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wes CASE NUMBER: 502020CA008922XXXXMB Div: AD ****
Filing # 112166357 E-Filed 08/21/2020 09:08:35 AM
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY
ERNESTINA DE ARMAS; AND MARIO SALVADOR DE
ARMAS,
Plaintiffs,
v.
CHARLIE WILL MITCHELL; AND GEICO GENERAL CIVIL DIVISION
INSURANCE COMPANY,
CASE NO.:
Defendant.
PLAINTIFFS’, NOTICE OF SERVING INTERROGATORIES TO
DEFENDANT, GEICO GENERAL INSURANCE COMPANY
Plaintiffs, ERNESTINA DE ARMAS and MARIO SALVADOR DE ARMAS, by and through the
undersigned attorney, hereby gives notice of propounding Plaintiff's Interrogatories upon
Defendant, GEICO GENERAL INSURANCE COMPANY, to be answered within Forty-five (45) days
from the date of service pursuant to the Florida Rules of Civil Procedure.
| HEREBY CERTIFY that a true and correct copy of the foregoing was attached to the
Complaint and Summons and served to Defendant, GEICO GENERAL INSURANCE COMPANY.
Dated: August 21. 2020.
RUBENSTEIN LAW, P.A.
Attorneys for Plaintiff
250 S. Australian Avenue, Suite 1000
West Palm Beach, FL 33401
Tel: (561) LAW-FIRM
ora ear cane
334-313-3790
ra
Email: Tim@rubensteinlaw.com
jmolano@Rubensteinlaw.com
eservice@rubensteinlaw.com
By: /s/ R. Timothy Vannatta
R. TIMOTHY VANN.
Florida Bar No.:
CHEN. DAIAARCACU AAIINTY Cl CHADAND ANFY FILED nain4ainnon na-na.2c An
PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Yule eu Ug.uU.u9 mvtPLAINTIFF’S INTERROGATORIES TO DEFENDANT,
GEICO GENERAL INSURANCE COMPANY
(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. 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, the 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.
3. Describe in detail how the incident described in the complaint happened.4.
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.
State the facts upon which you rely for each affirmative defense in your answer.
Ao vou rcantand any person ar ontitu athor than Nofandant CHARLIF WII MITCHELL ic
Do you contend any persen er entity other than Defendant, CHARLIE WILL MITCHELL fs,
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.7.
go
List the names and addresses of all persons who are believed or known by you, your
agents, or your attorneys to have any knowledge concerning any of the issues in this
lawsuit; and specify the subject matter about which the witness has knowledge.
Maen tenes bane ae de ines bene abet pinta net ae enn ele wenden hee ae ae Labale af
Have YOu neara OF GS yOu KiOW avout aly StatEMENt GF reMarK Made oy Or Oi Venan GI
any party to this lawsuit 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.
State the name and address of every person known to you, your agents, or your attorneys
who has knowledge about, or possession, custody, or control of, any model, plat, map,
drawing, motion picture, videotape, or photograph pertaining to any fact or issue
involved in this controversy; and describe as to each, what item such person has, the
name and address of the person who took or prepared it, and the date it was taken or
prepared.10.
11.
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.
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.12.
13.
14.
Did any mechanical defect in the motor vehicle which Defendant, CHARLIE WILL
MITCHELL, was driving at the time of the incident described in the complaint contribute
ta tha incidant? Ica dnceriha tha natures af tha dafart and haus it santrihvtad ta tha
10 une meen: 50, GeScnoe wie Naure Or ure UCIect anu now i COmuimuceU tO wie
incident.
Was the motor vehicle that Plaintiff, MARIO SALVADOR DE ARMAS, 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?
Are you asserting any coverage defenses in this case? If so, please state the specific basis
for any coverage defense you intend to argue in this matter.AFFIANT
STATE OF FLORIDA)
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared
, who being duly sworn, deposes and says that the answers to
Interrogatories attached hereto are true to the best of his/her knowledge, information and belief.
SWORN TO AND SUBSCRIBED before me on this day of
2020
AT LARGE
My Commission Expires:
Personally known:
or Produced Identification:
Type of Identification Produced:
Preview
wes CASE NUMBER: 502020CA008922XXXXMB Div: AD **** Filing # 112166357 E-Filed 08/21/2020 09:08:35 AM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY ERNESTINA DE ARMAS; AND MARIO SALVADOR DE ARMAS, Plaintiffs, v. CHARLIE WILL MITCHELL; AND GEICO GENERAL CIVIL DIVISION INSURANCE COMPANY, CASE NO.: Defendant. PLAINTIFFS’, NOTICE OF SERVING INTERROGATORIES TO DEFENDANT, GEICO GENERAL INSURANCE COMPANY Plaintiffs, ERNESTINA DE ARMAS and MARIO SALVADOR DE ARMAS, by and through the undersigned attorney, hereby gives notice of propounding Plaintiff's Interrogatories upon Defendant, GEICO GENERAL INSURANCE COMPANY, to be answered within Forty-five (45) days from the date of service pursuant to the Florida Rules of Civil Procedure. | HEREBY CERTIFY that a true and correct copy of the foregoing was attached to the Complaint and Summons and served to Defendant, GEICO GENERAL INSURANCE COMPANY. Dated: August 21. 2020. RUBENSTEIN LAW, P.A. Attorneys for Plaintiff 250 S. Australian Avenue, Suite 1000 West Palm Beach, FL 33401 Tel: (561) LAW-FIRM ora ear cane 334-313-3790 ra Email: Tim@rubensteinlaw.com jmolano@Rubensteinlaw.com eservice@rubensteinlaw.com By: /s/ R. Timothy Vannatta R. TIMOTHY VANN. Florida Bar No.: CHEN. DAIAARCACU AAIINTY Cl CHADAND ANFY FILED nain4ainnon na-na.2c An PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Yule eu Ug.uU.u9 mvtPLAINTIFF’S INTERROGATORIES TO DEFENDANT, GEICO GENERAL INSURANCE COMPANY (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. 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, the 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. 3. Describe in detail how the incident described in the complaint happened.4. 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. State the facts upon which you rely for each affirmative defense in your answer. Ao vou rcantand any person ar ontitu athor than Nofandant CHARLIF WII MITCHELL ic Do you contend any persen er entity other than Defendant, CHARLIE WILL MITCHELL fs, 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.7. go List the names and addresses of all persons who are believed or known by you, your agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. Maen tenes bane ae de ines bene abet pinta net ae enn ele wenden hee ae ae Labale af Have YOu neara OF GS yOu KiOW avout aly StatEMENt GF reMarK Made oy Or Oi Venan GI any party to this lawsuit 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. State the name and address of every person known to you, your agents, or your attorneys who has knowledge about, or possession, custody, or control of, any model, plat, map, drawing, motion picture, videotape, or photograph pertaining to any fact or issue involved in this controversy; and describe as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared.10. 11. 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. 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.12. 13. 14. Did any mechanical defect in the motor vehicle which Defendant, CHARLIE WILL MITCHELL, was driving at the time of the incident described in the complaint contribute ta tha incidant? Ica dnceriha tha natures af tha dafart and haus it santrihvtad ta tha 10 une meen: 50, GeScnoe wie Naure Or ure UCIect anu now i COmuimuceU tO wie incident. Was the motor vehicle that Plaintiff, MARIO SALVADOR DE ARMAS, 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? Are you asserting any coverage defenses in this case? If so, please state the specific basis for any coverage defense you intend to argue in this matter.AFFIANT STATE OF FLORIDA) COUNTY OF ) BEFORE ME, the undersigned authority, personally appeared , who being duly sworn, deposes and says that the answers to Interrogatories attached hereto are true to the best of his/her knowledge, information and belief. SWORN TO AND SUBSCRIBED before me on this day of 2020 AT LARGE My Commission Expires: Personally known: or Produced Identification: Type of Identification Produced: