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Filing # 59442317 E-Filed 07/24/2017 06:02:35 PM
IN THE CIRCUIT COURT OF THE
11™ 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,
Defendants.
FIRST REQUEST TO PRODUCE TO PLAINTIFF
Defendant, MET II HOTEL, LLC d/b/a MARRIOT MARQUIS MIAMI, requests that
Plaintiff produce the following for inspection and photocopying at the offices of
undersigned counsel, pursuant to the Florida Rules of Civil Procedure:
1, All income tax returns, including all attachments, for the five (5) years
immediately preceding the year of the accident, through the present.
2. All W-2 forms or other payroll receipts, for the five (5) years immediately
preceding the year of the accident, through the present.
3 All medical records, including x-rays, CAT scans and/or MRIs (and including any
psychological profiles or reports) relating to the injuries sustained in the incident
described in the complaint.
4. All physical evidence, drawings, maps, video tapes, motion pictures, laser copies
of photographs, or other visual representations relating to the accident scene,
injuries, or any other issue in this suit.
5. All statements taken of any party to this suit which relate in any way to the
incident described in the complaint.
6 All statements taken of any non-party witness which relate in any way to the
incident described in the complaint.
7 All medical records, including x-rays, CAT scans and/or MRIs (and including any
psychological profiles or reports) in Plaintiff's possession or control regarding anyCase No.: 2017-014536 CA 01 Page 2
10.
11
12.
13.
14
15.
16.
17.
18
19.
20.
condition or treatment undergone by Plaintiff in the last ten years, not related to
the injuries sustained in the incident described in the complaint.
All bills, receipts, statements or other documents evidencing all expenses incurred
by Plaintiff in connection with the incident described in the complaint.
Any and all correspondence, memoranda, notes, or other written communications
between Plaintiff (or his counsel) and Defendant (or its insurer) relating to the
incident described in the complaint
Any and all correspondence, memoranda, notes, or other written communications
between Plaintiffs and any non-parties to this suit, relating to the incident
described in the complaint.
Any and all reports of, and written communications with, experts expected to
testify at trial of this cause.
Any and all curriculum vitae for experts expected to testify at trial of this cause
Any and all police reports, accident reports, or other reports prepared by any law
enforcement or other investigative agencies, relating to the incident described in
the complaint.
Any and all reports prepared by fire rescue, paramedics, ambulance service, or
other emergency response service.
Copy of the plaintiffs' marriage license or marriage certificate.
Any and all insurance policies, claims, agreements, reports, correspondence or
other communications with any workers' compensation carrier, including without
limitation, cancelled checks or other documents showing any payments received
from said carrier.
Any documents evidencing payments received, from any source, as a result of the
alleged injuries.
Any and all insurance policies, claims, agreements, reports, correspondence or
other communications with any insurance carrier, including without limitation
cancelled checks or other documents showing any payments received from said
carrier.
Legible copy of the front and back of Plaintiff's drivers license.
Should this lawsuit involve a trip/slip and fall incident, produce the shoes worn at
the time of the alleged incident for inspection.Case No.: 2017-014536 CA 01 Page 3
21. Copy of the return of service from the process server/court officer, showing when,
where and on whom service of the summons and complaint was made.
Defendant hereby requests the responding party to notify the office of the undersigned of
the costs to duplicate the records, prior to the actual copying of the documents.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing was sent
by Electronic Mail on this 24" day of July, 2017 to Robert W. Rodriguez, Esq., 5001 SW 74"
Court, Suite 105, Miami, FL 33155 at robertwrodriguez@gmail.com
wBrian S. Keif
BRIAN S. KEIF, ESQ.
Florida Bar #: 367281
LAW OFFICE OF HUGH BEHAN
Employees of a Member Company of
Zurich Insurance Group
Attorneys for Defendant, MET II
4000 Hollywood Boulevard, Suite 430-N
Hollywood, FL 33021
Telephone: (954) 989-8775
Facsimile: (954) 967-6536
E-Service: usz.sifti@zurichna.com
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Filing # 59442317 E-Filed 07/24/2017 06:02:35 PM IN THE CIRCUIT COURT OF THE 11™ 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, Defendants. FIRST REQUEST TO PRODUCE TO PLAINTIFF Defendant, MET II HOTEL, LLC d/b/a MARRIOT MARQUIS MIAMI, requests that Plaintiff produce the following for inspection and photocopying at the offices of undersigned counsel, pursuant to the Florida Rules of Civil Procedure: 1, All income tax returns, including all attachments, for the five (5) years immediately preceding the year of the accident, through the present. 2. All W-2 forms or other payroll receipts, for the five (5) years immediately preceding the year of the accident, through the present. 3 All medical records, including x-rays, CAT scans and/or MRIs (and including any psychological profiles or reports) relating to the injuries sustained in the incident described in the complaint. 4. All physical evidence, drawings, maps, video tapes, motion pictures, laser copies of photographs, or other visual representations relating to the accident scene, injuries, or any other issue in this suit. 5. All statements taken of any party to this suit which relate in any way to the incident described in the complaint. 6 All statements taken of any non-party witness which relate in any way to the incident described in the complaint. 7 All medical records, including x-rays, CAT scans and/or MRIs (and including any psychological profiles or reports) in Plaintiff's possession or control regarding anyCase No.: 2017-014536 CA 01 Page 2 10. 11 12. 13. 14 15. 16. 17. 18 19. 20. condition or treatment undergone by Plaintiff in the last ten years, not related to the injuries sustained in the incident described in the complaint. All bills, receipts, statements or other documents evidencing all expenses incurred by Plaintiff in connection with the incident described in the complaint. Any and all correspondence, memoranda, notes, or other written communications between Plaintiff (or his counsel) and Defendant (or its insurer) relating to the incident described in the complaint Any and all correspondence, memoranda, notes, or other written communications between Plaintiffs and any non-parties to this suit, relating to the incident described in the complaint. Any and all reports of, and written communications with, experts expected to testify at trial of this cause. Any and all curriculum vitae for experts expected to testify at trial of this cause Any and all police reports, accident reports, or other reports prepared by any law enforcement or other investigative agencies, relating to the incident described in the complaint. Any and all reports prepared by fire rescue, paramedics, ambulance service, or other emergency response service. Copy of the plaintiffs' marriage license or marriage certificate. Any and all insurance policies, claims, agreements, reports, correspondence or other communications with any workers' compensation carrier, including without limitation, cancelled checks or other documents showing any payments received from said carrier. Any documents evidencing payments received, from any source, as a result of the alleged injuries. Any and all insurance policies, claims, agreements, reports, correspondence or other communications with any insurance carrier, including without limitation cancelled checks or other documents showing any payments received from said carrier. Legible copy of the front and back of Plaintiff's drivers license. Should this lawsuit involve a trip/slip and fall incident, produce the shoes worn at the time of the alleged incident for inspection.Case No.: 2017-014536 CA 01 Page 3 21. Copy of the return of service from the process server/court officer, showing when, where and on whom service of the summons and complaint was made. Defendant hereby requests the responding party to notify the office of the undersigned of the costs to duplicate the records, prior to the actual copying of the documents. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing was sent by Electronic Mail on this 24" day of July, 2017 to Robert W. Rodriguez, Esq., 5001 SW 74" Court, Suite 105, Miami, FL 33155 at robertwrodriguez@gmail.com wBrian S. Keif BRIAN S. KEIF, ESQ. Florida Bar #: 367281 LAW OFFICE OF HUGH BEHAN Employees of a Member Company of Zurich Insurance Group Attorneys for Defendant, MET II 4000 Hollywood Boulevard, Suite 430-N Hollywood, FL 33021 Telephone: (954) 989-8775 Facsimile: (954) 967-6536 E-Service: usz.sifti@zurichna.com