1. Make corrections for grammar, punctuation, spelling, etc.
2. Make substantive corrections (i.e., correct dates, names, facts)
3. Make all necessary formatting changes (i.e., font, font size, margins, consistent word choice, etc.)
4. Add comments to explain your changes or additional information you think necessary
5. make a Request to Produce any four documents of your choice.
   1. Make sure you are specific about the time frame
   2. Clearly identify the document you want produced.

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT

IN AND FOR PINELLAS COUNTY, FLORIDA

Case No.: 20-21458-CA

HOMER SIMPSON and

MARGE SIMPSON,

vs.

Plaintiffs,

HAPPY SUMO, INC., a Florida corporation,

Defendant.

/

PLAINTIFF'S NOTICE OF SERVICE OF ADN FIRST INTERROGATORIES TO DEFENDANTS, HAPPY SUMO, INC.

TO: HAPPY SUMO, INC.

c/o

St. Petersburg, FL

Attorney for Defendant

YOU ARE HEREBY REQUIRED, in accordance with the applicable Rules of Civil Procedure and within the time fixed thereby, to answer under oath and in writing the following interrogatories numbered 1 through 22, inclusive within 90 days of service.

I HEREBY CERTIFY that copies of this Notice and the original and one copy of the

Interrogatories have been furnished to Jim Bronson, Esquire, Attorney for Defendant John Justice, Esquire, by electronic mail at , this ____ day of February, 2010. /s/ Jane Justice .

Jane q.

Florida Bar No.: 9

Attorney for Plaintiff

D, Cheatum, & Howe

2112 Central Avenue, FL 33772

Telephone:

:

PLAINTIFFS' NOTICE OF SERVICE OF AND FIRST INTERROGATORIES TO DEFENDANT ,HAPPY SUMO, INC.

DEFINITIONS

1. "Person" as used herein shall mean and include an individual, association, firm, partnership, corporation or any other entity of any type, whether public or private.

1. "Communication" as used herein shall mean any document, oral statement, meeting or conference, formal or informal, at any time or place, and under any circumstances whatsoever, whereby information of any nature was stated, written, recorded or, in any manner, transmitted or transferred.

1. "Document" is used herein in its broadest sense and shall include, without limitation,and in the singular as well as in the plural, any stored or retained data or information in any form, whether by computer or otherwise, including, but not limited to estimates, invoices, canceled checks, billing statements, purchase orders, photographs, memoranda (including written memoranda of telephone conversations, other oral communications, discussions, agreements, acts and activities), letters, postcards, telegrams, correspondence, intraoffice and interoffice communications, handwritten or typewritten notes, pamphlets, diaries, sound recordings, transcripts of sound recordings, contracts, agreements, books, manuals, reports, catalogues, price lists, financial statements, books of account, journals, ledgers, indices, software, data bases, computer programs, data processing cards, other data processing materials, data sheets, tapes, photostats, microfilm, directives, bulletins, circulars, notices, messages, tabulations, economic or statistical studies, surveys, polls, minutes, instructions, requests, calendars, notebooks, desk pads, appointment books, specifications, drawings, diagrams, sketches, and writings and records of every kind and character, including preliminary drafts and other copies of the foregoing, however produced or reproduced.

1. "Relating to", "relates to" or "incident to" a given subject as used herein shall mean any document or communication that constitutes, evidences, contains, embodies, comprises, reflects, identifies, states, refers to, deals with, comments on, responds to, describes, involves or is, in any way, pertinent to the given subject.

1. "Identify" or "identification" as used herein shall mean:
   1. With respect to an individual, full name, title, job description, and present business and home addresses (last known if present addresses are unknown) and present business and home telephone numbers (last known if present numbers are unknown).If there have been changes in title or job description during the time period identified in the interrogatory, all titles and job descriptions should be given for the identified time period, together with the period during which each title or job description was held.

1. With respect to a person other than an individual, its full name, principal place of business, and all business addresses and telephone numbers.

1. With respect to a document, specify its title, type of document, date, author, addressee(s), recipient(s), identifying number(s), if any, substance of its content, subject matter, present location, custodian, and each person who has had custody, possession or control of the document and each copy thereof. All documents should be so identified whether or not the document is in your possession, custody or control and whether or not the document is claimed to be privileged. In addition to the foregoing, as to each document which has been destroyed or other disposed, identify each person who destroyed or otherwise disposed of such document and each person or directed or participated in such destruction or disposal.

1. With respect to an oral statement or communication, the maker(s), recipient(s), when made, where made, individual(s) present when made, mode of communication, subject matter, date, time of day, duration, substance of what was said by each participant, and identify each document referring or relating to such oral communication.

1. With respect to a witness, the information called for when used with respect to an individual in Paragraph 5A above, together with each witness' residence and business telephone numbers, and state as to each whether an oral or written statement has been taken from each witness (indicate which and the date of each).

1. "Describe" as used herein shall mean:
   1. With respect to a communication, identify the date of the communication, who was present, the words or substance of the communication, who said what, the mode of the communication (e.g., in writing, by telephone, in person), the location of each of the participants at the time of the communication, and any document relating to the communication; and

1. With respect to an act or conduct, identify the details of the act or conduct, who participated, where it occurred, what each individual participating in such act or conduct did, and any document memorializing the act or conduct.

1. The term "persons" means any natural person, firm, corporation, partnership, joint venture or any other form of business entity.

1. The terms "you" or "your" include the persons to whom these requests are addressed, and all that person's agents, representatives or attorneys.

1. The terms "present," "present date," or "present time," mean the date upon which the response to this set of Requests is served upon Plaintiff.

1. The term "relating to" or "referring to" or "pertaining to" or "otherwise constitution evidence of" shall mean to consist of refer to reflect or be in any way logically or factually connected with the matter discussed.

1. The terms "and" and "or" shall be read in the conjunctive or disjunctive or both, as the case may be, all to the end that the interpretation be applied which results in the most extensive response.
2. The terms "document" and "documents" mean the original and any copy of any bearing or containing writing, impressions or a magnetic field, including, without limitation, any drawing, graph, chart, photograph, phono-records or electronic or mechanical matter (including microfilm of any kind or nature, tape or recording), or any other date compilations from which information can be obtained (translated, if necessary, through detections devices into reasonably usable forms), and further including without transcripts, all pamphlets, studies, reports, records, price lists, quotations memoranda, minutes, journal budgets, and any and all other writings or papers of any kind, including drafts, revisions, copies or reproductions of other writings or papers of any kind, including drafts, revisions, copies or reproductions of any of the forgoing, and information stored in computers or other data storage or processing equipment to the extent that the same are or were in the possession, custody or control of Defendant, or any other employees or agents, or are known by Defendant, or any of his employees or agents, to exist or have existed.

1. The term "incident" means the incident complained of in the Plaintiff's complaint.

1. Unless words or terms have been given a specific definition herein, each word or term used herein shall be given its usual and customary dictionary definition except where such word or term has a specific custom or usage definition, in which event such word or term shall be interpreted in accordance with the specific custom or usage definition.

INTERROGATORIES

1. Please identify each and every person answering or assisting in the preparation of the answers to these Interrogatories.

1. Were you aware, prior to the filing of the Complaint in this action that the Plaintiff, HOMER SIMPSON, was injured while a business invitee at HAPPY SUMO, INC., on or about November 1, 2020? If so, state when and by whom the occurrence described in the Complaint was made known to you and whether said notice was written or oral, and if written, the name and address of the person who now has custody of said written notice.

1. Please identify any insurance policy which may cover claims under any allegations from Plaintiffs' Complaint; and if so, identify the policy by policy number, limits of coverage, and insurance company. Identify any benefits of the policy, including providing defense counsel, that are being provided under any reservation of rights; and if so, identify the reservation of rights letter.
2. Please state the names, addresses and job titles of any and all persons who wereresponsible for the upkeep, cleaning, maintenance and/or inspection of the subjectarea, including but not limited to food storage,onthedateofthe allegedoccurrence,includingoutsidecontractors.

1. State the name, address and job title of all employees on duty at thetimeoftheallegedoccurrence,specificallythose who interacted withthePlaintiffsandgive theirlocationat the timeof theeventssetforthintheComplaint.

1. State the name and addressof the restaurant and/or kitchensupervisorwho was on duty at thetimeoftheincidentwhichissubject tothislawsuit.

1. Wasaninvestigationmadebyyouorinyourbehalfasaresultoftheincidentcitedin the Complaint filed by Plaintiff?Ifso, state the date it was made, the name,address and occupation of each person who made it and whether any report wasmadeof it.
2. Wereanystatementsobtainedbyyouorinyourbehalffromanypersonconcerningthe accident?Ifso, state the date and time it was obtained, the name, address andoccupation of the person who made it and whether it was written or oral and ifwritten,the nameandaddressofthepersonwho hascustodyofit.

1. Did any person witness the accident?Ifso, state the name or other means ofidentification, address, occupation and name of witness and the location from which(s)hewitnessedtheaccident.

1. Do you know of anyone who took or claims to have taken any photographs of thescene of the accident,the personsor objectsinvolved?Ifso, state the subject matterofsuchphotographs,thedateeachwastaken,theidentityandaddressofthepersonor persons taking such photographs and the name and address of each person whohaspossessionorcontrolofsuchphotographs.

1. Who do you contendwas responsiblefor the cleaning,upkeep and/or maintenanceoftheguestroomandbathroomwhere thesubjectincidentoccurred?

1. Identify any person not already named as a party to this lawsuit whomyou contendcaused or contributed to the occurrence complained of, including any employee, agent,architect,engineer,designer,contractor,subcontractororothers.

1. Identify each employee with personal knowledge of the incident, as well as his or her jobtitle and job or function which was being performed by that individual at the time of theincident.

1. Identifyeachpersoninterviewedconcerningtheincident?

1. Please state, what you believe happenedto Plaintiff on the premisesof the Happy Sumo restaurant, whichis subjectto this lawsuit, and includeinyourAnswerthebasisuponwhichyouhaveformedthatbelief.

1. Identify any insurance agreement(s) under which any insurance business may be liable tosatisfy part or all of any judgment which may be entered in this action, or to indemnify orreimburse you for payments made to satisfy the judgment, including in your answer theamountand limitsofanysuchliabilityinsurancecoverage.

1. Identifyin detail any changesthat have been made byyou, or anyone on yourbehalf, asto the physical site of the accident or as to any warnings or signs relating thereto since theoccurrenceinquestion.

1. Identify any procedures which you followed, before and after the time of the incident inquestion, concerning the inspection, repair and/or cleaning of the area where Plaintiffsinjuriesoccurred.

1. Identify any warnings, whether verbal or written (such as by a sign, or otherwise) whichwere given to the Plaintiff, specifically, and/or to guests in general, before this accidentoccurred,concerningtheconditionwhichcausedorcontributedtotheincidentcomplainedofinthislawsuit.

1. At the time of Plaintiffs injury, do you contend that any person or entity other than youmanaged the premises on which Plaintiff alleges he was injured and, if so, state each andevery fact on which you base the contention, and identify all writings that support thecontention?

1. WhateffortsweremadebytheDefendanttocorrecttheconditionwhichPlaintiffcontendscausedtheoccurrenceinquestionaftertheaccidentinquestion?

1. Please describe what training procedures, if any, are followed in the course of training ofDefendant's employees, specifically regarding preparation of food and interaction with customers who are unfamiliar with the risks of consuming raw seafood. This includes any and all writtenmaterial, slides, photographs, films, videotapes, etc. which Defendant utilizes in trainingitsemployees.

HAPPY SUMO, INC., a Florida corporation:

By:_________________________________

____________________________________

(PRINT)

Its:_________________________

STATE OF FLORIDA )

COUNTY OF _________ )

The foregoing instrument was acknowledged before me this ___ day of ____________, 2010 by, ___________________________, as _____________________ of HAPPY SUMO, INC.who took an oath and

( ) Is personally known to me.

( ) Has produced as identification.

NOTARY PUBLIC

(SIGN) _______________________________

(PRINT)______________________________

State of Florida at Large (Seal)