Preview
Filing # 103512413 E-Filed 02/18/2020 05:45:27 PM
IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
CASE NO.: 2019-008931-CA-01 (02)
LAMAR MITCHELL,
Plaintiff,
vs.
MIAMI-DADE COUNTY and
GINLEY LAWN SERVICE &
LANDSCAPING, INC., a Florida
For Profit Corporation,
Defendants.
a
DEFENDANT, GINLEY LAWN SERVICE & LANDSCAPING, INC’S FIRST
REQUEST FOR PRODUCTION TO DEFENDANT MIAMI-DADE COUNTY
Defendant, Ginley Lawn Service & Landscaping, Inc., (“Ginley”), by and
through the undersigned counsel and pursuant to Rule 1.350 of the Florida Rule of
Civil Procedure, hereby propounds their First Request For Production to Defendant
Miami-Dade County (“Miami-Dade”) to be answered separately and fully in writing
within the time period required by law.
Respectfully submitted,
Nive M. Hiller
Niva Harney-Hiller, Esq.
Florida Bar Number: 31058
nharney@hamiltonmillerlaw.com
Reeba Hartley-Belle, Esq.
Florida Bar Number: 117036
rhartleybelle@hamiltonmillerlaw.com
Hamilton, Miller & Birthisel, LLP
150 SE 2nd Street, Suite 1200
Miami, Florida 33131
HAMILTON, MILLER & BIRTHISEL LvP
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02)
Telephone: (305) 379-3686
Facsimile: (305) 379-3690
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on February 18, 2020, the foregoing document is
being filed with the Clerk of Court using the E-filing Portal and served on all
counsel of record or pro se parties identified on the below Service List either via
transmission of Notices of Electronic Filing generated by the E-filing Portal or
in some other authorized manner for those counsel or parties who are not
authorized to receive electronically via the E-filing Portal.
Niva Harney-Hiller, Esq.
SERVICE LIST
Andres Hermida, Esq.
Florida Bar Number: 1010725
MORGAN & MORGAN, P.A.
703 Waterford Way, Suite 1050
Miami, Florida 33126
Telephone: (305) 929-1912
Facsimile: (805) 929-1930
AHermida@forthepeople.com
JJaime@forthepeople.com
Counsel for Plaintiff Lamar Mitchell
Daniel Frastai, Esq.
Florida Bar Number: 0666041
ABIGAIL PRICE-WILLIAMS
Stephen P. Clark Center
111 Northwest First Street, Suite 2810
Miami, Florida 33128-1993
Telephone: (305) 375-5480
Facsimile: (805) 375-5634
Frastai@miamidade.gov
jeane.neal@miamidade.gov
Counsel for Defendant Miami-Dade
County
HAMILTON, MILLER & BIRTHISEL LvP
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02)
Definitions
1. "Document(s)" or "written communication(s)" is used in the
broad and liberal sense and means written, typed, printed, recorded or
graphic matter, however produced or reproduced, of any kind and
description, and whether an original, master, duplicate or copy,
including, but not limited to, accounts, advertisements, agreements,
appointment books, bank checks, bills, books, books of account,
bulletins, cablegrams, cancelled checks, cashier's checks, catalogs,
charts, check stubs, communications, computer printouts, contracts,
corporate records, correspondence, desk calendars, diaries, diary
entries, drawings, e-mail, graphic records, guarantees, inter-office
communications, intra-office communications, invoices, ledger books,
letters, logs, mailgrams, magazines, manuals, marginal notes
(appearing on any document), memoranda, minutes (e.g., board of
directors, committee), models, motion pictures, notations, notebooks,
notes, offers, pamphlets, papers, photographs, physical objects, plans,
printed matter, projections, prospectuses, publications, receipts,
reports, returns, sketches, sound recordings (including, by way of
example, any type of personal or telephone conversation, meeting or
conference) specifications, statements, statistics, studies, summaries,
surveys, tape recordings, tapes, telegrams, telefaxes, teletypes,
transcriptions (including, by way of example, any type of personal or
telephone conversation, meeting or conference), transcripts, video tapes,
vouchers, warranties, working papers, worksheets; and _ all
amendments, changes, drafts, modifications of any of the foregoing, of
which you have knowledge or which are now or were formerly in your
actual or constructive possession, custody or control. The responses
concerning documents requested shall include information regarding
whether such document is an original, a duplicate, or a copy thereof.
2. "Concern," "concerning," "evidencing," "regarding,"
"reflecting," "relates," or "relates to" shall mean relating to, referring to,
connected with, commenting on, responding to, containing, evidencing,
showing, memorializing, describing, analyzing, comprising, or
constituting.
3. "You" and "your" shall refer to and include your agents,
attorneys, experts, investigators, representatives and all others,
whether past or present, who have obtained information for or on behalf
of you.
4. If a corporation, "you" and "your" shall refer to and include
any of your affiliates and subsidiaries, agents, associates, attorneys,
directors, employees, experts, independent contractors, representatives,
HAMILTON, MILLER & BIRTHISEL LvP
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORSDA 33131 - TELEPHONE: 305-379-3686 - FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02)
servants, and all others, whether past or present, who have obtained
information for or on behalf of the corporation.
5. The words "and" and "or" shall be construed conjunctively
and disjunctively as necessary to make the request inclusive rather than
exclusive.
6. "Identify," or "state the identity of":
(a) When used in reference to a natural person means to please state?
@
(2)
G))
(4)
(5)
His/her full name;
Present or last known business and residence
address;
His/her present or last known occupation and
position;
His/her present or last known employer or business
affiliation;
His/her occupation or position at the time in
question specified in the particular request.
(b) When used in reference to a "document" means to please state!
@
(2)
G))
(4)
(5)
(6)
@
A description of the type of document (e.g., letter,
memorandum, telegram, etc.);
The identity of the person or persons who authored
or prepared it;
In the case of an agreement or contract, the identity
of the parties’ signatory;
The identity of the addressee(s), if any, and the
recipient(s) of the original and a copy thereof;
The title thereof, if any, and a description of the
general nature of its subject matter;
The date of the document, or, if none, the
approximate date of its preparation;
The manner of distribution and publication, if any;
HAMILTON, MILLER & BIRTHISEL LvP
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02)
(8) The present location or custodian of the original and
each copy thereof;
(9) The identity of any persons who can identify it;
(10) Whether such documents contained, enclosed, were
attached to or accompanied by any other documents,
and if so, state the identity thereof;
(11) Ifa privilege is claimed, the specific basis therefore.
(c) In lieu of identifying a particular document when such
identification is requested, a copy of such document may, at your
option, be attached to the response to these requests; provided
that any specific information required pursuant to the foregoing
definition which is not fully set forth on the face of such copy of a
document must be separately provided in response to these
requests.
7. "Person" shall mean any natural person, firm, corporation,
partnership, joint venture or any other form of business entity.
8. Masculine pronouns shall not connote any particular
gender but shall be taken to mean masculine, feminine or neutral
gender, as the case may be.
9. "Date" shall mean the exact day, month, and year, if
ascertainable, or, if not, the best approximation thereof (including
relationship to other events).
10. “Ginley,” as used herein, shall refer to GINLEY LAWN
SERVICE & LANDSCAPING, INC., its affiliates and subsidiaries,
agents, associates, attorneys, directors, employees, experts,
independent contractors, representatives, servants, and all others,
whether past or present, who have obtained information for or on behalf
of the corporation.
11. "Incident," as used herein, shall refer to the incident which
you allege to have occurred, as is more fully set forth in your Amended
Complaint.
12. "The subject matter of this lawsuit,” as used herein, shall
refer to all facts and issues as set forth in your Amended Complaint.
HAMILTON, MILLER & BIRTHISEL LvP
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02)
13. "Medical condition," as used herein, shall refer to any
condition, including but not limited to, that for which you are making a
claim, regardless of whether it is a physical illness, disease or injury,
mental illness, disease or injury or aggravation of a preexisting
condition.
14. "Physician," as used herein, shall refer to and include
doctors, nurses, other healthcare providers and practitioners of the
healing arts.
15. “Plaintiff” refers to LAMAR MITCHELL.
16. Legal counsel includes Plaintiff's Counsel, Andres
Hermida, Esq. and the partners, associates, paralegals, secretaries,
and other employees of Morgan & Morgan, P.A.
17. “Miami-Dade” refers to MIAMI-DADE COUNTY.
18. Legal counsel includes Miami-Dade’s Counsel, Daniel
Frastai, Esq. and the partners, associates, paralegals, secretaries, and
other employees of Abigail Price-Williams.
HAMILTON, MILLER & BIRTHISEL LvP
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02)
DEFENDANT, GINLEY LAWN SERVICE & LANDSCAPING, INC’S FIRST
REQUEST FOR PRODUCTION TO DEFENDANT MIAMI-DADE COUNTY
1. Full and complete copies of any and all documents, reports, and/or materials
relating to all inspections and/or maintenance of the alleged incident area,
Miami-Dade Transit bus station located at the corner of US-1 and SW 244th
Street, Miami, Florida 33032 (“incident area”) and its surroundings from
October 15, 2017 to May 15, 2018.
RESPONSE:
2. All contracts/agreements between Miami-Dade County and Ginley Lawn
Service & Landscaping, Inc.’s and any other company, general contractor
and/or subcontractor involved in projects relating to the landscaping
maintenance, litter pick-up and removal, etc.
RESPONSE:
8. Any and all correspondence between your company and any other
person/entity involved in the landscaping maintenance, litter pick-up and
removal, etc., which relate to the subject incident.
RESPONSE:
4. Full and complete copies of any and all correspondence, including but not
limited to letters, e-mails, etc., between Miami-Dade County and Ginley Lawn
Service & Landscaping, Inc. which relate to all inspections and/or maintenance
of the alleged incident area and its surroundings from October 15, 2017 to May
15, 2018.
RESPONSE:
5. Full and complete copies of any and all correspondence, including but not
limited to letters, e-mails, etc., between Miami-Dade County and Ginley Lawn
Service & Landscaping, Inc. which relate to projects involving the removal of
large objects from October 15, 2017 to May 15, 2018.
RESPONSE:
HAMILTON, MILLER & BIRTHISEL LvP
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02)
6. Full and complete copies of any and all correspondence, including but not
limited to letters, e-mails, etc., between Miami-Dade County and Ginley Lawn
Service & Landscaping, Inc. which relate to the subject incident.
RESPONSE:
7. Full and complete copies of any and all bills, invoices, receipts, purchase
orders, documents relating to compensation, etc. between Miami-Dade County
and Ginley Lawn Service & Landscaping, Inc. which relate to projects
involving the removal of large objects from October 15, 2017 to May 15, 2018.
RESPONSE:
8. All inspection reports, including the full name and contact information of all
inspectors, who visited the incident area prior to and after Ginley Lawn Service
& Landscaping, Inc. performed their maintenance services from October 15,
2017 to May 15, 2018.
RESPONSE:
9. Any and all photographs and videos (reproduction from negatives or laser
copies, not photocopies) of all site inspections of the incident area prior to and
after Ginley Lawn Service & Landscaping, Inc. performed their maintenance
services from October 15, 2017 to May 15, 2018.
RESPONSE
10. Any and all reports, statements, or written opinions prepared by any expert(s)
retained by Miami-Dade and expected to testify at trial.
RESPONSE:
11. Any and all statements (recorded or written) taken by Miami-Dade as a result
of the incident alleged in the Plaintiffs Amended Complaint.
RESPONSE:
12.Any and all statements (recorded or written) taken by Miami-Dade in this
lawsuit, including Ginley Lawn Service & Landscaping, Inc. via its employees,
HAMILTON, MILLER & BIRTHISEL LvP
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02)
agents, or representatives, as a result of the incident alleged in the Plaintiffs
Amended Complaint.
RESPONSE:
13.Any and all statements (recorded or written) taken of any witness to the
incident alleged in the Plaintiff's Amended Complaint.
RESPONSE:
14. Any and all documents reflecting any communications sent to Ginley Lawn
Service & Landscaping, Inc., either before or after the incident complained of,
relating to the allegations raised in the Amended Complaint.
RESPONSE:
HAMILTON, MILLER & BIRTHISEL LvP
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690
Preview
Filing # 103512413 E-Filed 02/18/2020 05:45:27 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 2019-008931-CA-01 (02) LAMAR MITCHELL, Plaintiff, vs. MIAMI-DADE COUNTY and GINLEY LAWN SERVICE & LANDSCAPING, INC., a Florida For Profit Corporation, Defendants. a DEFENDANT, GINLEY LAWN SERVICE & LANDSCAPING, INC’S FIRST REQUEST FOR PRODUCTION TO DEFENDANT MIAMI-DADE COUNTY Defendant, Ginley Lawn Service & Landscaping, Inc., (“Ginley”), by and through the undersigned counsel and pursuant to Rule 1.350 of the Florida Rule of Civil Procedure, hereby propounds their First Request For Production to Defendant Miami-Dade County (“Miami-Dade”) to be answered separately and fully in writing within the time period required by law. Respectfully submitted, Nive M. Hiller Niva Harney-Hiller, Esq. Florida Bar Number: 31058 nharney@hamiltonmillerlaw.com Reeba Hartley-Belle, Esq. Florida Bar Number: 117036 rhartleybelle@hamiltonmillerlaw.com Hamilton, Miller & Birthisel, LLP 150 SE 2nd Street, Suite 1200 Miami, Florida 33131 HAMILTON, MILLER & BIRTHISEL LvP 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02) Telephone: (305) 379-3686 Facsimile: (305) 379-3690 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on February 18, 2020, the foregoing document is being filed with the Clerk of Court using the E-filing Portal and served on all counsel of record or pro se parties identified on the below Service List either via transmission of Notices of Electronic Filing generated by the E-filing Portal or in some other authorized manner for those counsel or parties who are not authorized to receive electronically via the E-filing Portal. Niva Harney-Hiller, Esq. SERVICE LIST Andres Hermida, Esq. Florida Bar Number: 1010725 MORGAN & MORGAN, P.A. 703 Waterford Way, Suite 1050 Miami, Florida 33126 Telephone: (305) 929-1912 Facsimile: (805) 929-1930 AHermida@forthepeople.com JJaime@forthepeople.com Counsel for Plaintiff Lamar Mitchell Daniel Frastai, Esq. Florida Bar Number: 0666041 ABIGAIL PRICE-WILLIAMS Stephen P. Clark Center 111 Northwest First Street, Suite 2810 Miami, Florida 33128-1993 Telephone: (305) 375-5480 Facsimile: (805) 375-5634 Frastai@miamidade.gov jeane.neal@miamidade.gov Counsel for Defendant Miami-Dade County HAMILTON, MILLER & BIRTHISEL LvP 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02) Definitions 1. "Document(s)" or "written communication(s)" is used in the broad and liberal sense and means written, typed, printed, recorded or graphic matter, however produced or reproduced, of any kind and description, and whether an original, master, duplicate or copy, including, but not limited to, accounts, advertisements, agreements, appointment books, bank checks, bills, books, books of account, bulletins, cablegrams, cancelled checks, cashier's checks, catalogs, charts, check stubs, communications, computer printouts, contracts, corporate records, correspondence, desk calendars, diaries, diary entries, drawings, e-mail, graphic records, guarantees, inter-office communications, intra-office communications, invoices, ledger books, letters, logs, mailgrams, magazines, manuals, marginal notes (appearing on any document), memoranda, minutes (e.g., board of directors, committee), models, motion pictures, notations, notebooks, notes, offers, pamphlets, papers, photographs, physical objects, plans, printed matter, projections, prospectuses, publications, receipts, reports, returns, sketches, sound recordings (including, by way of example, any type of personal or telephone conversation, meeting or conference) specifications, statements, statistics, studies, summaries, surveys, tape recordings, tapes, telegrams, telefaxes, teletypes, transcriptions (including, by way of example, any type of personal or telephone conversation, meeting or conference), transcripts, video tapes, vouchers, warranties, working papers, worksheets; and _ all amendments, changes, drafts, modifications of any of the foregoing, of which you have knowledge or which are now or were formerly in your actual or constructive possession, custody or control. The responses concerning documents requested shall include information regarding whether such document is an original, a duplicate, or a copy thereof. 2. "Concern," "concerning," "evidencing," "regarding," "reflecting," "relates," or "relates to" shall mean relating to, referring to, connected with, commenting on, responding to, containing, evidencing, showing, memorializing, describing, analyzing, comprising, or constituting. 3. "You" and "your" shall refer to and include your agents, attorneys, experts, investigators, representatives and all others, whether past or present, who have obtained information for or on behalf of you. 4. If a corporation, "you" and "your" shall refer to and include any of your affiliates and subsidiaries, agents, associates, attorneys, directors, employees, experts, independent contractors, representatives, HAMILTON, MILLER & BIRTHISEL LvP 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORSDA 33131 - TELEPHONE: 305-379-3686 - FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02) servants, and all others, whether past or present, who have obtained information for or on behalf of the corporation. 5. The words "and" and "or" shall be construed conjunctively and disjunctively as necessary to make the request inclusive rather than exclusive. 6. "Identify," or "state the identity of": (a) When used in reference to a natural person means to please state? @ (2) G)) (4) (5) His/her full name; Present or last known business and residence address; His/her present or last known occupation and position; His/her present or last known employer or business affiliation; His/her occupation or position at the time in question specified in the particular request. (b) When used in reference to a "document" means to please state! @ (2) G)) (4) (5) (6) @ A description of the type of document (e.g., letter, memorandum, telegram, etc.); The identity of the person or persons who authored or prepared it; In the case of an agreement or contract, the identity of the parties’ signatory; The identity of the addressee(s), if any, and the recipient(s) of the original and a copy thereof; The title thereof, if any, and a description of the general nature of its subject matter; The date of the document, or, if none, the approximate date of its preparation; The manner of distribution and publication, if any; HAMILTON, MILLER & BIRTHISEL LvP 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02) (8) The present location or custodian of the original and each copy thereof; (9) The identity of any persons who can identify it; (10) Whether such documents contained, enclosed, were attached to or accompanied by any other documents, and if so, state the identity thereof; (11) Ifa privilege is claimed, the specific basis therefore. (c) In lieu of identifying a particular document when such identification is requested, a copy of such document may, at your option, be attached to the response to these requests; provided that any specific information required pursuant to the foregoing definition which is not fully set forth on the face of such copy of a document must be separately provided in response to these requests. 7. "Person" shall mean any natural person, firm, corporation, partnership, joint venture or any other form of business entity. 8. Masculine pronouns shall not connote any particular gender but shall be taken to mean masculine, feminine or neutral gender, as the case may be. 9. "Date" shall mean the exact day, month, and year, if ascertainable, or, if not, the best approximation thereof (including relationship to other events). 10. “Ginley,” as used herein, shall refer to GINLEY LAWN SERVICE & LANDSCAPING, INC., its affiliates and subsidiaries, agents, associates, attorneys, directors, employees, experts, independent contractors, representatives, servants, and all others, whether past or present, who have obtained information for or on behalf of the corporation. 11. "Incident," as used herein, shall refer to the incident which you allege to have occurred, as is more fully set forth in your Amended Complaint. 12. "The subject matter of this lawsuit,” as used herein, shall refer to all facts and issues as set forth in your Amended Complaint. HAMILTON, MILLER & BIRTHISEL LvP 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02) 13. "Medical condition," as used herein, shall refer to any condition, including but not limited to, that for which you are making a claim, regardless of whether it is a physical illness, disease or injury, mental illness, disease or injury or aggravation of a preexisting condition. 14. "Physician," as used herein, shall refer to and include doctors, nurses, other healthcare providers and practitioners of the healing arts. 15. “Plaintiff” refers to LAMAR MITCHELL. 16. Legal counsel includes Plaintiff's Counsel, Andres Hermida, Esq. and the partners, associates, paralegals, secretaries, and other employees of Morgan & Morgan, P.A. 17. “Miami-Dade” refers to MIAMI-DADE COUNTY. 18. Legal counsel includes Miami-Dade’s Counsel, Daniel Frastai, Esq. and the partners, associates, paralegals, secretaries, and other employees of Abigail Price-Williams. HAMILTON, MILLER & BIRTHISEL LvP 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02) DEFENDANT, GINLEY LAWN SERVICE & LANDSCAPING, INC’S FIRST REQUEST FOR PRODUCTION TO DEFENDANT MIAMI-DADE COUNTY 1. Full and complete copies of any and all documents, reports, and/or materials relating to all inspections and/or maintenance of the alleged incident area, Miami-Dade Transit bus station located at the corner of US-1 and SW 244th Street, Miami, Florida 33032 (“incident area”) and its surroundings from October 15, 2017 to May 15, 2018. RESPONSE: 2. All contracts/agreements between Miami-Dade County and Ginley Lawn Service & Landscaping, Inc.’s and any other company, general contractor and/or subcontractor involved in projects relating to the landscaping maintenance, litter pick-up and removal, etc. RESPONSE: 8. Any and all correspondence between your company and any other person/entity involved in the landscaping maintenance, litter pick-up and removal, etc., which relate to the subject incident. RESPONSE: 4. Full and complete copies of any and all correspondence, including but not limited to letters, e-mails, etc., between Miami-Dade County and Ginley Lawn Service & Landscaping, Inc. which relate to all inspections and/or maintenance of the alleged incident area and its surroundings from October 15, 2017 to May 15, 2018. RESPONSE: 5. Full and complete copies of any and all correspondence, including but not limited to letters, e-mails, etc., between Miami-Dade County and Ginley Lawn Service & Landscaping, Inc. which relate to projects involving the removal of large objects from October 15, 2017 to May 15, 2018. RESPONSE: HAMILTON, MILLER & BIRTHISEL LvP 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02) 6. Full and complete copies of any and all correspondence, including but not limited to letters, e-mails, etc., between Miami-Dade County and Ginley Lawn Service & Landscaping, Inc. which relate to the subject incident. RESPONSE: 7. Full and complete copies of any and all bills, invoices, receipts, purchase orders, documents relating to compensation, etc. between Miami-Dade County and Ginley Lawn Service & Landscaping, Inc. which relate to projects involving the removal of large objects from October 15, 2017 to May 15, 2018. RESPONSE: 8. All inspection reports, including the full name and contact information of all inspectors, who visited the incident area prior to and after Ginley Lawn Service & Landscaping, Inc. performed their maintenance services from October 15, 2017 to May 15, 2018. RESPONSE: 9. Any and all photographs and videos (reproduction from negatives or laser copies, not photocopies) of all site inspections of the incident area prior to and after Ginley Lawn Service & Landscaping, Inc. performed their maintenance services from October 15, 2017 to May 15, 2018. RESPONSE 10. Any and all reports, statements, or written opinions prepared by any expert(s) retained by Miami-Dade and expected to testify at trial. RESPONSE: 11. Any and all statements (recorded or written) taken by Miami-Dade as a result of the incident alleged in the Plaintiffs Amended Complaint. RESPONSE: 12.Any and all statements (recorded or written) taken by Miami-Dade in this lawsuit, including Ginley Lawn Service & Landscaping, Inc. via its employees, HAMILTON, MILLER & BIRTHISEL LvP 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690CASE NO.: 2019-008931-CA-01 (02) agents, or representatives, as a result of the incident alleged in the Plaintiffs Amended Complaint. RESPONSE: 13.Any and all statements (recorded or written) taken of any witness to the incident alleged in the Plaintiff's Amended Complaint. RESPONSE: 14. Any and all documents reflecting any communications sent to Ginley Lawn Service & Landscaping, Inc., either before or after the incident complained of, relating to the allegations raised in the Amended Complaint. RESPONSE: HAMILTON, MILLER & BIRTHISEL LvP 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 - TELEPHONE: 305-379-3686 » FACSIMILE: 305-379-3690