On July 13, 2017 a
Party Discovery
was filed
involving a dispute between
Galway Bay Mobile Homeowners Association, Inc.,
and
Biza Corp. D B A Galway Bay Mobile Home Park,
for Other - Matters not falling within the other Civil Subcatego
in the District Court of Monroe County.
Preview
Filing #128321973 E-Filed 06/08/2021 01:43:37 PM
IN THE CIRCUIT COURT IN AND FOR MONROE COUNTY, FLORIDA
GALWAY BAY MOBILE HOMEOWNERS
ASSOCIATION, INC., GENERAL JURISDICTION DIVISION
Plaintiff, CASE NO.: 17- CA-00166-M
vs.
BIZA, CORP, d/b/a GALWAY BAY MOBILE
HOME PARK,
Defendant.
PLAINTIFF’S RESPONSE TO DEFENDA: 'S’ FIRST EXPERT RE UEST FOR
PRODUCTION OF DOCUMENTS TO PLAINTIFF, GALWAY BAY MOBILE
HOMEOWNERS’ ASSOCIATION, INC.
Plaintiff, GALWAY BAY MOBILE HOMEOWNERS’ ASSOCIATION, INC. (‘Plaintiff
HOA”), serves its Response to Defendant’s Expert Request for Production to Plaintiff.
Response:
Produced — Report is all inclusive of everything.
Produced — Report is all inclusive of everything.
Produced — Report is all inclusive of everything.
Produced — Report is all inclusive of everything
Produced — Report is all inclusive of everything.
Produced — Report is all inclusive of everything.
Produced — Report is all inclusive of everything.
Produced — Report is all inclusive of everything.
Produced — Report is all inclusive of everything.
10. None. Expert has not relied upon or reviewed any articles or literature.
6/8/2021 1:43 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 1
11 Produced — Integra Realty Resources — Miami | Caribbean and contact information is listed in
Report.
12 Produced — Curriculum Vitae lists this information.
13 Produced — Curriculum Vitae lists this information.
14 None. Expert has not received transcripts from prior deposition testimony or trial testimony.
15, None. Expert does not advertise, nor has brochures no advertisements.
16. None. Expert has not been listed as a defendant in any civil or criminal proceeding.
17. None. Expert was contracted on a pro-bono basis and there not an engagement letter or service
agreement prepared.
18 Produced- 2018 and 2019 Report.
19. Produced.
20. Produced — Report is all inclusive of everything.
21 Produced - Curriculum Vitae lists this information.
22 None. Expert was contracted on a pro-bono basis and there was no billing file kept.
23 Produced — 2018 and 2019 Report.
Respectfully submitted,
LEGAL SERVICES OF GREATER MIAMI, INC.
By: /s/ Davalyn Suarez
Davalyn Suarez, Esq.
Florida Bar No. 1015563
Attorney for Plaintiff
4343 West Flagler Street, Suite 100
Miami, Florida 33134
Telephone: (305) 438-2552
Facsimile: (305) 438-2552
E-mail: dsuarez@legalservicesmiami.org
Page 2 of3
6/8/2021 1:43 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 2
Secondary: pleadings@legalservicesmiami.org
Secondary: crodriguez@legalservicesmiami.org
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via Notice of
Electronic Filing on June 7, 2021, to Brett Lieberman Esq., Attorneys for Plaintiff at
bri ett@elrolaw.com.
By: /s/ Davalyn Suarez
Davalyn Suarez, Esq.
Florida Bar No. 1015563
Page 3 of3
6/8/2021 1:43 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 3
Document Filed Date
June 08, 2021
Case Filing Date
July 13, 2017
Category
Other - Matters not falling within the other Civil Subcatego
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Filing #128321973 E-Filed 06/08/2021 01:43:37 PM IN THE CIRCUIT COURT IN AND FOR MONROE COUNTY, FLORIDA GALWAY BAY MOBILE HOMEOWNERS ASSOCIATION, INC., GENERAL JURISDICTION DIVISION Plaintiff, CASE NO.: 17- CA-00166-M vs. BIZA, CORP, d/b/a GALWAY BAY MOBILE HOME PARK, Defendant. PLAINTIFF’S RESPONSE TO DEFENDA: 'S’ FIRST EXPERT RE UEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF, GALWAY BAY MOBILE HOMEOWNERS’ ASSOCIATION, INC. Plaintiff, GALWAY BAY MOBILE HOMEOWNERS’ ASSOCIATION, INC. (‘Plaintiff HOA”), serves its Response to Defendant’s Expert Request for Production to Plaintiff. Response: Produced — Report is all inclusive of everything. Produced — Report is all inclusive of everything. Produced — Report is all inclusive of everything. Produced — Report is all inclusive of everything Produced — Report is all inclusive of everything. Produced — Report is all inclusive of everything. Produced — Report is all inclusive of everything. Produced — Report is all inclusive of everything. Produced — Report is all inclusive of everything. 10. None. Expert has not relied upon or reviewed any articles or literature. 6/8/2021 1:43 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 1 11 Produced — Integra Realty Resources — Miami | Caribbean and contact information is listed in Report. 12 Produced — Curriculum Vitae lists this information. 13 Produced — Curriculum Vitae lists this information. 14 None. Expert has not received transcripts from prior deposition testimony or trial testimony. 15, None. Expert does not advertise, nor has brochures no advertisements. 16. None. Expert has not been listed as a defendant in any civil or criminal proceeding. 17. None. Expert was contracted on a pro-bono basis and there not an engagement letter or service agreement prepared. 18 Produced- 2018 and 2019 Report. 19. Produced. 20. Produced — Report is all inclusive of everything. 21 Produced - Curriculum Vitae lists this information. 22 None. Expert was contracted on a pro-bono basis and there was no billing file kept. 23 Produced — 2018 and 2019 Report. Respectfully submitted, LEGAL SERVICES OF GREATER MIAMI, INC. By: /s/ Davalyn Suarez Davalyn Suarez, Esq. Florida Bar No. 1015563 Attorney for Plaintiff 4343 West Flagler Street, Suite 100 Miami, Florida 33134 Telephone: (305) 438-2552 Facsimile: (305) 438-2552 E-mail: dsuarez@legalservicesmiami.org Page 2 of3 6/8/2021 1:43 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 2 Secondary: pleadings@legalservicesmiami.org Secondary: crodriguez@legalservicesmiami.org CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via Notice of Electronic Filing on June 7, 2021, to Brett Lieberman Esq., Attorneys for Plaintiff at bri ett@elrolaw.com. By: /s/ Davalyn Suarez Davalyn Suarez, Esq. Florida Bar No. 1015563 Page 3 of3 6/8/2021 1:43 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 3