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Filing # 109582362 E-Filed 06/30/2020 10:19:09 AM
IN THE COUNTY COURT OF THE
SEVENTEETH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
15020 ASSOCIATES REALTY
CASE NO.: CACE-19-022883
Plaintiff,
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
Peet
DEFENDANT CITIZENS PROPERTY INSURANCE CORPORATION'S
WITNESS LIST
COMES NOW, DEFENDANT, CITIZENS PROPERTY INSURANCE
CORPORATION, by and through undersigned counsel, and hereby files its Witness List:
1. Corporate Representative of Citizens Property Insurance Corporation
c/o undersigned counsel
Testimony: will provide testimony concerning Citizens’ pre-suit investigation,
determination of claim, factual basis of affirmative defenses.
2. Records Custodian for Citizens Property Insurance Corporation
c/o undersigned counsel
Testimony: will authenticate Citizens’ business records concerning claim at issue.
3. Corporate Representative for Royal Cabinetry & Millwork
3635 E 10" Court
Hialeah, FL 33013
Page 1 of 5
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/30/2020 10:19:08 AM.****Testimony: expected to testify concerning the repairs that were made to property
and costs incurred for same.
. Records Custodian for Royal Cabinetry & Millwork
3635 E 10" Court
Hialeah, FL 33013
Testimony: expected to authenticate business records, if any, created/received by
Royal Cabinetry & Millwork in the course of rendering services to the insured
property.
. Roger Russ,
Field Adjuster
Testimony: expected to testify concerning his inspection of the property pre-suit
. Ed Garcell
c/o Morgan & Morgan, P.A.
703 Waterford Way, Suite 1050
Miami, FL 33126
Testimony: expected to testify concerning the facts surrounding the loss as well
as Plaintiff's claim for damages.
. Michelle Garcell
c/o Morgan & Morgan, P.A.
703 Waterford Way, Suite 1050
Miami, FL 33126
Testimony: expected to testify concerning the facts surrounding the loss as well
as damages.
. Jorge Gilligan
c/o Morgan & Morgan, P.A.
703 Waterford Way, Suite 1050
Miami, FL 33126
Testimony: expected to testify concerning the facts surrounding the loss as well
as damages.
. Corporate Representative for 15020 Associates
c/o Morgan & Morgan, P.A.
703 Waterford Way, Suite 1050
Page 2 of 510.
11.
12.
13.
14.
Miami, FL 33126
Testimony: expected to testify concerning the facts surrounding the loss as well
as Plaintiff's claim for damages.
Records Custodian for 15020 Associates
c/o Morgan & Morgan, P.A.
703 Waterford Way, Suite 1050
Miami, FL 33126
Testimony: expected to authenticate documents Plaintiff will produce and/or
intends to introduce into evidence, if any, in support of the repairs that were made
to the property.
Corporate Representative for National Restoration Experts, Inc.
1800 N. Powerline Road, Suite 9
Pompano Beach, FL 33069
Testimony: expected to testify concerning services provided to the insured
property.
Record’s Custodian, National Restoration Experts, Inc.
1800 N. Powerline Road, Suite 9
Pompano Beach, FL 33069
Testimony: expected to authenticate business records, if any, created by National
Restoration Experts, Inc. in the course of rendering services to the insured
property.
Carlos Delgado
Eco Assurance, LLC
2451 SW 85'" Avenue
Miramar, FL 33025
Testimony: expected to testify concerning services provided to the insured
property.
Records Custodian
Eco Assurance, LLC
2451 SW 85 Avenue
Miramar, FL 33025
Testimony: expected to authenticate business records, if any, created by Eco
Assurance, LLC in the course of rendering services to the insured property.
Page 3 of 515. Corporate Representative for Serv Pro of Pembroke Pines
20911 Johnson Street, Suite 102
Pembroke Pines, FL 33029
Testimony: expected to testify concerning services provided to the insured
property.
16. Records Custodian for Serv Pro of Pembroke Pines
20911 Johnson Street, Suite 102
Pembroke Pines, FL 33029
Testimony: expected to authenticate business records, if any, created by Serv Pro
of Pembroke Pines in the course of rendering services to the insured property.
17. David M. Di Puglia
APC Engineering Enterprises, Inc.,
2510 W 10 Avenue
Hialeah, FL 33010
Testimony: Mr. Di Puglia has been listed in Plaintiff's witness list. Defendant has
no knowledge concerning Mr. Di Puglia’s involvement in this case.
18. Records Custodian
APC Engineering Enterprises, Inc.,
2510 W. 10 Avenue
Hialeah, FL 33010
Testimony: Defendant presumes APC Engineering Enterprises, Inc. was retained
by Plaintiff. Defendant has no knowledge concerning Mr. Di Puglia’s
involvement in this case.
19. Any and all expert witnesses required for rebuttal or impeachment purposes.
20. All witnesses listed in Plaintiff's Expert Witness List.
21. All witnesses listed in Plaintiff’s Fact Witness List.
22. All persons or entities referenced in any pre-trial Exhibit List.
23. All persons or entities referenced in any responses to interrogatories.
24. All persons or entities referenced in any documents produced by either party.
25. All persons or entities referenced by a witness in any deposition.
26. All persons whose depositions were taken in this action.
Page 4 of 527. Any person who through discovery between the date of this Witness Disclosure
and the deadline are found to have knowledge concerning the issues herein or any
other additional witness as continuing discovery may disclose.
28. All persons or entities that have inspected the subject property.
29. All persons or entities that have performed any repairs on the subject property.
30. All persons or entities that will be used for rebuttal purposes.
31. All persons or entities that will be used for impeachment purposes.
Defendant hereby retains the right to amend this witness list, including the
designation of experts, as needed.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the above and foregoing
has been furnished via email to Patrick Graves, Esq., Morgan & Morgan, P.A., 703
Waterford Way, Suite 1050, Miami, FL 33126, this 30 day of _JY"° 2020.
WADSWORTH, MARGREY & DIXON, LLP
Attorneys for Defendants
The Jane Building
261 N.E. 1* Street, 5 Floor
Miami, FL 33132
(305) 777-1000 Telephone
(305) 777-1001 Facsimile
By: (s/ Elizabeth Gonzalez
Elizabeth Gonzalez, Esq.
Florida Bar No. 58702
E-mail: eg@wmd-law.org
Christopher W. Wadsworth, Esq.
Florida Bar No.: 78026
E-mail: cw@wmd-law.org
Secondary: pleadings@wmd-law.org,
Page 5 of 5
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Filing # 109582362 E-Filed 06/30/2020 10:19:09 AM IN THE COUNTY COURT OF THE SEVENTEETH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA 15020 ASSOCIATES REALTY CASE NO.: CACE-19-022883 Plaintiff, CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. Peet DEFENDANT CITIZENS PROPERTY INSURANCE CORPORATION'S WITNESS LIST COMES NOW, DEFENDANT, CITIZENS PROPERTY INSURANCE CORPORATION, by and through undersigned counsel, and hereby files its Witness List: 1. Corporate Representative of Citizens Property Insurance Corporation c/o undersigned counsel Testimony: will provide testimony concerning Citizens’ pre-suit investigation, determination of claim, factual basis of affirmative defenses. 2. Records Custodian for Citizens Property Insurance Corporation c/o undersigned counsel Testimony: will authenticate Citizens’ business records concerning claim at issue. 3. Corporate Representative for Royal Cabinetry & Millwork 3635 E 10" Court Hialeah, FL 33013 Page 1 of 5 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/30/2020 10:19:08 AM.****Testimony: expected to testify concerning the repairs that were made to property and costs incurred for same. . Records Custodian for Royal Cabinetry & Millwork 3635 E 10" Court Hialeah, FL 33013 Testimony: expected to authenticate business records, if any, created/received by Royal Cabinetry & Millwork in the course of rendering services to the insured property. . Roger Russ, Field Adjuster Testimony: expected to testify concerning his inspection of the property pre-suit . Ed Garcell c/o Morgan & Morgan, P.A. 703 Waterford Way, Suite 1050 Miami, FL 33126 Testimony: expected to testify concerning the facts surrounding the loss as well as Plaintiff's claim for damages. . Michelle Garcell c/o Morgan & Morgan, P.A. 703 Waterford Way, Suite 1050 Miami, FL 33126 Testimony: expected to testify concerning the facts surrounding the loss as well as damages. . Jorge Gilligan c/o Morgan & Morgan, P.A. 703 Waterford Way, Suite 1050 Miami, FL 33126 Testimony: expected to testify concerning the facts surrounding the loss as well as damages. . Corporate Representative for 15020 Associates c/o Morgan & Morgan, P.A. 703 Waterford Way, Suite 1050 Page 2 of 510. 11. 12. 13. 14. Miami, FL 33126 Testimony: expected to testify concerning the facts surrounding the loss as well as Plaintiff's claim for damages. Records Custodian for 15020 Associates c/o Morgan & Morgan, P.A. 703 Waterford Way, Suite 1050 Miami, FL 33126 Testimony: expected to authenticate documents Plaintiff will produce and/or intends to introduce into evidence, if any, in support of the repairs that were made to the property. Corporate Representative for National Restoration Experts, Inc. 1800 N. Powerline Road, Suite 9 Pompano Beach, FL 33069 Testimony: expected to testify concerning services provided to the insured property. Record’s Custodian, National Restoration Experts, Inc. 1800 N. Powerline Road, Suite 9 Pompano Beach, FL 33069 Testimony: expected to authenticate business records, if any, created by National Restoration Experts, Inc. in the course of rendering services to the insured property. Carlos Delgado Eco Assurance, LLC 2451 SW 85'" Avenue Miramar, FL 33025 Testimony: expected to testify concerning services provided to the insured property. Records Custodian Eco Assurance, LLC 2451 SW 85 Avenue Miramar, FL 33025 Testimony: expected to authenticate business records, if any, created by Eco Assurance, LLC in the course of rendering services to the insured property. Page 3 of 515. Corporate Representative for Serv Pro of Pembroke Pines 20911 Johnson Street, Suite 102 Pembroke Pines, FL 33029 Testimony: expected to testify concerning services provided to the insured property. 16. Records Custodian for Serv Pro of Pembroke Pines 20911 Johnson Street, Suite 102 Pembroke Pines, FL 33029 Testimony: expected to authenticate business records, if any, created by Serv Pro of Pembroke Pines in the course of rendering services to the insured property. 17. David M. Di Puglia APC Engineering Enterprises, Inc., 2510 W 10 Avenue Hialeah, FL 33010 Testimony: Mr. Di Puglia has been listed in Plaintiff's witness list. Defendant has no knowledge concerning Mr. Di Puglia’s involvement in this case. 18. Records Custodian APC Engineering Enterprises, Inc., 2510 W. 10 Avenue Hialeah, FL 33010 Testimony: Defendant presumes APC Engineering Enterprises, Inc. was retained by Plaintiff. Defendant has no knowledge concerning Mr. Di Puglia’s involvement in this case. 19. Any and all expert witnesses required for rebuttal or impeachment purposes. 20. All witnesses listed in Plaintiff's Expert Witness List. 21. All witnesses listed in Plaintiff’s Fact Witness List. 22. All persons or entities referenced in any pre-trial Exhibit List. 23. All persons or entities referenced in any responses to interrogatories. 24. All persons or entities referenced in any documents produced by either party. 25. All persons or entities referenced by a witness in any deposition. 26. All persons whose depositions were taken in this action. Page 4 of 527. Any person who through discovery between the date of this Witness Disclosure and the deadline are found to have knowledge concerning the issues herein or any other additional witness as continuing discovery may disclose. 28. All persons or entities that have inspected the subject property. 29. All persons or entities that have performed any repairs on the subject property. 30. All persons or entities that will be used for rebuttal purposes. 31. All persons or entities that will be used for impeachment purposes. Defendant hereby retains the right to amend this witness list, including the designation of experts, as needed. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via email to Patrick Graves, Esq., Morgan & Morgan, P.A., 703 Waterford Way, Suite 1050, Miami, FL 33126, this 30 day of _JY"° 2020. WADSWORTH, MARGREY & DIXON, LLP Attorneys for Defendants The Jane Building 261 N.E. 1* Street, 5 Floor Miami, FL 33132 (305) 777-1000 Telephone (305) 777-1001 Facsimile By: (s/ Elizabeth Gonzalez Elizabeth Gonzalez, Esq. Florida Bar No. 58702 E-mail: eg@wmd-law.org Christopher W. Wadsworth, Esq. Florida Bar No.: 78026 E-mail: cw@wmd-law.org Secondary: pleadings@wmd-law.org, Page 5 of 5