Vrachovska v. Moas et al, 1:15-cv-21494, No. 8-8 - Docket Alarm

Vrachovska v. Moas et al, 1:15-cv-21494, No. 8-8 - Docket Alarm

Case 1:15-cv-21494-JAL Document 8-8 Entered on FLSD Docket 04/28/2015 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Nevena T...

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Case 1:15-cv-21494-JAL Document 8-8 Entered on FLSD Docket 04/28/2015 Page 1 of 3

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Nevena Tsvetenova Vrachovska,

Case No: 1:15-cv-21494-JAL

Plaintiff, v. PLAINTIFF NEVENA TSVETENOVA VRACHOVSKA’S AMENDED FIRST SET OF INTERROGATORIES

Ronnie Moas, and Philanthropy and Philosophy, Inc., Defendants.

/

Pursuant to Rule 33 of the Federal Rules of Civil Procedure, Plaintiff Nevena Tsvetenova

Vrachovska

hereby

propounds

her

Amended

First

Set

of

Interrogatories upon Defendants Ronnie Moas and Philanthropy and Philosophy, Inc. Defendants shall serve their written reply to these Interrogatories within thirty days of service hereof on the offices of Plaintiff’s counsel, Randazza Legal Group, 3625 S. Town Center Drive, Suite 150, Las Vegas, NV 89135. INSTRUCTIONS AND DEFINITIONS 1.

As used in these Interrogatories, unless otherwise specifically

indicated, the term “Moas” includes Defendant Ronnie Moas, his past or present employees, agents, representatives, attorneys, or other persons or entities acting or purporting to act for, on behalf of, or with all or any of them. The term “P&P” includes Defendant Philanthropy and Philosophy, Inc. and all of its past or present employees, agents, representatives, attorneys, or other persons or entities acting or purporting to act for, on behalf of, or with all or any of them. The terms “You,” “Your,” and “Defendants” shall refer to Defendants collectively.

1 Plaintiff’s Amended First Set of Interrogatories

f Find authenticated court documents without watermarks at docketalarm.com.

Case 1:15-cv-21494-JAL Document 8-8 Entered on FLSD Docket 04/28/2015 Page 2 of 3

2.

As used in these Interrogatories, unless otherwise specifically

indicated, the term “the Email” shall refer to the email communication sent to Plaintiff’s counsel Marc J. Randazza by Moas on April 27, 2015, and attached as Exhibit 1 to the Memorandum of Points and Authorities in Support of Plaintiff’s Motion for Early Discovery. 3.

As used in these Interrogatories, unless otherwise specifically

indicated, the term “Mr. Lewitt” refers to Michael Eric Lewitt, an attorney registered with the New York State bar, Registration Number 2026045. 4.

In the following Interrogatories, the terms “possession and control”

are used in a comprehensive sense and refer to possession or control by any one or a combination of the following persons or corporations: a.

Any corporation or other business entity controlled by or affiliated with Defendants;

b.

Any employee, agent or consultant of or for Defendants or any such controlled or affiliated corporation or business entity;

c.

Counsel for Defendants or any such controlled or affiliated corporation or business entity.

5.

Whenever in the following Interrogatories a request is made to

“identify” a person or entity, this shall mean to giver the person or entity’s name, company title if a person, contact address and telephone number sufficient for service of process. 6.

Should Defendants deem any information to be privileged that is

the subject of any Interrogatory, Defendants shall indicate that they claim privilege therefore, briefly state the grounds on which the claim of privilege rests, identify who is making the claim of privilege, and identify the extent to which the information sought is privileged. 2 Plaintiff’s Amended First Set of Interrogatories

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Case 1:15-cv-21494-JAL Document 8-8 Entered on FLSD Docket 04/28/2015 Page 3 of 3

INTERROGATORIES INTERROGATORY NO. 1: Identify the person identified as “Michael” in the Email, including all states in which he or she is licensed to practice law and his or her bar numbers in such states. INTERROGATORY NO. 2: Identify all communications You have had with Mr. Lewitt regarding the subject

matter

of

this

action,

including

communications

prior

to,

contemporaneous with, and subsequent to Plaintiff’s filing of her Complaint in this action. INTERROGATORY NO. 3: Identify all other persons and entities who have provided you with advice similar to the advice provided by the person identified as “Michael” in the Email, including all states in which they are licensed to practice and their bar numbers in such states.

DATED: this 28th day of April, 2015.

Respectfully Submitted, s/ Marc Randazza MARC J. RANDAZZA Florida Bar No.: 625566 RANDAZZA LEGAL GROUP 3625 S. Town Center Drive Las Vegas, Nevada 89135 Tele: 702-420-2001 Fax: 305-437-7662 Email: [email protected] 3

Plaintiff’s Amended First Set of Interrogatories

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