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Filing # 198471438 E-Filed 05/16/2024 01:05:29 PM
IN THE CIRCUIT COURT OF THE
THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH
COUNTY, FLORIDA
ASHLEY PARMESHWAR, CASE NO:
Plaintiff,
v.
ERNESTO MEDINA,
Defendant.
____________________________________/
PLAINTIFF’S NOTICE OF SERVICE OF INTERROGATORIES
TO DEFENDANT, ERNESTO MEDINA
The Plaintiff, ASHLEY PARMESHWAR, by and through the undersigned
attorney, propounds upon Defendant, ERNESTO MEDINA interrogatories to be
answered under oath in writing, within forty-five (45) days from the date of service
hereof in accordance with the Rule 1.340, Florida Rules of Civil Procedure.
I HEREBY CERTIFY THAT a copy of the foregoing has been served upon the
above-named Defendant the same date of service as that of the Summons and
Complaint.
/s/ Devry R. Kelley
Devry R. Kelley, Esquire
Florida Bar No.: 0567302
DAN NEWLIN INJURY ATTORNEYS
7335 W. Sand Lake Road, Suite 300
Orlando, FL 32819
Direct: (321) 270-0434
Fax: (863) 225-9853
Attorney for Plaintiff
Devry.pleadings@newlinlaw.com
Devry.Kelley@newlinlaw.com
Marlene.Zervos@newlinlaw.com
5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
GENERAL PERSONAL INJURY NEGLIGENCE INTERROGATORIES TO
DEFENDANT, ERNESTO MEDINA
PLEASE INSERT YOUR ANSWERS IN THE SPACE PROVIDED BELOW EACH
INTERROGATORY. SHOULD ADDITIONAL SPACE BE NEEDED, PLEASE ATTACH
AN EXTRA SHEET. "YOU" AND "YOUR" REFER TO THE DEFENDANT TO WHOM
THESE INTERROGATORIES ARE DIRECTED. DEFENDANT INCLUDES ALL
AGENTS, SERVANTS, OR EMPLOYEES OF THE DEFENDANT. 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. List all former names and when you were known by those names. State all
addresses where you have lived for the past ten (10) years, the dates you lived at
each address, your Social Security number, and your date of birth.
3. Have you ever been convicted of a crime, other than any juvenile adjudication,
which under the law under which you were convicted was punishable by death or
imprisonment in excess of one (1) year, or that involved dishonesty or a false
statement regardless of the punishment? If so, state as to each conviction the
specific crime and the date and place of conviction,
5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
4. 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.
5. Describe in detail how the incident described in the Complaint happened, including
all actions taken by the you to prevent the incident:
6. 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.
7. State the facts upon which you rely for each affirmative defense in your Answer.
5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
8. Do you contend any person or entity other than you is, 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.
9. 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, was entered to the charge;
what court or agency heard the charge; was any written report prepared by anyone
regarding the charge, and, if so, what is the name mad address of the person or
entity who 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 is the name and address of the person who recorded the
testimony.
10. 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.
11. Have you heard or do you know about any statement or remark made by or on
behalf of any party 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.
5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4
12. 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.
13. 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 s 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.
14. Have you made an agreement with anyone that would limit that party's liability to
anyone or any of the damages sued upon in this case? If so, state the terms of the
agreement and the parties to it.
15. 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.
16. Do you wear glasses, contact lenses, or hearing aids?
5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5
17. Were you suffering from physical infirmity, disability, or sickness at the time of the
incident described in the Complaint? If so, what was the nature of the infirmity,
disability, or sickness?
18. Did you consume any alcoholic beverages or take any drugs or medications within
twelve (12) hours before the time of the incident described in the Complaint. If so,
state the type and amount of alcoholic beverages, drugs, or medication which were
consumed, and when and where you consumed them:
19. Did any mechanical defect in your motor vehicle contribute to the incident? If so,
describe the nature of the defect and how it contributed to the incident.
20. List the name and address of all persons, corporations or entities who were
registered title owners or who had ownership interest, or right to control, the motor
vehicle that you were driving at time of the incident described in the Complaint;
and describe both the nature of the ownership interest or right to control the
vehicle, and the vehicle itself, including the make, model, year, and vehicle
identification number.
5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6
21. At the time of the incident described in the Complaint, did you have permission to
drive the vehicle? If so, state the names and addresses of all persons who have
such permission.
22. At the time of the incident described in the Complaint, were you engaged in any
mission or activity for any other person or entity, including any employer? If so,
state the name and address of that person or entity and the nature of the mission
or activity.
23. Was the motor vehicle that you were driving at the time of the incident described
in the Complaint damaged in the accident, and if so, what was the cost to repair
the damage?
24. At the time of this incident, please explain or identify:
a. What were you doing?
b. Where were you going?
c. The purpose for your travel?
d. Your employer, including name, address, phone number, duration, and
terms of employment relationship?
5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7
25. List the names, titles, and addresses of all persons who have provided information,
aid or assistance in answering any issues addressed in these interrogatory
questions and give a brief summary of the information or assistance rendered by
that person(s).
26. Describe in complete detail the appearance of the Plaintiff immediately after the
Plaintiff's alleged occurrence, including any obvious injuries, the emotional state of
the Plaintiff, and whether the Plaintiff appeared in pain or otherwise.
27. Provide the name, address, and account number of all mobile phone accounts that
you had at the time of the subject loss.
5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 8
SIGNATURE PAGE
STATE OF __________________
COUNTY OF ________________
Before me the undersigned officer, authorized to administer oaths and take
acknowledgments, personally appeared ________________________ who after being
duly sworn, deposes and says: That the answers to the above and foregoing
Interrogatories are true and correct to the best of __________________________
knowledge and belief.
_________________________________
Signature of ERNESTO MEDINA
SWORN TO AND SUBSCRIBED before me this ______ day of _______________ 2024.
_____________________________
Notary Public (signature)
_____________________________
Notary Public (type, print stamp commission)
My Commission Expires: _______________
c Personally Known OR
c Produced Identification
c Type of Identification Produced
5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 9
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Filing # 198471438 E-Filed 05/16/2024 01:05:29 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA ASHLEY PARMESHWAR, CASE NO: Plaintiff, v. ERNESTO MEDINA, Defendant. ____________________________________/ PLAINTIFF’S NOTICE OF SERVICE OF INTERROGATORIES TO DEFENDANT, ERNESTO MEDINA The Plaintiff, ASHLEY PARMESHWAR, by and through the undersigned attorney, propounds upon Defendant, ERNESTO MEDINA interrogatories to be answered under oath in writing, within forty-five (45) days from the date of service hereof in accordance with the Rule 1.340, Florida Rules of Civil Procedure. I HEREBY CERTIFY THAT a copy of the foregoing has been served upon the above-named Defendant the same date of service as that of the Summons and Complaint. /s/ Devry R. Kelley Devry R. Kelley, Esquire Florida Bar No.: 0567302 DAN NEWLIN INJURY ATTORNEYS 7335 W. Sand Lake Road, Suite 300 Orlando, FL 32819 Direct: (321) 270-0434 Fax: (863) 225-9853 Attorney for Plaintiff Devry.pleadings@newlinlaw.com Devry.Kelley@newlinlaw.com Marlene.Zervos@newlinlaw.com 5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 GENERAL PERSONAL INJURY NEGLIGENCE INTERROGATORIES TO DEFENDANT, ERNESTO MEDINA PLEASE INSERT YOUR ANSWERS IN THE SPACE PROVIDED BELOW EACH INTERROGATORY. SHOULD ADDITIONAL SPACE BE NEEDED, PLEASE ATTACH AN EXTRA SHEET. "YOU" AND "YOUR" REFER TO THE DEFENDANT TO WHOM THESE INTERROGATORIES ARE DIRECTED. DEFENDANT INCLUDES ALL AGENTS, SERVANTS, OR EMPLOYEES OF THE DEFENDANT. 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. List all former names and when you were known by those names. State all addresses where you have lived for the past ten (10) years, the dates you lived at each address, your Social Security number, and your date of birth. 3. Have you ever been convicted of a crime, other than any juvenile adjudication, which under the law under which you were convicted was punishable by death or imprisonment in excess of one (1) year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction the specific crime and the date and place of conviction, 5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 4. 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. 5. Describe in detail how the incident described in the Complaint happened, including all actions taken by the you to prevent the incident: 6. 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. 7. State the facts upon which you rely for each affirmative defense in your Answer. 5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 8. Do you contend any person or entity other than you is, 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. 9. 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, was entered to the charge; what court or agency heard the charge; was any written report prepared by anyone regarding the charge, and, if so, what is the name mad address of the person or entity who 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 is the name and address of the person who recorded the testimony. 10. 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. 11. Have you heard or do you know about any statement or remark made by or on behalf of any party 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. 5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4 12. 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. 13. 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 s 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. 14. Have you made an agreement with anyone that would limit that party's liability to anyone or any of the damages sued upon in this case? If so, state the terms of the agreement and the parties to it. 15. 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. 16. Do you wear glasses, contact lenses, or hearing aids? 5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5 17. Were you suffering from physical infirmity, disability, or sickness at the time of the incident described in the Complaint? If so, what was the nature of the infirmity, disability, or sickness? 18. Did you consume any alcoholic beverages or take any drugs or medications within twelve (12) hours before the time of the incident described in the Complaint. If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when and where you consumed them: 19. Did any mechanical defect in your motor vehicle contribute to the incident? If so, describe the nature of the defect and how it contributed to the incident. 20. List the name and address of all persons, corporations or entities who were registered title owners or who had ownership interest, or right to control, the motor vehicle that you were driving at time of the incident described in the Complaint; and describe both the nature of the ownership interest or right to control the vehicle, and the vehicle itself, including the make, model, year, and vehicle identification number. 5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6 21. At the time of the incident described in the Complaint, did you have permission to drive the vehicle? If so, state the names and addresses of all persons who have such permission. 22. At the time of the incident described in the Complaint, were you engaged in any mission or activity for any other person or entity, including any employer? If so, state the name and address of that person or entity and the nature of the mission or activity. 23. Was the motor vehicle that you were driving at the time of the incident described in the Complaint damaged in the accident, and if so, what was the cost to repair the damage? 24. At the time of this incident, please explain or identify: a. What were you doing? b. Where were you going? c. The purpose for your travel? d. Your employer, including name, address, phone number, duration, and terms of employment relationship? 5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7 25. List the names, titles, and addresses of all persons who have provided information, aid or assistance in answering any issues addressed in these interrogatory questions and give a brief summary of the information or assistance rendered by that person(s). 26. Describe in complete detail the appearance of the Plaintiff immediately after the Plaintiff's alleged occurrence, including any obvious injuries, the emotional state of the Plaintiff, and whether the Plaintiff appeared in pain or otherwise. 27. Provide the name, address, and account number of all mobile phone accounts that you had at the time of the subject loss. 5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 8 SIGNATURE PAGE STATE OF __________________ COUNTY OF ________________ Before me the undersigned officer, authorized to administer oaths and take acknowledgments, personally appeared ________________________ who after being duly sworn, deposes and says: That the answers to the above and foregoing Interrogatories are true and correct to the best of __________________________ knowledge and belief. _________________________________ Signature of ERNESTO MEDINA SWORN TO AND SUBSCRIBED before me this ______ day of _______________ 2024. _____________________________ Notary Public (signature) _____________________________ Notary Public (type, print stamp commission) My Commission Expires: _______________ c Personally Known OR c Produced Identification c Type of Identification Produced 5/16/2024 1:05 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 9