Filing # 190383730 E-Filed 01/23/2024 05:57:18 PM
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`ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 01/24/2024 12:29:05 PM
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`DEFINITION OF TERMS
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`Asusedin these Interrogatories, the following terms and definitions are intended to apply:
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`1. Person - refers to any corporation, individual, joint venture, partnership, group, association,
`government agency,or any other identifiable entity.
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`2. Communication - refers to the transmission, transfer, or receipt of information in any form, by
`any means, in any mannerat any timeor place, under any circumstances whatsoever.
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`3. Directly employed means that such employees work exclusively for the Plaintiff, are listed on
`or are part of payroll with the Plaintiff, and such payment or compensation for the services of such
`employees are directly compensated by the Plaintiff, and not due to an independent contractor,
`subcontractor agreement, or other agreement or arrangement.
`(ex:
`the Plaintiff files required tax
`information as it pertains to its employees with the state and federal government, employee filed an
`employmentapplication with the Plaintiff and hired as a result, etc.)
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`4. Document or Documents- refers to writings, letters, telegrams, memoranda, recorded
`recollections of conferences or telephone conversations, reports, studies, lists, any written compilation of
`data, papers, books, records, contracts, drawings, photographs, mechanicalor electronic recordings in any
`form, and all other identifiable objects upon which any inscription, handwriting, typing, printing, drawing,
`representation by any means, whether magnetic,electrical, photostatic, or any other form of
`communication is recorded, reproduced, perpetuated. maintained or preserved. These terms similarly
`embrace the reproduction or copies of the foregoing.
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`5. Identify a Document- refers to the requirement that the identity of the person preparing the
`documentbe disclosed, the identity of all persons signing, issuing and/or attesting to such documentbe
`disclosed, the identity of addresses or distributees be disclosed, the nature, contents and/or substances of
`the documentbe disclosed with sufficient particularity so as to enable identification, the date which the
`documentbears no date, a disclosure of that fact together with the date upon which such document was
`prepared, a disclosure of the physical location of the document together with the namesand addresses of
`the custodian or custodians of the document.
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`6. Identify a Person - when employed with regard to a natural person refers to the name of such
`person, the present or last known address of such person, the name and address of such person's employer
`and the position of employment held by such person. Theclause "identify person" is employed with
`reference to a person not an individual, such term shall require the name and principal office of such
`person, the date and place of incorporation, if applicable, and such other information as necessary to
`identify, locate and/or communicate with such person.(ex: the Plaintiff files required tax information asit
`pertains to its employees with the state and federal government, employeefiled an employment
`application with the Plaintiff and hired as a result, etc.
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`Indirectly employed means those persons that work for the Plaintiff, but such payment and or
`7.
`compensation for their services was and/or is due to an independentcontractor, subcontractor agreement,
`or other agreement or arrangement between the Plaintiff and such person that does not indicate “direct
`employment”as described in definition #7 of these interrogatories.
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`INSTRUCTIONS FOR USE
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`Confidential
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`All information is to be divulged whichis in the possession of the individualparty, his
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`attorney, investigators, agents, employees or other representatives of the named party andhis attorney.
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`If you lack the information necessary to answerany of the Interrogatories, describe the
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`specific efforts made by you or anyone on your behalf to ascertain the information andstate as definitely
`as possible when you anticipate obtaining the information and supplementing your responses.
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`Interrogatories to Plaintiff
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`1. State the name, address and telephone numberof the person answering these Interrogatories on behalf of
`the Plaintiff. Also, state the person's official position or relationship including the duties and/or
`obligations of such person.
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`2. The person answering these Interrogatories must have the authority to answer these Interrogatories on the
`behalf of the Plaintiff and whose responseswill bind the Plaintiff to these Interrogatories.
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`3. As of the date you are responding to these interrogatories, please state the exact dollar amount the
`Plaintiff contends is at issue in this case for benefits and the dollar amount the Plaintiff contends is at
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`issue in this case for interest.
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`4. Please state the formula for how the Plaintiff calculated the dollar amount it believes it is owed for
`benefits and interest. Also, state the names of any witnesses who may have knowledge of how you
`determined the amount you billed for your services and/or any publications or computer programs you
`may have used to determine the amountto bill for your servicesin relation to this claim.
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`5. Please state each and every fact that supports the Plaintiffs contention that it is owed the additional
`benefits and interest, referenced in Interrogatory #3, above.
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`6. List the specific codes that form the basis for your contention that additional benefits are owed to the
`Plaintiff in relation to this claim, the additional amount you believe you are owed for each Code and each
`and every fact knownor believed by you that supports your contention that the specific code was not paid
`correctly.
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`STATE OF FLORIDA
`COUNTY OF
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`Affiant
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`BEFORE ME,the undersigned authority, this day personally appeared
`, who swears and affirms that he/she has executed the foregoing
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`Interrogatories and that the answersare true and correctto the best of his/her knowledge.
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`WITNESS myhand andofficial seal this
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`, 2024.
`day of
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`Confidential
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`My Commission Expires:
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`NOTARY PUBLIC
`STATE OF FLORIDA
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`Personally known OR
`Produced Identification
`Type ofIdentification Produced
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`Confidential
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