IN THE CIRCUIT COURT FOR THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
DR JAMES MCDONOUGH,
Plaintiff,
vs.

CASE NO.: 15-08342-CA-08
CIVIL DIVISION

ALEJANDRO MURGUIDO,
and LUIS GOMEZ, individually,
Defendants.
______________________________________/
NOTICE OF PLAINTIFF DR. JAMES ERIC McDONOUGH’S FIRST SET OF
INTERROGATORIES DIRECTED TO DEFENDANT ALEJANDRO MURGUIDO
Pursuant to Rule 1.340 Florida Rules of Civil Procedure, the Plaintiff requires Defendant
Alejandro Murguido to answer each of the following interrogatories in writing and under oath
within thirty (30) days.
I hereby certify that a copy of this cover page was filed with the Clerk of the Court and
that the interrogatories were emailed to the Defendant this 19th day of April, 2016.

J. GREENSTEIN, P.A.
Counsel for the Plaintiff
Dadeland Towers
9200 S. Dadeland Blvd., Suite 308
Miami, Fl. 33156
Ph: (305) 772-7083
Fax: (305) 938-5038
By:/s/ Alan Greenstein
GREENSTEIN
Florida Bar No. 237817

 INTERROGATORIES
1.

Please state your employment history for the past twenty years.

ANSWER:

2.
Please state in detail the nature of any disciplinary proceedings brought against you while
you have been working in law enforcement. Please state the department you were with and the
outcome of the disciplinary proceeding.
ANSWER:

3.
Please describe in detail the encounter that occurred between you and Dr. McDonough on
October 29, 2012. This would include, but is not limited to, any conversation or exchange of
words between yourself and Dr. McDonough.
ANSWER:

 4.
Did you call the police on October 29, 2012? If.so, what department did you call and
what happened with Dr. McDonough when they arrived?
ANSWER:

5.
On what date did you file a formal complaint with the Miami-Dade Police Department
against Dr. McDonough? Why did you wait until that date? Please describe in detail what you
told the Miami-Dade Police.
ANSWER:

 6.
Please state on what on other dates you reported the details of the incident of October 29,
2012 to any police or law enforcement agency. Please state in detail what, if anything, you told
those law enforcement agencies.
ANSWER:

7.
Were you advised by anyone that Dr. McDonough had filed (or attempted to file) an
Internal Affairs complaint against you? If so, who advised you and when?
ANSWER:

8.
On February 28, 2013 you filed an injunction for stalking (or repeat violence) against Dr.
McDonough. Why did you file for an injunction? Please state why you did not appear for your
deposition in the case. Please state why you did not appear for the hearing on the request for an
injunction.
ANSWER:

 9.
On August 22, 2014 you filed an injunction for stalking (or repeat violence) against Dr.
McDonough. Why did you file for an injunction? Please state why you did not appear for the
hearing on the request for an injunction.
ANSWER:

AFFIANT
STATE OF
COUNTY OF

)
) SS:
)

BEFORE ME, the undersigned authority, personally appeared
______________________

, who, after being duly sworn, deposes

and says that he/she has knowledge of the foregoing Answers to Interrogatories, and that they are

 true and correct to the best of his/her knowledge.
DATED THIS

day of

, 20

.

I HEREBY CERTIFY that on this day, before me, an officer duly authorized to
, to

administer oaths and take acknowledgments, personally appeared
me known to be the person described in and who executed the foregoing instrument, who

acknowledged before me that he/she executed same, that I relied upon the following form of
.

identification of the above-named person:

SWORN TO AND SIGNED BEFORE ME, I HEREBY WITNESS my hand and official
seal in the County and State last aforesaid this

day of

NOTARY PUBLIC
My Commission Expires:
Notary's Printed Name

, 20

.