IN THE COUNTY COURT OF THE

17TH JUDICIAL CIRCUIT IN AND FOR

BROWARD COUNTY, FLORIDA

ERNA JEAN,
Plaintiff,
v. CASE NO.: CACE-20-006552

LAKESIDE CONDOMINIUM AT
LAUDERDALE LAKES ASSOCIATION, INC.
and WESTWAY TOWING, INC.,
Defendants.
_________________________________/

PLAINTIFF, ERNA JEAN’S NOTICE OF SERVING

OF INTERROGATORIES TO THE DEFENDANTS

PLAINTIFF, ERNA JEAN (herein “Plaintiff”), by and through the undersigned counsel,
and gives notice that pursuant to Rule 1.340 of the Florida Rules of Civil Procedure,
DEFENDANT has propounded the attached interrogatories to DEFENDANTS, LAKESIDE
CONDOMINIUM AT LAUDERDALE LAKES ASSOCIATION, INC. and WESTWAY
TOWING, INC. (herein “Defendants”) and requests that Defendants respond to these
interrogatories under oath within 30 days.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing instrument was served via email to the
below service list on May 9, 2024.

/s/ Antoine Dumas

ANTOINE DUMAS
Florida Bar No. 126146
Attorney for Defendant
TALENTED TENTH LAW, PLLC
1451 W. Cypress Creek Road, Ste 300
Ft. Lauderdale, FL 33309
Telephone: 754-800-5291
Fax: 754-999-2140
Email: [email protected]

SERVICE LIST
Andre G. Raihelson, Esq.
LAW OFFICES OF ANDRE G.
RAIKHELSON, LLC.
301Yomato, Suite 1240
Boca Raton, FL 33431
Phone: (954) 895-5566
Email: [email protected]
Attorney for Plaintiff

Olesa Trayber, Esq.

2750 NE 185 St., Ste. 204
Aventura, FL 33180
Phone: (954) 980-8052
Email: [email protected]
Attorney for Plaintiff
 INSTRUCTIONS & DEFINITIONS
INSTRUCTIONS
Please comply with the following instructions when responding to this request:
1. Identification. Wherever a request asks for the identify of a person or entity, you
should provide any information known to you regarding that person’s or entity’s full
name, physical address, mailing address if different from the physical address, telephone
number, email address, and any other pertinent information necessary to locate and
identify the person or entity.
2. Restatement of Interrogatory: Please restate each interrogatory immediately before
your response thereto. If requested, Proponent will supply Respondent with a copy of the
discovery request in Microsoft Word to reduce the burden of restating each numbered
discovery request.
3. Manner of Production: If Plaintiff determines that it will produce documents in lieu
of answering any interrogatory, then when producing documents and things responsive to
this discovery request, Respondent may choose to either produce the documents in the
manner in which they are ordinarily maintained or may organize the production to
correspond with the numbered request that sought the production.
4. Production as Created/Maintained: If Respondent chooses to produce documents as
they are ordinarily maintained, then Proponent’s counsel must be present at the time
documents and things are selected from Respondent’s filing system for production, or
Respondent must provide information sufficient to disclose how the document/ESI was
created, maintained and ultimately was stored in Respondent’s paper filing system or
electronic data files.
5. Production by Category/Response: If Respondent chooses to produce responsive
documents and things to correspond with the numbered request to which the production
is responsive, then Respondent must categorize the responsive documents in a manner
that identifies the numbered request to which the documents and things are responsive.
6. Bates Numbering: Unless Respondent is producing a document or thing on which it
would be impossible or unreasonably expensive to affix a bates number, Proponent
requests that Respondent affix a bates number on each page of each responsive document
and thing so that the responsive documents and things may be identified in the written
response to the discovery requests.
7. Scheduling Inspections: If Respondent intends to produce responsive documents and
things by making them available for inspection and copying, then Respondent must
provide Proponent’s counsel with dates and locations for the inspection and copying of
responsive documents.
8. Attachments: If Respondent produces emails or paper correspondence that has any
attachments, then Respondent must produce the attachment in a manner that will allow
Proponent to understand that the document being produced is an attachment and to which
other document it is an attachment.
9. Multiple Copies of Email Strings: If Respondent produces an email string, then it
should produce the complete email string. However, if all recipients are reflected on an
email string and the other copies of the email string from other recipients are subsumed
within the email string produced, then there is no need to produce other copies of the
same email message.
10. Altered/Notated Originals: If the original of a document is within Respondent’s
possession, custody, or control. Any copy of a document on which any notation, addition,
alteration, or change has been made is to be treated as constituting an additional original
document.
11. Possession/Custody/Control: Each document request herein seeks all information
available to you, your attorneys or agents, and any other person acting on Respondent’s
behalf. Therefore, if a document or thing is responsive to a discovery request is in the
possession, custody or control of any person who has been employed, retained,
contracted or hired to create, store, maintain, modify, or otherwise deal with documents
or things on behalf of the Respondent, then said document or thing is considered to be in
the possession, custody and control of the Respondent and Respondent must obtain a
copy of said document or thing from the person or entity having possession of it and then
produce it.
12. Claiming Privilege: If Respondent contends that any documents or other items
responsive to any discovery request are privileged, then Respondent should state an
objection on grounds of privilege. Respondent must comply with the request to the extent
not privileged, and must provide (without revealing any privileged information) as to
each withheld document:
(1) Description: Briefly describe the nature and contents of the privileged document;
(2) Author: Identify the name, occupation and capacity of each person from whom
the privileged information emanated;
(3) Recipients: Identify the name, occupation and capacity of all persons to whom the
alleged privileged information was disseminated;
(4) Date: State the date the privileged information was created and disseminated; and
(5) Privilege: Identify the privilege claimed.
13. Objections. To the extent that you consider any of the following interrogatories
objectionable, answer so much of each interrogatory and each part thereof as is not
objectionable in your view and separately state that part of each interrogatory as to which
you raise objection and each ground for each such objection.
14. Knowledge. With respect to any answer or portion of any answer to any of the
following interrogatories, identify each person from whom information was obtained on
which such answer or part thereof was based.
15. Continuation. These interrogatories are continuing in character. You are therefore
requested to file supplementary answers if you obtain further or different information
prior to any hearing or trial.
16. Miscellaneous. The following instructions also apply:
1) Whenever you are instructed to state a date or a dollar amount, if such date or
amount is unknown to you, state your best estimate of such date or amount and
indicate that it is an estimate.
2) The words “and” and “or” shall be construed conjunctively or disjunctively as
necessary to make the request inclusive rather than exclusive.
3) The word “including” shall be construed to mean “including but not limited to” or
“including without limitation.”
4) The use of the past tense shall include the present tense, and the use of the present
tense shall include the past tense, so as to make the question inclusive rather than
exclusive.
5) The singular includes the plural, and vice versa.
 6) Each question is to be accorded a separate answer, and questions are not to be
combined for the purpose of supplying a common answer thereto.
7) Unless otherwise indicated, the relevant time period for purposes of these
interrogatories is the time period from January 1, 2016, to the date of the filing of
your answers to these interrogatories, to be updated through the date of any hearing
or trial.

DEFINITIONS
The following definitions apply to these discovery requests:
A. As used herein, "DEFENDANT” means the DEFENDANT, Traci Lewis.
B. As used herein “Askerov” or “Respondent” means the PLAINTIFF.
C. As used herein, “You” and shall mean PLAINTIFF.
D. As used herein, “Complaint” shall mean the Complaint filed on behalf of Plaintiffs on
or about April 16, 2020.
E. As used herein, “litigation” shall refer to the instant lawsuit.
F. As used herein, “furnishings” shall refer to the designer couch, marble dining table,
dining chairs, glass vase or any other part of the property alleged to have been damaged
by the Defendant in this lawsuit.
G. As used herein, “subject property” shall refer to Plaintiff’s residential property that
was leased in an agreement to the Defendants, as it pertains to 2711 South Ocean Dr.,
Unit 3905, Hollywood, Florida, 33019.
H. As used herein, “Date” shall mean the exact date, month, and year is ascertainable, or
if not, the best approximation thereof.
I. The term “Computer System” shall mean and refer to your entire computing
environment. The Computer System includes all hardware (the actual computers
themselves), peripherals (e.g., terminals, printers, modems, and data storage devices), and
software (e.g., program applications) used in your household and/or office or store. This
environment may consist of one large computer serving many users or one or more
personal computers working individually or linked together through a network or group
of networks.
J. The term “document” shall mean any written or any other tangible thing of every kind
and description, including electronically stored information, whether in draft or final
form, original or reproduction, in your actual or constructive possession, custody or
control, including but not limited to: letters, correspondence, notes, films, transcripts,
telegrams, teletype messages, contracts and agreements including drafts, proposals, and
any and all modifications thereof, licenses, memoranda, transcripts and recordings of
telephone conversations or personal conversations, microfilm, microfiche, books,
newspapers, magazines, advertisements, periodicals, bulletins, circulars, pamphlets,
statements, notices, memoranda (including inter- and intra-office memoranda,
memoranda for file, pencil jotting, expense accounts, recorded recollections and any
other written form of notation of events thereto, draft minutes, resolutions and agendas),
expressions and/or statements of policy, lists of persons attending meetings and
conferences, reports, rules, regulations, directions, communications, reports, financial
statements, tax returns, ledgers, books of account, proposals, prospectuses, offers, orders,
receipts, analyses, audits, working papers, computations, projections, tabulations,
financial records, blueprints, plans, writings, drawings, graphs, charts, photographs,
phono-records, invoices, receipts, working papers, desk calendars, appointment books,
diaries, time sheets, logs, movies, tapes for visual audio reproduction, recordings,
magnetic computer tapes and discs, reports and/or summaries of investigations, opinions
and/or reports of consultants, appraisals, reports and/or summaries of negotiations,
computer punch cards, electronic mail (a.k.a. “e-mail” or “email”) (including e-mail
saved on computers, e-mail in hard copy form, and any deleted messages which may be
retrieved from backup systems or from your Internet Service Provider), voice mail, any
other data compilations from which information can be obtained (translated, if necessary,
into reasonably usable form), and/or all material similar to any of the foregoing, however
denominated. The term “document” shall also include copies containing additional
writing or marks not present on the originals and copies that are otherwise not identical
copies of the originals. Additionally, the term “document” shall include any meta-data
associated with the underlying document.
K. As used herein, (a) “Identify” or “identity,” when used in reference to a natural person,
means to state his or her full name, home and office telephone number and address,
business title, business affiliation or, if the above are not known, such information as was
last known. If such person has, or at any time in question had, any relationship to you or
to any other party to this action, “identify” also means to state what the relationship is or
was. (b)“Identify” or “identity,” when used in reference to a corporation, partnership or
any legal entity other than a natural person, means to state its full name, form of
organization, jurisdiction of any incorporation, current or last known address, and its
principal place of business (c)“Identify” or “identity,” when used in reference to a
document, means to state the Bates-label number for the document (if applicable) and to
state the type of document (e.g., letter, memorandum, contract, telegram, etc.), its date,
author or authors, addressee or addressees, if any, a summary of its contents, and its
present location or custodian. If any such document is no longer in your possession or
subject to your control, “identify” also means to state what disposition was made of it and
the date of such disposition. (d) “Identify” or “identity,” when used in reference to any
act, means to describe in substance the event or events constituting such act, what
transpired, the place and date thereof, and to identify the persons present, the persons
involved, and all documents relating to the act. (e) “Identify” or “identity,” when used in
any other context, means to state and describe in complete detail.
L. Information “relating” to a given subject matter, as used herein, means information
that constitutes, embodies, comprises, reflects, identifies, states, refers to, deals with,
comments on, responds to, describes, analyzes, contains information containing, or is in
any way pertinent to that subject matter, including, without limitation, documents
concerning the preparation or presentation of other documents.
M. Unless otherwise specified, the terms “person” or “persons” as used herein mean
natural persons, corporations, associations, partnerships, joint ventures, proprietorships,
governmental agencies, departments or offices or other legal entities, whether foreign or
domestic.
N. Unless otherwise defined, all words and phrases used herein shall be accorded their
usual meaning in plain and ordinary usage.
 INTERROGATORIES
1. State: 1) full name; 2) current address; and 3. occupation
ANSWER:

2. Describe your role within the condominium company at the time of the alleged unlawful
towing incident.
ANSWER:

3. Describe the events leading up to the towing of the personal car, including dates, time,
and locations.
ANSWER:

4. What specific authority or permission did the condominium company have to tow
personal vehicles from the property?
ANSWER:

5. Were there any posted signs or regulations regarding parking and towing on the
condominium property at the time of the alleged incident? If yes, please describe these
signs or regulations.
ANSWER:

6. Did the condominium company provide any notice or warning to the owner of the
personal car before towing it? If yes, please provide a copy and details of the notice
given.
ANSWER:
7. State the reason(s) the condominium believed the towing of the personal car was lawful,
if applicable.
ANSWER:

8. After being informed that the plaintiff’s car was registered and met all necessary
requirements, what additional rationale did you have for retaining her vehicle and
proceeding with the towing?
ANSWER:

9. Provide documentation, including any contracts, agreements, or bylaws, that authorize

the condominium company to tow personal vehicles from the property.
ANSWER:

10. List any witnesses to the events surrounding the alleged unlawful towing of the personal
car, including their names, addresses, and contact information.
ANSWER:

11. Have you ever been involved in any prior incidents of towing personal vehicles from the
condominium property? If yes, please describe these incidents.
ANSWER:

12. State any affirmative defenses you intent to raise in response to the allegations of
unlawful towing of the personal car.
ANSWER:
 SIGNATURE BLOCK IF EXECUTED IN THE PRESENCE OF A NOTARY PUBLIC

STATE OF FLORIDA )
COUNTY OF ____________ )

Signature: _____________________________
Printed Name: __________________________
As ________________________

SWORN TO AND SUSCRIBED BEFORE ME, personally appeared ______________________

and is personally known to me or produced the following identification:
____________________________ this _____ of ____________, 2022.
(SEAL)
________________________________
Notary Public
State of Florida
My Commission Number:
My Commission Expires:

SIGNATURE BLOCK IF EXECUTED UNDER PENALTY OF PERJURY

STATE OF FLORIDA )
COUNTY OF ____________ )

Pursuant to section 92.525 of the Florida Statutes, I declare under penalties of perjury that I have
read the foregoing instrument and that the facts stated in it are true except for facts stated “on
information and belief” which are true to the best of my knowledge and belief.

Signature: ____________________________________
Printed Name: _________________________________
As _________ _________________________________

Dated: