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Filing # 126748537 E-Filed 05/13/2021 12:48:35 PM
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.
_______________________________________/
NOTICE OF SERVING EXPERT
INTERROGATORIES ON PLAINTIFF
Defendant, MET II HOTEL, LLC, gives notice of serving the attached Expert
Interrogatories on Plaintiff to be answered within 30 days, as provided in the Florida Rules of
Civil Procedure
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 May 13, 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 MARK C. BURTON
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
Case No.: 2017-014536 CA 01 Page 2
______________________________________________________________________________
EXPERT WITNESS INTERROGATORIES TO PLAINTIFF
1. Please state the name and address of each person who may or is expected by you, your
attorney, or any representative of yours, to testify as an expert witness during the trial of
this matter.
2. Please state the following information for each expert witness listed in Number 1 above:
(a) Each expert’s profession or occupation, and the specialty field in which each is an
expert.
(b) The name and address of each school each expert attended and a description of
each degree received and the date received.
(c) The name of any and all professional or trade associations or societies of which
each is a member or to which each is related, stating their status with each and the
inclusive dates of such status.
(d) The title, name of publication, subject matter, publisher and date of publication of
any books, papers or articles on subjects in their field authored by each such person.
(e) The number of years each has practiced or worked in their field.
(f) Each expert’s place of employment for the past ten (10) years.
(g) The subject matter on which each expert is expected to testify.
Case No.: 2017-014536 CA 01 Page 3
______________________________________________________________________________
3. Whether each expert has even been a witness in any other lawsuit, and, if so, for each
lawsuit, whether he/she testified for Plaintiff or Defendant, give the name of the suit, kind
of suit involved, name of the Court, approximate date of testimony case number, the
name and address of the parties or attorneys for whom such expert gave evidence.
4. State the number of times each such expert has testified for this Plaintiff’s counsel and his
counsel’s law office prior to this lawsuit and identify the subject lawsuits by name and county.
[BOECHER INTERROGATORY.]
5. Please state whether any of your experts listed in No. 1 above have determined any facts
or formed any opinions concerning any issues involved in this case.
Case No.: 2017-014536 CA 01 Page 4
______________________________________________________________________________
6. If so, please state in detail:
(a) The name of the expert or experts, and the issue about which he has an opinion.
(b) The fact or facts determined and the opinion or opinions formed by each expert.
(c) The substance of the facts relied on by such experts in arriving at their opinion or
opinions.
(d) A summary of the grounds relied on by each expert in reaching their opinion.
7. State, in detail, the facts upon which each opinion set forth in Answer to Interrogatory
Number 4 above is based, and as to each fact that is in any way relied upon by such
person in arriving at their opinion, state:
(a) The name and address of the person supplying such facts.
(b) The form in which such facts were supplied to them.
Case No.: 2017-014536 CA 01 Page 5
______________________________________________________________________________
8. If any person named in Answer to Interrogatory Number 1 has submitted a written report
or opinion related to the subject matter of this case, state:
(a) The name of the person submitting such written report or opinion related to the
subject matter of this case.
(b) The date (or dates, if more than one) of such written report or opinion.
(c) The name or other means of identification and address of the person to whom such
written reports or opinion was submitted and the name and address of the person
who has present custody of the report.
9. Please attach a copy of each such written report or opinion set forth in your Answer to
Interrogatory No. 6 above to your answers to these interrogatories. This request is made
under the provision of Rule 1.280, Fla.R.Civ.P., and you are requested to attach a copy of
such report to these answers to interrogatories, and supply a copy to the undersigned
attorneys, by mail, at the time the answers to interrogatories are required to be filed, and
served, under the applicable Rules of Civil Procedure.
Case No.: 2017-014536 CA 01 Page 6
______________________________________________________________________________
10. Please state whether any item or object relevant to this lawsuit has been tested, analyzed,
examined or inspected by any of the experts listed in your Answer to Interrogatory No. 1.
If so, state:
(a) Please describe in detail, sufficient to identify, each item or object that was tested,
analyzed, examined or inspected, and the name of the expert.
(b) The facts or information you were seeking in having these tests, examinations or
inspections made.
(c) The steps used in each test, examination or inspection of any object or item
material to this lawsuit.
(d) Please state the findings resulting from each inspection, analysis, examination or
test conducted.
(e) The facts or opinions derived from the tests.
(f) Please state the date of each test, the name and address of the person conducting
the test, and the name of each test performed.
11. Have any experts listed in your Answer to Interrogatory No. 1 above submitted any other
reports with regard to any issues relevant to this lawsuit?
Case No.: 2017-014536 CA 01 Page 7
______________________________________________________________________________
12. If so, state:
(a) The name of each such expert.
(b) A description of each report that was made.
(c) The date that each report was made.
(d) The name, or other means of identification of the person to whom each report was
submitted.
(e) The name and address of the person who has present custody of each report.
(f) The number of years each has practiced or worked in their field.
(g) The places of their employment for the past ten (10) years.
13. As to each expert consulted by you or your attorneys, relative to the subject matter of this
case, but you do not expect to call to testify at trial, state:
(a) Their name, profession and professional address.
(b) Subject matter about which they were consulted.
(c) If they submitted any written reports or opinions relative to this subject matter
about which they consulted, indicate the date (or dates) of such report, and the
name and address of the person to whom submitted.
Case No.: 2017-014536 CA 01 Page 8
______________________________________________________________________________
COUNTY OF ________________
STATE OF __________________
BEFORE ME, the undersigned authority, personally appeared, ____________________,
who, after being duly cautioned and sworn, deposes and says the he/she has read the above
Answers to Interrogatories attached hereto and the information therein is true and correct.
______________________________________
AFFIANT
The foregoing instrument was acknowledged before me this ___ day of
________________, 2021, by ___________________________________________;
_________ Who is personally known to me.
_________ Who produced the following identification _______________________________.
_________ Who did take an oath.
_________ Who did not take an oath.
______________________________________ My Commission Expires:
Signature of Notary
______________________________________ (Notary Seal)
Print Name of Notary
Preview
Filing # 126748537 E-Filed 05/13/2021 12:48:35 PM 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. _______________________________________/ NOTICE OF SERVING EXPERT INTERROGATORIES ON PLAINTIFF Defendant, MET II HOTEL, LLC, gives notice of serving the attached Expert Interrogatories on Plaintiff to be answered within 30 days, as provided in the Florida Rules of Civil Procedure 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 May 13, 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 MARK C. BURTON 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 Case No.: 2017-014536 CA 01 Page 2 ______________________________________________________________________________ EXPERT WITNESS INTERROGATORIES TO PLAINTIFF 1. Please state the name and address of each person who may or is expected by you, your attorney, or any representative of yours, to testify as an expert witness during the trial of this matter. 2. Please state the following information for each expert witness listed in Number 1 above: (a) Each expert’s profession or occupation, and the specialty field in which each is an expert. (b) The name and address of each school each expert attended and a description of each degree received and the date received. (c) The name of any and all professional or trade associations or societies of which each is a member or to which each is related, stating their status with each and the inclusive dates of such status. (d) The title, name of publication, subject matter, publisher and date of publication of any books, papers or articles on subjects in their field authored by each such person. (e) The number of years each has practiced or worked in their field. (f) Each expert’s place of employment for the past ten (10) years. (g) The subject matter on which each expert is expected to testify. Case No.: 2017-014536 CA 01 Page 3 ______________________________________________________________________________ 3. Whether each expert has even been a witness in any other lawsuit, and, if so, for each lawsuit, whether he/she testified for Plaintiff or Defendant, give the name of the suit, kind of suit involved, name of the Court, approximate date of testimony case number, the name and address of the parties or attorneys for whom such expert gave evidence. 4. State the number of times each such expert has testified for this Plaintiff’s counsel and his counsel’s law office prior to this lawsuit and identify the subject lawsuits by name and county. [BOECHER INTERROGATORY.] 5. Please state whether any of your experts listed in No. 1 above have determined any facts or formed any opinions concerning any issues involved in this case. Case No.: 2017-014536 CA 01 Page 4 ______________________________________________________________________________ 6. If so, please state in detail: (a) The name of the expert or experts, and the issue about which he has an opinion. (b) The fact or facts determined and the opinion or opinions formed by each expert. (c) The substance of the facts relied on by such experts in arriving at their opinion or opinions. (d) A summary of the grounds relied on by each expert in reaching their opinion. 7. State, in detail, the facts upon which each opinion set forth in Answer to Interrogatory Number 4 above is based, and as to each fact that is in any way relied upon by such person in arriving at their opinion, state: (a) The name and address of the person supplying such facts. (b) The form in which such facts were supplied to them. Case No.: 2017-014536 CA 01 Page 5 ______________________________________________________________________________ 8. If any person named in Answer to Interrogatory Number 1 has submitted a written report or opinion related to the subject matter of this case, state: (a) The name of the person submitting such written report or opinion related to the subject matter of this case. (b) The date (or dates, if more than one) of such written report or opinion. (c) The name or other means of identification and address of the person to whom such written reports or opinion was submitted and the name and address of the person who has present custody of the report. 9. Please attach a copy of each such written report or opinion set forth in your Answer to Interrogatory No. 6 above to your answers to these interrogatories. This request is made under the provision of Rule 1.280, Fla.R.Civ.P., and you are requested to attach a copy of such report to these answers to interrogatories, and supply a copy to the undersigned attorneys, by mail, at the time the answers to interrogatories are required to be filed, and served, under the applicable Rules of Civil Procedure. Case No.: 2017-014536 CA 01 Page 6 ______________________________________________________________________________ 10. Please state whether any item or object relevant to this lawsuit has been tested, analyzed, examined or inspected by any of the experts listed in your Answer to Interrogatory No. 1. If so, state: (a) Please describe in detail, sufficient to identify, each item or object that was tested, analyzed, examined or inspected, and the name of the expert. (b) The facts or information you were seeking in having these tests, examinations or inspections made. (c) The steps used in each test, examination or inspection of any object or item material to this lawsuit. (d) Please state the findings resulting from each inspection, analysis, examination or test conducted. (e) The facts or opinions derived from the tests. (f) Please state the date of each test, the name and address of the person conducting the test, and the name of each test performed. 11. Have any experts listed in your Answer to Interrogatory No. 1 above submitted any other reports with regard to any issues relevant to this lawsuit? Case No.: 2017-014536 CA 01 Page 7 ______________________________________________________________________________ 12. If so, state: (a) The name of each such expert. (b) A description of each report that was made. (c) The date that each report was made. (d) The name, or other means of identification of the person to whom each report was submitted. (e) The name and address of the person who has present custody of each report. (f) The number of years each has practiced or worked in their field. (g) The places of their employment for the past ten (10) years. 13. As to each expert consulted by you or your attorneys, relative to the subject matter of this case, but you do not expect to call to testify at trial, state: (a) Their name, profession and professional address. (b) Subject matter about which they were consulted. (c) If they submitted any written reports or opinions relative to this subject matter about which they consulted, indicate the date (or dates) of such report, and the name and address of the person to whom submitted. Case No.: 2017-014536 CA 01 Page 8 ______________________________________________________________________________ COUNTY OF ________________ STATE OF __________________ BEFORE ME, the undersigned authority, personally appeared, ____________________, who, after being duly cautioned and sworn, deposes and says the he/she has read the above Answers to Interrogatories attached hereto and the information therein is true and correct. ______________________________________ AFFIANT The foregoing instrument was acknowledged before me this ___ day of ________________, 2021, by ___________________________________________; _________ Who is personally known to me. _________ Who produced the following identification _______________________________. _________ Who did take an oath. _________ Who did not take an oath. ______________________________________ My Commission Expires: Signature of Notary ______________________________________ (Notary Seal) Print Name of Notary