IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA

, CASE NO.

Plaintiff,
v.

Defendant.
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PLAINTIFFS' FIRST SET OF INTERROGATORIES

  Plaintiffs serve the Defendant its first set of interrogatories and request that the Defendant

respond to the request within 30 days of service of this request as prescribed by Fla. R. Civ P.

____.

DEFINITIONS AND INSTRUCTIONS

1. The terms “Plaintiffs” mean the Plaintiffs,.

2. The term “person” means any natural person, individual, proprietorship, partnership,

corporation, association, organization, joint venture, firm, other business enterprise,

governmental body, group of natural persons or other entity.

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,

worksheets, receipts, returns, computer printouts, prospectuses, financial statements, schedules,

affidavits, contracts, canceled checks, statements, transcripts, statistics, surveys, magazine

articles, releases (and any and all drafts, alterations and modifications, changes and amendments

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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

limitation, tapes, cassettes, disks and records).

4. The term “communication” means any oral or written statement, dialogue,

colloquialism, discussion, conversation, agreement or expression of any kind.

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

outside the scope.

6. The terms “you,” “your,” and “Defendant” means the Defendant,

7. The term “Action” means the lawsuit initiated by Plaintiffs against Defendant in the

Seventeenth Judicial Circuit Court, Broward County of Florida, Case No..

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

connected with the matter discussed.

10. The term “all” includes the term “any” and the term “any” includes “all.” The terms

“all” and “any” shall be construed as any and all.

11. The term "Plaintiffs' lender" means Plaintiffs' lender or loan servicer

INTERROGATORIES

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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.

Date: June 12, 2022 Respectfully Submitted by:

LAW OFFICES OF

By:/s/