs’ property (whether engineers, contractors, meteorologists, scientists,underwriters or adjusters) over the past 3 years for the evaluation of claims submitted to Defendant by Defendant’s insureds. 10.State the total amount of compensation, fees and costs which have been paid by or on behalf of the Defendant to any of its experts or consultants for work on this case in the past three (3) years.Signature of Agent for Defendant CLEAR BLUE INSURANCE COMPANY STATE OF COUNTY OF BEFORE ME, the undersigned authority, appeared , who is personally known to me or who has provided as identification, and he / she states that the above and foregoing Answers to Interrogatories are true and correct. NOTARY PUBLIC-State of My Commission Expires: