This is Janie Mcfarland’s Answers To Defendant’s First Set Of Interrogatories in case against Charlottesville Super 8 Motel (3:15-cv-00016-GEC-JCH) found in document 15-1 on pages 3 to 8. This may not be %100 accurate, so refer to the official court document for complete accuracy. Items such as social security information has been removed.
Note that after page 3 of 40, it appears jump from question #2 to question number 6. This also happens after page 5 of 40 and is how it appeared in the original court document.
Janie Mcfarland’s Answers To Defendant’s First Set Of Interrogatories
1. Sate your full name, and any other names your have been known by, you present and last previous address, date of birth, marital status, and Social Security Number. If answering in a corporate capacity, please include title, length of time in said position, and length of time with corporation.
Janie McFarland; Janie Marie Farland; Janie Marie Holmes; Janie Marie Hill 36 Genova Court, Farmingdale, NY 11735; 23 Johnson Street, Amityville, NY 11701;
2. If you have ever been involved in any other occurrence resulting in bodily or other injury to you or any other person, state the details of the occurrence, the names and addresses of the persons involved, and whether any claim or suit was made by or against you. Pleas include the name, address, claim representative, and claim numbers of any insurance company involved, and if suit was filed, state the name of the case, the case number and Court where it was filed, and the names, addresses, and telephone numbers of any attorneys representing any parties in such case(s).
a) US Navy- Rotary Cuff Repair; 1992 During Armed Forces Physical Training; US Navy, Fort Farfan, Panama; Disability Claim Filed;
b) OHL Delivery Service, 475 Doughty Blvd, Inwood, NY 11096: Hip/Back Injury; Personal Injury Claim Filed; Atty: Neil Moldovan, l Old Country Rd, Carle Place, NY 11514; 516-294-3300,
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b) Name: Desiree Scott (Defendant’s Employee)
Last Known Work: Super 8 Motel, 390 Greenbrier Drive, Charlottesville, VA 2290 I;
Conversation which occurred:
I wrapped bed bug in tissue and took to the front desk; discussed with Ms. Scott incident of bugs, bites that experienced; Ms. Scott defendant asked for my contact information;
c) Name: Valeria Grange
Last Known Work: Do not know;
Telephone Number: 516-835-0861;
Conversation which occurred:
On bus back to New York I told Ms. Grange about incident of bed bugs and showed some of the bites; Ms. Grange then informed me she was also bitten during the night on her chest area; Ms. Grange then showed the bite on her chest area
d) Name: Rev. Dr. Vernon D. Shelton Sr.
Last Know Work: Holy Trinity Baptist Church, 300 Albany A venue, Amityville, NY 1170 I;
Telephone Number: 631-842-6770
Conversation which occurred:
I spoke with Rev. Shelton about bed bugs that were in my and Ms. Woods’ bed; showed him pictures of the bites;
e) Name: Ann Brown
Last Know Work: Holy Trinity Baptist Church, 300 Albany Avenue, Amityville, NY 11701;
Telephone Number: 631-842-6770;
Conversation which occurred:
Met with Ms. Brown in hotel hall area; informed her of bed bug incident and bites experienced; also discussed conversation had with hotel employee Desiree Scott
6. Prior to and during the course of your stay at the hotel, list other locations you visited, the reasons for said visits and the number of people present at those locations. Please include any vehicles or other modes of transportation you were in.
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a) Desiree Scott; September 15, 2014
I was informed by Ms. Scott via telephone that the exterminator hired to inspect the room found bedbugs in the dust ruffle and box-spring of the bed I was provided. Ms. Scott went on to explain the room would be taken out of service for approximately a week to undergo heat treatment; which would consist of the room being heated to a temperature of 140 degrees (Fahrenheit) for a period of four (4) hours.
b) Timothy Kelsey;
September 29, 2014
Informed via telephone that I would receive an email in reference to the letter I sent to Defendant dated September 23, 2014
October 29, 2014
Telephone call during which Mr. Kelsey apologized for dropping the ball and was informed that information regarding the incident would be forwarded to Defendant’s insurance company.
c) Nichole Meyer (Liberty Mutual Insurance Company)
October 30, 2014
Telephone call during which Ms. Meyer sated that claim was initiated and a claim number was assigned.
December 9, 2014
Email stating that she is waiting for additional information from the extermination company and that she will contact me once she has all the pertinent information to make a decision.
12. Please state the names, addresses and telephone numbers of all persons who have given you statements, signed, written or recorded, concerning the occurrence which is the subject matter of this suit. Please include the date of each statement; the mane, address and telephone number of the person who took the statement; and the present custodian( s) of such statements.
13. Have you filed suit or made a claim against any person or entity not party to this case, including but not limited to health, disability or workers’ compensation insurers, for damages arising out of the
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b) Bodily Injury:
I sustained 45 bedbug bites on my face, scalp, neck, arms, underarms, chest/breasts, back, thighs, ankles, feet, and hands. I had sever swelling in the areas where I was bitten, as well as intense itching and pain. Some of the bites have left scars which are still visible. They also have cause periodic swelling in my left foot (which still still occurs up to the date of this submission) which at times requires me to wear a medical boot.
16. A follow up Please describe any complaints of injury or damages, and any restrictions on your activities, that you contend were caused by the subject occurrence, from the time of the subject occurrence up to the present time, and specify any such complaints and/or restrictions that you contend are permanent. Please include in your Answer aU facts, medical tests, medical examinations, or medical findings upon which you rely to support your contentions, including but not limited to the duration of such complaints and restrictions.
As mentioned in the previous item, my left foot swells periodically requiring me to wear a medical boot. When the foot is swollen I have difficultly walking and at times I cannot walk at all. During these periods I cannot attend social or church functions or fulfill certain duties as a church minister. I cannot cannot walk from parking area to church location or maintain my walking exercise routine. During wet weather, if I am able to walk I cannot do so because I cannot allow my foot to get wet or the boot to become water logged. Did not leave the house for days at a time outside of doctor visits during the first several weeks following the incident because bites severe and unsightly. I have permanent scaring on several parts of my body where I was bitten.
17. Please give the name and address of each health care provider which has examined, treated, or diagnosed you, or engaged in any consultation with any other physician concerning your in connection with your injuries, damages, complaints, or symptoms that you allege were caused by or affected in any manner by the subject occurrence. As to each health care provider, state the date or dates or each such examination, treatment, diagnosis, or consultation, and whether or not such health care provider will be called as a witness at the trial of this suit.
a) Dr. Richard Bebirian, I Carman Gate, Massapequa, NY 11758, 516-795-4343
Seen September – October 2014
b) VA Medical Center, 79 Middleville Road, Northport, NY I 1768
Seen March 2015 – Present
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Answer the names of all health care providers who treated, examined or consulted with you therefore, the approximate dates of such treatment, or consultation, and the diagnosis or prognosis related to such injuries or disease, disability, malady, medical condition or illness.
22. Please itemize the expenses and losses, economic and/or non economic, incurred by you or which you anticipate as a result of the occurrence. Please include in your Answer all facts upon which you rely to support any contention that you may have that any such expense are necessary, fair and reasonable as a result of the subject occurrence and include that names and addresses of any witness who will testify that such losses are necessary, fair and reasonable as a result of the subject occurrence.
a) loss of ability to travel/drive at will
b) loss of ability to freely participate in social and ministerial functions
c) loss of ability to walk at all times without assistance/apparatus
As stated in answers to previous items, this incident has left me in a state where my foot swells periodically and unexpectedly. As a result I am no longer able to travel or drive as freely as I was prior to the incident. This has limited my ability to participate in social and ministerial functions; interactions that integral to my quality of life. It has also limited my ability to walk, ( and at times wear shoes) which is my primary form of exercise and has resulted in a loss of mobility.
23. If you have been gainfully employed or had any earned income in the last five (5) years give the name and address of employer; nature of work; hourly, weekly, or other periodic compensation, both gross and “take-home”; and length of time employed for the present time, the time of the occurrence and all other times within the last five (5) year.
ANSWER: Not Applicable; no earned income or employment in last five (5) years.
24. Please state whether you have ever been convicted or a felony or of a crime involving moral turpitude. If so, please state the nature, time, place, court, and case number of any such crime and conviction.
ANSWER: No, never.
25. Name all experts whom you propose to call as witnesses on any issue in this case, furnish a copy of his or her report, and in addition, give the following information for each expert:
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b) Whether your case was discharged or dismissed;
c) The date of discharge or dismissal ( or expected discharge or dismissal);
d) And the case number of any bankruptcy cases
Yes, chapter 7. Discharged February 2000.
30. Please state each act or omission of the Defendants which you contend caused or contributed to the subject occurrence, identifying specifically the facts and opinions which you rely on to support you contentions.
Defendant failed to inspect the room in such a manner that would have enabled it detect the presence of bedbugs prior to giving me the room. If Defendant did inspect the room and was aware of the infestation, it did not give me any notice of such infestation before providing me the room. This is evidenced by the presence of bedbugs and bites I suffered during my stay and further evidence by the findings of the exterminator as reported to be by Ms. Scott who stated that bedbugs were found in the dust ruffle and box spring of the bed I was given.
Janie McFarland, prose
36 Genova Court
Farmingdale NY 11735
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- Case Progress:
- McFarland's Lawsuit against Super 8
- Super 8's Answer to McFarland's Lawsuit
- Interrogatories (questions asked of McFarland)
- McFarland asks court to rule against Super 8
- Super 8 asks court to rule against McFarland
- Lawsuit Docket
- McFarlands Opposition Brief