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Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 1 of 14
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Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 3 of 14
7300 N. Kendall Drive, Suite 4450, Miami, Florida 33156 

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IN THE ELEVENTH JUDICIAL CIRCUIT COURT 

IN AND FOR MIAMI-DADE COUNTY, FLORIDA 

ROGELIO RIVERO ALEMAN, CIRCUIT CIVIL DIVISION 

 Plaintiff, CASE NO.: 2020-011498-CA-01 

vs. 

A & J GENERAL CONTRACTORS CORP., 

MIGUEL A. GUERRERO, SR., and 

MIGUEL A. GUERRERO, JR., 

 Defendants. 

______________________________/ 

PLAINTIFF’S FIRST REQUESTS FOR PRODUCTION TO DEFENDANT 

 Plaintiff, Rogelio Rivero Aleman, through his undersigned counsel and pursuant to Fla. R. 

Civ. P. 1.280, 1.350 and other applicable rules and laws, requests that Defendants, A & J 

General Contractors Corp., Miguel A. Guerrero, Sr., and Miguel A. Guerrero, Jr., produce the 

following documents and materials at the office of the undersigned within 45 days of the service 

of the Summons and Complaint days: 

INSTRUCTIONS

1. All documents are to be produced as they are kept in the ordinary course of 

business or shall be organized and labeled without permanently marking the item produced so as 

to correspond with the categories of each numbered request hereof. 

2. Each draft, final document, original, reproduction and each signed and unsigned 

document and every additional copy of such document where such copy contains any 

commentary, note, notation or other change whatsoever that does not appear in the original or 

on the copy of the same document produced shall be deemed and considered to constitute a 

separate document. 

3. If any of the documents encompasses by the attached request for production of 

documents is/are deemed by you to be privileged, furnish all non-privileged documents. 

4. If you fail to produce or otherwise withhold from production any documents 

because you have deemed same to be covered by a privilege, provide the following information 

for each document withheld: 

Filing # 108186545 E-Filed 06/01/2020 11:43:05 AM Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 4 of 14
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(a) The nature of the privilege claimed; 

(b) The name and capacity of the person(s) who prepared the document; 

(c) The date, if any, borne on the document; 

(d) A brief description of its subject matter and physical date; 

(e) The source of the factual information from which such document was 

prepared; 

(f) The name and capacity of all addresses of recipients of the original or 

copies thereof. 

5. When appropriate, the singular form of the word should be interpreted in the 

plural as may be necessary to bring within the scope hereof any documents which might 

otherwise be construed to be outside the scope hereof. 

DEFINITIONS

A. All references to any Person (as defined below) includes his/her/its employees, 

agents, servants, subsidiaries, parent company, affiliated company and any other person or entity 

or representative (as defined below) acting or purporting to act on behalf or under its/his/her 

control. 

B. "You", "Your" refers to the Person (as described below) to whom this request is 

addressed, including his/her/its employees, agents, subcontractors, servants, subsidiaries, parent 

company, affiliated company and any other person or entity or representative (as defined below) 

acting or purporting to act on behalf or under its/his/her control. 

C. "Person" means any natural individual in any capacity whatsoever or any entity or 

organization, including divisions, departments, and other units herein, and shall include, but not 

limited to, public or private corporations, partnerships, joint ventures, voluntary or 

unincorporated associations, organizations, proprietorships, trusts, estates, governmental 

agencies, commissions, bureaus, or departments and the agents, servants and employees of same. 

D. "Materials" shall mean all "Documents", "Writings", "Agreements", and 

"Communications" as those terms are defined herein. 

E. "Document(s)" or "Writing(s)" shall be deemed to be every record of every type, 

and is used in the broadest sense and includes any medium upon which intelligence or 

information can be recorded and further includes, but is not limited to all originals, nonidentical 

copies and drafts of the following items whether printed, handwritten, typed recorded or stored 

on any electromagnetic storage device, or reproduced by hand, including without limitation 

correspondence, memoranda, invoices, receipts, records, ledger cards or other account records, 

vouchers, checks, shoporders, diary, calendar instruction, summaries of personal conversations or 

interviews, minutes or records of meetings or conferences, transcripts, opinions or reports of 

consultants, projections, drafts, contract agreements, confirmations, statistical statements, studies 

telegrams, telexes, books, note reports, logs, diaries, tape recordings, video cassettes and date 

compilations from information can be obtained, charts, photographs, notebooks, drawings, plans, 

Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 5 of 14
7300 N. Kendall Drive, Suite 4450, Miami, Florida 33156 

TEL 305.230.4884 FAX 305.230.4844 

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printed material of any kind, charts and interoffice communications, and any other writing of 

whatever description, including but not limited to any information contained in any computer or 

represented by a computer program, signed or unsigned, regardless of whether approved, signed 

sent, received, redrafted or executed, study, work paper, handwritten, tape, photograph, 

microfilm, data sheet, date processing card, or any other written, recorded, transcribed, punched, 

taped filmed, or graphic matter, however produced or reproduced. 

F. "Agreement" shall mean all agreements, contracts, undertakings or other 

arrangements, whether oral, written, non-final, enforceable, superseded or modified by 

subsequent agreements. 

G. "Communication" means any oral or written statement, dialog, colloquy, 

discussion or conversation and also means any transfer of thoughts or ideas between persons by 

means of documents and includes any transfers of data from one location to another by 

electronic or similar means. 

H. "Representative" means any and all agents, employees, servants, officers, 

directors, attorneys or other persons acting or purporting to act on behalf of the person, 

corporation or entity in question. 

I. "Evidencing" means having a tendency to show, prove or disprove. 

J. "With Respect to Documents" the term "identify" means I) state the author or 

writer thereof and the parties thereto; ii) state its title and identifying date; iii) state the date of the 

document or if no date, state the exact nature and substance thereof; iv) identify each person 

having possession, care, custody or control of the original and copies therefor; and v) if such 

document was, but no longer is in your possession or subject to your control, state what 

disposition was made of it and who is in control of same. 

K. With Respect To "Person" the term "Identify" means: I) state the person as 

defined in Definition "C"; ii) state the person's business address; iii) state the person's residence 

address; iv) state the person's business telephone number; and v) state the person's residential 

telephone number. 

L. "Employment" shall include not only full time salaried retention but also the 

performance of services of any type, whether compensated or not, including, but not limited to, 

formal or informal advisory and consulting services. 

M. The words "and" and "or" as used herein shall be construed either disjunctively or 

conjunctively as required by the context to bring the scope of these interrogatories any answer 

that might be deemed outside their scope by other construction. 

N. "Control" means in your possession, custody or control or under your direction 

and includes in the possession, custody or control of those under the direction of you or your 

employees, subordinates, counsel, accountant, consultant, expert, parent or affiliated corporation 

and any other person purporting to act on your behalf. 

Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 6 of 14
7300 N. Kendall Drive, Suite 4450, Miami, Florida 33156 

TEL 305.230.4884 FAX 305.230.4844 

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O. "Relate to" or "Relating to" shall mean directly or indirectly, refer to reflect, 

describe, pertain to, arise out of or in connection with, or in any way legally, logically or factually 

be connected with the matter discussed. 

P. "Ownership Interest" shall mean an interest whether owned or possessed, vested 

or contingent, and whether title is held legally in your name, spouse's name or children's name, 

or parent, subsidiary or other related company and shall include beneficial interest or interest 

held through any trust in your family's or business entity's name. 

Q. "Including" shall mean including but not limited to. 

R. "Defendants" shall mean the above-named Defendants in this action. 

S. "Plaintiff" shall mean the above-named Plaintiff in this action. 

Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 7 of 14
7300 N. Kendall Drive, Suite 4450, Miami, Florida 33156 

TEL 305.230.4884 FAX 305.230.4844 

www.fairlawattorney.com 



PLAINTIFF’S FIRST SET OF REQUEST FOR PRODUCTION 

1) All personnel files you maintained for Plaintiff, including all documents executed and/or 

provided to him from interviewing, applying, hiring, up through today. 

2) All documents concerning monies paid, advanced, loaned, or otherwise provided to 

Plaintiff during the three years prior to the filing of the Complaint in this action. 

3) All documents provided by/for Defendants to Plaintiff concerning his working for 

Defendant from January 1, 2014 to the present. 

4) All receipts relating to cash payments made to Plaintiff by or for Defendants from January 

1, 2014 to the present. 

5) All time sheets and time records used to determine and/or document the days, hours, and 

times that Plaintiff worked for Defendants from January 1, 2014 to the present. 

6) All correspondence, written statements, notes of conversations, memoranda, and other 

documents concerning oral or written communications between you and Plaintiff from 

January 1, 2014 to the present. 

7) All documents in your possession, custody, and/or control that were written and/or 

signed by Plaintiff regarding any issue in this lawsuit. 

8) All documents reflecting the job performance of Plaintiff from January 1, 2014 to the 

present. 

9) Every form W-4, 1099, W-2, W-4, I-9, application, written work agreement, written pay 

agreement, written disclosure statement, and other employment-related document 

concerning Plaintiff. 

10) All documents that Defendants sent to or received from the U.S. Department of Labor 

(“USDOL”) for the period during the past five (5) years. 

Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 8 of 14
7300 N. Kendall Drive, Suite 4450, Miami, Florida 33156 

TEL 305.230.4884 FAX 305.230.4844 

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11) All documents that explain the meaning of any codes, shorthand, untitled columns of 

data fields, or other data presentation conventions used in the documents that Defendant 

produced in this litigation. 

12) All documents concerning investigations of Defendants by the U.S. Department of Labor, 

any state employment service, or any other agency of state, federal, or local government, 

concerning compliance with laws concerning the payment of wages to employees past 3 

years. 

13) If you or your agents or employers have made a settlement, deal, agreement, or 

arrangement of any kind with a person or party of their attorney, including an insurance 

policy, concerning or that would apply to this case (including the resolution of any claim 

brought against you pursuant to the Fair Labor Standards Act), please produce a copy of 

such settlement, deal, agreement, or arrangement. This request includes, but is not 

limited to, an arrangement to indemnify another party or to pay any attorney’s fees or 

expenses of any party, and also an arrangement for another person or entity to indemnify 

you or pay any of your attorney’s fees or expenses. 

14) All correspondence or other communications and documents whatsoever exchanged 

between you and each person whom you may call as an expert witness. 

15) All documents that have been made or prepared by an expert whom you may call to 

testify as a witness in this case. 

16) All documents that state the subject matter on which any expert witness whom you 

expect to call at trial is expected to testify, that have been provided or relied on by any 

such expert, or that state the substance of the facts or opinions to which the expert is 

expected to testify or grounds for each opinion. 

Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 9 of 14
7300 N. Kendall Drive, Suite 4450, Miami, Florida 33156 

TEL 305.230.4884 FAX 305.230.4844 

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17) All statements that were signed or recorded by parties and witnesses and all statements 

that were offered and refused signature by parties and witnesses. 

18) All documents concerning to the business structure of Defendants for the period from 

January 1, 2014 to the present, including those showing the identity of all persons who 

own or operate the business and all persons who recruit, solicit, hire, employ, furnish, or 

evaluate workers for the business, as well as all persons responsible for accounts 

receivables, accounts payables, and payroll. 

19) All documents showing Plaintiff’s total earnings for each pay period, the hourly rate or 

piece rate, the hours of employment which had been offered, the hours Plaintiff actually 

worked, the deductions made from the wages, and all other documents utilized to 

determine when Plaintiff started work each day, stopped working for a break, resumed 

working after a break, and ceased working at the end of each day. 

20) Documents identifying each check/payment sent to Plaintiff and the week or weeks each 

such check was intended to pay for. 

21) All documents consulted, reviewed, and/or referenced in connection with your providing 

answers/responses to Plaintiff’s Interrogatories. 

22) All documents identified in your disclosures pursuant to Fed. R. Civ. P. 26. 

23) All documents identifying and/or describing the job duties of Plaintiff. 

24) All employee manuals, handbooks, and all memoranda distributed, made available, 

signed by, and/or actually provided to Plaintiff from January 2012 to the present. 

25) All documents supporting your Answer and Affirmative Defenses to the operative 

Complaint, or otherwise supporting the contention that you are not liable to Plaintiff as 

alleged in the operative Complaint in this case. 

Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 10 of 14
7300 N. Kendall Drive, Suite 4450, Miami, Florida 33156 

TEL 305.230.4884 FAX 305.230.4844 

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26) All documents on which Defendants based their belief that Plaintiff was not entitled to 

overtime wages. 

27) All documents on which Defendants contend their defenses that they paid Plaintiff for all 

hours worked, including all overtime hours worked. 

28) Copies of all documents describing the duties that Defendants expected Plaintiff to 

perform. 

29) Copies of all documents, including electronic materials, in which Defendants billed any 

person or entity for the time expended by Plaintiff from January 1, 2014 to April 20, 

2019. 

30) All documents and information upon which Defendants relied for their good faith belief 

that, at all material times they, were acting in compliance with the FLSA, including all 

documents reflecting the date each such document and /or piece of information was 

consulted and from where each was received / retrieved. 

31) All emails exchanged with Plaintiff from January 1, 2014 to the present. 

32) All text messages exchanged with Plaintiff from January 1, 2014 to the present. 

33) All documents supporting Defendants’ Affirmative Defenses. 

34) All policies of insurance that would provide benefits and/or indemnity to Defendants for 

the claim asserted in the operative Complaint and all reservation of rights letters 

regarding same. 

35) Documents identifying the locations at which Plaintiff performed services on behalf of 

Defendants from January 1, 2014 to April 20, 2019. 

36) All of the Corporate Defendant’s bank records, including without limitation bank 

statements, cancelled checks, etc., from any and all bank the Corporate Defendant 

Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 11 of 14
7300 N. Kendall Drive, Suite 4450, Miami, Florida 33156 

TEL 305.230.4884 FAX 305.230.4844 

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has/had accounts with for during the years 2018, 2019, and 2020. 

37) Defendants’ 2018, 2019, 2020, and current federal and state tax returns, including all 

attachments, schedules, and supporting documents for all annual and quarterly reports / 

filings. 

38) A copy of all receipts of whatever kind that reflect the amount of money paid to (or owed 

to) Defendants by their clients for the years 2018, 2019 and 2020. This request also 

includes any receipts with respect to money that was received by Defendant(s) and later 

paid to the state, local or federal government or any subdivision thereof. 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was filed on June 1, 

2020, and served with the Summons and Complaint in this cause. 

 FAIRLAW FIRM 

 Counsel for Plaintiff 

 7300 N. Kendall Drive 

 Suite 450 

 Miami, FL 33156 

 Tel: 305.230.4884 

 Fax: 305.230.4844 

 s/Brian H. Pollock, Esq. 

 Brian H. Pollock, Esq. 

 Fla. Bar No. 174742 

 brian@fairlawattorney.com 

Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 12 of 14
FORM 1.997. CIVIL COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of 

pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the 

Clerk of Court for the purpose of reporting data pursuant to section 25.075, Florida Statutes. (See instructions 

for completion.)

I. CASE STYLE

 IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT,

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

 Case No.: _________________

Judge: ____________________ 

Rogelio Rivero Aleman

 Plaintiff

 vs.

A & J GENERAL CONTRACTORS CORP., MIGUEL A. GUERRERO Sr, MIGUEL A. GUERRERO Jr

Defendant

II. AMOUNT OF CLAIM

 Please indicate the estimated amount of the claim rounded to the nearest dollar $32,000

III. TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the 

most descriptive label is a subcategory (is indented under a broader category), place an x on both the main 

category and subcategory lines. 

Condominium

Contracts and indebtedness

Eminent domain

Auto negligence

 Negligence – other

 Business governance

  Business torts

 Environmental/Toxic tort

 Third party indemnification

 Construction defect

 Mass tort

 Negligent security

 Nursing home negligence

 Premises liability – commercial

 Premises liability – residential

Products liability

Real Property/Mortgage foreclosure

 Commercial foreclosure

 Homestead residential foreclosure

 Non-homestead residential foreclosure

 Other real property actions

 Professional malpractice

 Malpractice – business

 Malpractice – medical

 Malpractice – other professional

 Other

 Antitrust/Trade Regulation

 Business Transaction

 Circuit Civil - Not Applicable

 Constitutional challenge-statute or ordinance

 Constitutional challenge-proposed amendment

 Corporate Trusts

 Discrimination-employment or other

 Insurance claims

 Intellectual property

 Libel/Slander

 Shareholder derivative action

 Securities litigation

 Trade secrets

 Trust litigation

 County Civil

 Small Claims up to $8,000 

 Civil 

 Replevins

 Evictions

 Other civil (non-monetary)

 

Filing # 108184811 E-Filed 06/01/2020 11:29:03 AM Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 13 of 14
COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the 

Administrative Order. Yes No 

IV. REMEDIES SOUGHT (check all that apply):

 Monetary;

 Non-monetary declaratory or injunctive relief;

 Punitive 

V. NUMBER OF CAUSES OF ACTION: 

(Specify) 

3

VI. IS THIS CASE A CLASS ACTION LAWSUIT?

Yes

 No

VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

No

 Yes – If “yes” list all related cases by name, case number and court:

1:19-CV-24956

VIII. IS JURY TRIAL DEMANDED IN COMPLAINT?

  Yes

 No

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and 

that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425.

Signature: s/ Brian H Pollock 

 Attorney or party 

FL Bar No.: 174742 

 (Bar number, if attorney) 

 Brian H Pollock

 (Type or print name) 

 Date: 06/01/2020

Case 1:20-cv-22723-MGC Document 1-2 Entered on FLSD Docket 07/01/2020 Page 14 of 14