In the Circuit Court of the 11Th 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. ______/

DEFENDANT MIAMI-DADE COUNTY’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO RH DESIGN & ASSOCIATES, INC.

Miami-Dade County, a political subdivision of the State of Florida, pursuant to

Fl.R.Civ.P. 1.350 requests Plaintiff, RH Design & Associates, Inc., to produce or permit inspection and copy of the following documents.

DEFINITIONS

For purposes of this Request, the following definitions apply:

A. The term “you,” “your,” “Plaintiff,” or “RH Design” refers to RH Design &

Associates, Inc., its officers, employees and owners.

B. The term "Dade County," “County,” or "Defendant" refers to Miami-Dade County, its departments, agencies, instrumentalities, officers and employees.

C. The term "Complaint" refers to your Second Amended Complaint. D. Capitalized terms not defined here shall have the same meaning as those terms have in the Complaint.

E. 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, punched, taped, filmed 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 aural 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.

F. The term "all documents" means any document as above defined known to you and every such document that can be located or discovered by reasonably diligent efforts.

G. 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.

H. The term "person" means any natural person, corporation, partnership, proprietorship, association, organization, or group of natural persons. I. The term "relating to" or "relates to" means in any way directly or indirectly, concerning, referring to, disclosing, describing, confirming, supporting, evidencing, or representing.

J. 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.

K. The terms "and" and "or", as used herein, are both conjunctive and disjunctive.

L. All singular words include the plural, and all plural words include the singular.

M. All words in the present tense include the past, and all words in the past tense include the present.

INSTRUCTIONS

N. Each request and part thereof, shall be answered separately, fully and completely without reference to any answer of any other request.

O. Unless otherwise indicated, the relevant time period referred to in this Request for

Production is from January 1, 2000 through the date of your response to this Request.

P. 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.

REQUEST

1. Any and all documents used, referred to, referenced or relating to your responses to the County’s First Set of Interrogatories.

2. Any and all correspondence relating to the issues raised in the Complaint, including any between RH Design and the County, financial institutions, subcontractors, sub- subcontractors, material suppliers, architects, and engineers.

3. All applications or requests to any entity for funding, loans or grants for the projects referenced in the Complaint and any responses to those applications or requests.

4. RH Design & Associates, Inc.’ job cost ledgers for projects referenced in the

Complaint and the work including all records of invoicing and payments for subcontractors, personnel, materials, supplies and overhead which costs RH Design claims is a cost of the work referenced in the Complaint.

5. Drafts, worksheets, tabulations, or other documents prepared by RH Design, Inc. in connection with the RFA are described in the Complaint.

6. Any documents with itemized computation of any damages sought.

7. Any documents supporting any claim to damages sought in this case.

14. All documents, correspondences, filings, or pleadings in RH Design & Associates,

Inc. v. Rusaleka Limited Partnership, et. al., Case No. 03-12810 CA 10 and Eugene Jackson v.

Rafael Huguet, Case No. 10-29135 CA 02. Respectfully submitted,

R. A. Cuevas, Jr. MIAMI-DADE COUNTY ATTORNEY By: s/ Oren Rosenthal Oren Rosenthal Assistant County Attorneys Florida Bar No. 86320 Miami-Dade County Attorney’s Office 111 N.W. 1st Street, Suite 2810 Miami, Florida 33128 Telephone: (305) 375-5151 Facsimile: (305) 375-5634 Email: [email protected]

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S. mail and facsimile on this 16th day of November, 2010 to the following attorney of record:

Robert H. Fernandez, P.A. Infante, Zumpano, Hudson & Miloch, LLC 500 South Dixie Highway, Suite 302 Coral Gables, Florida 33146 Telephone: 305-503-2990 Direct: 786-345-2124 Fax: 305-774-5908

______Oren Rosenthal Assistant County Attorney