In The County Court in and For Broward County, Florida
In The County Court in and For Broward County, Florida
In The County Court in and For Broward County, Florida
, CASE NO.
Plaintiff,
v.
Defendant.
____________________/
respond to the request within 30 days of service of this request as prescribed by Fla. R. Civ P.
____.
2. The term “person” means any natural person, individual, proprietorship, partnership,
3. The term “document” means any written or graphic matter or other means of
preserving thought or expression and all tangible things from which information can be
processed or transcribed, including the originals and all nonidentical copies, whether different
from the original by reason of any notation made on such copy or otherwise, including, but not
limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax,
bulletins, mails, meetings or other communications, intraoffice and interoffice telephone calls,
diaries, chronological data, minutes, books, reports, studies, summaries, pamphlets, bulletins,
printed matter, charts, ledgers, invoices, proposals, purchase orders, work orders, plans, designs,
articles, releases (and any and all drafts, alterations and modifications, changes and amendments
1
of any of the foregoing) graphic or aural records or representations of any kind (including,
without limitation, photographs, microfiche, microfilm, videotape, records and motion pictures)
and electronic, mechanical or electric records or representations of any kind (including, without
5. As used herein the singular shall include the plural, the plural shall include the
singular, and the masculine, feminine, and neuter shall include each of the other genders. “And”
as well as “or” shall be construed disjunctively as well as conjunctively, as necessary to bring
within the scope of the interrogatory all responses that might otherwise be construed to be
7. The term “Action” means the lawsuit initiated by Plaintiffs against Defendant in the
8. The term “Complaint” means the complaint, as amended to date, caused to be filed in
this Action.
9. The term “refer or relate” as used in this request means reflecting, evidencing,
regarding, pertaining to, consisting of, indicating, concerning or in any way logically or factually
10. The term “all” includes the term “any” and the term “any” includes “all.” The terms
11. The term "Plaintiffs' lender" means Plaintiffs' lender or loan servicer
INTERROGATORIES
2
INTERROGATORY NO. 1: With respect to each full and partial denial, contained in your
response to Plaintiff’s Request for Admissions served concurrently with these Interrogatories,
please indicate by paragraph the denial you are referring to and state the following:
(a) The specific factual basis in which the matter set forth in each such
Request is not true.
(b) The name, phone number, address and email address of each person with knowledge of the
specific factual basis set forth in response to paragraph (a) above.
LAW OFFICES OF
By:/s/