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Filing# 148375530 E-Filed 04/26/2022 10:10:31 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL
CIRCUIT,
IN
AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-20-017305
ROGENIA HANDSPIKE,
Plaintiffs,
V
HERITAGE PROPERTY AND CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S EXPERT WITNESS REQUEST FOR PRODUCTION
Defendant, HERITAGE PROPERTY
& CASUALTY INSURANCE COMPANY
("Heritage"),
by and through its undersignedcounsel, pursuant to Fl. R. Civ. Pro.,includingRule
1.350, and hereby files its Expert Witness Request for Production.
1.
A copy of your disclosed expert Don Wilcox's Curriculum Vitae.
2.
A copy ofyour disclosed expert Al Brizuela's Curriculum Vitae.
3.
A copy of your disclosed expert Benito Alvarez's Curriculum Vitae.
4.
Copies of any and all documents, exhibits and/or reports Don Wilcox is expected
to use as a demonstrative aid or to be admitted into evidence at the trial in this cause.
5.
Copies of any and all documents, exhibits and/or reports Al Brizuela is expectedto
use as a demonstrative aid or to be admitted into evidence at the trial in this cause.
6.
Copies of any and all documents, exhibits and/or reports Benito Alvarez is expected
to use as a demonstrative aid or to be admitted into evidence at the trial in this cause.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/26/2022 10:10:31 AM.****
CASE NO.: CACE-20-017305
7.
Complete copiesof all materials providedto Don Wilcox, includingbut not limited
to records,reports, correspondence,notes, memoranda, research and studies,and any and all other
materials ofwhatsoever kind of nature, reviewed or utilized by Don Wilcox this matter.
8
Complete copiesof all materials providedto Al Brizuela,includingbut not limited
to records,reports, correspondence,notes, memoranda, research and studies,and any and all other
materials ofwhatsoever kind of nature, reviewed or utilized by Al Brizuela this matter.
9-
Complete copies of all materials provided to Benito Alvarez, includingbut not
limited to records,reports, correspondence,notes, memoranda, research and studies,and any and
all other materials of whatsoever kind of nature, reviewed or utilized by Benito Alvarez this matter.
10.
Copy of all writingsand/or conclusions made by Don Wilcox regardingthe issues
involved herein or any other materials used in arrivingat Don Wilcox's opinions in the instant
matter, and any and all materials preparedby or for Don Wilcox with regardto any issue with
respect to the above-captionedmatter.
11.
Copy of all writingsand/or conclusions made by Al Brizuela regardingthe issues
involved herein or any other materials used in arrivingat Al Brizuela's opinionsin the instant
matter, and any and all materials prepared by or for Al Brizuela with regard to any issue with
respect to the above-captionedmatter.
12.
Copy of all writingsand/or conclusions made by Benito Alvarez regardingthe
issues involved herein or any other materials used in arrivingat Benito Alvarez's opinions in the
instant matter, and any and all materials preparedby or for Jose Uz with regardto any issue with
respect to the above-captionedmatter.
13.
Complete statement of all billingsand chargesfor Don Wilcox's work in this case.
14.
Complete statement of all billings
and chargesfor Al Brizuela's work in this case.
2
CASE NO.: CACE-20-017305
15.
Complete statement of all billingsand charges for Benito Alvarez's work in this
case.
16.
Complete copiesof any and all Don Wilcox's reports, documents and/or charts you
intend to relyupon in this matter.
17.
Complete copiesof any and all Al Brizuela's reports, documents and/or charts you
intend to relyupon in this matter.
18.
Complete copiesof any and all Benito Alvarez's reports, documents and/or charts
you intend to relyupon in this matter.
19.
All documents which you reasonablyexpect to offer into evidence duringthe trial
of this matter.
20.
Complete copy of all letters,memorandums, correspondence, emails or other
communications from the Plaintiffs,Plaintiff's attorneys or Plaintiff's attorney'slaw firm or
anyone on Plaintiff's behalfwith Don Wilcox.
21.
Complete copy of all letters,memorandums, correspondence,emails or other
communications from the Plaintiffs,Plaintiff's attorneys or Plaintiff's attorney'slaw firm or
anyone on Plaintiffs' behalf with Al Brizuela.
22.
Complete copy of all letters,memorandums, correspondence,emails or other
communications from the Plaintiffs,Plaintiff's attorneys or Plaintiff's attorney'slaw firm or
anyone on Plaintiffs' behalfwith Benito Alvarez.
23.
Complete copy of all letters,memorandums, correspondence,emails or other
communications from Don Wilcox to the Plaintiff,Plaintiff's attorneys or Plaintiff's attorney's
law firm or anyone on Plaintiff's behalf.
3
CASE NO.: CACE-20-017305
24.
Complete copy of all letters,memorandums, correspondence,emails or other
communications from Al Brizuela to the Plaintiff,Plaintiff's attorneys or Plaintiff's attorney'slaw
firm or anyone on Plaintiff's behalf.
25.
Complete copy of all letters,memorandums, correspondence,emails or other
communications from Benito Alvarez to the Plaintiff,Plaintiff's attorneys or Plaintiff's attorney's
law firm or anyone on Plaintiff's behalf.
26.
Copy of any and all photographs,charts,drawings,etc. reviewed by Don Wilcox
in this matter.
27.
Copy of any and all photographs,charts,drawings,etc. reviewed by Al Brizuela in
this matter.
28.
Copy of any and all photographs,charts,drawings,etc. reviewed by Benito Alvarez
in this matter.
29.
Copy of any and all photographs,charts,drawings,etc. prepared by Don Wilcox in
this matter.
30.
Copy of any and all photographs,charts,drawings,etc. preparedby Al Brizuela in
this matter.
31.
Copy of any and all photographs,charts,drawings,etc. preparedby Benito Alvarez
in this matter.
32.
Copy of any and all publications,articles,research,journals,textbooks, treatises,
etc. consulted or reviewed by Don Wilcox in this matter.
33.
Copy of any and all publications,
articles,
research,journals,textbooks, treatises,
etc. consulted or reviewed by Al Brizuela in this matter.
4
CASE NO.: CACE-20-017305
34.
Copy of any and all publications,
articles,
research,journals,textbooks,treatises,
etc. consulted or reviewed by Benito Alvarez in this matter.
35.
Copy of any handwritten notes taken by Don Wilcox duringthe course ofhis review
in this matter.
36.
Copy ofany handwritten notes taken by Al Brizuela duringthe course ofhis review
in this matter.
37.
Copy of any handwritten notes taken by Benito Alvarez duringthe course of his
review in this matter.
38.
A complete copy, cover to cover, of the Don Wilcox's file,whether kept in paper
form, electronic form or other means.
39.
A complete copy, cover to cover, of the Al Brizuela's file,whether kept in paper
form, electronic form or other means.
40.
A complete copy, cover to cover, ofthe Benito Alvarez's file,whether kept in paper
form, electronic form or other means.
[CERTIFICATE OF SERVICE FOLLOWSI
5
CASE NO.: CACE-20-017305
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas served via E-
portalto David Garcia,Esq., Marin, Eljaiek,Lopez & Martinez P.L.; 2601 South Bayshore Drive,
18->th
Floor,
Coconut
Grove,
FL
33133;
(305)
444-5969;
mellaw5@mellawyers.com:eservice@mellawyers.com on this 261th day ofApril,2022, pursuant to
Rule 2.516.
COUNSEL FOR HERITAGE PROPERTY
AND CASUALTY INSURANCE COMPANY
1571 Sawgrass Corporate Parkway, Suite 400
Sunrise,Florida 33323
Office: 954-315-1450
By-. /s/ Kelly Kobielush
KELLY KOBIELUSH, ESQUIRE
Florida Bar No.: 74143
kkobielush@heritagepci.com
For service ofprocess,pleasealso include:
scappon@heritagepci.com
mcortese@heritagepci.com
6
Preview
Filing# 148375530 E-Filed 04/26/2022 10:10:31 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-20-017305 ROGENIA HANDSPIKE, Plaintiffs, V HERITAGE PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. i DEFENDANT'S EXPERT WITNESS REQUEST FOR PRODUCTION Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY ("Heritage"), by and through its undersignedcounsel, pursuant to Fl. R. Civ. Pro.,includingRule 1.350, and hereby files its Expert Witness Request for Production. 1. A copy of your disclosed expert Don Wilcox's Curriculum Vitae. 2. A copy ofyour disclosed expert Al Brizuela's Curriculum Vitae. 3. A copy of your disclosed expert Benito Alvarez's Curriculum Vitae. 4. Copies of any and all documents, exhibits and/or reports Don Wilcox is expected to use as a demonstrative aid or to be admitted into evidence at the trial in this cause. 5. Copies of any and all documents, exhibits and/or reports Al Brizuela is expectedto use as a demonstrative aid or to be admitted into evidence at the trial in this cause. 6. Copies of any and all documents, exhibits and/or reports Benito Alvarez is expected to use as a demonstrative aid or to be admitted into evidence at the trial in this cause. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/26/2022 10:10:31 AM.**** CASE NO.: CACE-20-017305 7. Complete copiesof all materials providedto Don Wilcox, includingbut not limited to records,reports, correspondence,notes, memoranda, research and studies,and any and all other materials ofwhatsoever kind of nature, reviewed or utilized by Don Wilcox this matter. 8 Complete copiesof all materials providedto Al Brizuela,includingbut not limited to records,reports, correspondence,notes, memoranda, research and studies,and any and all other materials ofwhatsoever kind of nature, reviewed or utilized by Al Brizuela this matter. 9- Complete copies of all materials provided to Benito Alvarez, includingbut not limited to records,reports, correspondence,notes, memoranda, research and studies,and any and all other materials of whatsoever kind of nature, reviewed or utilized by Benito Alvarez this matter. 10. Copy of all writingsand/or conclusions made by Don Wilcox regardingthe issues involved herein or any other materials used in arrivingat Don Wilcox's opinions in the instant matter, and any and all materials preparedby or for Don Wilcox with regardto any issue with respect to the above-captionedmatter. 11. Copy of all writingsand/or conclusions made by Al Brizuela regardingthe issues involved herein or any other materials used in arrivingat Al Brizuela's opinionsin the instant matter, and any and all materials prepared by or for Al Brizuela with regard to any issue with respect to the above-captionedmatter. 12. Copy of all writingsand/or conclusions made by Benito Alvarez regardingthe issues involved herein or any other materials used in arrivingat Benito Alvarez's opinions in the instant matter, and any and all materials preparedby or for Jose Uz with regardto any issue with respect to the above-captionedmatter. 13. Complete statement of all billingsand chargesfor Don Wilcox's work in this case. 14. Complete statement of all billings and chargesfor Al Brizuela's work in this case. 2 CASE NO.: CACE-20-017305 15. Complete statement of all billingsand charges for Benito Alvarez's work in this case. 16. Complete copiesof any and all Don Wilcox's reports, documents and/or charts you intend to relyupon in this matter. 17. Complete copiesof any and all Al Brizuela's reports, documents and/or charts you intend to relyupon in this matter. 18. Complete copiesof any and all Benito Alvarez's reports, documents and/or charts you intend to relyupon in this matter. 19. All documents which you reasonablyexpect to offer into evidence duringthe trial of this matter. 20. Complete copy of all letters,memorandums, correspondence, emails or other communications from the Plaintiffs,Plaintiff's attorneys or Plaintiff's attorney'slaw firm or anyone on Plaintiff's behalfwith Don Wilcox. 21. Complete copy of all letters,memorandums, correspondence,emails or other communications from the Plaintiffs,Plaintiff's attorneys or Plaintiff's attorney'slaw firm or anyone on Plaintiffs' behalf with Al Brizuela. 22. Complete copy of all letters,memorandums, correspondence,emails or other communications from the Plaintiffs,Plaintiff's attorneys or Plaintiff's attorney'slaw firm or anyone on Plaintiffs' behalfwith Benito Alvarez. 23. Complete copy of all letters,memorandums, correspondence,emails or other communications from Don Wilcox to the Plaintiff,Plaintiff's attorneys or Plaintiff's attorney's law firm or anyone on Plaintiff's behalf. 3 CASE NO.: CACE-20-017305 24. Complete copy of all letters,memorandums, correspondence,emails or other communications from Al Brizuela to the Plaintiff,Plaintiff's attorneys or Plaintiff's attorney'slaw firm or anyone on Plaintiff's behalf. 25. Complete copy of all letters,memorandums, correspondence,emails or other communications from Benito Alvarez to the Plaintiff,Plaintiff's attorneys or Plaintiff's attorney's law firm or anyone on Plaintiff's behalf. 26. Copy of any and all photographs,charts,drawings,etc. reviewed by Don Wilcox in this matter. 27. Copy of any and all photographs,charts,drawings,etc. reviewed by Al Brizuela in this matter. 28. Copy of any and all photographs,charts,drawings,etc. reviewed by Benito Alvarez in this matter. 29. Copy of any and all photographs,charts,drawings,etc. prepared by Don Wilcox in this matter. 30. Copy of any and all photographs,charts,drawings,etc. preparedby Al Brizuela in this matter. 31. Copy of any and all photographs,charts,drawings,etc. preparedby Benito Alvarez in this matter. 32. Copy of any and all publications,articles,research,journals,textbooks, treatises, etc. consulted or reviewed by Don Wilcox in this matter. 33. Copy of any and all publications, articles, research,journals,textbooks, treatises, etc. consulted or reviewed by Al Brizuela in this matter. 4 CASE NO.: CACE-20-017305 34. Copy of any and all publications, articles, research,journals,textbooks,treatises, etc. consulted or reviewed by Benito Alvarez in this matter. 35. Copy of any handwritten notes taken by Don Wilcox duringthe course ofhis review in this matter. 36. Copy ofany handwritten notes taken by Al Brizuela duringthe course ofhis review in this matter. 37. Copy of any handwritten notes taken by Benito Alvarez duringthe course of his review in this matter. 38. A complete copy, cover to cover, of the Don Wilcox's file,whether kept in paper form, electronic form or other means. 39. A complete copy, cover to cover, of the Al Brizuela's file,whether kept in paper form, electronic form or other means. 40. A complete copy, cover to cover, ofthe Benito Alvarez's file,whether kept in paper form, electronic form or other means. [CERTIFICATE OF SERVICE FOLLOWSI 5 CASE NO.: CACE-20-017305 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas served via E- portalto David Garcia,Esq., Marin, Eljaiek,Lopez & Martinez P.L.; 2601 South Bayshore Drive, 18->th Floor, Coconut Grove, FL 33133; (305) 444-5969; mellaw5@mellawyers.com:eservice@mellawyers.com on this 261th day ofApril,2022, pursuant to Rule 2.516. COUNSEL FOR HERITAGE PROPERTY AND CASUALTY INSURANCE COMPANY 1571 Sawgrass Corporate Parkway, Suite 400 Sunrise,Florida 33323 Office: 954-315-1450 By-. /s/ Kelly Kobielush KELLY KOBIELUSH, ESQUIRE Florida Bar No.: 74143 kkobielush@heritagepci.com For service ofprocess,pleasealso include: scappon@heritagepci.com mcortese@heritagepci.com 6