On February 26, 2016 a
Request,Application
was filed
involving a dispute between
Garcia, Rolando Orama,
Lugo, Ali Isabel Casanola,
Myrtil, Marie,
Myrtil, Serge,
and
Garcia, Rolando Orama,
Lugo, Ali Isabel Casanola,
Gotham Insurance Company,
Mekka Miami Group Corp,
for Auto Negligence
in the District Court of Miami-Dade County.
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Filing # 55301224 E-Filed 04/19/2017 01:57:11 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: 2016-4811 CA 06
SERGE MYRTIL & MARIE MYRTIL,
his wife,
Plaintiffs,
vs.
ROLANDO ORAMA GARCIA, ALI
ISABEL CASANOLA LUGO, and
MEKKA MIAMI GROUP CORP,
Defendants.
/
PLAINTIFFS’ SECOND RE! UEST FOR PRODUCTION TO DEFENDANT.
MEKKA MIAMI GROUP CORP
Plaintiffs, SERGE MYRTIL & MARIE MYRTIL, his wife, pursuant to Florida Rule of
Civil Procedure 1.350, propound the following requests to produce
1 Copies of records and documents evidencing alcohol sales for January 31, 2015, through
February 1, 2015.
Copies of all bottle menus for Club Mekka on January 31, 2015, through February 1,
2015
Copies of all menus for Club Mekka on January 31, 2015, through February 1, 2015
Betich & Bhankerg, FX.
SEW WORLG TOWER + 160 Mf, RISTAYRE SOMLEVAREL QUITE DMM « MIAME, FLOBIDA M4552 « TEL (406) HEN-6323
Copies of contracts and agreements related to the ATM machines on the premises at Club
Mekka on January 31, 2015, through February 1, 2015
Copies of all photographs and videos depicting the layout of Club Mekka as it would
have appeared on January 31, 2015, through February 1, 2015
Copies of all records and documents evidencing tips collected for employees working at
the subject club on January 31, 2015, through February 1, 2015.
Copies of all records and documents related to transactions made at the ATM machines
located on the subject premises on January 31, 2015, through February 1, 2015
Copies of all incident reports during the three years prior to February 1, 2015, related to
underage drinking and/or intoxication at the subject premises.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been served by eservice/email on
this 19th day of April, 2017 via eservice to: Wayne Hrivnak, Esq., counsel for Defendants, and
REGINALD J. CLYNE, ESQ. and FLORENCE M. RUBIO, ESQ., counsel for MEKKA MIAMI
GROUP CORP.
DEUTSCH & BLUMBERG, P.A.
Attorneys for Plaintiff
New World Tower, Suite 2802
100 North Biscayne Boulevard
Miami, Florida 33132
(305) 358-6329
(305) 358-9304 (fax)
ccaballero@deutschblumber: it
By: s/ Cosme Caballero
COSME CABALLERO, ESQ.
Florida Bar No. 90937
Betich & Bhankerg, FX.
SEW WORLG TOWER + 160 Mf, RISTAYRE SOMLEVAREL QUITE DMM « MIAME, FLOBIDA M4552 « TEL (406) HEN-6323
Preview
Filing # 55301224 E-Filed 04/19/2017 01:57:11 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 2016-4811 CA 06 SERGE MYRTIL & MARIE MYRTIL, his wife, Plaintiffs, vs. ROLANDO ORAMA GARCIA, ALI ISABEL CASANOLA LUGO, and MEKKA MIAMI GROUP CORP, Defendants. / PLAINTIFFS’ SECOND RE! UEST FOR PRODUCTION TO DEFENDANT. MEKKA MIAMI GROUP CORP Plaintiffs, SERGE MYRTIL & MARIE MYRTIL, his wife, pursuant to Florida Rule of Civil Procedure 1.350, propound the following requests to produce 1 Copies of records and documents evidencing alcohol sales for January 31, 2015, through February 1, 2015. Copies of all bottle menus for Club Mekka on January 31, 2015, through February 1, 2015 Copies of all menus for Club Mekka on January 31, 2015, through February 1, 2015 Betich & Bhankerg, FX. SEW WORLG TOWER + 160 Mf, RISTAYRE SOMLEVAREL QUITE DMM « MIAME, FLOBIDA M4552 « TEL (406) HEN-6323 Copies of contracts and agreements related to the ATM machines on the premises at Club Mekka on January 31, 2015, through February 1, 2015 Copies of all photographs and videos depicting the layout of Club Mekka as it would have appeared on January 31, 2015, through February 1, 2015 Copies of all records and documents evidencing tips collected for employees working at the subject club on January 31, 2015, through February 1, 2015. Copies of all records and documents related to transactions made at the ATM machines located on the subject premises on January 31, 2015, through February 1, 2015 Copies of all incident reports during the three years prior to February 1, 2015, related to underage drinking and/or intoxication at the subject premises. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been served by eservice/email on this 19th day of April, 2017 via eservice to: Wayne Hrivnak, Esq., counsel for Defendants, and REGINALD J. CLYNE, ESQ. and FLORENCE M. RUBIO, ESQ., counsel for MEKKA MIAMI GROUP CORP. DEUTSCH & BLUMBERG, P.A. Attorneys for Plaintiff New World Tower, Suite 2802 100 North Biscayne Boulevard Miami, Florida 33132 (305) 358-6329 (305) 358-9304 (fax) ccaballero@deutschblumber: it By: s/ Cosme Caballero COSME CABALLERO, ESQ. Florida Bar No. 90937 Betich & Bhankerg, FX. SEW WORLG TOWER + 160 Mf, RISTAYRE SOMLEVAREL QUITE DMM « MIAME, FLOBIDA M4552 « TEL (406) HEN-6323