MICHAEL KAPLAN VS PUBLIX SUPER MARKETS, INC. ET AL, 2021-018570-CA-01, Doc-24-Notice-of-Interrogatory (Fla. 11th Cir. Ct. Nov. 2, 2021) (2024)

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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 the names, business addresses, dates of employment, and rates of pay regarding all
`employers, including self-employment, for whom you have worked in the past 10 years.
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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 10 years, the dates you lived at each address, your
`Social Security number, your date of birth, and, if you are or have ever been married, the
`name of your spouse or spouses, the date you were married, and the county where you
`were married. In addition, please state if you are a U.S. citizen, and if you are not a U.S.
`citizen, please state your immigration status.
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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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`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 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.
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`Were you suffering from any pre-existing physical or emotional condition, physical
`Infirmity, disability, or sickness at the time of the occurrence of the accident described in
`the Complaint, whether or not there was any treatment for such conditions? If so, what
`was the nature of the condition, infirmity, disability, or sickness?
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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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`10. 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 this charge, and, if
`so, what is the name and address of the person or entity that 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?
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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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`Describe each injury for which you are claiming damages in this case, specifying the part
`of your body that was injured, the nature of the injury, and, as to any injuries you contend
`are permanent, the effects on you that you claim are permanent.
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`List each item of expense or damage, other than loss of income or earning capacity, that
`you claim to have incurred as a result of the incident described in the complaint, giving
`for each item the date incurred, the name and business address of the person or entity to
`whom each was paid or is owed, and the goods or services for which each was incurred.
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`Do you contend that you have lost any income, benefits, or earning capacity in the past or
`future as a result of the incident described in the complaint? If so, state the nature of the
`income, benefits, or earning capacity, and the amount and the method that you used in
`computing the amount.
`Has anything been paid or is anything payable from any third party for the damages listed
`in your answers to these interrogatories? If so, state the amounts paid or payable, the
`name and business address of the person or entity who paid or owes said amounts, and
`which of those third parties have or claim a right of subrogation.
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`List the names and business addresses of each physician who has treated or examined
`you, and each medical facility where you have received any treatment or examination for
`the injuries for which you seek damages in this case; and state as to each the date of
`treatment or examination and the injury or condition for which you were examined or
`treated.
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`List the names and business addresses of all other physicians, medical facilities, or other
`health care providers by whom or at which you have been examined or treated in the past
`10 years; and state as to each the dates of examination or treatment and the condition or
`injury for which you were examined or treated.
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`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.
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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 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.
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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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`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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`Please state if you have ever made a workers' compensation claim, and if so, state the
`name and address of the person or entity that you made the claim against, the name of the
`insurer, the date of accident, a description of the accident, the injuries sustained, whether
`you filed a formal petition for benefits, and if so, the claim or OJCC number.
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`Please identify by name, address and telephone number all pharmacies at which you have
`had prescriptions filled in the five year period prior to the accident to present.
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`25.
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`Please identify your cell phone carrier and cell phone number on the date of the accident.
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`26. Were you involved in any accidents resulting in injury in the ten year period prior to the
`lawsuit accident, or since the lawsuit accident, and if so, describe the nature of accident,
`injuries sustained, and the name, address and telephone number of any doctor or facility
`where you sought medical treatment.
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` have read the foregoing Answers to Initial Interrogatories and do swear that they are true and
`correct to the best of my knowledge and belief.
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`________________________
`Signature
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`STATE OF FLORIDA )
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`COUNTY OF
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`4861-8202-3937.1
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`________________________________
`Notary Public, State of Florida
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`My Commission expires:
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`BEFORE ME, the undersigned authority, personally appeared MICHAEL KAPLAN
`after being first duly sworn, deposes and says that he/she has read the foregoing Answers to
`Initial Interrogatories and the same are true and correct and he/she signed his/her name thereto
`for the purposes therein expressed.
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`Witness my Hand and Official Seal at_________________________________ , this
`______day of _______________, 2021.
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`NOTARY - PLEASE CHECK APPROPRIATE BOX:
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`______Personally known to me; or
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` ______Produced as identification:
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`Type of ID.: _____________________________
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`IN THE CIRCUIT COURT OF THE
`ELEVENTH JUDICIAL CIRCUIT IN AND
`FOR MIAMI-DADE COUNTY, FLORIDA
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`CIRCUIT CIVIL DIVISION
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`MICHAEL KAPLAN,
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`CASE NO.: 2021-018570-CA-01
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`Plaintiff,
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`4861-8202-3937.1
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