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Filing # 78691010 E-Filed 10/01/2018 05:13:03 PM
IN THE CIRCUIT CQURT OF THE
TTH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO. 17-014926 CA 01 (37)
XIOMARA LLERENA AND
ROBERTO LLERENA ,
Plaintiffs,
vs.
QUINTANA FAMILY DAY CARE HOME
D/B/A LEARNING AND GROWING FAMILY
CHILD CARE,
Defendant.
e
ia nernenrrreenoneenoimnicath
DEFENDANT'S EXPERT REQUEST TO PRODUCE
Defendant, Quintana Family Day Care Home D/B/A Learning and Growing Family
Child Care, pursuant to Florida Rule of Civil Procedure 1.350, requests that Plaintiffs, Xiomara
Llerena and Roberto Lierena, produce and permit Defendant to inspect and photograph the
following:
Instructions: The iterns below are directed to any and all experts retained pursuant to
Rule 1.280(b). In accordance with Florida Rules of Civil Procedure 1.280(b), 1.350(a) and 1.390,
a party is said to be in constructive possession of items in the possession of their experts.
Such production is required by said rules without the need for issuance of a subpoena duces
tecum.V
12.
3.
Items to be produced within 30 days by retained experts:
Your entire file, excluding any items that you claim to be work product. Please
bring any work product materials from your files to the deposition.
Any and all materials you reviewed in this matter, including, but not lirnited to,
depositions, correspondence, photographs, reports, books, articles, literature,
films, tests, experiments, statements, results of inspections of vehicles,
drawings, blueprints, or other reference materials that you used or are relying
on.
Any and ail reports you prepared or furnished in this case.
Any and all reoorts which were furnished to you by other experts in this case.
Your curriculum vitae.
Any and all test results and/or experiments you conducted in this case.
Any and all photographs which were taken by you, your agents, servants or
employees.
Any and all films taken by you, your servants, agents or employees.
Any and all videotapes taken by you, your servants, agents or employees.
Your complete billing file in this case, including, but not limited to, the charges
you have rendered, the statements that you have rendered, the time spent on
this case, and other relevant materials concerning the time and billings on this
case.
Any and ail notes, writings, memoranda, etc., which you have prepared on this
case,
Any and all cornputer printouts from computers used by you or your agents,
servants or employees.
Any and all notes taken or prepared and calculations performed by you or
your agents, servants or employees which were prepared for this case.15.
16.
17,
18.
19.
20.
21
22.
Any materials you intend to use at trial to impeach the parties, their witnesses
Acken, 865 So.2d 1267 (Fla. 2004).
Copies of any and all impeachment materials, including but limited to, prior
depositions, trial transcripts, or other sworn testimony, articles, textbooks, or
other writings, or any other impeachment material not listed above,
concerning Defendants’ expert witnesses that you intend to use at deposition
and/or trial.
For the last 5 years, a list of cases (or any document which would identify the
case name) in which you have been retained by the Plaintiff's counsei or his
law firm
For the last 5 years, a list of cases (or any document which would identify the
case name) in which you have been paid for a conference with the Plaintiff's
counsel or his law firm.
For the last 5 years, a list of cases (or any document which would identify the
case name) in which you have been paid by Plaintiffs counsel for a deposition
or trial testimony.
For the last 5 years, a copy of any correspondence to or from plainti#’s counsel
on any cases, redacting only information privileged by HIPPA.
For the last 5 years, a list cases (or any document which would identify the
amounts) of incorne received by the Plaintiff's counsel.
Any documents evidence incarne you have made on iitigation cases for the
last 5 years.
A copy of any and all reports or updated reports prepared for the Plaintiff by
Plaintiff's experts, including but not limited to the following:
a Any and all reports (preliminary, final or otherwise),
rough drafts, work sheets and materials in any manner connected with
the opinions or conclusions reached concerning the subject matter of
his/her expert opinion.
b. Any and all materials considered, consulted, and used as
a basis or predicate for opinions and conclusions, including but notlimited to, published articles, data or documents furnished by the party
engaging services.
c. All cornputations, calculations and formulas considered,
utilized, produced or in any manner connected with opinions or
conclusions.
It is hereby requested that the aforesaid production of copies be made and sent to
the offices of LUKS, SANTANIELLO, PETRILLO & JONES. If plaintiff offers to make such
documents available for inspection only, it is hereby requested that copies be provided to
undersigned counsel and we will reimburse all reasonable or actual charges associated with
said copies.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via Electronic Mail, to all counsel of record on the attached Service List, this 1 day of
October, 2078.
LUKS, SANTANIELLO, PETRILLO & JONES
Attorneys for Defendant
150 W. Flagler Street
Suite 2600
Miami, FL 33130
Telephone: (305) 377-8900
Facsimile: (305) 377-8901
By:___/s’ Heather
DANIEL J. SANT,
Florida Bar No.: 860948
HEATHER M, CALHOON
Florida Bar No.: 495573
LUKSMIA-Pleadings@LS-Law.comMichael J. Carmona, Esq
Friedland Law Group
1430 South Dixie Highway
Suite 305
Coral Gables, FL 33746
email@friedlandlawgroup.com
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Filing # 78691010 E-Filed 10/01/2018 05:13:03 PM IN THE CIRCUIT CQURT OF THE TTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO. 17-014926 CA 01 (37) XIOMARA LLERENA AND ROBERTO LLERENA , Plaintiffs, vs. QUINTANA FAMILY DAY CARE HOME D/B/A LEARNING AND GROWING FAMILY CHILD CARE, Defendant. e ia nernenrrreenoneenoimnicath DEFENDANT'S EXPERT REQUEST TO PRODUCE Defendant, Quintana Family Day Care Home D/B/A Learning and Growing Family Child Care, pursuant to Florida Rule of Civil Procedure 1.350, requests that Plaintiffs, Xiomara Llerena and Roberto Lierena, produce and permit Defendant to inspect and photograph the following: Instructions: The iterns below are directed to any and all experts retained pursuant to Rule 1.280(b). In accordance with Florida Rules of Civil Procedure 1.280(b), 1.350(a) and 1.390, a party is said to be in constructive possession of items in the possession of their experts. Such production is required by said rules without the need for issuance of a subpoena duces tecum.V 12. 3. Items to be produced within 30 days by retained experts: Your entire file, excluding any items that you claim to be work product. Please bring any work product materials from your files to the deposition. Any and all materials you reviewed in this matter, including, but not lirnited to, depositions, correspondence, photographs, reports, books, articles, literature, films, tests, experiments, statements, results of inspections of vehicles, drawings, blueprints, or other reference materials that you used or are relying on. Any and ail reports you prepared or furnished in this case. Any and all reoorts which were furnished to you by other experts in this case. Your curriculum vitae. Any and all test results and/or experiments you conducted in this case. Any and all photographs which were taken by you, your agents, servants or employees. Any and all films taken by you, your servants, agents or employees. Any and all videotapes taken by you, your servants, agents or employees. Your complete billing file in this case, including, but not limited to, the charges you have rendered, the statements that you have rendered, the time spent on this case, and other relevant materials concerning the time and billings on this case. Any and ail notes, writings, memoranda, etc., which you have prepared on this case, Any and all cornputer printouts from computers used by you or your agents, servants or employees. Any and all notes taken or prepared and calculations performed by you or your agents, servants or employees which were prepared for this case.15. 16. 17, 18. 19. 20. 21 22. Any materials you intend to use at trial to impeach the parties, their witnesses Acken, 865 So.2d 1267 (Fla. 2004). Copies of any and all impeachment materials, including but limited to, prior depositions, trial transcripts, or other sworn testimony, articles, textbooks, or other writings, or any other impeachment material not listed above, concerning Defendants’ expert witnesses that you intend to use at deposition and/or trial. For the last 5 years, a list of cases (or any document which would identify the case name) in which you have been retained by the Plaintiff's counsei or his law firm For the last 5 years, a list of cases (or any document which would identify the case name) in which you have been paid for a conference with the Plaintiff's counsel or his law firm. For the last 5 years, a list of cases (or any document which would identify the case name) in which you have been paid by Plaintiffs counsel for a deposition or trial testimony. For the last 5 years, a copy of any correspondence to or from plainti#’s counsel on any cases, redacting only information privileged by HIPPA. For the last 5 years, a list cases (or any document which would identify the amounts) of incorne received by the Plaintiff's counsel. Any documents evidence incarne you have made on iitigation cases for the last 5 years. A copy of any and all reports or updated reports prepared for the Plaintiff by Plaintiff's experts, including but not limited to the following: a Any and all reports (preliminary, final or otherwise), rough drafts, work sheets and materials in any manner connected with the opinions or conclusions reached concerning the subject matter of his/her expert opinion. b. Any and all materials considered, consulted, and used as a basis or predicate for opinions and conclusions, including but notlimited to, published articles, data or documents furnished by the party engaging services. c. All cornputations, calculations and formulas considered, utilized, produced or in any manner connected with opinions or conclusions. It is hereby requested that the aforesaid production of copies be made and sent to the offices of LUKS, SANTANIELLO, PETRILLO & JONES. If plaintiff offers to make such documents available for inspection only, it is hereby requested that copies be provided to undersigned counsel and we will reimburse all reasonable or actual charges associated with said copies.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Electronic Mail, to all counsel of record on the attached Service List, this 1 day of October, 2078. LUKS, SANTANIELLO, PETRILLO & JONES Attorneys for Defendant 150 W. Flagler Street Suite 2600 Miami, FL 33130 Telephone: (305) 377-8900 Facsimile: (305) 377-8901 By:___/s’ Heather DANIEL J. SANT, Florida Bar No.: 860948 HEATHER M, CALHOON Florida Bar No.: 495573 LUKSMIA-Pleadings@LS-Law.comMichael J. Carmona, Esq Friedland Law Group 1430 South Dixie Highway Suite 305 Coral Gables, FL 33746 email@friedlandlawgroup.com