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    Plaintiff Motion To Compel 1 Set of Interrogatories

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    al_crespo
    Steven Miro filed a motion to compel the City of Miami to respond to his first set of interrogatories. The City's responses were due on April 9th but they did not respond or communicate until April 13th when they requested an extension until April 17th, which Miro agreed to. As of the date of the filing, April 27th, the City still had not responded. Miro is requesting an order requiring the City to immediately respond without objections and for an award of fees and costs due to the City's delay tactics throughout the lawsuit.

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    Plaintiff Motion To Compel 1 Set of Interrogatories

    Uploaded by

    al_crespo
    351 views3 pages
    Steven Miro filed a motion to compel the City of Miami to respond to his first set of interrogatories. The City's responses were due on April 9th but they did not respond or communicate until April 13th when they requested an extension until April 17th, which Miro agreed to. As of the date of the filing, April 27th, the City still had not responded. Miro is requesting an order requiring the City to immediately respond without objections and for an award of fees and costs due to the City's delay tactics throughout the lawsuit.

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    Plaintiff Motion to Compel 1 Set of Interrogatories

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    Plaintiff Motion to Compel 1 Set of Interrogatories

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    Steven Miro filed a motion to compel the City of Miami to respond to his first set of interrogatories. The City's responses were due on April 9th but they did not respond or communicate until April 13th when they requested an extension until April 17th, which Miro agreed to. As of the date of the filing, April 27th, the City still had not responded. Miro is requesting an order requiring the City to immediately respond without objections and for an award of fees and costs due to the City's delay tactics throughout the lawsuit.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    351 views3 pages

    Plaintiff Motion To Compel 1 Set of Interrogatories

    Uploaded by

    al_crespo
    Steven Miro filed a motion to compel the City of Miami to respond to his first set of interrogatories. The City's responses were due on April 9th but they did not respond or communicate until April 13th when they requested an extension until April 17th, which Miro agreed to. As of the date of the filing, April 27th, the City still had not responded. Miro is requesting an order requiring the City to immediately respond without objections and for an award of fees and costs due to the City's delay tactics throughout the lawsuit.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
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    The plaintiff is filing a motion to compel the City of Miami to respond to interrogatories and is requesting fees and costs due to the city's failure to respond on time.

    The plaintiff is requesting an order from the court requiring the City of Miami to immediately respond to the plaintiff's first set of interrogatories without objections and for an award of fees and costs.

    The plaintiff is filing this motion because the City of Miami did not respond to the interrogatories by the due date and still had not responded as of the date of this filing, despite requesting an extension.

    Filing # 106708363 E-Filed 04/27/2020 08:31:16 AM

    IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT


    IN AND FOR MIAMI-DADE COUNTY, FLORIDA
    Case No.: 2019-030366

    STEVEN MIRO

    Plaintiff,
    v.

    CITY OF MIAMI

    Defendant.
    _______________________________________/

    PLAINTIFF’S MOTION TO COMPEL THE CITY OF MIAMI TO


    ANSWER PLAINTIFF’S FIRST SET OF INTERROGATORIES,
    AND FOR FEES AND COSTS

    Pursuant to Rule 1.380, Plaintiff Steven Miro hereby files his

    motion to compel the City of Miami to answer the Plaintiff’s first set

    of interrogatories and for an award of fees and costs.

    1. Defendant’s response to the Plaintiff’s first of

    interrogatories was due on April 9, 2020.

    2. On April 13, 2020, after the due date came and went

    without a response or any communication from the City, the City

    responded to Plaintiff’s ‘meet and confer’ email and requested a

    belated extension until April 17, 2020. Plaintiff nevertheless agreed

    to the untimely request.


    3. As of the date of this filing the City has still not

    responded.

    4. By rule, all objections are waived.

    5. City of Miami should be ordered to respond to the

    interrogatories as quickly as possible.

    6. City of Miami must pay the Plaintiff’s fees and costs due

    to its complete failure to respond.

    7. The City has a track record of delaying this lawsuit,

    seeking multiple frivolous motions for a protective order,

    cancellation of depositions and other tactics.

    For the reasons stated above, Plaintiff requests an order

    requiring the City to immediately respond to Plaintiff’s first set of

    interrogatories without objections and for an award of fees and

    costs.

    Respectfully submitted,

    _/s/ Matthew Sarelson


    Matthew Seth Sarelson, Esq.
    Florida Bar 888281
    MATTHEW SETH SARELSON, P.A.
    Attorneys for Plaintiff Steven Miro
    2100 Ponce de Leon, Suite 1290
    Coral Gables, Florida 33134
    305.773.1952
    [email protected]

    2
    CERTIFICATE OF CONFERRAL

    I hereby certify that I conferred with the City of Miami about

    this matter but I have been unable to get the City to respond to the

    discovery without court intervention.

    /s/ Matthew Sarelson

    CERTIFICATE OF SERVICE

    I hereby certify that on April 27, 2020, I filed this document via

    the Court’s e-portal system which will then email it to all counsel of

    record.

    /s/ Matthew Sarelson


    Matthew Sarelson

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