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Filing # 115163531 E-Filed 10/19/2020 10:08:51 AM
IN THE CIRCUIT COURT OF THE 177
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-19-026028
MLADEN MALOVIC and NEDA MALOVIC,
Plaintiffs,
va
FAMILY SECURITY INSURANCE COMPANY,
INC.,
Defendant.
/
DEFENDANT’S NOTICE OF SERVICE
OF EXPERT INTERROGATORIES TO PLAINTIFFS
Defendant, FAMILY SECURITY INSURANCE COMPANY, INC., by and through its
undersigned counsel, hereby propounds the following Expert Interrogatories to Plaintiffs, to be
answered in writing, under oath, and within thirty (30) days after service hereof.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served by e-mail
via the Florida Courts E-Filing Portal on October 19, 2020 upon: Aaron D. Silvers, Esq., Weisser
Elazar & Kantor, PLLC, Counsel for Plaintiffs, 800 East Broward Blvd, Ste 510, Fort Lauderdale,
FL 33301; Service E-Mails: as@weklaw.com, cb@weklaw.com & pb@weklaw.com.
BRESSLER, AMERY & Ross, P.C.
200 East Las Olas Blvd.
Suite 1500
Fort Lauderdale, Florida 33301
T: 954.499.7979
F: 954.499.7969
E-Mail: miainsurance@bressler.com
gplasencia@pbressler.com
hzelinger@bressler.com
By: /s/_ Gabriela A. Plasencia
GABRIELA A. PLASENCIA, ESQ.
Florida Bar No.: 115788
HOPE C. ZELINGER, ESQ.
Florida Bar No.: 92173
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/19/2020 10:08:51 AM.****FIRST SET OF EXPERT INTERROGATORIES TO PL.
TIFFS
1. Please state the name, last known address and telephone number of any and all
expert witnesses that you expect to call to testify as expert witnesses on behalf of Plaintiffs at the
trial of this cause, and as to each, please state with specificity the subject matter on which he/she
is expected to testify and the substance of the facts and opinions to which he/she is expected to
testify.
Answer:
2. Please state the fields of expertise of any and all expert witnesses whose name(s)
appear(s) in your answer to Interrogatory | above and set forth the professional education, training
and experience held by each expert witness and a brief summary of his/her qualifications including
professional society and association memberships, professional degrees and academic or
professional honors. Alternatively, please attach a current curriculum vitae.
Answer:
3. Please state whether or not any or all of the expert witnesses whose name(s)
appear(s) in the answer to Interrogatory 1 above have prepared any kind of written report; and, if
so, please state the date of the report, and the name and last known address and telephone number
of the person who currently has custody and control of the report.
Answer:
4. Please state whether or not any or all of the expert witnesses whose name(s)
appear(s) in the answer to Interrogatory 1 above, have/has ever testified on behalf of Plaintiffs;
and, if so, please state the number of times, whether the testimony was in court or by deposition,
the date upon which the testimony was given and the case styles, and numbers and Court
identifying information with regard to each occasion.
Answer:5. Please state whether any or all of the expert witnesses whose name(s) appear(s) in
your answer to Interrogatory 1 above have been provided with any kind of written report or factual
summary and, if so, please state the name and last known address and telephone number of the
person who currently has custody and control of the report.
Answer:
6. Please state the total amount of damages being claimed as a result of this lawsuit
and the individual and documentation relied upon in support of same. Please provide a breakdown
of the total amount of damages sought under Coverage A, B, C & D.
Answer:
7. Please state the general litigation experience of any and all expert witnesses whose
name(s) appear(s) in your answer to Interrogatory 1 above and set forth for each expert witness
named:
a. The percentage of work performed for Defendants and the percentage of work
performed for Plaintiffs.
b. The expert’s involvement as an expert witness in terms of percentage of income derived
from serving as an expert witness, percentage of hours spent serving as an expert
witness and number of hours spent serving as an expert witness.
c. The total number of times this expert has been hired by your law firm over the last three
(3) years.
Answer:
8. Please state, within the last three (3) years, all cases in which any expert witness
whose name(s) appear(s) in the answer to Interrogatory 1 above, testified either at deposition or at
trial. For each case named, for identification purposes, please state the name of the expert witness
who testified, the case style, the case number, the Court, and all dates testimony was given.
Answer:9. Please state, within the last three (3) years, all cases in which any expert witness
whose name(s) appear(s) in the answer to Interrogatory 1 above has been retained to perform
expert, litigation, or forensic services on behalf of the attorneys and/or law firms representing
Plaintiffs in this litigation.
Answer:
10. Please identify the total amount of money that each expert witness whose name(s)
appear(s) in the answer to Interrogatory 1 above has been paid by Plaintiffs and/or counsel for
Plaintiffs within the last three (3) years.
Answer:
ll. Please state, for each expert witness whose name(s) appear(s) in the answer to
Interrogatory 1 above, the amount of time spent and the amount of compensation charged for
services rendered in the pending case.
Answer:
12. Please state, for each expert witness whose name(s) appear(s) in the answer to
Interrogatory 1 above, if they have ever been to property located 1781 42" Terrace SW, Naples,
FL, 34116, and if so, on what date(s).
Answer:
13. For each expert disclosed, please provide the date the expert was retained and by
whom.
Answer:14. Pursuant to Florida Rule of Civil Procedure 1.280, please state the opinion that the
expert is expected to testify and the summary and grounds for each opinion stated.
Answer:
15. Did the expert submit any other reports based upon tests, examinations or analyses
of documents that he conducted in which he did not render an opinion? If so, state the following:
a. State a description of each report that was made.
b. The date that each report was made.
c. The name or other means of identification of the person to whom this report was
submitted.
d. The name and address of the person who has present custody of the report.
Answer:
16. State the hourly rate charged by the above-named experts for (a) review of material;
(b) travel; (c) deposition; and (d) trial.
Answer:Print Name:
STATE OF FLORIDA )
) SS.
COUNTY OF
The foregoing instrument was acknowledged before me this __ day of. ;
20. by , who is ( ) personally known to me or who has ( ) produced
the following identification , and who, after first being duly sworn,
deposes that the above Answers to Expert Interrogatories are true and correct to the best of
Affiant’s knowledge and belief.
Sworn and subscribed before me this __ day of , 20
NOTARY PUBLIC
(Print, Type or Stamp Commissioned Name of
Notary Public)
My commission expires:Print Name:
STATE OF FLORIDA )
) SS.
COUNTY OF
The foregoing instrument was acknowledged before me this __ day of. ;
20. by , who is ( ) personally known to me or who has ( ) produced
the following identification , and who, after first being duly sworn,
deposes that the above Answers to Expert Interrogatories are true and correct to the best of
Affiant’s knowledge and belief.
Sworn and subscribed before me this __ day of , 20
NOTARY PUBLIC
(Print, Type or Stamp Commissioned Name of
Notary Public)
My commission expires:
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Filing # 115163531 E-Filed 10/19/2020 10:08:51 AM IN THE CIRCUIT COURT OF THE 177 JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-19-026028 MLADEN MALOVIC and NEDA MALOVIC, Plaintiffs, va FAMILY SECURITY INSURANCE COMPANY, INC., Defendant. / DEFENDANT’S NOTICE OF SERVICE OF EXPERT INTERROGATORIES TO PLAINTIFFS Defendant, FAMILY SECURITY INSURANCE COMPANY, INC., by and through its undersigned counsel, hereby propounds the following Expert Interrogatories to Plaintiffs, to be answered in writing, under oath, and within thirty (30) days after service hereof. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by e-mail via the Florida Courts E-Filing Portal on October 19, 2020 upon: Aaron D. Silvers, Esq., Weisser Elazar & Kantor, PLLC, Counsel for Plaintiffs, 800 East Broward Blvd, Ste 510, Fort Lauderdale, FL 33301; Service E-Mails: as@weklaw.com, cb@weklaw.com & pb@weklaw.com. BRESSLER, AMERY & Ross, P.C. 200 East Las Olas Blvd. Suite 1500 Fort Lauderdale, Florida 33301 T: 954.499.7979 F: 954.499.7969 E-Mail: miainsurance@bressler.com gplasencia@pbressler.com hzelinger@bressler.com By: /s/_ Gabriela A. Plasencia GABRIELA A. PLASENCIA, ESQ. Florida Bar No.: 115788 HOPE C. ZELINGER, ESQ. Florida Bar No.: 92173 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/19/2020 10:08:51 AM.****FIRST SET OF EXPERT INTERROGATORIES TO PL. TIFFS 1. Please state the name, last known address and telephone number of any and all expert witnesses that you expect to call to testify as expert witnesses on behalf of Plaintiffs at the trial of this cause, and as to each, please state with specificity the subject matter on which he/she is expected to testify and the substance of the facts and opinions to which he/she is expected to testify. Answer: 2. Please state the fields of expertise of any and all expert witnesses whose name(s) appear(s) in your answer to Interrogatory | above and set forth the professional education, training and experience held by each expert witness and a brief summary of his/her qualifications including professional society and association memberships, professional degrees and academic or professional honors. Alternatively, please attach a current curriculum vitae. Answer: 3. Please state whether or not any or all of the expert witnesses whose name(s) appear(s) in the answer to Interrogatory 1 above have prepared any kind of written report; and, if so, please state the date of the report, and the name and last known address and telephone number of the person who currently has custody and control of the report. Answer: 4. Please state whether or not any or all of the expert witnesses whose name(s) appear(s) in the answer to Interrogatory 1 above, have/has ever testified on behalf of Plaintiffs; and, if so, please state the number of times, whether the testimony was in court or by deposition, the date upon which the testimony was given and the case styles, and numbers and Court identifying information with regard to each occasion. Answer:5. Please state whether any or all of the expert witnesses whose name(s) appear(s) in your answer to Interrogatory 1 above have been provided with any kind of written report or factual summary and, if so, please state the name and last known address and telephone number of the person who currently has custody and control of the report. Answer: 6. Please state the total amount of damages being claimed as a result of this lawsuit and the individual and documentation relied upon in support of same. Please provide a breakdown of the total amount of damages sought under Coverage A, B, C & D. Answer: 7. Please state the general litigation experience of any and all expert witnesses whose name(s) appear(s) in your answer to Interrogatory 1 above and set forth for each expert witness named: a. The percentage of work performed for Defendants and the percentage of work performed for Plaintiffs. b. The expert’s involvement as an expert witness in terms of percentage of income derived from serving as an expert witness, percentage of hours spent serving as an expert witness and number of hours spent serving as an expert witness. c. The total number of times this expert has been hired by your law firm over the last three (3) years. Answer: 8. Please state, within the last three (3) years, all cases in which any expert witness whose name(s) appear(s) in the answer to Interrogatory 1 above, testified either at deposition or at trial. For each case named, for identification purposes, please state the name of the expert witness who testified, the case style, the case number, the Court, and all dates testimony was given. Answer:9. Please state, within the last three (3) years, all cases in which any expert witness whose name(s) appear(s) in the answer to Interrogatory 1 above has been retained to perform expert, litigation, or forensic services on behalf of the attorneys and/or law firms representing Plaintiffs in this litigation. Answer: 10. Please identify the total amount of money that each expert witness whose name(s) appear(s) in the answer to Interrogatory 1 above has been paid by Plaintiffs and/or counsel for Plaintiffs within the last three (3) years. Answer: ll. Please state, for each expert witness whose name(s) appear(s) in the answer to Interrogatory 1 above, the amount of time spent and the amount of compensation charged for services rendered in the pending case. Answer: 12. Please state, for each expert witness whose name(s) appear(s) in the answer to Interrogatory 1 above, if they have ever been to property located 1781 42" Terrace SW, Naples, FL, 34116, and if so, on what date(s). Answer: 13. For each expert disclosed, please provide the date the expert was retained and by whom. Answer:14. Pursuant to Florida Rule of Civil Procedure 1.280, please state the opinion that the expert is expected to testify and the summary and grounds for each opinion stated. Answer: 15. Did the expert submit any other reports based upon tests, examinations or analyses of documents that he conducted in which he did not render an opinion? If so, state the following: a. State a description of each report that was made. b. The date that each report was made. c. The name or other means of identification of the person to whom this report was submitted. d. The name and address of the person who has present custody of the report. Answer: 16. State the hourly rate charged by the above-named experts for (a) review of material; (b) travel; (c) deposition; and (d) trial. Answer:Print Name: STATE OF FLORIDA ) ) SS. COUNTY OF The foregoing instrument was acknowledged before me this __ day of. ; 20. by , who is ( ) personally known to me or who has ( ) produced the following identification , and who, after first being duly sworn, deposes that the above Answers to Expert Interrogatories are true and correct to the best of Affiant’s knowledge and belief. Sworn and subscribed before me this __ day of , 20 NOTARY PUBLIC (Print, Type or Stamp Commissioned Name of Notary Public) My commission expires:Print Name: STATE OF FLORIDA ) ) SS. COUNTY OF The foregoing instrument was acknowledged before me this __ day of. ; 20. by , who is ( ) personally known to me or who has ( ) produced the following identification , and who, after first being duly sworn, deposes that the above Answers to Expert Interrogatories are true and correct to the best of Affiant’s knowledge and belief. Sworn and subscribed before me this __ day of , 20 NOTARY PUBLIC (Print, Type or Stamp Commissioned Name of Notary Public) My commission expires: