Document for Gemalto Cogent Inc Plaintiff vs. Mosa Technology Solutions LLC Defendant

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                                Filing # 90723750 E-Filed 06/06/2019 08:58:58 PM

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

Case No.: CACE 19-011773

GEMALTO COGENT INC.,
Plaintiff,
v

MOSA TECHNOLOGY SOLUTIONS, LLC a Georgia Limited Liability Corporation,
Defendant.

PLAINTIFF'S CERTIFICATE OF SERVICE OF INTERROGATORIES

COMES NOW the Plaintiff, by and through the undersigned attorney and states that a
copy of Plaintiff's Interrogatories are being served with the Complaint and must be answered
pursuant to the Florida Rules of Civil Procedure within 45 days of service.
were emailed this date.

I HEREBY CERTIFY that a true and correct copy of the foregoing was served with the
summons.

LEE B. GARTNER, P.A.

1440 CORAL RIDGE DRIVE, SUITE 221
Coral Springs, Florida 33071

(954) 755-5350 - Telephone

/s/_Lee B. Gartner

LEE B. GARTNER
Florida Bar No.: 173491

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/06/2019 08:58:56 PM.****PLAINTIFF’S INTERROGATORIES

PLAINTIFF,GEMALTO COGENT INC., instructs Defendant, MOSA
TECHNOLOGY SOLUTIONS, LLC a Georgia Limited Liability Corporation, to answer, under
oath, the following interrogatories, pursuant to the Florida Rules of Civil Procedure they must
be answered within 45 days of the service of summons and Interrogatories.

1. Please state the name, address (business and home) and telephone numbers
(business and home), of the person answering these interrogatories.

2. Please state the named of the person(s) who placed the orders on Defendant’s
behalf for the goods described in the exhibits to the Complaint, and the date each order was
placed.

3. If Defendant claims that the goods (as described in the exhibits attached to the
Complaint) received failed to conform to those which it ordered, please state, with particularity,
how the goods failed to confirm to those ordered.

4. If Defendant claims that the prices reflected in the exhibits attached to the
Complaint do not represent the prices agreed upon. Please indicate what the agreed prices were
to be, and who, on Plaintiff's behalf, agreed to them.

5. If Defendant claims any defect or problem with any of the goods described in the
exhibits attached to the Complaint, please state the nature of the defect or problem, the date it
was first observed, and the person who first observed it.

6. If Defendant claims any defect or problem with any of the goods described in the
exhibits attached to the Complaint, please state whether Defendant notified Plaintiff of such
defect or problem, and if so, state:

A. The date Plaintiff was notified and the content of the notification.
B. Who at Plaintiff was given notification.
Cc. Who from Defendant gave notification.

Dz. The content of Plaintiffs reply to each notification.7. If Defendant made an offer to return any of the goods described in the exhibits
attached to the Complaint state:

A. The date of each offer and whether it was made orally or in writing.
B. To whom at Plaintiff each offer was made.
Cc. Who from Defendant made each offer.
Dz. Plaintiffs reply to each offer.
8. If Defendant returned any of the goods described in the exhibits attached to the
Complaint state:
A. A description of the goods and the quantity returned.

B. What authority Defendant had from Plaintiff to make each return, the
name of the person who gave Defendant such authority, and when such authority was obtained.

Cc. When each return was made.

9. If Defendant objected to any of the documents attached as Exhibits to the
Complaint when they were originally received, state:

A. Whether Defendant’s objection was oral or in writing.
B. When each objection was made.
Cc. To whom Defendant conveyed each objection.

Dz. Who made each objection.

10. If Defendant claims to have paid any or all of the amount claimed due in the
Complaint, please identify the date and manner of all the payments (including check numbers, if
payment was made by check) and how they were delivered to Plaintiff.

11. If Defendant has not paid the entire amount claimed due in the Complaint, please
state the reasons for not paying that amount.12. Please name each person known to Defendant or to Defendant’s attorneys who
has personal knowledge of the matters at issue and telephone numbers, and relationship to
Defendant.

CERTIFICATE OF PERSON ANSWERING PLAINTIFF’S INTERROGATORIES

STATE OF }
COUNTY OF }

BEFORE ME the undersigned authority, personally appeared
after being duly sworn, says within his/her personal knowledge that the answers to Plaintiff’s
Interrogatories are true and correct.

Notary Public