Preview
COPY
SLATER & ZuURZ LLP
ATTORNEYS © COUNSELORS AT LAW
ONE CASCADE PLAZA
SUITE 2210
AKRON, OHIO 44308-1135
TELEPHONE (330) 762.0700
FAX (330) 762-3023
IN THE COURT OF COMMON PL
Oa COUN YONG eSSMON PLEAS.couRA
CATHLEEN A. CROWE ycasENo, “22HAR 21 AMI: 08
Deviesown or aazso-eses =» upce Gal ARES OA
Plaintif soompi? SURE FERSONAL 6 JVC
)INJURIES
vs. )
)INTERROGATORIES AND REQUEST
AUDREY SMITH )FOR PRODUCTION OF DOCUMENTS
14639 Warwick Rd. )ATTACHED HERETO
Marshallville, OH 44645
and
GEICO SECURE INSURANCE
COMPANY
One Geico Center
Macon, Georgia 31296
Defendants
wee SSS SSS SL
Now comes the Plaintiff, by and through the undersigned counsel and for her
Complaint against the Defendants states:
41. That on or about October 29, 2021 at approximately 4:43 p.m., the Plaintiff
was stopped in traffic facing northbound on State Route 57 in the Township of
Wadsworth, County of Medina and State of Ohio.
2. That on said date and at said time, Defendant Smith, negligently operated
her motor vehicle by colliding with the rear of the Plaintiffs vehicle, proximately
causing the personal injuries and damages detailed below.COPY
3. That as a direct and proximate result of the aforesaid negligence of
Defendant Smith, the Plaintiff sustained personal injuries incurred and will continue to
incur medical bills, lost wages and pain and suffering.
4, That shortly after the accident, the Plaintiff was contacted by a
representative of Defendant, Geico Secure Insurance Company.
5. The employee and/or agent of Defendant Geico, in an attempt to get the
Plaintiff to settle her injury claim, misrepresented the amounts of the medical bills that
the Plaintiff would receive following her medical treatment.
6. That this misrepresentation by Geico Secure Insurance Company through
an agent and/or employee of its, caused the Plaintiff to rely to her detriment on the
misrepresentation made by the Geico Secure Insurance Company employee.
7. That based upon this misrepresentation, Geico Secure Insurance Company
SUITE 2210
AKRON, OHIO 44308-1135
by and through its employee, induced the Plaintiff to settle her personal injury claim
ONE CASCADE PLAZA
TELEPHONE (330) 762-0700
FAX (330) 762-3923
for an amount significantly less than her medical bills.
SLATER & ZURZ LLP
ATTORNEYS 6 COUNSELORS AT LAW
Wherefore, the Plaintiff requests Judgment against Defendant Smith, in an
amount in excess of Twenty Five Thousand Dollars ($25,000.00). The Plaintiff further
requests that the alleged settlement between Defendant, Geico Secure Insurance
Company and the Plaintiff be voided. The Plaintiff requests costs, interest and such
other and further relief as to which the Plaintiff may be entitled at law or in equity.COPY
SLATER & ZuURZ LLP
ATTORNEYS & COUNSELORS AT LAW
ONE CASCADE PLAZA
SUITE 2210
AKRON, OHIO 44308-1135,
TELEPHONE (330) 762-0700
FAX (330) 762-3923
Respectfully submitted,
SLATER & ZURZ, LLP
JOHN J. LYNETT, (0991474
ROBERT P. HORTON #0084231
Attorneys for Plaintiff
One Cascade Plaza, Suite 2210
Akron, Ohio 44308-1135
(330) 762-0700
(330) 762-3923 fax
jlynett@slaterzurz.com,COPY
IN THE COURT OF COMMON PLEAS
MEDINA COUNTY, OHIO
CATHLEEN A. CROWE )CASE NO.
)
Plaintiff )JUDGE
)
vs. )
)INTERROGATORIES AND REQUEST
AUDREY SMITH, et al. )EOR PRODUCTION OF DOCUMENTS
)DIRECTED TO DEFENDANT,
Defendants )AUDREY SMITH
)
)
Now comes the Plaintiff by and through the undersigned counsel, and
pursuant to Rule 33 of the Ohio Rules of Civil Procedure, hereby submits the
following Interrogatories to Defendant, Audrey Smith, to be answered under oath
within twenty-eight (28) days of service hereof. These Interrogatories are to be
regarded as continuing with responses to be supplemented as any information may
SUITE 2210
AKRON, OHIO 44308-1135,
become available.
SLATER & ZURZ LLP
ONE CASCADE PLAZA
TELEPHONE (330) 762-0700
FAX (330) 762-3923
ATTORNEYS & COUNSELORS AT LAW
In addition, pursuant to Rule 34 of the Ohio Rules of Civil Procedure, the
Plaintiff hereby requests that the Defendant produce the following documents for
copying and inspection within twenty eight (28) days of service hereof to the law
offices of Slater & Zurz, 2210 One Cascade Plaza, Akron, Ohio 44308-1135. These
Requests are to be regarded as continuing with responses to be supplemented as
any information may become available.
INTERROGATORY NO. 1
State your name, address, date of birth, social security number and driver's
license number.
ANSWER:.COPY
INTERROGATORY NO. 2
Are you employed? If so, state:
a. name and address of your employer;
b. your job title or description;
c. the dates which you have been employed by the above specified
employer;
ANSWERS:
INTERROGATORY NO. 3
As of the date of the accident delineated in Plaintiffs Complaint, were you
covered by any insurance agreement under which the insurer may be liable to satisfy
part or all of any judgment rendered in this matter? If so, state:
SUITE 2210
AKRON, OHIO 44308-1135
a. the name and address of the insurer;
FAX (330) 762-3923
ONE CASCADE PLAZA
TELEPHONE (330) 762-0700
b. the effective dates of coverage of the policy;
SLATER & ZURZ LLP
ATTORNEYS & COUNSELORS AT LAW
c. the applicable limits of liability.
ANSWERS:
INTERROGATORY NO. 4
State whether or not the Defendant has been correctly named in the
Complaint.
ANSWER:‘COPY
INTERROGATORY NO. 5
If the answer to the preceding Interrogatory is in the negative, in what respect
was the name of the Defendant incorrectly designated?
ANSWER:
INTERROGATORY NO. 6
State the name and last known address of every person known to you, your
agents, and/or representatives who claim knowledge of the circumstances of the
incident involved in this case.
ANSWER:
ONE CASCADE PLAZA,
SUITE 2210
AKRON, OHIO 44308-1135.
TELEPHONE (330) 762-0700
FAX (330) 762-3923.
INTERROGATORY NO. 7
SLATER & ZURZ LLP
ATTORNEYS & COUNSELORS AT LAW
State whether a statement has been obtained by you, your agents, attorneys
or representative from any of the persons identified in your answer to the preceding
Interrogatory.
ANSWER:.COPY
INTERROGATORY NO. 8
If the answer to the preceding Interrogatory was in the affirmative, state the
following:
a. the name of each person from whom a statement was obtained;
b. the date or dates on which each statement was obtained from each
person;
ANSWERS:
INTERROGATORY NO. 9
Do you claim that any other person, firm or corporation was negligent in a
22 »
4 : 9 g . manner which caused or contributed to cause the incident referred to in the
wis 823
Tzeogne complaint?
NZgusge
we Suoos
ee 33628 ANSWER:
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Fz6 oft
Preview
COPY SLATER & ZuURZ LLP ATTORNEYS © COUNSELORS AT LAW ONE CASCADE PLAZA SUITE 2210 AKRON, OHIO 44308-1135 TELEPHONE (330) 762.0700 FAX (330) 762-3023 IN THE COURT OF COMMON PL Oa COUN YONG eSSMON PLEAS.couRA CATHLEEN A. CROWE ycasENo, “22HAR 21 AMI: 08 Deviesown or aazso-eses =» upce Gal ARES OA Plaintif soompi? SURE FERSONAL 6 JVC )INJURIES vs. ) )INTERROGATORIES AND REQUEST AUDREY SMITH )FOR PRODUCTION OF DOCUMENTS 14639 Warwick Rd. )ATTACHED HERETO Marshallville, OH 44645 and GEICO SECURE INSURANCE COMPANY One Geico Center Macon, Georgia 31296 Defendants wee SSS SSS SL Now comes the Plaintiff, by and through the undersigned counsel and for her Complaint against the Defendants states: 41. That on or about October 29, 2021 at approximately 4:43 p.m., the Plaintiff was stopped in traffic facing northbound on State Route 57 in the Township of Wadsworth, County of Medina and State of Ohio. 2. That on said date and at said time, Defendant Smith, negligently operated her motor vehicle by colliding with the rear of the Plaintiffs vehicle, proximately causing the personal injuries and damages detailed below.COPY 3. That as a direct and proximate result of the aforesaid negligence of Defendant Smith, the Plaintiff sustained personal injuries incurred and will continue to incur medical bills, lost wages and pain and suffering. 4, That shortly after the accident, the Plaintiff was contacted by a representative of Defendant, Geico Secure Insurance Company. 5. The employee and/or agent of Defendant Geico, in an attempt to get the Plaintiff to settle her injury claim, misrepresented the amounts of the medical bills that the Plaintiff would receive following her medical treatment. 6. That this misrepresentation by Geico Secure Insurance Company through an agent and/or employee of its, caused the Plaintiff to rely to her detriment on the misrepresentation made by the Geico Secure Insurance Company employee. 7. That based upon this misrepresentation, Geico Secure Insurance Company SUITE 2210 AKRON, OHIO 44308-1135 by and through its employee, induced the Plaintiff to settle her personal injury claim ONE CASCADE PLAZA TELEPHONE (330) 762-0700 FAX (330) 762-3923 for an amount significantly less than her medical bills. SLATER & ZURZ LLP ATTORNEYS 6 COUNSELORS AT LAW Wherefore, the Plaintiff requests Judgment against Defendant Smith, in an amount in excess of Twenty Five Thousand Dollars ($25,000.00). The Plaintiff further requests that the alleged settlement between Defendant, Geico Secure Insurance Company and the Plaintiff be voided. The Plaintiff requests costs, interest and such other and further relief as to which the Plaintiff may be entitled at law or in equity.COPY SLATER & ZuURZ LLP ATTORNEYS & COUNSELORS AT LAW ONE CASCADE PLAZA SUITE 2210 AKRON, OHIO 44308-1135, TELEPHONE (330) 762-0700 FAX (330) 762-3923 Respectfully submitted, SLATER & ZURZ, LLP JOHN J. LYNETT, (0991474 ROBERT P. HORTON #0084231 Attorneys for Plaintiff One Cascade Plaza, Suite 2210 Akron, Ohio 44308-1135 (330) 762-0700 (330) 762-3923 fax jlynett@slaterzurz.com,COPY IN THE COURT OF COMMON PLEAS MEDINA COUNTY, OHIO CATHLEEN A. CROWE )CASE NO. ) Plaintiff )JUDGE ) vs. ) )INTERROGATORIES AND REQUEST AUDREY SMITH, et al. )EOR PRODUCTION OF DOCUMENTS )DIRECTED TO DEFENDANT, Defendants )AUDREY SMITH ) ) Now comes the Plaintiff by and through the undersigned counsel, and pursuant to Rule 33 of the Ohio Rules of Civil Procedure, hereby submits the following Interrogatories to Defendant, Audrey Smith, to be answered under oath within twenty-eight (28) days of service hereof. These Interrogatories are to be regarded as continuing with responses to be supplemented as any information may SUITE 2210 AKRON, OHIO 44308-1135, become available. SLATER & ZURZ LLP ONE CASCADE PLAZA TELEPHONE (330) 762-0700 FAX (330) 762-3923 ATTORNEYS & COUNSELORS AT LAW In addition, pursuant to Rule 34 of the Ohio Rules of Civil Procedure, the Plaintiff hereby requests that the Defendant produce the following documents for copying and inspection within twenty eight (28) days of service hereof to the law offices of Slater & Zurz, 2210 One Cascade Plaza, Akron, Ohio 44308-1135. These Requests are to be regarded as continuing with responses to be supplemented as any information may become available. INTERROGATORY NO. 1 State your name, address, date of birth, social security number and driver's license number. ANSWER:.COPY INTERROGATORY NO. 2 Are you employed? If so, state: a. name and address of your employer; b. your job title or description; c. the dates which you have been employed by the above specified employer; ANSWERS: INTERROGATORY NO. 3 As of the date of the accident delineated in Plaintiffs Complaint, were you covered by any insurance agreement under which the insurer may be liable to satisfy part or all of any judgment rendered in this matter? If so, state: SUITE 2210 AKRON, OHIO 44308-1135 a. the name and address of the insurer; FAX (330) 762-3923 ONE CASCADE PLAZA TELEPHONE (330) 762-0700 b. the effective dates of coverage of the policy; SLATER & ZURZ LLP ATTORNEYS & COUNSELORS AT LAW c. the applicable limits of liability. ANSWERS: INTERROGATORY NO. 4 State whether or not the Defendant has been correctly named in the Complaint. ANSWER:‘COPY INTERROGATORY NO. 5 If the answer to the preceding Interrogatory is in the negative, in what respect was the name of the Defendant incorrectly designated? ANSWER: INTERROGATORY NO. 6 State the name and last known address of every person known to you, your agents, and/or representatives who claim knowledge of the circumstances of the incident involved in this case. ANSWER: ONE CASCADE PLAZA, SUITE 2210 AKRON, OHIO 44308-1135. TELEPHONE (330) 762-0700 FAX (330) 762-3923. INTERROGATORY NO. 7 SLATER & ZURZ LLP ATTORNEYS & COUNSELORS AT LAW State whether a statement has been obtained by you, your agents, attorneys or representative from any of the persons identified in your answer to the preceding Interrogatory. ANSWER:.COPY INTERROGATORY NO. 8 If the answer to the preceding Interrogatory was in the affirmative, state the following: a. the name of each person from whom a statement was obtained; b. the date or dates on which each statement was obtained from each person; ANSWERS: INTERROGATORY NO. 9 Do you claim that any other person, firm or corporation was negligent in a 22 » 4 : 9 g . manner which caused or contributed to cause the incident referred to in the wis 823 Tzeogne complaint? NZgusge we Suoos ee 33628 ANSWER: wgZg Z2% Fz6 oft