In the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida

IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE 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.

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DEFENDANT MIAMI-DADE COUNTY’S

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

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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, attorney’s 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, attorney’s 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 person’s 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 Granada’s claims that are the subject of this lawsuit, and specify what information those individuals have that is related to Granada’s 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: