Trial Materials: Sage Beach Condominium Association, Inc., et al Plaintiff vs. PMG Driftwood LLC , et al Defendant

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                                Filing# 144789602 E-Filed 03/01/2022 10:11:44 AM
 IN THE CIRCUIT COURT OF THE SEVENTHEETH JUDICIAL CIRCUIT,
 IN AND FOR BROWARD COUNTY, FLORIDA
 SAGE BEACH CONDOMINIUM
 ASSOCIATION, INC., a Florida not-for-profit
 corporation,
 Plaintiff,
 V
 CASE NO.: CACE-20017530
 DIVISION: 07
 PMG DRIFTWOOD, LLC, a Florida limited
 liability
 company; GLENEWINKEL
 CONSTRUCTION COMPANY, LLC, a Florida
 CONSOLIDATED WITH
 limited liability
 company; URVANX, INC., a
 CASE NO. CACE-20017790
 Florida corporation;SHAMROCK
 ENGINEERING CORP., a Florida corporation,
 CALVIN, GIORDANO & ASSOCIATES, INC.,
 a Florida corporation;and CHM STRUCTURAL
 ENGINEERS, LLC, a Florida limited liability
 Company; ARMSTRONG AIR CONDITION &
 HEATING OF CENTRAL FLORIDA, INC., a
 Florida corporation;ASSOCIATED STEEL AND
 ALUMINUM, INC., a Florida corporation;
 B. CODY PLUMBING, INC., a Florida corporation;
 BRADFORD PRODUCTS, LLC, a North Carolina
 limited liability
 company; BUILDING ENVELOPE
 SYSTEMS, INC., a Florida corporation;
 CONSTRUCTION SPECIALTIES, INC., a New
 Jersey corporation;DUN-RITE MARBLE &
 GRANIT, INC., a Florida corporation;EAST
 COAST CONTRACTORS SUPPLY, INC., a Florida
 Corporation;FERGUSON ENTERPRISES, INC., a
 Florida corporation;FINE LINE ELECTRIC, INC., a
 Florida corporation;FLOOD PANEL, LLC, a Florida
 limited liability
 company; HOLLYWOOD STONE,
 INC., a Florida corporation;J.L.K. CAUKING AND
 COATINGS COMPANY, a Florida corporation;
 LUSHLIFE, LLC, a Florida limited liability
 company;
 NEW DOOR INSTALLATION CO., a Florida
 corporation;NEXT DOOR DISTRIBUTION
 COMPANY, an inactive Florida corporation;R&L
 PAINTING, INC., a Florida corporation;ROSEN
 MATERIALS, LLC, a Florida limited liability
 company;
 SECURITY INNOVATIVE SOLUTIONS, INC.,
 a Florida corporation;SOUTHERN COAST
 ENTERPRISES, INC., a Florida corporation;
 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/01/2022 10:11:44 AM.****
 SOUTH DADE LIGHTING, INC., a Florida
 Corporation;SOUTHERN FIRE CONTROL,
 INC., a Florida corporation;TEKTON
 CONSTRUCTION, CORP., a Florida Corporation;
 ZARRELLA CONSTRUCTION, INC., a Florida
 corporation;
 Defendants.
 I
 PMG DRIFTWOOD, LLC, a Florida
 limited liability
 company,
 Counter-Plaintiff,
 V
 SAGE BEACH CONDOMINIUM
 ASSOCIATION, INC., a Florida not-for-profit
 corporation,
 Counter-Defendant.
 I
 HOLLYWOOD STONE, INC.'s EXPERT WITNESS DISCLOSURE
 Defendant HOLLYWOOD STONE, INC. ("HOLLYWOOD STONE") by and through
 its undersigned counsel, and pursuant to this Court's Case Management Order hereby files its
 Expert Witness Disclosure, and designatesthe followingexpert witness:
 1.
 Identity of Expert. The identityof the expert this Defendant intends to call at
 trial is:
 Luke Miorelli,P.E.
 MEC Forensics,LLC
 4715 North Harbor City Blvd.
 Melbourne, Fl 32935
 2.
 Subject Matter of Testimony and Substance of Opinions: Substance of facts
 and opinions about which Mr. Miorelli may testifyinclude testimony for and on behalf of
 HOLLYWOOD STONE to rebut the allegednature and extent of any construction defects,
 deficiencies,code violations,industrystandard violations,contractual deviations,and/or damages
 at the Projectthat is the subjectmatter ofthis litigation,
 the cause of any such allegeddefects,damages,
 and the reasonableness and quantificationof any recommended repairs,if any. Mr. Miorelli's
 LitigationPackage includinghis Curriculum Vitae, rate sheet,case list and report is attached to
 Exhibit "A."
 3
 Mr. Miorelli will be produced for depositionat a mutually agreeabletime and place
 in accordance with the Court's CMO.
 4.
 As discoveryis ongoing and additional discoverywill be undertaken priorto trial,
 As such, Mr. Miorelli reserves the rightto amend and/or supplement this disclosure of expert
 witnesses upon proper notice to the partiesand to the Court.
 CERTIFICATE OF SERVICE
 St
 I HEREBY CERTIFY that, on this 1? day of March, 2022, I electronically
 filed the
 foregoing with the Clerk of the Court via the Florida Courts' e-FilingPortal,pursuant to and in
 compliance with Rule 2.516, Florida Rules of Judicial Administration, which completes service
 by furnishinga true and correct copy of the foregoingvia electronic mail to all counsel of record.
 LAW OFFICES OF SANTEIRO & GARRISON
 thu8hn#49
 Christine M. Hoke
 FBN 094412
 6300 UniversityParkway
 Suite 101
 Sarasota,FL 34240
 Tel:
 (800)226-3224, Ext. 4113
 Primary:
 Secondary: lburgos@fcci-group.com
 Secondary:legalservice@fcci-group.com
 Attorney for Defendant, Hollywood Stone, Inc.
 IBIT "A."
 VEC Forensics, BBC
 LUKE MIORELLI, P.E.
 EDUCATION
 BS, Civil Engineering, University of Florida, 1978.
 EXPERIENCE
 January 2022 to Present: MEC Forensics, LLC Owner
 Forensic Engineering - Building Envelope issues, construction defects, design defects, construction
 claims, insurance claims, cost to cure, Standard of Care, expert witness testimony.
 1995 to December 2021: President, M.E. Construction, Inc.
 Commercial Construction - Professional Offices, Medical Offices and labs, Industrial buildings,
 Convenience Stores, Telecommunications facilities,Television Towers and Support facilities,
 Churches, Retail Centers, Event Halls.
 Civil Design - site plans, roads, drainage, surface water pollution control, sanitary sewer systems,
 water distribution systems, utilityrelocation, zoning changes, zoning variances, FDEP, FDOT,
 County and City permitting.
 Structural Design - structural steel, reinforced concrete, pre-stressed concrete, timber, wood,
 reinforced masonry, structural renovations, structural modifications, piling,signs, and satellite dishes.
 Forensic Engineering - roof inspections, water infiltration,water damages, construction defects,
 design defects, construction claims, insurance claims, cost to cure, expert witness testimony.
 1980 to 1995: Vice President/CEO, Miorelli Engineering, Inc.
 Commercial Construction - Office and industrial buildings to 120,000 SF, including reinforced
 concrete, tilt-upconcrete, reinforced masonry, structural steel, pre-engineered steel, post tensioned
 structures and miscellaneous hybrid building types.
 Civil Design - roads, drainage, surface water pollution control, sanitary sewer systems, water
 distribution systems, utilityrelocation, zoning changes, zoning variances, site planning and layout.
 Structural Design - Structural Steel, reinforced concrete, prestressed concrete, timber, wood,
 reinforced masonry, structural renovations, structural modifications, piling,signs. Forensic
 Engineering - roof inspections, water infiltration,water damages, construction defects, design defects,
 storm damage, insect damage, construction claims, insurance claims, expert witness testimony.
 1978 to 1980: Cost analyst, Fluor Corporation, Shedgum, Saudi Arabia.
 Duties included cost tracking and forecasting, estimating changes and subcontractor change orders
 on $1.25 billion NGL plant construction.
 Professional
 Florida Certified General Contractor, 1981, License# CCG019528.
 Registrations/
 Florida Professional Engineer, August 2, 1985 PE # 0036127
 Certifications:
 Certified Masonry Inspector
 Board Certified Senior Member National Academy of Forensic Engineers
 Board Certified Diplomate International Board of Forensic Engineers and
 Scientists
 Community
 Rotary Club
 Support:
 Vice Chairman Brevard County Construction Licensing Board Member
 Vice Chair Brevard County Building Code Board of Adjustments
 V.EC Forensics, LLC
 BillingRates January 31, 2022
 Thank you for engaging MEC Forensics, LLC for your forensic engineering needs. Below you
 will find our rate scale.
 Luke Miorelli,P.E. Principal
 $325.00 per hour
 Professional Engineer, VP/ CGC
 $215.00 per hour
 Engineers, Project Managers and Sr. Estimators
 $125.00 per hour
 E.I. and Estimators
 $120.00 per hour
 Drafting
 $ 87.00 per hour
 Clerical
 $ 75.00 per hour
 Assistant
 $ 75.00 per hour
 CD
 $ 20.00 per disc / $30.00 flashdrive
 Mileage
 0.5854 per mile
 Thermal Imaging Equipment use, if needed
 $165.00 per day
 Reproduction and other expenses
 @ Cost
 4715 N Us Highway 1, Melbourne, FI 32935
 321-749-6664 Miorelli.Luke@gmail.com
 CGC 019528 ENG. 036127




 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 Year
 Case
 Testimony
 Issue
 Jurisdiction
 Attorney
 Defendant /
 Plaintiff
 2002
 Honeymoon Hill
 Deposition and Trial
 Free air space for
 18th Circuit Court
 Frese, Hansen, Et Al
 Plaintiff
 Construction vs. Toledo
 Testimony for the
 Condensing units,
 of Florida
 Engineering
 contractor
 Cracking in exterior
 building envelope,
 differential movement
 between buildings
 causing water intrusion.
 Case settled when Mr.
 Miorelli pointed out the
 contract between the
 partiesdid not allow for
 attorneys' fees
 2002
 M.H. Williams, Inc. vs.
 Mediation Testimony for
 Construction defects
 Mediation
 David Larson
 Plaintiff
 Magnolia Plantation Golf
 the contractor
 mostly Punchlist items.
 Club
 Case settled with
 contractor accepting
 partialimmediate
 payment. Owner file
 for Bankruptcy shortly
 afterwards.
 2004
 Barbara Sadala vs.
 Deposition Testimony for
 Latent Defects.
 18th Circuit Court
 Herbert Allen, Jr
 Plaintiff
 Maronda Hornes
 the owner
 Moisture, Mold. The
 of Florida
 exterior walls of the
 home were built off-site
 and failed to flash the
 windows. The
 intersection of the eaves
 of portions of the roof
 were built as to direct
 water into the wood
 framed exterior walls.
 The Owner prevailed.
 2004
 Dave Armstrong Builders
 Deposition Testimony for
 Construction Defects,
 David Larkin
 Plaintiff
 vs. Riverside Bank
 the Contractor
 Contract disputesover
 Punchlist items and
 some materials not
 being supplied as
 lofll
 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 specified.Case settled
 for undisclosed amount.
 2005 /
 Craftmaster Auto Body vs.
 Deposition and Trial
 Design and
 18th Circuit Court
 Allan Whitehead
 Plaintiff
 2007
 Meade Construction
 Testimony for the Owner
 Construction Defects.
 of Florida
 Exterior load bearing
 wall on a monolithic
 foundation settled into
 the retention swale built
 too close to the wall.
 2005
 Adams Construction vs.
 ,th
 Deposition Testimony for
 Contract interpretation
 18t] Circuit Court
 Defendant
 Versailles Condominium
 the Contractor
 and specification
 of Florida
 interpretation.
 Contractor installed
 steel members exposed
 to the weather at an
 Oceanside
 condominium. Contract
 called for epoxy
 coatings and welding
 that were
 incompattable.
 2006
 Siberski/Valentine vs.
 Deposition and Arbitration
 Construction defects,
 Arbitration
 Nance, Cacciatore,
 Plaintiff
 Mercedes Homes
 Testimony for the Owner
 code compliance.
 PA
 Stucco, paint,flashing,
 and caulkingwere
 improperly installed or
 missing causing
 systemicwater
 intrusion.
 2006
 Gautum vs. Mercedes
 Deposition and Arbitration
 Construction defects,
 Arbitration
 Nance, Cacciatore,
 Plaintiff
 Homes
 Testimony for the Owner
 code compliance.
 PA
 Stucco, paint,flashing,
 and caulkingwere
 improperly installed or
 missing causing
 systemicwater
 intrusion.
 2006
 Solari vs. Mercedes Homes
 Deposition and Arbitration
 Construction defects,
 Arbitration
 Nance, Cacciatore,
 Plaintiff
 Testimony for the Owner
 code compliance.
 PA
 Stucco, paint,flashing,
 2ofll
 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 and caulking were
 improperly installed or
 missing causing
 systemic water
 intrusion.
 2007
 Firlejczykvs. Mercedes
 Deposition and Arbitration
 Construction defects,
 Arbitration
 Nance, Cacciatore,
 Plaintiff
 Homes
 Testimony for the Owner
 code compliance.
 PA
 Stucco, paint,flashing,
 and caulking were
 improperly installed or
 missing causing
 systemicwater
 intrusion.
 2007
 Heine vs. Parent
 Deposition and Trial
 Construction defects,
 196 Circuit Court
 Allan Whitehead
 Plaintiff
 Construction
 Testimony for the Owner
 code compliance.
 of Florida
 Large expensive custom
 home in John's Island,
 Indian River County, Fl
 was built below the
 flood plain.Resulted in
 swimming pool being
 very shallow and
 drainageissues with the
 home.
 2007
 Villasol Realty Co. vs. J &
 Deposition Testimony for
 Contract interpretation
 Michael
 Defendant
 S Curb/Concrete, Inc.
 the Contractor
 and specification
 Riemenschneider
 interpretation.
 Contract documents
 called for the use of a
 2" pump permitted
 through SJRWMD to
 dewater the site for
 excavation of the
 stormwater system.
 The pump proved to be
 too small and delayed
 the work. Because of
 the delay, Tropical
 weather caused the
 excavation to re-flood.
 3ofll
 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 2007
 Hobson-Magnuson vs.
 Trial Testimony for the
 Construction Defects
 18th Circuit Court
 Ed Kinberg
 Plaintiff
 TNT Electric and
 home owner
 and PermittingPunch
 of Florida
 Construction
 list items and qualityof
 work.
 2007
 Dave Armstrong Custom
 Arbitration Testimony for
 Construction Defects
 Arbitration
 David Larkin
 Plaintiff
 Homes vs. Charles Gibson
 the Contractor
 Punchlist dispute
 2008
 Michael Weideman vs.
 Trial Testimony for the
 Construction Defects
 18th Circuit Court of
 Charles Schillinger
 Defendant
 Villanueva
 Roofer
 Florida case #05-
 2006-CA-037750
 2008
 Rahal Development vs. Dr.
 Arbitration Testimony for
 Construction Defects /
 Arbitration
 Michael Minot
 Plaintiff
 Niazi
 the Contractor
 Scheduling
 Cardinal change in the
 plans. The original
 plans showed a simple
 home. What resulted
 was a McMansion with
 all ofthe trimmings.
 Highlightsof the
 arbitration were the
 Owner representing
 himself with his
 attorney describing
 himself as a Potted
 Plant. The Contractor
 recounted how he and
 the Owner, after signing
 the Contract, spent the
 remainder of the
 evening at a local
 Topless Bar.
 2008
 Ingram vs. Builder
 Deposition and trial
 Construction Defects,
 18th Circuit Court
 Allan Whitehead
 Defendant
 testimony for the
 code compliance
 of Florida case
 Homeowner
 #05-2005-CA-
 067465
 2008
 JupiterOcean Grand vs.
 Deposition testimony for
 Construction Defects,
 19m Circuit Court
 Andrew Showen
 Defendant
 Rob's Interiors
 Rob' s Interiors
 Stucco and water
 of Florida
 intrusion
 2009
 Andrews vs. Jackson
 Deposition & Trial
 Construction Defects,
 18th Circuit Court
 Allan Whitehead
 Plaintiff
 Homes
 testimony for Andrews
 Code Compliance
 of Florida
 4ofll
 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 2009
 Salgar Construction vs.
 Trial Testimony for Salgar
 Construction Defects,
 18th Circuit Court
 Charles Schillinger
 Plaintiff
 Abbas Pazouhandeh
 Construction
 Cost to complete
 of Florida
 2009
 Paulon Construction
 Arbitration Testimony for
 Construction Defects
 Arbitration
 Charles Schillinger
 Defendant
 Management vs. River
 the Construction manager
 Bluff Condominium
 Association
 2009
 Somerset Development vs.
 Trial Testimony for
 Construction Delays,
 18th Circuit Court
 Gray Robinson PA
 Defendant
 Meade/Treadway
 Somerset
 Hurricane impact on
 of Florida
 Jack Kirschenbaum
 schedules
 2009
 Core General Contractors,
 Trial Testimony for Rene
 Construction Defects,
 19m Judicial
 Andrew Douglas
 Plaintiff
 Inc vs. Rene & Lizbeth
 & Lizbeth Arencibia
 Cost to repair
 Circuit of Indian
 Arencibia
 River County
 Case# 2007-1378-
 CA03
 2009
 Herman & Joyce Cole vs.
 Trial Testimony for the
 Construction Defects,
 18th Circuit Court
 Gray Robinson PA
 Defendant
 Somerset Riverfront
 Developer
 Schedule
 of Florida
 Jack Kirschenbaum
 Development, Inc
 2010
 Apotheker vs. Superior
 Arbitration Testimony
 Window leaks
 Brevard County
 Owner
 Plaintiff
 Window
 2010
 Charles & Marsha Foglio
 Deposition Testimony for
 Construction Defects
 18th Judicial
 Diane Zelmer
 Defendant
 vs. Ocean Beach
 Owner
 Circuit Court for
 Development & Kabbord
 Brevard County
 Properties,Inc
 2010
 John Knox Villagev. Blue
 Deposition Testimony for
 Construction
 17th Judicial
 Gaunt, Pratt,
 Plaintiff
 Water Builders
 the Contractor and
 Defects/Cost to Cure
 Circuit Court for
 Radford, Methe &
 Subcontractors
 Broward County
 Rockenbach, P.A.
 2010
 J. Remyn v. Publix, et al.
 Deposition Testimony for
 Construction
 18th Judicial
 High, Stack, &
 Plaintiff
 Plaintiff
 DefecUPersonal Injury
 Circuit Court for
 Gordon
 Brevard County
 Michael Kirby
 2011
 LeJar(lin at Baytown Warf
 Deposition Testimony for
 Construction Defects
 1st Judicial Circuit
 Gray Robinson PA /
 Defendant
 Townhomes
 Plaintiff
 for Walton
 Trevor Arnold
 County
 2011
 LaColonnade
 Deposition Testimony for
 Construction Defects
 18th Judicial
 Frese, Hansen PA
 Defendant
 Condominium
 Plaintiff
 Circuit Court for
 Allan Whitehead
 Brevard County
 2011
 Siano v Holmes Regional
 Deposition Testimony for
 Construction
 18th Judicial
 Nance, Cacciatore
 Plaintiff
 Medical Center
 Plaintiff
 DefecUPersonal Injury
 Circuit Court for
 PA
 Brevard County
 Sammy Cacciatore
 5ofll
 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 2011
 Marine Bank v Florida
 Trial Testimony for
 Construction Cost /
 18th Judicial
 Frese Hansen PA
 Defendant
 Business Bank, Island
 Florida Business Bank
 Estimate to Complete
 Circuit Court for
 Allen Whitehead
 Oaks Condominium
 Brevard County
 2011
 Joyce Bowles v Carmax
 Deposition Testimony for
 Construction
 18th Judicial
 Luks, Santaniello,
 Defendant
 Auto Superstores,Inc
 Carmax
 DefecUPersonal Injury
 Circuit Court for
 Petrillo & Jones
 Seminole County
 Paul Jones
 2012
 The Bartrum v C.B.
 Deposition Testimony for
 Construction Defect
 District Court for
 Wicker Smith PA
 Defendant
 Contractors v Rosewell
 Bartrum
 the Northern
 Robert Saunders
 Masonry
 District of Florida,
 Gainesville
 Division
 2012
 Siena Place Condominium
 Deposition Testimony for
 Construction Defect
 9th Judicial
 Gray Robinson PA
 Defendant
 v Ray Engineering,Inc.
 Siena Place Condominium
 Circuit Court of
 Trevor Arnold
 Florida
 2012
 Siena Condominium at
 Deposition Testimony for
 Construction Defect
 9th Judicial
 Law Offices of Jack
 Defendant
 Celebration
 Dunn Corporation
 Circuit Court of
 D. Evans
 Florida
 Teresa Eyerman
 2012
 Baldwin Park v Axiom
 Deposition for Axiom
 Construction Defect
 9th Judicial
 Klein Glasser Park
 Defendant
 Circuit Court of
 Lowe & Pelstring
 Florida
 Houston Park
 2012
 FDIC v MHF Construction
 Deposition for MHF
 Construction Defect
 11TH Judicial
 Johnson Law Group
 Defendant
 Construction
 Circuit Court of
 Michael Wargo
 Florida
 2012
 Manning Building
 Trial Testimony for
 Construction Defect
 18th Judicial
 Worman & Sheffler,
 Plaintiff
 Supplies,Inc. v Jane
 Manning
 Circuit Court for
 P.A. Robert Worman
 Madry, John Pavlakos
 Brevard County
 Gen. Contr. Inc. & John
 Pavlakos
 2013
 Thomas & Constantina
 Deposition Testimony for
 Construction Defect
 18th Judicial
 Law Offices of
 Defendant
 Andrew, Laufen, Inc. &
 Andrew
 Circuit Court for
 Freese Hansen
 James Jackson v Mid-
 Brevard County
 Allen Whitehead
 Continent Casualty
 Company
 2013
 RCL Construction, Inc. v
 Deposition Testimony for
 Construction Defect
 19m Judicial
 Randy Brennan, PA.
 Defendant
 Wackenhut
 RCL Construction, Inc.
 Circuit of Indian
 River County
 2013
 Concrete Restoration, Inc.
 Deposition Testimony for
 Construction Defect
 18th Judicial
 Luks, Santaniello,
 Defendant
 v Lantana Ocean Front
 Lantana Ocean Front
 Circuit Court for
 Petrillo & Jones
 Condo Assoc.
 Condo Assoc.
 Brevard County
 Paul Jones
 6ofll
 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 2013
 Eunice Elizabeth
 Deposition Testimony for
 Construction Defect
 18th Judicial
 Michael Kahn, PA
 Plaintiff
 Wenninger v PhillipC.
 Eunice Elizabeth
 Circuit Court for
 Houbler Trust / Camelot
 Wenninger
 Brevard County
 Realty of Brevard
 2013
 Town ofMelboume Beach
 Deposition & Trial
 Construction Defect
 18th Judicial
 Gray Robinson PA
 Plaintiff
 v Outlaw and Jones Inc.
 Testimony for Town of
 Circuit Court for
 Jack Kirschenbaum
 Melbourne Beach
 Brevard County
 2013
 Don Facciobene, Inc. v
 Deposition & Trial
 Construction Defect
 18th Judicial
 Law Offices of
 Defendant
 Mansion Restaurant
 Testimony for Don
 Circuit Court for
 Freese Hansen
 Facciobene, Inc.
 Brevard County
 Allen Whitehead
 2013
 Stephen Long Residence
 Deposition Testimony for
 DefecUPersonal Injury
 18th Judicial
 Dean Mead
 Defendant
 Slug-A-Bug
 Circuit Court for
 Brevard County
 2014
 Global v Melbourne
 Deposition Testimony for
 Construction Defect
 18th Judicial
 Gray Robinson PA
 Defendant
 AirportAuthority
 Melbourne Airport
 Circuit Court for
 Authority
 Brevard County
 2014
 Reme Home
 Deposition Testimony for
 Construction Defect /
 18th Judicial
 Fritz Reme
 Plaintiff
 Owner
 Contract Dispute
 Circuit Court for
 Brevard County
 2014
 Wagner, Patricia
 Deposition Testimony for
 Construction Defect /
 18th Judicial
 Patricia Wagner
 Plaintiff
 Owner
 Contract Dispute
 Circuit Court for
 Brevard County
 2014
 Willow Creek v Apache
 Deposition Testimony for
 Construction Defect
 Johnson Law Group
 Defendant
 Stucco
 Apache Stucco
 Michael E. Wargo,
 Esq
 2014
 Midway Contracting
 Deposition Testimony for
 Construction Defect
 9th Judicial Circuit
 Vasquez & Tosko,
 Defendant
 Midway Contracting
 Court of Florida
 LLP
 Jonathon Wright
 2014
 Don Facciobene, Inc. v
 Trial Testimony for Don
 Construction Defect
 18th Judicial
 Law Offices of
 Defendant
 Mansion Restaurant
 Facciobene, Inc.
 Circuit Court for
 Freese Hansen
 Brevard County
 Allen Whitehead
 2015
 Pure Living @ Heathrow
 Deposition Testimony for
 Construction Defect
 Luks, Santaniello,
 Defendant
 DefendanU2nd Party
 Petrillo & Jones
 Plaintiff
 Thomas Farrell
 2015
 DR Horton vs Southern
 Deposition Testimony for
 Design Defect
 13th Judicial
 Law office of Jack
 Defendant
 Building Products
 Defendant
 Circuit Court for
 Evans
 Hillsborough
 Teresa Eyerman
 County
 7ofll
 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 2015
 Crossroads Daycare
 Deposition Testimony for
 Building Condition
 18th Judicial
 Dean Mead
 Plaintiff
 Plaintiff
 Circuit Court for
 Kim Rezanka
 Brevard County
 2015
 Samuel Johnson vs High
 Deposition Testimony for
 Personal Injury
 13th Judicial
 Vasquez & Tosko,
 Defendant
 Reach
 High Reach
 Circuit Court for
 LLP
 Hillsborough
 Jonathon Wright
 County
 2015
 ARKS, LLC
 Deposition Testimony for
 Subrogation Claim for
 18th Judicial
 Schwartz Law Group
 Plaintiff
 Plaintiff
 Fire Damage
 Circuit Court for
 David J. Pascuzzi
 Brevard County
 2015
 The Peninsula Condo v
 Deposition Testimony for
 Construction Defect
 11th Judicial
 Ciklin, Lubitz,
 Defendant
 Professional Plumbing
 Defendant
 Circuit Court for
 Martens &
 Miami Dade
 O'Connell
 County
 Christine Hoke
 2015
 Promenade v Monument
 Deposition Testimony for
 Construction Defect
 Klein, Glasser
 Defendant
 Stucco
 Defendant
 2015
 Windsor v Lusk Lathing
 Deposition Testimony for
 Construction Defect
 9th Judicial Circuit
 Old Dominion
 Defendant
 Defendant
 Court for Orange
 Insurance
 County
 Jeff Bogert
 2016
 Steidle Bros. Construction,
 Deposition Testimony for
 Construction Defect
 18th Judicial
 Vasquez & Tosko,
 Defendant
 Inc.
 Defendant
 Circuit Court for
 LLP
 Brevard County
 Esteban F. Scornik
 2016
 UDR of Tenn, LP vs
 Deposition Testimony for
 Construction Defect
 13th Judicial
 Bush Ross, PA
 Defendant
 Urban Studio
 Defendant
 Circuit Court for
 Amanda Buffington,
 Hillsborough
 Esq.
 County
 2016
 J A Croson v Osceola
 Deposition Testimony for
 Construction Defect
 9th Judicial Circuit
 Boyd & Jenerette,
 Defendant
 Brownstone
 Defendant
 Court for Orange
 PA,
 County
 Beth-Ann Schulman
 2017
 1041 Sunswept Rd, Palm
 Deposition Testimony for
 Failure to Disclose
 18th Judicial
 Fallace & Larkin
 Defendant
 Bay, FL
 Defendant
 Circuit Court for
 Dave Larkin
 Brevard County
 2017
 Savannah Townhomes,
 Deposition Testimony for
 Construction Defect
 18th Judicial
 Amerisure Insurance
 Defendant
 Wyndemere
 Defendant
 Circuit Court for
 Jennifer Faircloth
 Seminole County
 2017
 Miami Drywall v The
 Deposition Testimony for
 Construction Defect
 17th Judicial
 The Hartford
 Defendant
 Beach Club
 Defendant
 Circuit Court for
 Kevin Claytor
 Broward County
 8ofll
 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 2017
 St. Pete vs Hennessey
 Deposition Testimony for
 Construction Defect
 6thJudicial Circuit
 Hill, Rugh, Keller &
 Defendant
 Defendant
 Court for Pinellas
 Main
 County
 Christopher Hill
 2017
 Long vs Hufford
 Trial Testimony for
 Failure to Disclose
 18th Judicial
 Lewis Brisbois
 Defendant
 Defendant
 Circuit Court for
 Brevard County
 2018
 Norman Turner Home
 Mediation Testimony for
 Failure to Disclose
 1? Judicial
 Jones Foster
 Defendant
 Defendant
 Circuit Court for
 Johnston & Stubbs
 Indian River
 Michael Gore
 County
 2018
 Villa Verde Condominium
 Deposition and Trial for
 Construction/Design
 18th Judicial
 Gray Robinson Law
 Defendant
 Defendant
 Defect
 Circuit Court for
 Trevor Arnold
 Brevard County
 2018
 Randazzo Bldrs v Villas @ Deposition for Defendant
 Construction Defect
 18th Judicial
 Ciklin, Lubitz,
 Defendant
 Lakes
 Circuit Court for
 Martens
 Seminole County
 Christine Hoak
 2018
 Haver v Maclean
 Trial Testimony for
 Failure to Disclose
 18th Judicial
 Vol Law Offices
 Plaintiff
 Plaintiff
 Circuit Court for
 David Vol
 Brevard County
 2018
 Univ ofFL Chemical Eng
 Deposition for Plaintiff
 Construction/Design
 St? Judicial Circuit
 Shutts & Bowen
 Plaintiff
 Addit
 Defects
 Court for Alachua
 County
 2018
 Western Waterproofing
 Deposition for Plaintiff
 Construction Contract
 14?h Judicial
 Boyd & Jenerette,
 Plaintiff
 Dispute
 Circuit Court of
 PA
 Bay County
 Beth-Ann Schulman
 2019
 Epic v Miami Drywall &
 Deposition for Defendant
 Construction Defect
 11th Judicial
 Rembold Hirschman
 Defendant
 Stucco
 Circuit Court of
 Miami-Dade
 County
 2019
 Summerhill Apt vs. The
 Deposition for the
 Construction Defects,
 4?h Judicial Circuit
 Gray Robinson
 Defendant
 Preston Partnership,LLC
 Defendant
 Cost to Cure
 Court of Duval
 Trevor Arnold
 County, Fl
 2019
 Lakes of Windermere -
 Deposition
 Construction Defects
 9th Judicial Circuit
 Boyd & Jenerette,
 Defendants
 Lake Reams Townhomes v
 Court for Orange
 PA
 Aston Orlando v Del Air,
 County
 Beth-Ann Schulman
 Energy Air, Maximum Air,
 American Builders Supply,
 Spraggins, Inc.
 9ofll




 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 2020
 UF-CTRB
 Deposition
 Construction Defects
 8th Judicial Circuit
 Gray Robinson
 Plaintiff
 Court for Alachua
 Trevor Arnold
 County
 2020
 Spring Isle v Pulte Home -
 Deposition
 Construction Defects
 9th Judicial Circuit
 Boyd & Jenerette,
 Defendant
 American Window
 SlidingGlass Doors
 Court for Orange
 PA
 County
 Beth-Ann Schulman
 2020
 Regalia v Miami Drywall
 Deposition
 Construction Defects
 11th Judicial
 Rembold Hirschman
 Defendant
 Drywall, Metal Studs,
 Circuit Court of
 Stucco, Showers water
 Miami-Dade
 intrusion
 County
 2020
 Alfred and Joan Suarez v
 Deposition/ Trial
 Construction Defects
 1? Judicial
 Fallace & Larkin
 Plaintiff
 VB Custom Homes
 Testimony
 Contract, Plans,
 Circuit Court for
 David Larkin
 workmanship
 Indian River
 County
 2020
 Paradise Palms Resort
 Deposition
 Construction Defects
 9th Judicial Circuit
 Wright, Fulford,
 Defendant
 HOA v C&C Windows
 Windows
 Court for Osceola
 Moorehead & Brown
 County
 Sharon Freeman
 2020
 Osborne v Vanacore
 Deposition/ Arbitration
 Construction Defects
 , Judicial Circuit KGPLP
 Defendant
 Testimony
 Stucco and Windows
 Court for Volusia
 Houston S. Parks III
 County
 2020
 Mesa-Taylor v Gale
 Deposition
 Construction Defects
 15th Judicial
 Boyd & Jenerette
 Defendant
 Insulation
 Circuit Court for
 Elizabeth Lefforge
 Palm Beach
 County
 2020
 Palau v Century Tile
 Deposition
 Construction Defect tile
 11th Judicial
 Law Offices of
 Defendant
 installation
 Circuit Court of
 Santeiro & Garrison
 Miami-Dade
 Christine Hoke
 County
 2020
 Martin, Lizzeta and Scott v
 Deposition
 Water damage while
 18th Judicial
 O'Conner &
 Defendant
 Federated Insurance
 under construction
 Circuit Court for
 O'Conner, PA
 Brevard County
 Ronald Harrop
 2020
 Palau v Century Tile
 Deposition
 Exterior Tile
 11th Judicial
 Law Offices of
 Defendant
 Construction Defect
 Circuit Court of
 Santeiro & Garrison
 Miami-Dade
 Christine Hoke
 County
 2020
 WMR Fountain Park
 Deposition
 Design Defects
 18th Judicial
 Gray Robinson
 Defendant
 Circuit Court for
 Trevor Arnold
 Brevard County
 10ofll
 List of cases in which Luke Miorelli, P.E. has testified as an expert in trial or deposition since 2002. (1/31/22)
 2020
 Osborne, Royal v
 Deposition
 Construction Defects
 7thJudicial Circuit
 Klien Glasser Park &
 Defendant
 Vanacore
 Arbitration Testimony
 Court of Volusia
 Lowe
 County
 Houston S Park III
 2021
 Compass Group
 ,
 Springhill
 Deposition
 Hardi Siding
 Judicial Circuit
 Boyd Jenerette
 DefendanUPlaintiff
 Suites NSB
 Court of Volusia
 Beth-Ann Schulman
 County
 2021
 Commercial Stucco
 Deposition
 Stucco Construction
 1 st Judicial
 Boyd Jenerette
 Defendant
 Englewood Senior Living
 Defects
 Circuit Court of
 Beth-Ann Schulman
 Pensacola
 Escambia County
 Price Family Homes v
 Deposition
 Construction Defects
 18th Judicial
 David Larkin
 Plaintiff
 2021
 Mallet
 Retainage Held
 Circuit of Brevard
 Fallace & larkin
 County
 2021
 Dassa v SE Power
 Deposition
 Personal Injury
 18th Judicial
 David Gordon
 Plaintiff
 Circuit of Brevard
 High Stack
 County
 2021
 UF - CTRB
 Deposition
 Construction/Design
 St? Judicial Circuit
 Trevor Arnold
 Plaintiff
 Defects
 Court for Alachua
 Gray Robinson
 County
 2021
 Miller v DR Horton
 Deposition
 Construction Defects
 18th Judicial
 Scott Blaue
 Plaintiff
 Fairway Lakes
 Site
 Circuit of Brevard
 County
 2021
 Kelly Riccard v MI Homes
 Deposition
 Construction Defects
 18th Judicial
 Robert W Rasch
 Plaintiff
 Circuit of
 Seminole County
 11 ofll
 MEC Forensics, LLC
 Sage Beac 1 Conc ominium
 Association,
 nc
 V
 - o ywooc Stone,nc.
 OpinionsConcerning work
 performedby
 HollywoodStone, Inc.
 Prepared for: Christine Hoke
 4715 N US Highway 1, Melbourne, FI 32935
 CGC 019528 PE 0036127 EB 7219 www.meconstruction.com




 Sage Beach Condo v Hollywood Stone
 February 16, 2022
 Introduction:
 The Sage Beach Condominium is located in Hollywood Beach, FI. The Condominium
 consists of two buildingsand a common area pool and deck. The publicroadways that wrap
 around the west building,the north public ROW and its associated beach access are
 primarilycovered with interlocking
 concrete pavers. Hollywood Pavers, Inc. (Hollywood)
 supplied and installed the pavers in the publicareas, the entrance pavers at the two
 buildings, and the pavers on the pool deck pursuant to a Contract with Glenewinkel
 Construction Company, LLC dated November 30, 2015.
 Kev documents that have been considered in this report:
 1.
 Adkins Engineers, Inc Report
 2.
 Keee Klimas Report
 Alleaed Defects:
 Atkins Engineers, Inc. (Adkins) prepared a Building Condition Turnover Report dated August
 26, 2021. In this report,Atkins allegesdefective work by Hollywood in three areas. The
 allegationsare restated below:
 1.
 Settling pavers at the west entrance drive of the west building in the traffic area.
 2.
 Defective grading of the pavers in front of the gym doors
 3.
 Broken and dislodged pavers in the public beach access walks.
 During our inspectionon January 17th, 2022 we found that the Gym area and the public
 beach access had alreadybeen repaired.We did observe an additional small area at the
 north end of the east buildingentrance which was exhibitingminor subsidence.
 The area at the west building is subsiding adjacent to the curb on the outside of the drive
 curve. This is an area where the tires of the vehicles will ride up onto the concrete flat curb
 and then drop onto the pavers causing the pavers to settle from the impact load. The
 solution is to remove the pavers out a couple of feet from the curb, raise and recompact the
 area, and re-install the pavers. The same repair is needed at the east building.
 The representativefrom Hollywood Stone told the Sage Beach representative and the
 Plaintiff Attorney that they were willingto make these repairs at no cost to Sage Beach
 Cost to Repair:
 Keene Klimas prepared an Opinion of Probable Cost for the allegeddefects. In this report,
 Item 12c & 12d reference the pool area which is actuallythe pool deck in front of the gym,
 and Item 23 Exterior Pavers.
 MEC Forensics, LLC
 Page 2 of 3
 Sage Beach Condo v Hollywood Stone
 February 16, 2022
 The gym/pool paver area was repairedwith some work on the doors and the adding of a
 gutter to take water away from the area. Hollywood is not responsible for any of this work.
 The estimate for the paver re-work at the entrance is over stated. The entire process of
 removing and resettingthe pavers will take less than a day for 3 men. Using Keene Klimas's
 labor rate of $48.12per hour, this equates to $1,154.88 for labor and another $200 for misc.
 materials or a total of $1,354.88 vs the KK cost of $4,498.73. Again, Hollywood Stone has
 offered to fix itfor free.
 Conclusions:
 Sage should take Hollywood Stone up on their offer to repairthe two areas that need
 attention.
 Thank you for the opportunityto provide you with Professional Engineeringservices. Please
 note that MEC Forensics, LLC reserves the rightto revise or update any of the
 observations, assessments, and/or recommendations as conditions change or
 additional information becomes available.
 This document is to inure to the benefit of the addressee only and may not be relied
 upon, used by, or referenced by any third party without the written consent of MEC
 Forensics, LLC If clarification or additional information is required,please do not
 hesitate to contact us.
 This item has been electronically
 signed and sealed bv Luke Miorelli,
 Digitally
 signed by
 &*.,M!956X
 P.E. on the date adjacent to the
 MEWM sealudngasmauthentkation Luke Miorelli
 l No 03.12. ''?
 A code.
 t
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 Printed copies of this document
 li>.?
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 ?
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 te,Z?,E'ff???s?n???nd
 sealed and the SHA authentication
 Date: 2022.02.28
 'e>Fdtc49
 code must be verified on any
 -*?tronic
 c?pies.
 13:07:35 -05'00'
 Luke Miorelli,P.E.
 FL P. E. # 36127
 MEC Forensics, LLC
 Page 3 of 3