Party Discovery: SRA Tamarac Medical Plaza LLC Plaintiff vs. Rosel RX Inc, et al Defendant

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                                Electronically Filed 09/25/2013 05:22:10 PM ET

IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY FLORIDA
SRA/TAMARAC MEDICAL PLAZA, LLC
CIVIL DIVISION
Plaintiff,
CASE NO.: 12-32198 CACE 13

FLA BAR NO.: 825778

ROSEL RX, INC. aka ROSEL RX, INC.,
and ERNESTO GARCIA,

Defendants.
/

NOTICE OF FILING UNEXECUTED ANSWER TO
SECOND INTERROGATORIES TO ROSEL RX, INC.

Defendants, ROSEL RX, INC. a/k/a ROSEL RX, INC. and ERNESTO GARCIA, by

 

and through the undersigned attorney, hereby notifies the Court of the filing of the attached
Answers to Interrogatories of ROSEL RX, INC. in the above-styled case.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via electronic mail & U.S. Mail this 25Yay of September, 2013 to: Alex P.

Rosenthal, Esq., Rosenthal Law Group, Weston Professional Centre, 2115 North Commerce
Parkway, Weston, Florida 33326, and email to: alex@rosenthalcounsel.com.

*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/25/2013 5:22:10 PM.****

 

NOTE: Pursuant to Fla.R.Jud.Admin. 2.516(b)(1)(A), Defendant’s counsel hereby
designates his primary email address for the purposes of email service as:
“efiling@gastesi.com”.

GASTESI & ASSOCIATES, P.A.
8105 N.W. 155th Street

Miami Lakes, FL 33016

Tel: 305-818-9993

   

GASTESI & ASSOCIATES, P.A.

8105 N.W. 158™ STREET, MIAMI LAKES, FLORIDA 33014 TEL: 305-818-9993 FAX: 305-818-9997 EMAIL: rgustesi@gastesi.comANSWERS TO SECOND INTERROGATORIES TO ROSEL RX, INC.

Emesto Garcia. President.
12220 S.W. 38" Street
Miami, Florida 33178.

Objection. It would be overly burdensome to have to set forth each and every fact
at this early stage of the litigation as to why the requests were denied. Discovery
is in its initial stages and there is still pending a Motion to Dismiss. Without
waiving the objection, Ernesto Garcia was not aware as to the exact legal name of
the landlord. The negotiations were principally with his daughter, Aymee, and
Manuel Espino. The requests were denied for a varity of reasons. The names of
the entities are extremely similar. The Plaintiff in this very litigation would not
agree during the hearing on the Motion to Dismiss that there were errors.
Therefore Ernesto Garcia cannot possibly now admit those requests are true.INTERROGATORIES

 

1. What is the name and address of the person answering these interrogatories, and,
if applicable, the person's official position or relationship with the parties to whom the
interrogatories are directed?

PLEASE SEE ATTACHED

2. If you denied any of Plaintiff's First Request for Admissions, state the factual basis
for each and every denial. Identify all persons who have knowledge of these facts; provide a
detailed summary of the substance of each listed person’s knowledge of these facts; and identify
all documents that support this response.

PLEASE SEE ATTACHED