Poole, Quanisha vs Simon, Shawn Patrick, 22-CA-001950, 61466095 (Fla. 13th Cir. Ct. Mar. 8, 2022) (2024)

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`INTERROGATORIES TO DEFENDANT, JULIANNA GAIL DELIGANS
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`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?
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`List all former names and when you were known by those names. State all addresses where
`you have lived for the past ten years, the dates you lived at each address, your social security
`number, and your date of birth.
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`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 year, or that involved dishonesty or a false statement regardless of the punishment? If
`so, state as to each conviction the specific crime, the date and the place of conviction.
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`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, 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.
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`Describe in detail how the incident described in the complaint happened, including all
`actions taken by you to prevent the incident.
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`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.
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`State the facts upon which you rely for each affirmative defense in your answer.
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`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.
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`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, did you enter 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
`and 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 was the name and address of the person who recorded the testimony?
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`List the names and addresses of all persons who are believed or known by you, your agents
`or attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify
`the subject matter about which the witness has knowledge.
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`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.
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`State the name and address of every person known to you, your agents or attorneys who has
`knowledge about, or possession, custody or control of any model, plat, map, drawing, motion
`picture, video tape, or photograph pertaining to any fact or issue involved in this controversy;
`and describe as to each, what such person has, the name and address of the person who took
`or prepared it, and the date it was taken or prepared.
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`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.
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`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.
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`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?
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`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.
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`Do you wear glasses, contact lenses or hearing aids? If so, who prescribed them, when were
`they prescribed, when were your eyes or ears last examined, and what is the name and
`address of the examiner?
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`Did you consume any alcoholic beverages or take any drugs or medications within 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.
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`Did any mechanical defect in the motor vehicle in which you were riding at the time of the
`incident described in the complaint contribute to the incident? If so, describe the nature of
`the defect and how it contributed to the incident.
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`List the name and address of all persons, corporations or entities who were registered title
`owners or who had ownership interest in, or right to control, the motor vehicle that the
`defendant driver was driving at the 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.
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`At the time of the incident described in the complaint, did the driver of the vehicle described
`in your answer to the preceding interrogatory have permission to drive the vehicle? If so,
`state the names and addresses of all persons who have permission.
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`At the time of the incident described in the complaint, was the defendant driver engaged in
`any mission or activity for any other person or entity, including any employer? If so, state
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`the name and address of that person or entity and the nature of the mission or activity.
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`23. Was the motor vehicle that the defendant driver was driving at the time of the incident
`described in the complaint damaged in the incident and if so, what were the costs to repair
`the damage?
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`Did Defendant, Julianna Gail Deligans, file a claim for Personal Injury Protection benefits?
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`25. Was Defendant, Julianna Gail Deligans, using a cellular phone at the time of the subject
`accident?
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`Please provide the company name, address, telephone number and cellular phone number(s)
`for any cellular phone(s) that the Defendant used or may have been using at the time of the
`accident which is the subject of this litigation, whether actually owned by the Defendant or
`not.
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`Pursuant to Wal-Mart, please provide the names and addresses of individuals who have
`furnished statements in anticipation of litigation. Wal-mart Stores Inc. v. Weeks, 696 So.2d.
`855 (2nd DCA 1997).
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`___________________________________
`JULIANNA GAIL DELIGANS
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`STATE OF FLORIDA
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`COUNTY OF _______________________
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`SWORN TO AND SUBSCRIBED before me, personally appeared JULIANNA GAIL
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`DELIGANS, who, after being first duly sworn, deposes and says that she executed the foregoing
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`Interrogatories on this _______ day of _______________, 2022.
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`_________________________
`NOTARY PUBLIC
`My Commission Expires:
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