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Filing # 118996745 E-Filed 01/04/2021 01:53:19 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, JW MARRIOTT MARQUIS MIAMI
Defendant.
/
PLAINTIFF’S REQUEST FOR EXPERT WITNESS INTERROGATORIES
COMES NOW, the Plaintiff, ALEXANDER GRIJAK, by and through his undersigned counsel,
hereby requests that Defendant, MET II HOTEL, LLC., d/b/a, JW MARRIOTT MARQUIS MIAMI,
answer, under oath and in writing, the following Interrogatories within the time proscribed by the Rules of
Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing was emailed this
th
4 day of January, 2021 to all those listed on the Florida E-Portal Service requesting service in this
matter.
ROBERT W. RODRIGUEZ, P.A.
Counsel for Plaintiff
4909 SW 74 Court
Miami, Florida 33155
Telephone: (305) 444-1446
Facsimile: (305) 907-5244
E-Serve:
RobertWRodriguez@GMail.Com
/s/ Robert W. Rodriguez
Fla Bar No.: 856975
1
EXPERT WITNESS INTERROGATORIES
1. Identify each person known to you, your agents, employees, investigators, or
attorneys whom you or your attorneys expect to call as an expert witness at trial, providing
the name, address and telephone number of each.
RESPONSE
2. Identify and define the specific field and subject matter on which each of the
above-named experts is expected to testify as it relates to this litigation; and, in that
regard, please provide the following information specifically and in detail:
a. Describe how each of the above-named expert’s particular area(s) of
expertise is relevant to the factual or legal issues presented in this litigation.
b. What factual assumptions is each of the above-named experts basing his/her
expertise and theories upon?
RESPONSE:
3. State the substance of the facts and opinions upon which or about which each expert
is expected to testify and a summary of the grounds for each opinion.
RESPONSE:
4. State the educational background, training, and experience of each person above,
which qualifies him/her as an expert, and identify the field of such expertise.
RESPONSE:
5. As to each such expert listed above, identify those whose testimony is expected to be
offered by deposition, and those whose testimony is expected to be offered in person at trial.
RESPONSE:
6. Please state the hourly rate charged by the above-named expert or experts for the
following: (a) review of material, (b) travel, (c) deposition, and (d) trial.
RESPONSE:
7. Please state the date each expert was retained and by whom.
RESPONSE:
2
8. Please state the dates the above-named expert or experts performed their examinations
and rendered their opinions.
RESPONSE:
9. Did any of the above-named experts submit a report setting forth the opinions or
conclusions reached from the expert's examination or any tests conducted? If so, please state
the date the report was submitted and the name and address of the person who has present
custody of the report.
RESPONSE:
10. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances,
or statutes which each expert has used in basing any opinion.
RESPONSE:
11. For each expert listed above, has he/she practiced or worked in this field during the past
five years? If so, please state:
a. Whether the expert or experts were self-employed, employed by someone else or
associated as a partner.
b. Each address where the expert practiced or was employed.
c. The dates the expert was with each employer.
d. The type of duty the expert performed with each employer.
RESPONSE:
12. If any of the above-named experts have not practiced or worked in the applicable field
during the last five (5) years, what were the experts’ employment during this time?
RESPONSE:
13. State whether any of the above-named expert witnesses has any litigation
experience, including the percentage of work performed for plaintiffs and percentage of work
performed for defendants.
RESPONSE:
3
14. State whether any of the above-named expert witnesses has ever testified on behalf of
clients represented by the attorney/law firm representing you herein; if so, please state the
number of times and the dates in which said testimony was given.
RESPONSE:
15. On how many previous occasions, within the last five years, has each of the above-
named experts provided testimony by way of deposition, interrogatories, affidavits, or in
court or before any administrative body or tribunal? If the answer is anything other than “zero,”
please provide the following information:
a. The case title, address of the court, the names and addresses of counsel involved,
and the date or dates that you provided the testimony.
b. A brief statement as to the nature of the case, the facts upon which the opinions
were based, the opinions that the each of the above-named experts expressed, and
which opinions were included and which were excluded.
c. Whether the each of the above-named experts testified for the Plaintiff or
Defendant.
RESPONSE:
16. State the amount that the attorney/law firm representing you has paid in expert witness
fees to each of the above-named experts during the past three years.
RESPONSE:
17. Have these experts concluded their review of materials necessary to render final
opinions regarding the issues in this case?
RESPONSE:
18. State as to the pending case, exactly each of the above-named experts was hired to do.
RESPONSE:
19. State on average, what each of the above-named experts’ charges for property
inspections and the types of services they provided in this case.
RESPONSE:
4
20. State the approximate each of the above-named experts spends of their professional
time or work devoted to service as an expert.
RESPONSE:
21. State a fair estimate of the hours each of the above-named experts expended as an
expert for each year in the last three (3) years.
RESPONSE:
22. State the amount of income earned by each of the above-named experts by
performing property inspections and/or other services for plaintiffs in claims with their
insurers each year in the last five (5) years.
RESPONSE:
23. State an approximate number of insurance claims each of the above-named experts
worked on average each year for the last five (5) years.
RESPONSE:
24. State whether or not each of the above-named experts has created any documents
which either list or itemize their expert services for each year of the last three (3) years. If
your answer to the preceding question was in the affirmative, please provide a copy of
that document or describe that document fully and state where it is presently located.
RESPONSE:
25. State with particularity or attach the financial terms regarding retention of each of
the above-named experts in the case at bar.
RESPONSE:
26. State the number of times each of the above-named experts has been retained by The
Law Office of Peterson Bernard.
RESPONSE:
5
JURAT
STATE OF ________________
COUNTY OF ______________
BEFORE ME, the undersigned authority, personally appeared _________________________,
who, after being first duly sworn, deposes and says that defendant is the person named in the foregoing
Answers to Interrogatories, that defendant has read the same, knows the contents thereof and the same are
true as stated.
X___________________________________
____________________________________
Print Name
STATE OF FLORIDA
COUNTY OF
Sworn to (or affirmed) and subscribed before me by means of [ ] physical presence or [ ] online
notarization, this day of , 2020, by
, who [ ] is personally known to me or who [ ] has produced
_________________ as identification
Notary Public, State of Florida
My Commission Expires:
6
Preview
Filing # 118996745 E-Filed 01/04/2021 01:53:19 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, JW MARRIOTT MARQUIS MIAMI Defendant. / PLAINTIFF’S REQUEST FOR EXPERT WITNESS INTERROGATORIES COMES NOW, the Plaintiff, ALEXANDER GRIJAK, by and through his undersigned counsel, hereby requests that Defendant, MET II HOTEL, LLC., d/b/a, JW MARRIOTT MARQUIS MIAMI, answer, under oath and in writing, the following Interrogatories within the time proscribed by the Rules of Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing was emailed this th 4 day of January, 2021 to all those listed on the Florida E-Portal Service requesting service in this matter. ROBERT W. RODRIGUEZ, P.A. Counsel for Plaintiff 4909 SW 74 Court Miami, Florida 33155 Telephone: (305) 444-1446 Facsimile: (305) 907-5244 E-Serve: RobertWRodriguez@GMail.Com /s/ Robert W. Rodriguez Fla Bar No.: 856975 1 EXPERT WITNESS INTERROGATORIES 1. Identify each person known to you, your agents, employees, investigators, or attorneys whom you or your attorneys expect to call as an expert witness at trial, providing the name, address and telephone number of each. RESPONSE 2. Identify and define the specific field and subject matter on which each of the above-named experts is expected to testify as it relates to this litigation; and, in that regard, please provide the following information specifically and in detail: a. Describe how each of the above-named expert’s particular area(s) of expertise is relevant to the factual or legal issues presented in this litigation. b. What factual assumptions is each of the above-named experts basing his/her expertise and theories upon? RESPONSE: 3. State the substance of the facts and opinions upon which or about which each expert is expected to testify and a summary of the grounds for each opinion. RESPONSE: 4. State the educational background, training, and experience of each person above, which qualifies him/her as an expert, and identify the field of such expertise. RESPONSE: 5. As to each such expert listed above, identify those whose testimony is expected to be offered by deposition, and those whose testimony is expected to be offered in person at trial. RESPONSE: 6. Please state the hourly rate charged by the above-named expert or experts for the following: (a) review of material, (b) travel, (c) deposition, and (d) trial. RESPONSE: 7. Please state the date each expert was retained and by whom. RESPONSE: 2 8. Please state the dates the above-named expert or experts performed their examinations and rendered their opinions. RESPONSE: 9. Did any of the above-named experts submit a report setting forth the opinions or conclusions reached from the expert's examination or any tests conducted? If so, please state the date the report was submitted and the name and address of the person who has present custody of the report. RESPONSE: 10. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances, or statutes which each expert has used in basing any opinion. RESPONSE: 11. For each expert listed above, has he/she practiced or worked in this field during the past five years? If so, please state: a. Whether the expert or experts were self-employed, employed by someone else or associated as a partner. b. Each address where the expert practiced or was employed. c. The dates the expert was with each employer. d. The type of duty the expert performed with each employer. RESPONSE: 12. If any of the above-named experts have not practiced or worked in the applicable field during the last five (5) years, what were the experts’ employment during this time? RESPONSE: 13. State whether any of the above-named expert witnesses has any litigation experience, including the percentage of work performed for plaintiffs and percentage of work performed for defendants. RESPONSE: 3 14. State whether any of the above-named expert witnesses has ever testified on behalf of clients represented by the attorney/law firm representing you herein; if so, please state the number of times and the dates in which said testimony was given. RESPONSE: 15. On how many previous occasions, within the last five years, has each of the above- named experts provided testimony by way of deposition, interrogatories, affidavits, or in court or before any administrative body or tribunal? If the answer is anything other than “zero,” please provide the following information: a. The case title, address of the court, the names and addresses of counsel involved, and the date or dates that you provided the testimony. b. A brief statement as to the nature of the case, the facts upon which the opinions were based, the opinions that the each of the above-named experts expressed, and which opinions were included and which were excluded. c. Whether the each of the above-named experts testified for the Plaintiff or Defendant. RESPONSE: 16. State the amount that the attorney/law firm representing you has paid in expert witness fees to each of the above-named experts during the past three years. RESPONSE: 17. Have these experts concluded their review of materials necessary to render final opinions regarding the issues in this case? RESPONSE: 18. State as to the pending case, exactly each of the above-named experts was hired to do. RESPONSE: 19. State on average, what each of the above-named experts’ charges for property inspections and the types of services they provided in this case. RESPONSE: 4 20. State the approximate each of the above-named experts spends of their professional time or work devoted to service as an expert. RESPONSE: 21. State a fair estimate of the hours each of the above-named experts expended as an expert for each year in the last three (3) years. RESPONSE: 22. State the amount of income earned by each of the above-named experts by performing property inspections and/or other services for plaintiffs in claims with their insurers each year in the last five (5) years. RESPONSE: 23. State an approximate number of insurance claims each of the above-named experts worked on average each year for the last five (5) years. RESPONSE: 24. State whether or not each of the above-named experts has created any documents which either list or itemize their expert services for each year of the last three (3) years. If your answer to the preceding question was in the affirmative, please provide a copy of that document or describe that document fully and state where it is presently located. RESPONSE: 25. State with particularity or attach the financial terms regarding retention of each of the above-named experts in the case at bar. RESPONSE: 26. State the number of times each of the above-named experts has been retained by The Law Office of Peterson Bernard. RESPONSE: 5 JURAT STATE OF ________________ COUNTY OF ______________ BEFORE ME, the undersigned authority, personally appeared _________________________, who, after being first duly sworn, deposes and says that defendant is the person named in the foregoing Answers to Interrogatories, that defendant has read the same, knows the contents thereof and the same are true as stated. X___________________________________ ____________________________________ Print Name STATE OF FLORIDA COUNTY OF Sworn to (or affirmed) and subscribed before me by means of [ ] physical presence or [ ] online notarization, this day of , 2020, by , who [ ] is personally known to me or who [ ] has produced _________________ as identification Notary Public, State of Florida My Commission Expires: 6