IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
HOWDY GOODNEIGHBOR,
Plaintiff,
v.
GIANT HERCULES,
Defendant.
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CASE NO. 09-CF-87654321
PLAINTIFF’S INTERROGATORIES TO DEFENDANT
1. What is your full name as well as your current address; date of birth; marital status; driver’s license number and issuing state; and the last four digits of your social security number?
2. What is the name of your homeowner’s liability insurance carrier, including the policy number and the policy limits for an occurrence such as the one alleged in the complaint?
3. How long have you resided at and owned your current residence; if you are not the owner of said residence, please state the name and address of the owner of said property?
4. What is your current employment and please state the name, address, and telephone number of your employer; dates of employment; job title and brief description of job duties; starting and current salary; all benefits received, including health, life, and disability insurance, pension, or profit sharing plans?
5. What, if any, financial assets do you own, including but not limited to 401K’s, HSA accounts, IRA accounts, stocks, mutual funds, certificates of deposit, bonds, real estate, motor vehicles, interest accruing accounts, and trusts?
6. What is the name; breed; color; age; and any other characteristic features of the dog in question?
7. What is the name and contact information of any veterinarians that have treated or with records pertaining to the dog described in the complaint and when was the last time the dog was vaccinated?
8. Has another animal ever bitten the dog in question and if so, did the dog receive veterinarian treatment for the bite?
9. Has the dog in question bitten any other persons during the animal’s lifetime and if the answer to this question is in the affirmative, please provide the date of the incident;