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Filing #81079556 E-Filed 11/20/2018 04:07:51 PM
NORTHWEST FEDERAL CREDIT UNION IN THE CIRCUIT COURT OF THE 8TH
Plaintiff, JUDICIAL CIRCUIT IN AND FOR ORANGE
COUNTY, FLORIDA
vs.
CIRCUIT CIVIL DIVISION
MARTHA MENDOZA and RAFAEL BAEZ, jointly
and severally CASE NO: 17-CA-9712-0
Defendant(s),
NOTICE OF SERVICE OF INTERROGATORIES
Pursuant to Florida Rule of Civil Procedure 1.340, the Plaintiff, NORTHWEST FEDERAL CREDIT
UNION propounds the following Interrogatories to the Defendant(s), MARTHA MENDOZA and RAFAEL
BAEZ, jointly and severally to be answered under oath within thirty (30) days from receipt.
‘| HEREBY CERTIFY that a true and correct copy of the above and foregoing was e-mailed this
’ / day of November, 2018 pursuant to Florida Rule of Judicial Administration 2.516 to Ashley
Réyes, Esq. The Elder Law Center of Kirson & Fuller , Attorney for Defendant at
areyes@kirsonfulelr.com and was e-mailed pursuant to Florida Rule of Judicial Administration 2,516 to
Benjamin Clayton Iseman, Esq., Swann, Hadley, Stump, Dietrich & Spears , Attorney for Defendant at
biseman@swannhadley.com
SPRECHMAN & FISHER, P.A.
Attorney for Plaintiff
2775 Sunny Isles Blvd, Ste 100
Miami, FL 33160-4007
305-931-0100, .80 440-6289
L/|
By.
Stacey S. Fisher; Esq.
Fla. Bar No: 826669
Designated E-mail address for pleadings:
pleadings@sprechmaniaw.com
All other correspondence:
stacey.fisher@sprechmanlaw.com
This communication is from a debt collector. This is an attempt to collect a debt,
and any information obtained will be used for that purpose.
438329:P439
ee
INTERROGATORIES
1 Please state the name, business and home addresses and telephone numbers of the
person(s) answering these interrogatories.
2 Please list the name, business and home addresses and telephone numbers, of the
person(s) who executed the contract attached to Plaintiff's Complaint on behalf of the Defendant.
3. If you claim that the Plaintiff failed to perform any conditions enabling Plaintiff to sue on
the contract, please list in detail each and every way the Plaintiff failed to perform.
4 If you take the position that the prices reflected in the exhibits to the Complaint do not
represent the prices agreed upon, please indicate what the agreed prices were to be, and who, on behalf
of the Plaintiff, so agreed to them.
5 If you claim that Plaintiff failed to perform pursuant to the terms of the Contract, please
state whether you notified the Plaintiff of such problems, and if so, please state:
a. The date of any such notification and the content of the same.
Whether such notification was oral or written.
To whom representing the Plaintiff such notification was given.
Who representing the Defendant(s) gave such notification.
The content of the Plaintiff's reply to each such notification.
If you objected to any of the exhibits attached to the Complaint upon their receipt, please
state:
a. Whether your objection was oral or in writing.
b When and by what method did you so object.
C. To whom representing the Plaintiff you conveyed your objection.
d, Who representing the Defendant(s) made the objection.
7. If you claim to have paid in full or in part the amount sued for in this case, please identify
the date and manner of payment, and the recipient of the same.
8. If you have not paid in full for the obligation which is the subject matter of this action,
please state your reason for not paying in full the amount listed on the Complaint.
9. Please list each person known to you or to your attorney who has personal knowledge of
the matters involved in this lawsuit, and as to each, please state their name, home and business
addresses and telephone numbers, and relationship to the Defendant(s), if any.
10. State the names, addresses, and telephone numbers of each person whom you intend to
call as a witness at the trial of this case, and provide a brief synopsis as to the anticipated testimony of
each.
a1. State the names, addresses, and telephone numbers of each person whom you intend to
call as an expert witness at the trial of this case, and provide a brief synopsis as to the anticipated
testimony of each.
412. With reference to each and every Affirmative Defense you have stated, state the factual
basis for your defense, identify all persons who have personal knowledge of the facts supporting the
defense and state the date and description of any documents which would support the defense.
STATE OF )
)
COUNTY OF )
Before me, the undersigned authority personally appeared , who, after
being duly sworn deposes and says that the answers to the interrogatories heretofore propounded are
true and correct to the best of his/her belief and knowledge, and who is
Personally known to me, or
Produced identification;
type of identification
Affiant
SWORN TO AND SUBSCRIBED before me this __ day of
, 2018, in County, Florida.
Notary Public, STATE OF FLORIDA
My commission Expires:
| hereby certify that a true and correct copy of the above and foregoing has been furnished, by
mail, this day of , 2018 to SPRECHMAN & FISHER, P.A., 2775 Sunny Isles
Bivd., Suite 100, Miami, Florida 33160.
138329:P439
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Filing #81079556 E-Filed 11/20/2018 04:07:51 PM NORTHWEST FEDERAL CREDIT UNION IN THE CIRCUIT COURT OF THE 8TH Plaintiff, JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA vs. CIRCUIT CIVIL DIVISION MARTHA MENDOZA and RAFAEL BAEZ, jointly and severally CASE NO: 17-CA-9712-0 Defendant(s), NOTICE OF SERVICE OF INTERROGATORIES Pursuant to Florida Rule of Civil Procedure 1.340, the Plaintiff, NORTHWEST FEDERAL CREDIT UNION propounds the following Interrogatories to the Defendant(s), MARTHA MENDOZA and RAFAEL BAEZ, jointly and severally to be answered under oath within thirty (30) days from receipt. ‘| HEREBY CERTIFY that a true and correct copy of the above and foregoing was e-mailed this ’ / day of November, 2018 pursuant to Florida Rule of Judicial Administration 2.516 to Ashley Réyes, Esq. The Elder Law Center of Kirson & Fuller , Attorney for Defendant at areyes@kirsonfulelr.com and was e-mailed pursuant to Florida Rule of Judicial Administration 2,516 to Benjamin Clayton Iseman, Esq., Swann, Hadley, Stump, Dietrich & Spears , Attorney for Defendant at biseman@swannhadley.com SPRECHMAN & FISHER, P.A. Attorney for Plaintiff 2775 Sunny Isles Blvd, Ste 100 Miami, FL 33160-4007 305-931-0100, .80 440-6289 L/| By. Stacey S. Fisher; Esq. Fla. Bar No: 826669 Designated E-mail address for pleadings: pleadings@sprechmaniaw.com All other correspondence: stacey.fisher@sprechmanlaw.com This communication is from a debt collector. This is an attempt to collect a debt, and any information obtained will be used for that purpose. 438329:P439 ee INTERROGATORIES 1 Please state the name, business and home addresses and telephone numbers of the person(s) answering these interrogatories. 2 Please list the name, business and home addresses and telephone numbers, of the person(s) who executed the contract attached to Plaintiff's Complaint on behalf of the Defendant. 3. If you claim that the Plaintiff failed to perform any conditions enabling Plaintiff to sue on the contract, please list in detail each and every way the Plaintiff failed to perform. 4 If you take the position that the prices reflected in the exhibits to the Complaint do not represent the prices agreed upon, please indicate what the agreed prices were to be, and who, on behalf of the Plaintiff, so agreed to them. 5 If you claim that Plaintiff failed to perform pursuant to the terms of the Contract, please state whether you notified the Plaintiff of such problems, and if so, please state: a. The date of any such notification and the content of the same. Whether such notification was oral or written. To whom representing the Plaintiff such notification was given. Who representing the Defendant(s) gave such notification. The content of the Plaintiff's reply to each such notification. If you objected to any of the exhibits attached to the Complaint upon their receipt, please state: a. Whether your objection was oral or in writing. b When and by what method did you so object. C. To whom representing the Plaintiff you conveyed your objection. d, Who representing the Defendant(s) made the objection. 7. If you claim to have paid in full or in part the amount sued for in this case, please identify the date and manner of payment, and the recipient of the same. 8. If you have not paid in full for the obligation which is the subject matter of this action, please state your reason for not paying in full the amount listed on the Complaint. 9. Please list each person known to you or to your attorney who has personal knowledge of the matters involved in this lawsuit, and as to each, please state their name, home and business addresses and telephone numbers, and relationship to the Defendant(s), if any. 10. State the names, addresses, and telephone numbers of each person whom you intend to call as a witness at the trial of this case, and provide a brief synopsis as to the anticipated testimony of each. a1. State the names, addresses, and telephone numbers of each person whom you intend to call as an expert witness at the trial of this case, and provide a brief synopsis as to the anticipated testimony of each. 412. With reference to each and every Affirmative Defense you have stated, state the factual basis for your defense, identify all persons who have personal knowledge of the facts supporting the defense and state the date and description of any documents which would support the defense. STATE OF ) ) COUNTY OF ) Before me, the undersigned authority personally appeared , who, after being duly sworn deposes and says that the answers to the interrogatories heretofore propounded are true and correct to the best of his/her belief and knowledge, and who is Personally known to me, or Produced identification; type of identification Affiant SWORN TO AND SUBSCRIBED before me this __ day of , 2018, in County, Florida. Notary Public, STATE OF FLORIDA My commission Expires: | hereby certify that a true and correct copy of the above and foregoing has been furnished, by mail, this day of , 2018 to SPRECHMAN & FISHER, P.A., 2775 Sunny Isles Bivd., Suite 100, Miami, Florida 33160. 138329:P439