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Filing # 136055097 E-Filed 10/06/2021 04:27:19 PM
1202.41114
IN THE CIRCUIT COURT OF THE
15" JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO: 50 2021 CA 007567 XXXXMB
HVC & NC LIMITED PARTNERSHIP,
Plaintiff,
vs.
VINTAGE & SPECIALTY WOOD LLC,
f/k/a WOOD SALES BY HARRY, INC.,
and HARRY RAYMOND,
Defendants.
/
DEFENDANT, HARRY RAYMOND, EXPERT WITNESS
INTERROGATORIES TO PLAINTIFF
COMES NOW, the Defendant, HARRY RAYMOND, by and through its undersigned
attorneys and pursuant to the Florida Rules of Civil Procedure, and Florida law and propounds the
following Expert Witness Interrogatories to the Plaintiff to be answered, under oath, within the time
prescribed in the Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I certify that the foregoing document has been furnished through the e-portal and/or by e-mail
on this 6"" day of October, 2021 to all counsel of record.
s/MARK R. ANTONELLI
Florida Bar No: 356948
mantonelli@gaebemullen.com
cgreer@gaebemullen.com
arrero@gaebemullen.com
Ibeggs@gaebemullen.com
Attorneys for Defendants, VINTAGE &
SPECIALTY WOOD LLC f/k/a WOOD SALES
BY HARRY, INC., & HARRY RAYMOND
GAEBE, MULLEN, ANTONELLI & DIMATTEO
420 South Dixie Highway, Third Floor
Coral Gables, Florida 33146
Tel: 305-667-0223 | Fax: 305-284-9844
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 10/06/2021 04:27:19 PM ***HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al
CASE NO: 50 2021 CA 007567 XXXXMB
EXPERT INTERROGATORIES TO PLAINTIFF
1. Please state the name, address and profession of each person whom you will expect to call
as an expert witness at trial or for any other purposes in this cause.
2. With regard to each listed above, state the background, education and experience which
qualify the individual to testify as an expert in the applicable area of expertise.
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CASE NO: 50 2021 CA 007567 XXXXMB
3. Give the name or title of each paper which each expert has authored in the expert's field of
expertise.
4. State the name, volume and page number of the publication in which the article or paper listed
above can be found.
Page 3 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al
CASE NO: 50 2021 CA 007567 XXXXMB
5. State the substance of the facts to which each expert is expected to testify.
6. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances, or
statutes which each expert has used in basing any opinion.
Page 4 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al
CASE NO: 50 2021 CA 007567 XXXXMB
7. State the opinion to which the aforementioned experts are expected to testify.
8. Give a summary of the grounds of each opinion stated.
Page 5 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al
CASE NO: 50 2021 CA 007567 XXXXMB
9. Has the expert listed above practiced or worked in this field during the past five years?
10. Tf so, please state:
a. Whether the expert was self-employed, employed by someone else or associated as a
partner.
b. Each address where the expert practiced or was employed.
c. The dates the expert was with each employer.
d. The type of duty the expert performed with each employer.
Page 6 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al
CASE NO: 50 2021 CA 007567 XXXXMB
11.
12.
13.
If the expert has not practiced or worked in the applicable field during the last five (5) years,
what was the expert's employment during this time?
Did the expert submit a report setting forth the opinions or conclusions reached from the
expert's examination or any tests conducted?
a. If so, state the date the report was submitted.
b. The name or other means of identification of the person to whom this report
was submitted.
c. The name and address of the person who has present custody of the report.
Did the expert submit any other reports based upon tests, examinations or analyses of
documents that the expert conducted in which the expert did not render an opinion.
a. Tf so, state the description of each report that was made.
b. The date which report was made.
c. The name or other means of identification of the person to whom each report was
submitted.
d. The name and address of the person who has present custody of said report.
Page 7 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al
CASE NO: 50 2021 CA 007567 XXXXMB
14.
15.
16.
If you will so do without a Request to Produce, attach a copy of any reports made by each
expert on the basis of any tests, examinations or analyses to your answers to these
Interrogatories.
Is the expert to be compensated for the expert's work and efforts in connection with this
action?
a. If so, how much is the expert to be paid?
b. If the expert has not been paid, then give the basis for payment, such as hourly rate,
weekly rate, etc.
Has the expert served as an expert witness in any other litigated case in the past three (3)
years?
Tf so, state as to each case:
a. The style of the case, the Court in which it was filed and the names and addresses of
the attorneys involved.
b. Whether the expert testified for the Plaintiff or Defendant.
c. The area or field in which the expert held himself out to be an expert.
Page 8 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al
CASE NO: 50 2021 CA 007567 XXXXMB
I HAVE READ THE FOREGOING ANSWERS TO INTERROGATORIES AND DO SWEAR
THAT THEY ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE AND
BELIEF.
HVC & NC LIMITED PARTNERSHIP
STATE OF FLORIDA
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared
who swears and deposes that has read the Answers to
Interrogatories and that the same are true and correct to the best of knowledge and belief.
SWORN TO AND SUBSCRIBED before me this day of 2021.
NOTARY PUBLIC, STATE OF FLORIDA
Qo Personally known by me, or
Qo Produced Identification:
Type of Identification
My Commission Expires:
Page 9 of 9
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Filing # 136055097 E-Filed 10/06/2021 04:27:19 PM 1202.41114 IN THE CIRCUIT COURT OF THE 15" JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 50 2021 CA 007567 XXXXMB HVC & NC LIMITED PARTNERSHIP, Plaintiff, vs. VINTAGE & SPECIALTY WOOD LLC, f/k/a WOOD SALES BY HARRY, INC., and HARRY RAYMOND, Defendants. / DEFENDANT, HARRY RAYMOND, EXPERT WITNESS INTERROGATORIES TO PLAINTIFF COMES NOW, the Defendant, HARRY RAYMOND, by and through its undersigned attorneys and pursuant to the Florida Rules of Civil Procedure, and Florida law and propounds the following Expert Witness Interrogatories to the Plaintiff to be answered, under oath, within the time prescribed in the Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished through the e-portal and/or by e-mail on this 6"" day of October, 2021 to all counsel of record. s/MARK R. ANTONELLI Florida Bar No: 356948 mantonelli@gaebemullen.com cgreer@gaebemullen.com arrero@gaebemullen.com Ibeggs@gaebemullen.com Attorneys for Defendants, VINTAGE & SPECIALTY WOOD LLC f/k/a WOOD SALES BY HARRY, INC., & HARRY RAYMOND GAEBE, MULLEN, ANTONELLI & DIMATTEO 420 South Dixie Highway, Third Floor Coral Gables, Florida 33146 Tel: 305-667-0223 | Fax: 305-284-9844 *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 10/06/2021 04:27:19 PM ***HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al CASE NO: 50 2021 CA 007567 XXXXMB EXPERT INTERROGATORIES TO PLAINTIFF 1. Please state the name, address and profession of each person whom you will expect to call as an expert witness at trial or for any other purposes in this cause. 2. With regard to each listed above, state the background, education and experience which qualify the individual to testify as an expert in the applicable area of expertise. Page 2 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al CASE NO: 50 2021 CA 007567 XXXXMB 3. Give the name or title of each paper which each expert has authored in the expert's field of expertise. 4. State the name, volume and page number of the publication in which the article or paper listed above can be found. Page 3 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al CASE NO: 50 2021 CA 007567 XXXXMB 5. State the substance of the facts to which each expert is expected to testify. 6. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances, or statutes which each expert has used in basing any opinion. Page 4 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al CASE NO: 50 2021 CA 007567 XXXXMB 7. State the opinion to which the aforementioned experts are expected to testify. 8. Give a summary of the grounds of each opinion stated. Page 5 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al CASE NO: 50 2021 CA 007567 XXXXMB 9. Has the expert listed above practiced or worked in this field during the past five years? 10. Tf so, please state: a. Whether the expert was self-employed, employed by someone else or associated as a partner. b. Each address where the expert practiced or was employed. c. The dates the expert was with each employer. d. The type of duty the expert performed with each employer. Page 6 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al CASE NO: 50 2021 CA 007567 XXXXMB 11. 12. 13. If the expert has not practiced or worked in the applicable field during the last five (5) years, what was the expert's employment during this time? Did the expert submit a report setting forth the opinions or conclusions reached from the expert's examination or any tests conducted? a. If so, state the date the report was submitted. b. The name or other means of identification of the person to whom this report was submitted. c. The name and address of the person who has present custody of the report. Did the expert submit any other reports based upon tests, examinations or analyses of documents that the expert conducted in which the expert did not render an opinion. a. Tf so, state the description of each report that was made. b. The date which report was made. c. The name or other means of identification of the person to whom each report was submitted. d. The name and address of the person who has present custody of said report. Page 7 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al CASE NO: 50 2021 CA 007567 XXXXMB 14. 15. 16. If you will so do without a Request to Produce, attach a copy of any reports made by each expert on the basis of any tests, examinations or analyses to your answers to these Interrogatories. Is the expert to be compensated for the expert's work and efforts in connection with this action? a. If so, how much is the expert to be paid? b. If the expert has not been paid, then give the basis for payment, such as hourly rate, weekly rate, etc. Has the expert served as an expert witness in any other litigated case in the past three (3) years? Tf so, state as to each case: a. The style of the case, the Court in which it was filed and the names and addresses of the attorneys involved. b. Whether the expert testified for the Plaintiff or Defendant. c. The area or field in which the expert held himself out to be an expert. Page 8 of 9HVC & NC LIMITED PARTNERSHIP v, VINTAGE, et al CASE NO: 50 2021 CA 007567 XXXXMB I HAVE READ THE FOREGOING ANSWERS TO INTERROGATORIES AND DO SWEAR THAT THEY ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE AND BELIEF. HVC & NC LIMITED PARTNERSHIP STATE OF FLORIDA COUNTY OF BEFORE ME, the undersigned authority, personally appeared who swears and deposes that has read the Answers to Interrogatories and that the same are true and correct to the best of knowledge and belief. SWORN TO AND SUBSCRIBED before me this day of 2021. NOTARY PUBLIC, STATE OF FLORIDA Qo Personally known by me, or Qo Produced Identification: Type of Identification My Commission Expires: Page 9 of 9