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Filing# 140627442 E-Filed 12/17/2021 06:09:49 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
CAMALA LEWIS DIXON,
Plaintiff,
V
CASE NO.: CACE-20-017636
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
PLAINTIFF'S FACT WITNESS AND EXHIBIT LIST
Plaintiff,Camala Lewis Dixon, by and through her undersigned attorneys, lists the
followingwitnesses and exhibits in compliance with this Court's Order of July 13, 2021.
The
Plaintiff reserves her rightto update this witness and exhibits list as additional witnesses are
determined in discoveryor pre-trial
investigation.
A. WITNESSES:
1.
Camala Lewis Dixon
c/o Adam Shamir, Esq.
800 East Broward Boulevard, Suite 510
Fort Lauderdale, Florida 33301
2.
David Y. Huebner
Stellar Public AdjustingServices
2450 NE Miami Gardens Drive, Suite 200
Miami, Florida 33180
3
Corporate Representative
ASAP Restoration Corporation
1805 S. Powerline Road, Unit A106
Deerfield Beach, Florida 33442
4.
Corporate Representative
Universal Property and Casualty Insurance Company
c/o Edgard K. Cespedes, Esq.
Akerman LLP
98 SE 7th Street,Suite 1100
Miami, Florida 33131
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/17/2021 06:09:49 PM.****
5.
Custodian of Records
Universal Propertyand CasualtyInsurance Company
c/o Edgard K. Cespedes, Esq.
Akerman LLP
98 SE 7th Street,Suite 1100
Miami, Florida 33131
6.
Gabriel Gonzalez
Alder Adjusting Corporation
c/o Edgard K. Cespedes, Esq.Akerman LLP
98 SE 7th Street,Suite 1100
Miami, Florida 33131
7.
Any and all impeachment or rebuttal witnesses are hereby reserved by Plaintiff to
be used at trial.
8.
All witnesses listed by Defendant to which Plaintiff does not object.
9-
Plaintiffreserves the rightto objectto any and all witnesses listed by other parties
to this action and reserves the rightto amend the schedule of witnesses should any
additional witnesses be identified through discovery.
10.
Plaintiffhereby
reserves the rightto call and/or produce any and all witnesses
and/or documentary evidence listed by the parties;to call and/or produce any and
all impeachment and/or rebuttal witnesses;and to call and/or produce any and all
newly discovered witnesses and/or documentary evidence upon notice to the
parties.
Plaintiffreserves the rightto amend this Witness Disclosure pending further discovery,without
waiving objectionsto same.
Plaintiffreserves the rightto objectto any Witness listed by Defendant in this action.
Plaintiffreserves the rightto list any witnesses whose existence becomes known after the filing
of this Witness Disclosure,without waiving objectionto same.
B. EXHIBITS:
1
Universal Property & Casualty Insurance Company Policy
2.
Stellar Public Adjusting Services - Repair Estimate
3.
Stellar Public Adjusting Services - Photographs
4.
Defendant' s Responses to Plaintiff' s Request for Production, including the documents
produced.
5.
Defendant's Answers to Plaintiff' s Interrogatories.
6.
Any and all depositiontranscriptsof any and all depositionstaken during the instant
lawsuit.
7.
Any and all exhibits attached to transcriptsof any and all depositionstaken during the
instant lawsuit.
8
Any and all estimates prepared by Defendant or on behalf of the Defendant.
9.
Any and all reports prepared by Defendant or on behalf of the Defendant.
10.
Any and all photographs,and photograph reports prepared by Defendant or on behalf of
the Defendant.
11.
Any and all expert reports prepared on behalf of any Defendant's experts, if any.
12.
Any and all expert reports prepared on behalf of Plaintiff' s experts, if any.
13.
Any and all correspondence from Defendant to Plaintiff priorto the instant lawsuit.
14.
Any and all correspondence from Plaintiff to Defendant priorto instant lawsuit.
15.
Any and all correspondence from the Insured' s public adjusterto Defendant priorto instant
lawsuit.
16.
Any and all correspondence from Insured to Defendant priorto the instant lawsuit.
17.
Any and all documents that have been produced during the course of discovery in the
instant lawsuit.
18.
Any and all exhibits listed by other partieshereto,without waiving objections.
19.
Any and all Answers to Interrogatories,
Responses to Requests to Produce, Responses to
Requests for Admissions, Depositions,Deposition Exhibits,Production from non-parties,
and any and all other pleadingsor discovery filed in the instant action,without waving
objections.
20.
Any and all correspondence between Defendant and any party or non-party in this action.
21.
Any and all documents, estimates, reports from Plaintiff' s expert.
22.
Any and all Affidavits filed in the instant case.
23.
Any and all documents or estimates prepared by Defendant or Defendant's representatives
experts.
24.
Any and all exhibits necessary for impeachment and/or rebuttal purposes.
25.
Any and all reports, estimates or invoices from individuals on Witness List or Expert
Witness List filed by either party.
26.
Any and all documents provided in response to request for copies.
27.
Any and all documents provided in response to Notice of Taking Deposition Duces Tecum.
28.
Plaintiffreserves the rightto amend/supplement this Exhibit List priorto Trial upon proper
notice to all parties.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished to: Edgard K. Cespedes, Esquire, Akerman LLP, Attorney for Defendant,
Universal Property & Casualty Insurance Company, using the Florida Courts E-Filing
Portal, to: edgard.cespedes@akerman.com as well as maria.revoredo@akerman.com on this
17th day of December, 2021.
By-. /sl Adam Shamir
ADAM SHAMIR, ESQ.
Florida Bar No: 99647
WEISSER ELAZAR & KANTOR, PLLC
Attorney for Plaintiff
800 East Broward Boulevard, Suite 510
Fort Lauderdale, Florida 33301
T: (954)486-2623
F: (954) 572-8695
Email: ASH@WEKLaw.com
KL@WEKLaw.com
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Filing# 140627442 E-Filed 12/17/2021 06:09:49 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CAMALA LEWIS DIXON, Plaintiff, V CASE NO.: CACE-20-017636 UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i PLAINTIFF'S FACT WITNESS AND EXHIBIT LIST Plaintiff,Camala Lewis Dixon, by and through her undersigned attorneys, lists the followingwitnesses and exhibits in compliance with this Court's Order of July 13, 2021. The Plaintiff reserves her rightto update this witness and exhibits list as additional witnesses are determined in discoveryor pre-trial investigation. A. WITNESSES: 1. Camala Lewis Dixon c/o Adam Shamir, Esq. 800 East Broward Boulevard, Suite 510 Fort Lauderdale, Florida 33301 2. David Y. Huebner Stellar Public AdjustingServices 2450 NE Miami Gardens Drive, Suite 200 Miami, Florida 33180 3 Corporate Representative ASAP Restoration Corporation 1805 S. Powerline Road, Unit A106 Deerfield Beach, Florida 33442 4. Corporate Representative Universal Property and Casualty Insurance Company c/o Edgard K. Cespedes, Esq. Akerman LLP 98 SE 7th Street,Suite 1100 Miami, Florida 33131 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/17/2021 06:09:49 PM.**** 5. Custodian of Records Universal Propertyand CasualtyInsurance Company c/o Edgard K. Cespedes, Esq. Akerman LLP 98 SE 7th Street,Suite 1100 Miami, Florida 33131 6. Gabriel Gonzalez Alder Adjusting Corporation c/o Edgard K. Cespedes, Esq.Akerman LLP 98 SE 7th Street,Suite 1100 Miami, Florida 33131 7. Any and all impeachment or rebuttal witnesses are hereby reserved by Plaintiff to be used at trial. 8. All witnesses listed by Defendant to which Plaintiff does not object. 9- Plaintiffreserves the rightto objectto any and all witnesses listed by other parties to this action and reserves the rightto amend the schedule of witnesses should any additional witnesses be identified through discovery. 10. Plaintiffhereby reserves the rightto call and/or produce any and all witnesses and/or documentary evidence listed by the parties;to call and/or produce any and all impeachment and/or rebuttal witnesses;and to call and/or produce any and all newly discovered witnesses and/or documentary evidence upon notice to the parties. Plaintiffreserves the rightto amend this Witness Disclosure pending further discovery,without waiving objectionsto same. Plaintiffreserves the rightto objectto any Witness listed by Defendant in this action. Plaintiffreserves the rightto list any witnesses whose existence becomes known after the filing of this Witness Disclosure,without waiving objectionto same. B. EXHIBITS: 1 Universal Property & Casualty Insurance Company Policy 2. Stellar Public Adjusting Services - Repair Estimate 3. Stellar Public Adjusting Services - Photographs 4. Defendant' s Responses to Plaintiff' s Request for Production, including the documents produced. 5. Defendant's Answers to Plaintiff' s Interrogatories. 6. Any and all depositiontranscriptsof any and all depositionstaken during the instant lawsuit. 7. Any and all exhibits attached to transcriptsof any and all depositionstaken during the instant lawsuit. 8 Any and all estimates prepared by Defendant or on behalf of the Defendant. 9. Any and all reports prepared by Defendant or on behalf of the Defendant. 10. Any and all photographs,and photograph reports prepared by Defendant or on behalf of the Defendant. 11. Any and all expert reports prepared on behalf of any Defendant's experts, if any. 12. Any and all expert reports prepared on behalf of Plaintiff' s experts, if any. 13. Any and all correspondence from Defendant to Plaintiff priorto the instant lawsuit. 14. Any and all correspondence from Plaintiff to Defendant priorto instant lawsuit. 15. Any and all correspondence from the Insured' s public adjusterto Defendant priorto instant lawsuit. 16. Any and all correspondence from Insured to Defendant priorto the instant lawsuit. 17. Any and all documents that have been produced during the course of discovery in the instant lawsuit. 18. Any and all exhibits listed by other partieshereto,without waiving objections. 19. Any and all Answers to Interrogatories, Responses to Requests to Produce, Responses to Requests for Admissions, Depositions,Deposition Exhibits,Production from non-parties, and any and all other pleadingsor discovery filed in the instant action,without waving objections. 20. Any and all correspondence between Defendant and any party or non-party in this action. 21. Any and all documents, estimates, reports from Plaintiff' s expert. 22. Any and all Affidavits filed in the instant case. 23. Any and all documents or estimates prepared by Defendant or Defendant's representatives experts. 24. Any and all exhibits necessary for impeachment and/or rebuttal purposes. 25. Any and all reports, estimates or invoices from individuals on Witness List or Expert Witness List filed by either party. 26. Any and all documents provided in response to request for copies. 27. Any and all documents provided in response to Notice of Taking Deposition Duces Tecum. 28. Plaintiffreserves the rightto amend/supplement this Exhibit List priorto Trial upon proper notice to all parties. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to: Edgard K. Cespedes, Esquire, Akerman LLP, Attorney for Defendant, Universal Property & Casualty Insurance Company, using the Florida Courts E-Filing Portal, to: edgard.cespedes@akerman.com as well as maria.revoredo@akerman.com on this 17th day of December, 2021. By-. /sl Adam Shamir ADAM SHAMIR, ESQ. Florida Bar No: 99647 WEISSER ELAZAR & KANTOR, PLLC Attorney for Plaintiff 800 East Broward Boulevard, Suite 510 Fort Lauderdale, Florida 33301 T: (954)486-2623 F: (954) 572-8695 Email: ASH@WEKLaw.com KL@WEKLaw.com