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Filing # 183840351 E-Filed 10/12/2023 01:20:01 PM
IN THE CIRCUIT COURT OF THE 20
JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO: 2023-000096 CA
ROSE PIETRASIAK,
Plaintiff,
vs.
BRIAN MOAR AND MARIANNE
MOAR,
Defendants.
DEFENDANTS’ MOTION TO COMPEL TO PLAINTIFF
Defendants, BRIAN MOAR and MARIANNE MOAR, by and through the
undersigned counsel, and pursuant to Rule 1.380, Florida Rules of Civil Procedure,
hereby files this Motion to Compel Plaintiff to respond to discovery requests, bearing
certificates of service of May 17, 2023 and May 18, 2023, and states as follows:
4
On May 17, 2023, Defendants propounded Interrogatories to Plaintiff. See
Exhibit “A.”
2 On May 18, 2023, Defendants served Plaintiff with a Request for
Production. See Exhibit “B.”
3 Plaintiff's response to said discovery requests were due within thirty (30)
days after service, thereby rendering them due on June 17, 2023 and June 18, 2023,
respectively. See Rules 1.340 and 1.350, Florida Rules of Civil Procedure.
4 To date, more than three (3) months have lapsed and Plaintiff has failed to
respond, object or produce any responsive documents to said discovery requests, nor
has Plaintiff requested an extension. Thus, Plaintiff has waived any right to object to
said discovery.
5 This motion complies with Florida Rules of Civil Procedure, in which
Defendant has made a good faith attempt to confer with Plaintiff's counsel, in an effort
to secure the requested information without judicial intervention. See emails as
Composite Exhibit “C.”
6 Without the requested information, counsel's attempt to property defend
this matter on behalf of its clients is being thwarted by Plaintiff's lack of compliance with
the Florida Rules of Civil Procedure.
WHEREFORE, Defendants respectfully request this Honorable Court enter an
Order (i) compelling Plaintiff to serve their responses to Defendants’ Interrogatories and
Request for Production and produce any and all documents within ten (10) days from
the date of this Court's Order; (ii) stating that Plaintiff has waived any objections to said
discovery requests; and (iii) any other relief as this Honorable Court deems just and
proper.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a copy of the foregoing has been furnished by via e-
mail to: Jason R. Leonard, Esq., Morgan and Morgan, P.A., Attorney for Plaintiff, 12800
N.W. University Drive, Suite 600, Fort Myers, FL; jasonleonard@forthepeople.com;
npaula@forthepeople..com; mblanco@forthepoeple.com; this 21st day of September,
2023.
BILLING, COCHRAN, LYLES, MAURO
& RAMSEY, P.A.
Attorneys for Defendants
515 East Las Olas Boulevard, Sixth Floor
Fort Lauderdale, FL 33301
Tel: (954) 764-7150
Fax: (954) 764-7279
BY:_/s/ Shaua 8. UcKamey
SHAWN B. McKAMEY, ESQ.
Florida Bar No.: 991384
sbm@belmr.com
deborahR@bclmr.com
lupeo@bclmr.com
3
Filing # 173397773 E-Filed 05/17/2023 04:49:07 PM
EXHIBIT "A"
IN THE CIRCUIT COURT OF THE 20™
JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO: 2023-000096 CA
ROSE PIETRASIAK,
Plaintiff,
vs.
BRIAN MOAR AND MARIANNE
MOAR,
Defendants.
/
DEFENDANTS’ BRIAN MOAR AND MARIANNE MOAR’S
NOTICE OF SERVING INITIAL INTERROGATORIES
The Defendant BRIAN MOAR AND MARIANNE MOAR, hereby provide notice of
propounding the attached Initial Interrogatories to Plaintiff, ROSE PIETRASIAK,to be
responded to within the time and manner prescribed by Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a copy of the foregoing has been furnished by via e-mail
to: Jason R. Leonard, Esq., Morgan and Morgan, P.A., Attorney for Plaintiff, 12800 N.W.
University Drive, Suite 600, Fort Myers, FL;
jasonleonard@forthepeople.com; npaula@forthepeople..com; mblanco@forthepoeple.com; this
17th day of May, 2023.
BILLING, COCHRAN, LYLES, MAURO
& RAMSEY, P.A.
Attorneys for Defendants,
Brian and Marianne Moar
SunTrust Center, Suite 600
515 East Las Olas Blvd.
Fort Lauderdale, FL 33301
(954) 764-7150
BY:__/s/ Shawn B. McKamey _
Shawn B. McKamey, Esq.
Florida Bar No.: 991384
sbm@belmr.com
lupeo@belmr.com
INITIAL INTERROGATORIES TO PLAINTIFF
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?
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.
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 even been married, the name of your
spouse or spouses.
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.
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 beverage,
drugs, or medication which were consumed, and when and where you
consumed them.
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.
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.
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.
10 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.
11 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.
12 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.
13 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.
14. What is your current rate of pay, job position and name of employer at
present?
15. Please advise whether you have been questioned by any federal or state
law enforcement agency about the safety or business practices of Jinko
Industries at any time and the substance of any such investigation.
STATE OF FLORIDA
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared
, who, after being duly sworn, deposes and says that the
foregoing Answers to Initial Interrogatories are true and correct to the best of
knowledge and belief.
SWORN TO and SUBSCRIBED before me, by who is personally
known to me or who has produced. as identification,
this day of , 2023
Notary Public
State of Pennsylvania
PRINTED NAME OF NOTARY
PUBLIC
NOTARY PUBLIC, SEAL OF OFFICE
Filing # 173444138 E-Filed 05/18/2023 11:20:38 AM
EXHIBIT "B"
IN THE CIRCUIT COURT OF THE 20™
JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO: 2023-000096 CA
ROSE PIETRASIAK,
Plaintiff,
vs.
BRIAN MOAR AND MARIANNE
MOAR,
Defendants.
/
DEFENDANTS’ BRIAN MOAR AND MARIANNE MOAR’S
RE ST TO PRODUCE TO PLAINTIFF
The Defendant BRIAN MOAR AND MARIANNE MOAR, hereby request, Plaintiff,
ROSE PIETRASIAK, to produce within the time and manner prescribed by Florida Rules of
Civil Procedure.
1 A copy of any and all medical records substantiating any claim of personal injury in this
case purportedly as a result of the motor vehicle incident of October 6, 2022.
A copy of any medical records pertaining to any physical or mental condition for which
the Plaintiff has received medical treatment in the last ten (10) years prior to the date of
loss of October 6, 2022. This would include, but not be limited to, records from the
Plaintiff's primary care physician, family medicine practitioner, cardiologist, psychiatrist
or psychologist or mental health counselor, neurologist or chiropractor.
A copy of any and all documents substantiating any alleged loss of earnings or loss of
earning capacity purportedly caused by the motor vehicle incident of October 6, 2022.
A copy of all wages earned in the twelve (12) months preceding October 6, 2022, as well
as a copy of all wages, earnings or other source of income realized by Plaintiff since the
date of loss of October 6, 2022 up through the current date.
A copy of any and all PIP claim documents submitted by the Plaintiff for making claim
for wage loss or medical benefits under any PIP policy that may have been in effect on
the date of loss, October 6, 2022.
A copy of any and all documentation evidencing any legal or business interests Plaintiff
had on October 6, 2022 in any limited liability company, corporation, partnership or other
business entity, since that date up through the current date.
A copy of any and all videos or photographic images on any social media site, including
but not limited to, Facebook, Snapchat, Instagram, Tumblir or similar platform, for
October 6, 2022 up through the current date.
Any and all documentation from the Plaintiffs mobile or cellular telephone service; i.e.
Verizon, Sprint, AT&T, etc., for October 6, 2022, which should include all incoming and
outgoing telephone calls together with the date and time of any communications. Text
messaging documentation on said account is likewise requested. No private information
needs to be produced herein and same can be redacted upon legal grounds, but the
evidence that Plaintiffs cellular phone was being utilized to text, call, FaceTime or look
at any videos or You Tube stations is sought for October 6, 2022.
9. A copy of Plaintiff's income tax returns filed with the IRS for the years 2016 - 2022.
10. A copy of Plaintiff's social security card and Florida Driver’s License.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a copy of the foregoing has been furnished by via e-mail
to: Jason R. Leonard, Esq., Morgan and Morgan, P.A., Attorney for Plaintiff, 12800 N.W.
University Drive, Suite 600, Fort Myers, FL; jasonleonard@forthepeople.com;
npaula@forthepeople..com; mblanco@forthepoeple.com; this 18th day of May, 2023.
BILLING, COCHRAN, LYLES, MAURO
& RAMSEY, P.A.
Attorneys for Defendants,
Brian and Marianne Moar
SunTrust Center, Suite 600
515 East Las Olas Blvd.
Fort Lauderdale, FL 33301
(954) 764-7150
BY:__/s/ Shawn B. McKamey
Shawn B. McKamey, Esq.
Florida Bar No.: 991384
sbm@belmr.com
lupeo@belmr.com
3
COMPOSITE EXHIBIT "C"
Deborah A. Rosenbaum
From: Deborah A. Rosenbaum
Sent: Thursday, September 14, 2023 12:35 PM
To: JASONLEONARD@FORTHEPEOPLE.COM; NPAULA@FORTHEPEOPLE.COM;
MBLANCO@FORTHEPEOPLE.COM
Ce: Shawn McKamey; Lupe OHare
Subject: PIETRASIAK
Attachments: DEF NOS ROGS TO PLTF (EFILED).pdf; ROGS TO PLTF.pdf; RFP TO PLTF (EFILED).pdf
Importance: High
Follow Up Flag: Follow up
Due By: Tuesday, September 19, 2023 5:30 AM
Flag Status: Flagged
Good afternoon Mr. Leonard,
| was going through discovery in the above referenced matter, and | do not see where
Plaintiff responded to the enclosed ROGS and RFP. Please advise when we can expect your
answers to Defendant's discovery requests at your earliest convenience. If | am mistaken,
please provide the E-service email containing Plaintiff's discovery responses.
Thank you in advance for your attention to this matter.
Kind regards,
Debbie
Deborah rt, Rosenbaum
Deborah A. Rosenbaum
Florida Registered Paralegal to
John W. Mauro, Esq.
Billing, Cochran, Lyles, Mauro & Ramsey, P.A.
515 East Las Olas Boulevard | 6th Floor | Fort Lauderdale, FL 33301
Phone: 954/764-7150 Ext. 221 | Fax: 954/764-0917 |Cell. 954-494-7754] E-mail: DeborahR@bcimr.com
Website: www.billingcochran.com
CONFIDENTIALITY NOTICE: This electronic message is intended to be viewed only by the individual or entity to whom it is
addressed. It may contain information that is privileged, confidential and exempt from disclosure under applicable law.
Any dissemination, distribution or copying of this communication is strictly prohibited without our prior permission. If
the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the
message to the intended recipient, or if you have received this communication in error, please notify us immediately by
return e-mail and delete the original message and any copies of it from your computer and email system.
Deborah A. Rosenbaum
From: Deborah A. Rosenbaum
Sent: Tuesday, September 19, 2023 9:19 AM
To: JASONLEONARD@FORTHEPEOPLE.COM; NPAULA@FORTHEPEOPLE.COM;,
MBLANCO@FORTHEPEOPLE.COM
Ce: Shawn McKamey; Lupe OHare
Subject: RE: PIETRASIAK
Attachments: DEF NOS ROGS TO PLTF (EFILED).pdf; ROGS TO PLTF.pdf; RFP TO PLTF (EFILED).pdf
Importance: High
Follow Up Flag: Follow up
Due By: Thursday, September 21, 2023 5:30 AM
Flag Status: Flagged
Good morning,
|.am following up from my previous email regarding Plaintiff's responses to the enclosed
discovery. These have been outstanding for quite some time as they were served on May
17, 2023. Therefore, please advise when we can expect Plaintiff's responses by Thursday,
September 21, 2023, in order to avoid unnecessary motion practice.
Thank you in advance for your prompt attention to this matter.
Kind regards,
Debbie
Deborah +t, Rosenbaum
Deborah A. Rosenbaum
Florida Registered Paralegal to
John W. Mauro, Esq.
Lori B. Lewellen, Esq.
Billing, Cochran, Lyles, Mauro & Ramsey, P.A.
515 East Las Olas Boulevard | 6th Floor | Fort Lauderdale, FL 33301
Phone: 954/764-7150 Ext. 221 | Fax: 954/764-0917 |Cell. 954-494-7754] E-mail: DeborahR@bclmr.com
Website: www.billingcochran.com
CONFIDENTIALITY NOTICE: This electronic message is intended to be viewed only by the individual or entity to whom it is
addressed. It may contain information that is privileged, confidential and exempt from disclosure under applicable law.
Any dissemination, distribution or copying of this communication is strictly prohibited without our prior permission. If
the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the
message to the intended recipient, or if you have received this communication in error, please notify us immediately by
return e-mail and delete the original message and any copies of it from your computer and email system.
From: Deborah A. Rosenbaum
Sent: Thursday, September 14, 2023 12:35 PM
To: JASONLEONARD@FORTHEPEOPLE.COM; NPAULA@FORTHEPEOPLE.COM; MBLANCO@FORTHEPEOPLE.COM
Cc: Shawn McKamey ; Lupe OHare
Subject: PIETRASIAK
Importance: High
Good afternoon Mr. Leonard,
| was going through discovery in the above referenced matter, and | do not see where
Plaintiff resoonded to the enclosed ROGS and RFP. Please advise when we can expect your
answers to Defendant's discovery requests at your earliest convenience. If 1am mistaken,
please provide the E-service email containing Plaintiff's discovery responses.
Thank you in advance for your attention to this matter.
Kind regards,
Debbie
Deborah +t, Rosenbaum
Deborah A. Rosenbaum
Florida Registered Paralegal to
John W. Mauro, Esq.
Billing, Cochran, Lyles, Mauro & Ramsey, P.A.
515 East Las Olas Boulevard | 6th Floor | Fort Lauderdale, FL 33301
Phone: 954/764-7150 Ext. 221 | Fax: 954/764-0917 |Cell. 954-494-7754| E-mail: DeborahR@pbclmr.com
Website: www.billingcochran.com
CONFIDENTIALITY NOTICE: This electronic message is intended to be viewed only by the individual or entity to whom it is
addressed. It may contain information that is privileged, confidential and exempt from disclosure under applicable law.
Any dissemination, distribution or copying of this communication is strictly prohibited without our prior permission. If
the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the
message to the intended recipient, or if you have received this communication in error, please notify us immediately by
return e-mail and delete the original message and any copies of it from your computer and email system.
Preview
Filing # 183840351 E-Filed 10/12/2023 01:20:01 PM IN THE CIRCUIT COURT OF THE 20 JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: 2023-000096 CA ROSE PIETRASIAK, Plaintiff, vs. BRIAN MOAR AND MARIANNE MOAR, Defendants. DEFENDANTS’ MOTION TO COMPEL TO PLAINTIFF Defendants, BRIAN MOAR and MARIANNE MOAR, by and through the undersigned counsel, and pursuant to Rule 1.380, Florida Rules of Civil Procedure, hereby files this Motion to Compel Plaintiff to respond to discovery requests, bearing certificates of service of May 17, 2023 and May 18, 2023, and states as follows: 4 On May 17, 2023, Defendants propounded Interrogatories to Plaintiff. See Exhibit “A.” 2 On May 18, 2023, Defendants served Plaintiff with a Request for Production. See Exhibit “B.” 3 Plaintiff's response to said discovery requests were due within thirty (30) days after service, thereby rendering them due on June 17, 2023 and June 18, 2023, respectively. See Rules 1.340 and 1.350, Florida Rules of Civil Procedure. 4 To date, more than three (3) months have lapsed and Plaintiff has failed to respond, object or produce any responsive documents to said discovery requests, nor has Plaintiff requested an extension. Thus, Plaintiff has waived any right to object to said discovery. 5 This motion complies with Florida Rules of Civil Procedure, in which Defendant has made a good faith attempt to confer with Plaintiff's counsel, in an effort to secure the requested information without judicial intervention. See emails as Composite Exhibit “C.” 6 Without the requested information, counsel's attempt to property defend this matter on behalf of its clients is being thwarted by Plaintiff's lack of compliance with the Florida Rules of Civil Procedure. WHEREFORE, Defendants respectfully request this Honorable Court enter an Order (i) compelling Plaintiff to serve their responses to Defendants’ Interrogatories and Request for Production and produce any and all documents within ten (10) days from the date of this Court's Order; (ii) stating that Plaintiff has waived any objections to said discovery requests; and (iii) any other relief as this Honorable Court deems just and proper. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a copy of the foregoing has been furnished by via e- mail to: Jason R. Leonard, Esq., Morgan and Morgan, P.A., Attorney for Plaintiff, 12800 N.W. University Drive, Suite 600, Fort Myers, FL; jasonleonard@forthepeople.com; npaula@forthepeople..com; mblanco@forthepoeple.com; this 21st day of September, 2023. BILLING, COCHRAN, LYLES, MAURO & RAMSEY, P.A. Attorneys for Defendants 515 East Las Olas Boulevard, Sixth Floor Fort Lauderdale, FL 33301 Tel: (954) 764-7150 Fax: (954) 764-7279 BY:_/s/ Shaua 8. UcKamey SHAWN B. McKAMEY, ESQ. Florida Bar No.: 991384 sbm@belmr.com deborahR@bclmr.com lupeo@bclmr.com 3 Filing # 173397773 E-Filed 05/17/2023 04:49:07 PM EXHIBIT "A" IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: 2023-000096 CA ROSE PIETRASIAK, Plaintiff, vs. BRIAN MOAR AND MARIANNE MOAR, Defendants. / DEFENDANTS’ BRIAN MOAR AND MARIANNE MOAR’S NOTICE OF SERVING INITIAL INTERROGATORIES The Defendant BRIAN MOAR AND MARIANNE MOAR, hereby provide notice of propounding the attached Initial Interrogatories to Plaintiff, ROSE PIETRASIAK,to be responded to within the time and manner prescribed by Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a copy of the foregoing has been furnished by via e-mail to: Jason R. Leonard, Esq., Morgan and Morgan, P.A., Attorney for Plaintiff, 12800 N.W. University Drive, Suite 600, Fort Myers, FL; jasonleonard@forthepeople.com; npaula@forthepeople..com; mblanco@forthepoeple.com; this 17th day of May, 2023. BILLING, COCHRAN, LYLES, MAURO & RAMSEY, P.A. Attorneys for Defendants, Brian and Marianne Moar SunTrust Center, Suite 600 515 East Las Olas Blvd. Fort Lauderdale, FL 33301 (954) 764-7150 BY:__/s/ Shawn B. McKamey _ Shawn B. McKamey, Esq. Florida Bar No.: 991384 sbm@belmr.com lupeo@belmr.com INITIAL INTERROGATORIES TO PLAINTIFF 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? 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. 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 even been married, the name of your spouse or spouses. 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. 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 beverage, drugs, or medication which were consumed, and when and where you consumed them. 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. 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. 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. 10 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. 11 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. 12 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. 13 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. 14. What is your current rate of pay, job position and name of employer at present? 15. Please advise whether you have been questioned by any federal or state law enforcement agency about the safety or business practices of Jinko Industries at any time and the substance of any such investigation. STATE OF FLORIDA COUNTY OF BEFORE ME, the undersigned authority, personally appeared , who, after being duly sworn, deposes and says that the foregoing Answers to Initial Interrogatories are true and correct to the best of knowledge and belief. SWORN TO and SUBSCRIBED before me, by who is personally known to me or who has produced. as identification, this day of , 2023 Notary Public State of Pennsylvania PRINTED NAME OF NOTARY PUBLIC NOTARY PUBLIC, SEAL OF OFFICE Filing # 173444138 E-Filed 05/18/2023 11:20:38 AM EXHIBIT "B" IN THE CIRCUIT COURT OF THE 20™ JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: 2023-000096 CA ROSE PIETRASIAK, Plaintiff, vs. BRIAN MOAR AND MARIANNE MOAR, Defendants. / DEFENDANTS’ BRIAN MOAR AND MARIANNE MOAR’S RE ST TO PRODUCE TO PLAINTIFF The Defendant BRIAN MOAR AND MARIANNE MOAR, hereby request, Plaintiff, ROSE PIETRASIAK, to produce within the time and manner prescribed by Florida Rules of Civil Procedure. 1 A copy of any and all medical records substantiating any claim of personal injury in this case purportedly as a result of the motor vehicle incident of October 6, 2022. A copy of any medical records pertaining to any physical or mental condition for which the Plaintiff has received medical treatment in the last ten (10) years prior to the date of loss of October 6, 2022. This would include, but not be limited to, records from the Plaintiff's primary care physician, family medicine practitioner, cardiologist, psychiatrist or psychologist or mental health counselor, neurologist or chiropractor. A copy of any and all documents substantiating any alleged loss of earnings or loss of earning capacity purportedly caused by the motor vehicle incident of October 6, 2022. A copy of all wages earned in the twelve (12) months preceding October 6, 2022, as well as a copy of all wages, earnings or other source of income realized by Plaintiff since the date of loss of October 6, 2022 up through the current date. A copy of any and all PIP claim documents submitted by the Plaintiff for making claim for wage loss or medical benefits under any PIP policy that may have been in effect on the date of loss, October 6, 2022. A copy of any and all documentation evidencing any legal or business interests Plaintiff had on October 6, 2022 in any limited liability company, corporation, partnership or other business entity, since that date up through the current date. A copy of any and all videos or photographic images on any social media site, including but not limited to, Facebook, Snapchat, Instagram, Tumblir or similar platform, for October 6, 2022 up through the current date. Any and all documentation from the Plaintiffs mobile or cellular telephone service; i.e. Verizon, Sprint, AT&T, etc., for October 6, 2022, which should include all incoming and outgoing telephone calls together with the date and time of any communications. Text messaging documentation on said account is likewise requested. No private information needs to be produced herein and same can be redacted upon legal grounds, but the evidence that Plaintiffs cellular phone was being utilized to text, call, FaceTime or look at any videos or You Tube stations is sought for October 6, 2022. 9. A copy of Plaintiff's income tax returns filed with the IRS for the years 2016 - 2022. 10. A copy of Plaintiff's social security card and Florida Driver’s License. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a copy of the foregoing has been furnished by via e-mail to: Jason R. Leonard, Esq., Morgan and Morgan, P.A., Attorney for Plaintiff, 12800 N.W. University Drive, Suite 600, Fort Myers, FL; jasonleonard@forthepeople.com; npaula@forthepeople..com; mblanco@forthepoeple.com; this 18th day of May, 2023. BILLING, COCHRAN, LYLES, MAURO & RAMSEY, P.A. Attorneys for Defendants, Brian and Marianne Moar SunTrust Center, Suite 600 515 East Las Olas Blvd. Fort Lauderdale, FL 33301 (954) 764-7150 BY:__/s/ Shawn B. McKamey Shawn B. McKamey, Esq. Florida Bar No.: 991384 sbm@belmr.com lupeo@belmr.com 3 COMPOSITE EXHIBIT "C" Deborah A. Rosenbaum From: Deborah A. Rosenbaum Sent: Thursday, September 14, 2023 12:35 PM To: JASONLEONARD@FORTHEPEOPLE.COM; NPAULA@FORTHEPEOPLE.COM; MBLANCO@FORTHEPEOPLE.COM Ce: Shawn McKamey; Lupe OHare Subject: PIETRASIAK Attachments: DEF NOS ROGS TO PLTF (EFILED).pdf; ROGS TO PLTF.pdf; RFP TO PLTF (EFILED).pdf Importance: High Follow Up Flag: Follow up Due By: Tuesday, September 19, 2023 5:30 AM Flag Status: Flagged Good afternoon Mr. Leonard, | was going through discovery in the above referenced matter, and | do not see where Plaintiff responded to the enclosed ROGS and RFP. Please advise when we can expect your answers to Defendant's discovery requests at your earliest convenience. If | am mistaken, please provide the E-service email containing Plaintiff's discovery responses. Thank you in advance for your attention to this matter. Kind regards, Debbie Deborah rt, Rosenbaum Deborah A. Rosenbaum Florida Registered Paralegal to John W. Mauro, Esq. Billing, Cochran, Lyles, Mauro & Ramsey, P.A. 515 East Las Olas Boulevard | 6th Floor | Fort Lauderdale, FL 33301 Phone: 954/764-7150 Ext. 221 | Fax: 954/764-0917 |Cell. 954-494-7754] E-mail: DeborahR@bcimr.com Website: www.billingcochran.com CONFIDENTIALITY NOTICE: This electronic message is intended to be viewed only by the individual or entity to whom it is addressed. It may contain information that is privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this communication is strictly prohibited without our prior permission. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, or if you have received this communication in error, please notify us immediately by return e-mail and delete the original message and any copies of it from your computer and email system. Deborah A. Rosenbaum From: Deborah A. Rosenbaum Sent: Tuesday, September 19, 2023 9:19 AM To: JASONLEONARD@FORTHEPEOPLE.COM; NPAULA@FORTHEPEOPLE.COM;, MBLANCO@FORTHEPEOPLE.COM Ce: Shawn McKamey; Lupe OHare Subject: RE: PIETRASIAK Attachments: DEF NOS ROGS TO PLTF (EFILED).pdf; ROGS TO PLTF.pdf; RFP TO PLTF (EFILED).pdf Importance: High Follow Up Flag: Follow up Due By: Thursday, September 21, 2023 5:30 AM Flag Status: Flagged Good morning, |.am following up from my previous email regarding Plaintiff's responses to the enclosed discovery. These have been outstanding for quite some time as they were served on May 17, 2023. Therefore, please advise when we can expect Plaintiff's responses by Thursday, September 21, 2023, in order to avoid unnecessary motion practice. Thank you in advance for your prompt attention to this matter. Kind regards, Debbie Deborah +t, Rosenbaum Deborah A. Rosenbaum Florida Registered Paralegal to John W. Mauro, Esq. Lori B. Lewellen, Esq. Billing, Cochran, Lyles, Mauro & Ramsey, P.A. 515 East Las Olas Boulevard | 6th Floor | Fort Lauderdale, FL 33301 Phone: 954/764-7150 Ext. 221 | Fax: 954/764-0917 |Cell. 954-494-7754] E-mail: DeborahR@bclmr.com Website: www.billingcochran.com CONFIDENTIALITY NOTICE: This electronic message is intended to be viewed only by the individual or entity to whom it is addressed. It may contain information that is privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this communication is strictly prohibited without our prior permission. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, or if you have received this communication in error, please notify us immediately by return e-mail and delete the original message and any copies of it from your computer and email system. From: Deborah A. Rosenbaum Sent: Thursday, September 14, 2023 12:35 PM To: JASONLEONARD@FORTHEPEOPLE.COM; NPAULA@FORTHEPEOPLE.COM; MBLANCO@FORTHEPEOPLE.COM Cc: Shawn McKamey ; Lupe OHare Subject: PIETRASIAK Importance: High Good afternoon Mr. Leonard, | was going through discovery in the above referenced matter, and | do not see where Plaintiff resoonded to the enclosed ROGS and RFP. Please advise when we can expect your answers to Defendant's discovery requests at your earliest convenience. If 1am mistaken, please provide the E-service email containing Plaintiff's discovery responses. Thank you in advance for your attention to this matter. Kind regards, Debbie Deborah +t, Rosenbaum Deborah A. Rosenbaum Florida Registered Paralegal to John W. Mauro, Esq. Billing, Cochran, Lyles, Mauro & Ramsey, P.A. 515 East Las Olas Boulevard | 6th Floor | Fort Lauderdale, FL 33301 Phone: 954/764-7150 Ext. 221 | Fax: 954/764-0917 |Cell. 954-494-7754| E-mail: DeborahR@pbclmr.com Website: www.billingcochran.com CONFIDENTIALITY NOTICE: This electronic message is intended to be viewed only by the individual or entity to whom it is addressed. It may contain information that is privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this communication is strictly prohibited without our prior permission. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, or if you have received this communication in error, please notify us immediately by return e-mail and delete the original message and any copies of it from your computer and email system.