IN THE CIRCUIT COURT OF THE 11TH

JUDICIAL CIRCUIT IN AND FOR MIAMIDADE COUNTY, FLORIDA

GENERAL JURISDICTION DIVISION
CASE NO. 09-60318 CA 05
RAFAEL HUGUET, JR., individually,
RH DESIGN & ASSOCIATES, INC.,
a Florida Corporation; and GRANADA
TOWERS, LLC, a Florida Limited
Liability Corporation
Plaintiffs,
vs.
MIAMI- DADE COUNTY,
Defendant.
__________________________________/
DEFENDANT MIAMI-DADE COUNTYS
FIRST SET OF INTERROGATORIES TO GRANADA TOWERS, LLC
Pursuant to Rules 1.280 and 1.340 of the Florida Rules of Civil Procedure, Defendant
Miami-Dade County (the County), by and through its undersigned counsel, propounds the
attached First Set of Interrogatories to Granada Towers, LLC (Granada) to be answered in
writing and under oath in the form and manner prescribed by the Florida Rules of Civil
Procedure.
Respectfully submitted,
R. A. Cuevas, Jr.
MIAMI-DADE COUNTY ATTORNEY
By: ____________

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the First Set of Interrogatories has
been mailed this 18th day of March, 2010 to: ROBERT H. FERNANDEZ, P.A., 500 S. Dixie
Highway, Suite 302, Coral Gables, FL 33146, Tel: 305-503-2990

_______________________________

DEFINITIONS
For purposes of these Interrogatories, the following definitions apply:
1. The term you, your, or Plaintiff refers to Granada.
2. The term County or Defendant refers to Miami-Dade County.
3. The term Complaint refers to your Second Amended Complaint.
4. Capitalized terms not defined here shall have the same meaning as those terms have in the
Complaint.
5. The phrase describe in detail means to recite the information in your possession for each
separate and distinct act, instance, occurrence, or communication, including the date, location
and identity of each and every person present or involved and the identity of each and every
communication and each and every document which relates to the act, instance, occurrence
or communication.
6. The term document means the original and any copy whether different from the original by
reason of any notation made on such copies or otherwise, regardless of the origin or location,
of any written, recorded, transcribed, taped, filed or graphic matter, however produced or
reproduced, including but not limited to any correspondence, telegram, book, letter,
memorandum, notes, diaries, statistics, minutes, contracts, studies, checks, statements,
receipts, returns, summaries, pamphlets, prospectuses, interoffice and intraoffice telephone
calls, meetings or other communications, bulletins, printed matter, computer printouts,

teletypes, telefax, invoices, worksheets (and all drafts, alterations, modifications or changes
to any of the foregoing); graphic and oral records or representations of any kind, including
without limitation, photographs, charts, graphs, microfiche, microfilm, video tape recordings,
motion pictures, electronic, mechanical, or electrical records or representations of any kind,
including without limitation, tapes, cassettes, discs and recordings.
7. The term all documents means any document as above defined known to you and every
such document which can be located or discovered by reasonably diligent efforts.
8. The term communication means any oral or written utterance, notation or statement of any
nature whatsoever, by and to whomsoever made, including but not limited to correspondence,
conversations, dialogues, discussions, interviews, meetings, consultations, agreements, and
other understandings between or among two or more people.
9. The term identify or identity when used in reference to:
a. A natural individual, means to state his or her full name, title, residential and business
addresses, and telephone numbers;
b. A corporation, means to state its full corporate name and any names under which it does
business, state of incorporation, the address of its principal place of business, and the
address of all its officers in Florida;
c. A business, means to state the full name or style under which the business is conducted,
its business address or addresses, the types of businesses in which it is engaged, the
geographic areas in which it conducts those businesses, and the identity of the person or
persons who own, operate and control the business;
d. A document, means to state the number of pages and the nature of the document (e.g.,
letter or memorandum), its title, date, the name or names of its author(s) and recipient(s)
and its present location and custodian(s);

e. A communication, if any part of the communication is written, means to identify the

document(s) which refers to or evidences the communication, and, to the extent that the
communication was unwritten, to identify the persons participating in the communication
and to state the date, manner, place and substance of the communication.
10. The term state the basis means to state in your answer each and every fact and legal theory
that you think relates to the claim, contention, allegation, or response.
11. The term person means any natural person, corporation, partnership, proprietorship,
association, organization, or group of natural persons.
12. The term relating to or relates to means in any way directly or indirectly, concerning,
referring to, disclosing, describing, confirming, supporting, evidencing, or representing.
13. The term representative means any and all present and former agents, employees, servants,
officers, directors, attorneys, or other persons acting or purporting to act on behalf of the
person in question.
14. The term telephone numbers refers to home, business, facsimile, and cellular telephone
numbers.
15. The terms and and or, as used herein, are both conjunctive and disjunctive.
16. All singular words include the plural, and all plural words include the singular.
17. All words in the present tense include the past, and all words in the past tense include the
present.

INSTRUCTIONS
18. Each Interrogatory and part thereof, shall be answered separately, fully and completely,
without reference to any answer of any other Interrogatory.

19. Unless otherwise indicated, the relevant time period referred to in these Interrogatories is
from the publication of the initial solicitation for the work described in the Complaint
through the date of your answer to these Interrogatories.
20. With respect to information or documents as to which you may claim privilege, attorneys
work product or trial preparation materials, you are requested to identify each such
document, in writing, on or before the date of the production set forth herein, together with
the following information: the nature, date, subject matter and author of the document, as
well as the identity of all persons to whom the document was directed, addressed or received,
and the paragraphs of the discovery requests to which the document corresponds. For each
such document, you are further required to state the basis for your claim of privilege,
attorneys work product, or trial preparation materials.

INTERROGATORIES
1.

What is the name, address and telephone number of the person or persons participating in

the answering of these interrogatories? For each person, if applicable, list the persons official
position or relationship with the party to whom the interrogatories are directed, as well as the
number of each interrogatory which the person participated in answering.

2.

State the name, address and telephone number of any and all individuals with knowledge

of Granadas claims that are the subject of this lawsuit, and specify what information those
individuals have that is related to Granadas claims.

3.

Please identify any and all past or present Granada employees who have worked on, or

have knowledge of, the matters identified in the Complaint. For each person, state their address,
telephone number, job description, general responsibilities at Granada, work preformed in
relation to the events described in the Complaint, dates of employment, and reason for
termination if the employee is no longer with Granada.

4.

State the amount and category of damages you seek in the Complaint, and identify each

and every document that supports your alleged entitlement to such damages. With regard to each
document identified pursuant to this interrogatory, state the nature, date, subject matter and
author of the document as well as the identity of all persons to whom the document was directed,
addressed, or received.

5.

State with particularity the method by which you quantified the damages identified in

Interrogatory Number 4.

6.

Describe in detail each instance of alleged breach by the County referred to in the

Complaint. For each alleged breach, describe with particularity the facts related to the breach,
the date of the breach, the name of the County employee(s) involved, the name of the Granada
employee(s) involved, the result of the alleged breach, and the provision of the Agreement
alleged to have been breached. For each alleged breach described, identify each and every
document that supports your allegation and state the nature, date, subject matter and author of the
document as well as the identity of all persons to whom the document was directed, addressed, or
received.

7.

Describe in detail all representations made by the County or its employees that support

your claim for Negligent Misrepresentation in Count III of the Complaint. For each alleged
representation described: (1) identify each and every document that supports your allegation and
state the nature, date, subject matter and author of the document as well as the identity of all
persons to whom the document was directed, addressed, or received; and (2) identify each and
every statement made that supports your allegation and state the nature, date, subject matter and
maker of the statement as well as the identity of all persons to whom the statement was directed,
addressed or received.

8.

Describe in detail all representations, statements or promises made by the County or its

employees that support your claim for Promissory Estoppel in Count VI of the Complaint. For
each alleged representation, statement or promise described: (1) identify each and every
document that supports your allegation and state the nature, date, subject matter and author of the
document as well as the identity of all persons to whom the document was directed, addressed, or
received; and (2) identify each and every statement made that supports your allegation and state
the nature, date, subject matter and maker of the statement as well as the identity of all persons to
whom the statement was directed, addressed or received.

I have read the foregoing Answers to Interrogatories and do swear that they are true and
correct of the best of my knowledge and belief.
Granada Towers, LLC
By:_____________________________
Sworn to and subscribed before me at Miami, Dade County, Florida this ______ day
of ______________________ 2010.
__ Who is personally known to me
__ Who produced identification
_________________________
Type of Identification
_____________________________________
Notary Public, State of Florida at Large
________________________________________
Print, type or stamp name of notary public
My Commission Expires: