Preview
Filing# 136079006 E-Filed 10/07/2021 09:05:32 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
JESUS VILLEDA AND JHANETH VILLEDA,
Plaintiff.
V
CASE NO.: CACE-19-021344
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
i
DEFENDANT'S WITNESS LIST
Defendant, CITIZENS PROPERTY INSURANCE CORPORATION ("Citizens"),
by and
through the undersigned counsel, and pursuant to the Florida Rules of Civil Procedure and this
Honorable Court's Uniform Order SettingCause for Jury Trial,Pre-Trial Conference and Pre-Trial
Instructions,hereby files its fact witness list as follows:
1.
Defendant's CorporateRepresentative
Citizens PropertyInsurance Corporation
301 W Bay Street,Suite 1300
Jacksonville,Florida 32202
2.
Donald Wilcox - Damage Expert
Pelican Solutions
210 Oregon Lane
Boca Raton, FL 33487
-
3.
Harold Bryant Field and Desk Adjuster
Citizens PropertyInsurance Corporation
301 W Bay Street,Suite 1300
Jacksonville,Florida 32202
4.
Xpress Restoration,INC
10891 NW 17TH ST UNIT 135
Miami, FL 33172
5.
Jesus Villeda and Jhaneth Villeda
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/07/2021 09:05:32 AM.****
CASE NO: 2018-036351-CA-01
C/O Plaintiff's Counsel
12708 NW 15TH ST
Coconut Grove, Florida 33133
6.
Any and all individuals mentioned duringdepositions.
7.
Any and all individuals listed or mentioned in either Plaintiff's or Defendant's responses
to discoveryrequests.
8.
All witnesses for impeachment or rebuttal purposes.
9.
All witnesses on Plaintiff's Witness List.
10. All witnesses,includingexperts, discovered between now and trial.
Citizens reserves the rightto supplement and/or amend its witness list with reasonable notice
to Plaintiff. Citizens further reserves the rightto call and/or produce any and all witnesses and or
documentary evidence listed by the parties,
to any and all impeachment and/or rebuttal witnesses and
exhibits necessary, and to call and/or produce any and all newly discovered witnesses and/or
documentary evidence upon notice to the parties.
DEFENDANT'S EXHIBIT LIST
1.
Copy of Citizens Property Insurance Corporations'Policy # 02178693, for policyterm
running from October 16, 2018, through October 16,2019.
2.
Copies of all permittingrecords, if any, from Broward County regarding Plaintiff's
property located at 12702 NW 15th ST, Sunrise,FL 33323-3138.
3.
Copies of all photographs taken by Field Adjuster,Harold Bryant.
4.
Copies of any reports from, photographstaken by, or documents or treatises relied upon by
any defense experts.
CASE NO: 2018-036351-CA-01
5.
Copies of any reports from, photographstaken by, or documents or treatises relied upon by
Plaintiff's experts.
6.
Copies of any statements from Plaintiff.
7.
Copies of any criminal convictions for Plaintiff.
8.
Copies of any criminal convictions for any witnesses listed by Plaintiff.
9.
Copies of all records of all insurance applicationsappliedfor,for the property located at
12702 NW 15th ST, Sunrise,FL 33323-3138.
10. Copies of Plaintiff's mortgages, promissory notes, closingdocuments, inspections,
and
deeds to property pertainingto the property located at 12702 NW 15th ST, Sunrise,FL
33323-3138.
11. Any and all blueprints,surveys, or other documents pertainingto the structure and
architecture regardingthe property located at 12702 NW 15th ST, Sunrise,FL 33323-3138.
12. Any and all photographs ofPlaintiff's property located at 12702 NW 15th ST, Sunrise,FL
33323-3138.
13. Copies ofrecords regardingPlaintiff's property located at 12702 NW 15th ST, Sunrise,FL
33323-3138.
14. Copy of any documents given to Plaintiff by priorowner of subjectproperty or by the
builder and or developerofthe subjectproperty located at 12702 NW 15th ST, Sunrise,FL
33323-3138.
15. Any and all statements and correspondence pertainingto Plaintiff's claim, between
Plaintiff and Defendant.
16. Copies of letters sent to Plaintiff by Defendant.
17. Copies of photographs,descriptionsand estimates provided by Plaintiff's loss consultant
and/or Public Adjuster.
18. Depositiontranscripts
of all witnesses with all exhibits.
CASE NO: 2018-036351-CA-01
19. Deposition transcripts
with exhibits of any persons deposed or scheduled or yet to be
deposed in this matter.
20. Claim History of Plaintiff.
21. All photographs and videos taken or to be taken by Plaintiff and Plaintiff" s agents,
representatives,
or anyone else in this action.
22. All correspondence sent to Plaintiff and/or Plaintiff's agents, representatives,
or anyone
else from Citizens and/or affiliate.
23. All correspondence received from Plaintiff and/or Plaintiff's agents, representatives
regardingthis action.
24. Any and all Answers to all Interrogatories,
filed by Plaintiff in this matter.
25. Any and all responses to all Requests for Admissions filed by Plaintiff in this matter.
26. Any and all Responses to all Requests for Production, Supplemental Requests for
Production filed by Plaintiff,
along with all documents responsiveto same.
27. All non-privilegeddocuments from Citizens' claim file for this matter.
28. Any documents contained in the Broward County Clerk ofCourt's file regardingthe instant
case and Plaintiff's additional cases for property damages.
29. Any documents contained in the Broward County Clerk of Court's file regardingPlaintiff.
30. Any documents contained in the Broward County Clerk of Court's file regarding the
property located at 12702 NW 15th ST, Sunrise,FL 33323-3138.
31. All diagrams,sketches,and/or drawings regardingthis action.
32. Any and all documents produced by Defendant, Plaintiff,
non-parties,and anyone else in
this action.
CASE NO: 2018-036351-CA-01
33. Any and all documents relied upon by experts, agents, representatives,
and/or anyone else
in this action.
34. Any and all expert reports and photos prepared by Plaintiff"s experts and or Plaintiff's
agents.
35. Demonstrative aids preparedby experts or anyone else in this action.
36. Any and all professionallicensing,certifications,
and business licensingregardingany and
all witnesses listed by Plaintiff and Defendant.
37. Any and all documents exchanged in response to requests for production,requests for
copies,propounded by any party to this suit.
38. Any and all exhibits listed by any other parties.
39. Any and all Answers to all Interrogatories,
Supplemental Interrogatories
filed by any
Plaintiff in any other Broward County litigation
matter or federal court matter.
40. Any and all answers to all Requests for Admissions filed by any Plaintiff in any other
Broward County litigation
matter or federal court matter.
41. Any and all Responses to all Request for Productions and responsivedocuments produced
in response to same filed by any Plaintiff in any other Broward County litigation
matter or
federal court matter.
Defendant reserves its rightto supplement this list as discovery proceeds.
CASE NO: 2018-036351-CA-01
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy ofthe foregoinghas been provided
via electronic correspondence to: Kaneily A. Valdes, Esq. at eservice@mellawyers.com on this
2 day ofOctober,2021.
RUBINTON SIMMS, P.A.
3440 Hollywood Blvd, Suite 460
Hollywood, Florida 33021
Telephone:
954-251-5500
Fax:
954-251-5501
By: /s/ Jessica Tome
JEFFREY A. RUBINTON, ESQ.
Florida Ban 821756
JESSICA TOME, ESQ.
Florida Ban 1028045
Primary E-Mail: tome@rubintonlaw.corn
Secondary E-Mail: jferrari@rubtintonlaw.com
Preview
Filing# 136079006 E-Filed 10/07/2021 09:05:32 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JESUS VILLEDA AND JHANETH VILLEDA, Plaintiff. V CASE NO.: CACE-19-021344 CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. i DEFENDANT'S WITNESS LIST Defendant, CITIZENS PROPERTY INSURANCE CORPORATION ("Citizens"), by and through the undersigned counsel, and pursuant to the Florida Rules of Civil Procedure and this Honorable Court's Uniform Order SettingCause for Jury Trial,Pre-Trial Conference and Pre-Trial Instructions,hereby files its fact witness list as follows: 1. Defendant's CorporateRepresentative Citizens PropertyInsurance Corporation 301 W Bay Street,Suite 1300 Jacksonville,Florida 32202 2. Donald Wilcox - Damage Expert Pelican Solutions 210 Oregon Lane Boca Raton, FL 33487 - 3. Harold Bryant Field and Desk Adjuster Citizens PropertyInsurance Corporation 301 W Bay Street,Suite 1300 Jacksonville,Florida 32202 4. Xpress Restoration,INC 10891 NW 17TH ST UNIT 135 Miami, FL 33172 5. Jesus Villeda and Jhaneth Villeda *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/07/2021 09:05:32 AM.**** CASE NO: 2018-036351-CA-01 C/O Plaintiff's Counsel 12708 NW 15TH ST Coconut Grove, Florida 33133 6. Any and all individuals mentioned duringdepositions. 7. Any and all individuals listed or mentioned in either Plaintiff's or Defendant's responses to discoveryrequests. 8. All witnesses for impeachment or rebuttal purposes. 9. All witnesses on Plaintiff's Witness List. 10. All witnesses,includingexperts, discovered between now and trial. Citizens reserves the rightto supplement and/or amend its witness list with reasonable notice to Plaintiff. Citizens further reserves the rightto call and/or produce any and all witnesses and or documentary evidence listed by the parties, to any and all impeachment and/or rebuttal witnesses and exhibits necessary, and to call and/or produce any and all newly discovered witnesses and/or documentary evidence upon notice to the parties. DEFENDANT'S EXHIBIT LIST 1. Copy of Citizens Property Insurance Corporations'Policy # 02178693, for policyterm running from October 16, 2018, through October 16,2019. 2. Copies of all permittingrecords, if any, from Broward County regarding Plaintiff's property located at 12702 NW 15th ST, Sunrise,FL 33323-3138. 3. Copies of all photographs taken by Field Adjuster,Harold Bryant. 4. Copies of any reports from, photographstaken by, or documents or treatises relied upon by any defense experts. CASE NO: 2018-036351-CA-01 5. Copies of any reports from, photographstaken by, or documents or treatises relied upon by Plaintiff's experts. 6. Copies of any statements from Plaintiff. 7. Copies of any criminal convictions for Plaintiff. 8. Copies of any criminal convictions for any witnesses listed by Plaintiff. 9. Copies of all records of all insurance applicationsappliedfor,for the property located at 12702 NW 15th ST, Sunrise,FL 33323-3138. 10. Copies of Plaintiff's mortgages, promissory notes, closingdocuments, inspections, and deeds to property pertainingto the property located at 12702 NW 15th ST, Sunrise,FL 33323-3138. 11. Any and all blueprints,surveys, or other documents pertainingto the structure and architecture regardingthe property located at 12702 NW 15th ST, Sunrise,FL 33323-3138. 12. Any and all photographs ofPlaintiff's property located at 12702 NW 15th ST, Sunrise,FL 33323-3138. 13. Copies ofrecords regardingPlaintiff's property located at 12702 NW 15th ST, Sunrise,FL 33323-3138. 14. Copy of any documents given to Plaintiff by priorowner of subjectproperty or by the builder and or developerofthe subjectproperty located at 12702 NW 15th ST, Sunrise,FL 33323-3138. 15. Any and all statements and correspondence pertainingto Plaintiff's claim, between Plaintiff and Defendant. 16. Copies of letters sent to Plaintiff by Defendant. 17. Copies of photographs,descriptionsand estimates provided by Plaintiff's loss consultant and/or Public Adjuster. 18. Depositiontranscripts of all witnesses with all exhibits. CASE NO: 2018-036351-CA-01 19. Deposition transcripts with exhibits of any persons deposed or scheduled or yet to be deposed in this matter. 20. Claim History of Plaintiff. 21. All photographs and videos taken or to be taken by Plaintiff and Plaintiff" s agents, representatives, or anyone else in this action. 22. All correspondence sent to Plaintiff and/or Plaintiff's agents, representatives, or anyone else from Citizens and/or affiliate. 23. All correspondence received from Plaintiff and/or Plaintiff's agents, representatives regardingthis action. 24. Any and all Answers to all Interrogatories, filed by Plaintiff in this matter. 25. Any and all responses to all Requests for Admissions filed by Plaintiff in this matter. 26. Any and all Responses to all Requests for Production, Supplemental Requests for Production filed by Plaintiff, along with all documents responsiveto same. 27. All non-privilegeddocuments from Citizens' claim file for this matter. 28. Any documents contained in the Broward County Clerk ofCourt's file regardingthe instant case and Plaintiff's additional cases for property damages. 29. Any documents contained in the Broward County Clerk of Court's file regardingPlaintiff. 30. Any documents contained in the Broward County Clerk of Court's file regarding the property located at 12702 NW 15th ST, Sunrise,FL 33323-3138. 31. All diagrams,sketches,and/or drawings regardingthis action. 32. Any and all documents produced by Defendant, Plaintiff, non-parties,and anyone else in this action. CASE NO: 2018-036351-CA-01 33. Any and all documents relied upon by experts, agents, representatives, and/or anyone else in this action. 34. Any and all expert reports and photos prepared by Plaintiff"s experts and or Plaintiff's agents. 35. Demonstrative aids preparedby experts or anyone else in this action. 36. Any and all professionallicensing,certifications, and business licensingregardingany and all witnesses listed by Plaintiff and Defendant. 37. Any and all documents exchanged in response to requests for production,requests for copies,propounded by any party to this suit. 38. Any and all exhibits listed by any other parties. 39. Any and all Answers to all Interrogatories, Supplemental Interrogatories filed by any Plaintiff in any other Broward County litigation matter or federal court matter. 40. Any and all answers to all Requests for Admissions filed by any Plaintiff in any other Broward County litigation matter or federal court matter. 41. Any and all Responses to all Request for Productions and responsivedocuments produced in response to same filed by any Plaintiff in any other Broward County litigation matter or federal court matter. Defendant reserves its rightto supplement this list as discovery proceeds. CASE NO: 2018-036351-CA-01 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy ofthe foregoinghas been provided via electronic correspondence to: Kaneily A. Valdes, Esq. at eservice@mellawyers.com on this 2 day ofOctober,2021. RUBINTON SIMMS, P.A. 3440 Hollywood Blvd, Suite 460 Hollywood, Florida 33021 Telephone: 954-251-5500 Fax: 954-251-5501 By: /s/ Jessica Tome JEFFREY A. RUBINTON, ESQ. Florida Ban 821756 JESSICA TOME, ESQ. Florida Ban 1028045 Primary E-Mail: tome@rubintonlaw.corn Secondary E-Mail: jferrari@rubtintonlaw.com