IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, ST. LUCIE COUNTY, FLORIDA

Case No. OO-CA-001074-(OC)

FIGG BRIDGE ENGINEERS, INC.,

Plaintiff,

V.

CHARLES GRANDE, EDWARD McKAY, ROGER SHARP and KEVIN STINNETTE,

Defendants.

_______________________________________________________________I

NOTICE OF SERVICE OF DEFENDANTS’

FIRST SET OF INTERROGATORIES ON PLAINTIFF

The defendants, pursuant to Fla. R. C iv. P. 1.340, hereby give notice of service of the Defendants’ First Set Interrogatories on Plaintiff, attached hereto, and request that they be answered in accordance with the Rules of Civil Procedure.

I HEREBY CERTIFY that a copy of this notice and the First Set of Interrogatories were provided by fax and by U.S. Mail on October 16, 2000 to counsel for the plaintiff: Harold G. Melville, Melville & Sowerby, P.L., 2940 S. 25~ St., Fort Pierce, FL 3498 1-5605.

Respectftilly submitted,

 

 

 

Robert Rivas

The Rivas Law Firm

311 S. Calhoun St., Suite 206

Tallahassee, FL 32301-1802

Tel: (850) 412-0306

Fax:(850)412-0909

Florida Bar No 896969

IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, ST. LUCIE COUNTY, FLORIDA

Case No. O0-CA-001074-(OC)

FIGG BRIDGE ENGINEERS, INC.,

Plaintiff,

V.

 

CHARLES GRANDE, EDWARD McKAY, ROGER SHARP and KEVIN STINNETTE,

Defendants.

_______________________________________________________________I

DEFENDANTS’ FIRST SET

OF INTERROGATORIES ON PLAINTIFF

The defendants, pursuant to Fla. R. C iv. P. 1.340, submit the following interrogatories to the plaintiff, Figg Bridge Engineers, Inc. ("Figg"):

1. Describe with particularity the "loss of business" damages Figg claims to have incurred as a result of the alleged defamation described in the complaint, setting forth each item of lost business; with whom or what entity the business would have been; how much Figg claims to have lost in connection wit each such item; and how Figg has determined that the loss of such item of business was a result of the alleged defamation.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case No. OO.CA-001074.(OC)

2. Describe with particularity the loss of "reputation" damages Figg claims to have incurred as a result of the alleged defamation described in the complaint, setting forth how any such loss of reputation has actually caused Figg any monetary damages, and how much such monetary loss has been and is expected to be.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3. Give the name and address of every person, government agency, corporation, or other entity that has withdrawn business from Figg, or declined to do business with Figg, as a result of the defamation alleged in this action.

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case No. 00.CA-001074.(OC)

4. This question is asked wit reference to the allegation in paragraph 14 of the Complaint that the "defamatory statements made by Grande, McKay, Stinnette and Sharp were all false and either known to be false to each of them and/or made with reckless disregard for the truth or falsity of the matters asserted." Please state with particularity the factual basis for Figg to reach this conclusion.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

5. Please identify any factual basis, if there is any, for Figg to conclude that any defendant acted with common law malice (also known as "express malice" or "malice in fact") in publishing any of the allegedly defamatory statements.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case No. OO.CA-001074-(OC)

6. With reference to the allegation in paragraph 20 of the Complaint (the allegation repeated in paragraphs 25, 30, 36, 41,46, 56, 62, and 67) that Figg "is not now nor has it ever been" under "a Federal Grand Jury criminal investigation," please state how Figg knows this statement to be true.

 

 

 

 

 

 

 

 

 

 

 

 

 

7. With reference to the allegation in paragraph 30 of the Complaint (the allegation repeated in paragraphs 36, 41, 46, 56, 62, and 67) that Figg "is not now nor has Figg ever been" under "a state criminal investigation," please state how Figg knows this to be true.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case No. OO-CA-001074-(OC)

8. Has any employee or officer of Figg had any communication with about this lawsuit with any officer or employee of the St. Lucie County Expressway and Bridge Authority? If so, identify what employee or officer of Figg had such a discussion, with what officer or employee of the Authority; state when this communication took place, and in what form (whether on the phone, in person, in writing, by e-mail, etc.); and state the substance of what was communicated.

 

 

 

 

 

 

 

 

 

 

 

 

FIGG BRIDGE ENGINEERS, INC.

 

 

By:

as its

STATE OF FLORIDA

COUNTY OF ST. LUCIE

 

BEFORE ME PERSONALLY APPEARED

who, being duly sworn, deposed and said that he or she is the

of Figg Bridge Engineers, Inc.; that he or she executed these answers to interrogatories in that capacity; and that these answers to interrogatories arc true and

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Case No. OO-CA-001074-(OC)

correct. The signatory:

(Notary must check one.)

 

is personally known to me; or

 

produced

as identification.

 

 

 

NOTARY PUBLIC, STATE OF FLORIDA

MY COMMISSION EXPIRES:

SEAL:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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