On January 06, 2001 a
Trial Materials
was filed
involving a dispute between
Grijak, Alexander,
and
Jw Marriott Marquis Miami,
Met Ii Hotel, Llc,
for Comm Premises Liability
in the District Court of Miami-Dade County.
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Filing # 128486245 E-Filed 06/10/2021 11:29:44 AM
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: 2017-014536-CA-01
ALEXANDER GRIJAK,
Plaintiff,
vs.
MET II HOTEL, LLC. d/b/a MARRIOTT
MARQUIS MIAMI,
Defendant.
_______________________________________/
DEFENDANT'S EXPERT WITNESS LIST
Defendant, MET II HOTEL, LLC d/b/a MARRIOTT MARQUIS MIAMI, by and through
undersigned counsel, and pursuant to the Court’s Pretrial Order, hereby lists its experts as
follows:
1. Richard E. Stogran, P.E., Engineering Design & Testing Corp., P.O. Box 940520,
Maitland, FL 32794-0520
Mr. Stogran will testify within the field of engineering regarding any testing, analysis, inspection,
review of file materials provided to him and research of applicable codes and standards. His C.V.
is attached.
2. Any and all physicians and/or health care providers who have rendered care and/or
treatment to the Plaintiff.
3. Any and all independent examining physicians and/or Court-appointed examining
physicians.
4. Any and all impeachment and/or rebuttal witnesses.
Defendant reserves the right to object and/or to call expert witnesses listed by Plaintiff to this
action and further reserves the right to amend this schedule of expert witnesses should additional
expert witnesses be identified subsequent to the date hereof and/or pending future discovery.
Case No.: 2017-014536 CA 01 Page 2
______________________________________________________________________________
Defendant will make Mr. Stogran available for deposition at a time and date that is mutually
agreeable, subsequent to Plaintiff’s expert being deposed. Expert files will be exchanged with
Plaintiff’s counsel prior to each deposition taking place, as mutually agreed upon.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing was sent via
the Florida Courts E-Filing Portal on June 10, 2021, to Robert W. Rodriguez, Esq., 5001 SW
74th Court, Suite 105, Miami, FL 33155 at robertwrodriguez@gmail.com;
tonyramos313@gmail.com; krisiarwrlaw@gmail.com (Attorney for Plaintiff)
/s/ Mark C. Burton
MARK C. BURTON, ESQ.
Florida Bar #: 650145
LAW OFFICE OF PETER DELAHUNTY
Employees of Zurich American Insurance Company
Attorneys for Defendant
4000 Hollywood Boulevard, Suite 430-N
Hollywood, FL 33021
Telephone: (954) 989-8775
Facsimile: (954) 967-6536
E-Service: usz.slftl@zurichna.com
Document Filed Date
June 10, 2021
Case Filing Date
January 06, 2001
Category
Comm Premises Liability
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Filing # 128486245 E-Filed 06/10/2021 11:29:44 AM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 2017-014536-CA-01 ALEXANDER GRIJAK, Plaintiff, vs. MET II HOTEL, LLC. d/b/a MARRIOTT MARQUIS MIAMI, Defendant. _______________________________________/ DEFENDANT'S EXPERT WITNESS LIST Defendant, MET II HOTEL, LLC d/b/a MARRIOTT MARQUIS MIAMI, by and through undersigned counsel, and pursuant to the Court’s Pretrial Order, hereby lists its experts as follows: 1. Richard E. Stogran, P.E., Engineering Design & Testing Corp., P.O. Box 940520, Maitland, FL 32794-0520 Mr. Stogran will testify within the field of engineering regarding any testing, analysis, inspection, review of file materials provided to him and research of applicable codes and standards. His C.V. is attached. 2. Any and all physicians and/or health care providers who have rendered care and/or treatment to the Plaintiff. 3. Any and all independent examining physicians and/or Court-appointed examining physicians. 4. Any and all impeachment and/or rebuttal witnesses. Defendant reserves the right to object and/or to call expert witnesses listed by Plaintiff to this action and further reserves the right to amend this schedule of expert witnesses should additional expert witnesses be identified subsequent to the date hereof and/or pending future discovery. Case No.: 2017-014536 CA 01 Page 2 ______________________________________________________________________________ Defendant will make Mr. Stogran available for deposition at a time and date that is mutually agreeable, subsequent to Plaintiff’s expert being deposed. Expert files will be exchanged with Plaintiff’s counsel prior to each deposition taking place, as mutually agreed upon. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing was sent via the Florida Courts E-Filing Portal on June 10, 2021, to Robert W. Rodriguez, Esq., 5001 SW 74th Court, Suite 105, Miami, FL 33155 at robertwrodriguez@gmail.com; tonyramos313@gmail.com; krisiarwrlaw@gmail.com (Attorney for Plaintiff) /s/ Mark C. Burton MARK C. BURTON, ESQ. Florida Bar #: 650145 LAW OFFICE OF PETER DELAHUNTY Employees of Zurich American Insurance Company Attorneys for Defendant 4000 Hollywood Boulevard, Suite 430-N Hollywood, FL 33021 Telephone: (954) 989-8775 Facsimile: (954) 967-6536 E-Service: usz.slftl@zurichna.com