THE CIRCUIT COURT, FIFTH
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
CASE NO: 03-2671 CA-K
KENNETH ASH and
NANCY ASH, :
GEOLINE SURVEYING INC. :
DEFENDANT, KENNETH ASH’S, INTERROGATORIES TO GEOLINE
COME NOW, KENNETH ASH, Plaintiff in the above-styled matter, by and through his undersigned attorneys, and propounds the following interrogatories to Defendant Geoline Surveying Inc. (hereinafter referred to as “you” or “your”) in accord with Rule 1.340 of the Florida Rules of Civil Procedure.
1. What is your name, address and, if you are answering for someone else, your official position?
2. Describe in detail, each act or omission on the part of plaintiff you contend constituted negligence that was a contributing legal cause of the accident in question.
3. List the names and addresses of all persons believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues raised by the pleadings and specify the subject matter about which the witness has knowledge.
4. List the name, residence address, business address and telephone number of each person believed or known by you, your agents or attorneys to have heard or who is purported to have heard the plaintiff make any statement, remark or comment concerning the accident described in the complaint and the substance of each statement, remark or comment.
5. Did any mechanical defect in the motor vehicle you were driving at the time of the accident contribute to the occurrence of the accident? If so, what was the nature of the defect?
6. Was the person driving the automobile owned by you suffering from physical infirmity, disability or sickness at the time of the occurrence of the accident described in the complaint? If so, what was the nature of the infirmity, disability, or sickness?
7. Did the person driving the automobile owned by you consume any alcoholic beverages or take any drugs or medication within 12 hours before the occurrence of the accident described in the complaint? If so, what type and amount of alcoholic beverages, drugs, or medications were consumed and where did the person driving the automobile owned by you consume them?
8. Has the person driving the automobile owned by you ever been convicted of a crime? If so, what was the date and place of conviction?
9. Does the person driving the automobile owned by you wear glasses or contact lenses? If so, who prescribed them, when were they prescribed, when was the person’s driving the automobile owned by you eyes last examined and by whom?
10. Does the person driving the automobile owned by you wear a hearing aid? If so, who last examined your ears?
11. List the name and address of all persons or corporations who were the registered title owners or who had any legal or equitable interest in the motor vehicle that the person driving the automobile owned by you was driving on the date of the accident described in the complaint.
12. Was the person driving the automobile owned by you charged with any violation of law arising out of the incident referred to in the complaint? If so:
a. what plea did you enter to the charge;
b. what court was the charge heard in;
c. what was the nature of the charge;
d. was the testimony at any trial on the charge recorded in any manner, and, if so, what was the name and address of the person who recorded the testimony?
13. Did you have liability insurance coverage that protects you from the damages sought by the complaint? If so:
a. what is the name of the insurance company having the coverage;
b. what is the extent of coverage provided in the policy or policies of insurance, including coverage for both personal injury and property damage;
c. what is the policy number of each policy?
14. Describe in detail how the accident happened, including all actions taken by the person driving the automobile owned by you to prevent the accident.
15. Do you intend to call any non-medical expert witnesses at the trial of this case? If so, please identify each witness; describe his qualifications as an expert; state the subject matter upon which he is expected to testify; state the substance of the facts and opinions to which he is expected to testify, and give a summary of the grounds for each opinion.
16. List the names, business addresses and business telephone numbers of all medical doctors by whom, and all hospitals at which, the person driving the automobile owned by you has been examined and/or treated in the past 5 years.
17. Describe all attempts you have made to contact or locate the co-defendant, Redacted.
VERIFICATION OF ANSWERS TO INTERROGATORIES
STATE OF FLORIDA
BEFORE ME, the undersigned authority, personally appeared, ________________________, being first duly sworn, deposes and says that the answers written after each of the foregoing interrogatories are true and correct to the best of his knowledge, information and belief, and subscribed his name hereto in certification thereof.
Sworn to and subscribed before me this day of 2003.
My Commission Expires:
I hereby certify that a true and correct copy of the foregoing has been furnished to the following via US Mail and facsimile on this _________th day of January, 2004:
Silverleaf Office Park
6224 NW 43rd Street, Suite B
Gainesville, FL 32653
____________________________________ Michael Massey
Florida Bar No. 0153680
SAJU, MASSEY & DUFFY, LLC
4421 NW Blitchton Road, PMB 417
Ocala, FL 34482
tel (352) 867-1347
fax (352) 629-3963