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Filing# 137120518 E-Filed 10/22/2021 03:37:12 PM
IN THE CIRCUIT COURT OF THE ,th
17'
DISTRICT IN AND FOR BROWARD
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO:
CACE-20-017319
LUIS MORENO and MARY BEATRICE
RAMOS, a married couple,
Plaintiffs,
VS.
BANTA PROPERTIES, INC., a Florida Profit
Corporation,and COLONIAL PARK
APARTMENTS, LLC, a Florida Limited Liability
Company,
Defendants.
i
PLAINTIFF'S NOTICE OF SERVING EXPERT WITNESS INTERROGATORIES TO
DEFENDANT BANTA PROPERTIES, INC.
Plaintiffs by and through their undersigned counsel,hereby propound the followingExpert
Witness Interrogatories
to Defendant BANTA PROPERTIES, INC. to be answered in the time
requiredin accordance with F.R.Civ.P. 1.340.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true copy ofthe above and foregoingwas E-Filed and E-Mailed
this 22Ind day of October 2021 to: Genevieve P. Rupelli,Esq. and Lindsay A. Adler, Esq., Cole,
Scott
& Kissane, P.A. (Genevieve.rupelli@csklegal.com;Lindsay.adler@csklegal.com;
Annette.habersham@csklegal.com).
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/22/2021 03:37:12 PM.****
Respectfullysubmitted,
THE LAW FIRM OF STUART H. SHARE, P.A.
Attorneysfor Plaintiffs
1000 Brickell Avenue
Suite 600
Miami, Florida 33131
Telephone:
(305) 371-8700
Facsimile:
(305) 749-8573
Stuart@sharelawpa.com
Josh@sharelawpa.com
amanda@sharelawpa.com
BY:
/s/ Stuart H. Share
STUART H. SHARE
Fla. Bar No: 511579
For the Firm
EXPERT WITNESS INTERROGATORIES TO DEFENDANT
1)
Please state the name, professionand professionaladdress of each person whom you or
your attorney(s)will or may call to testifyas an expert witness at the trial of this matter,
and as to each person state the following:
a.
His/her educational background, givingthe names of the institutions attended and
degrees earned with dates thereof.
b.
His/her specialty
within his/her profession.
C
His experienceswithin the field,givingthe dates,names and address of
institutions associated with, if any, and any other experienceindicatingdates and
places.
d.
The names of all professionalassociates or societies with which he/she is related
or is a member, statingthe status of each and the inclusive dates of such status.
e.
The title,names of publications,
name of publisher,and the date of publicationof
any publishedbooks, articles,
etc., authored by each such person.
f.
Whether he/she has ever been a witness any other lawsuit and, if so, for each
lawsuit,give the name of the suit,and kind of suit involved, the name of the
Court, the approximatedate ofthe testimony,and the name and address of the
partiesor attorneys for whom he/she gave evidence.
go
Whether he has ever been retained by your counsel and/or his firm,in the past. If
so, pleasespecifythe name or styleof the case and the name of the Court.
2)
State in
detail, the subject matter on which each person named in Answer to
Interrogatory#1 above is expectedto testify.
3)
State the opinionthat each such person will testify
to at trial.
4)
State in detail,the facts upon which each opinion set forth in Answer to Interrogatory#1
above is based, and as to each fact that is in any way relied upon by such person in
arrivingat his opinion,state:
a.
The names and addresses of the person supplying such facts.
b.
The form in which such facts were suppliedto him.
5)
If any person named in Answer to Interrogatory#1 above has submitted a written report
or opinionrelated to the subjectmatter ofthis case, state:
a.
The name of the person submittingsuch a written report or opinion,and
b.
The date (ordates if more than one) of such written report or opinion,and
C
The name and address of the person to whom such written report or opinionwas
submitted.
6)
Please attach a copy of each such written report or opinion set forth in your Answer to
Interrogatory #5 above.
You are requestedto attach a copy of the report to these
Answers to Interrogatoriesand supply a copy of the report to the undersigned attorney
by mail at the time the Answers to Interrogatoriesare required to be filed and served
under the applicableRules of Civil Procedure.
7)
As to each expert consulted by you or your attorney relative to the subjectmatter of this
case, but whom you do not expect to call to testify
at trial,
state:
a.
His name, professionand professionaladdress.
b.
The subjectmatter about which he was consulted.
C
If he has submitted any written reports or opinionsrelative to the subjectmatter
about which he was consulted,indicate the date or dates of such report and the
name and address of the person to whom such report was submitted.
d.
State any and all facts upon which said expert relies in any opinionshe has
expressedin said reports.
e.
State any and all documents upon which he relies in renderingsaid reports,
identifyingthe same with sufficient particularity
to be set forth in Request for
Production.
8)
Please state within the last three (3) years, how many cases Defense counsel has had
with each of the listed experts.
I have read the foregoingAnswers s to Plaintiffs' Expert Witness Interrogatories
and do
swear that they are true and correct to the best of my knowledge and belief.
Affiant
STATE OF FLORIDA
)
SS
COUNTY OF MIAMI-DADE)
BEFORE ME, the undersignedauthority,personallyappeared
who
,
is (personallyknown to me) (orhas produced
),as identification,
and who
after first being duly sworn by me deposes and says that he/she executed the foregoinganswers
to interrogatories
and that the answers contained therein are true and correct to the best of his/her
knowledge and belief.
SWORN to and SUBSCRIBED before me this
dayor
,2021.
NOTARY PUBLIC, State ofFlorida
My commission expires:
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Filing# 137120518 E-Filed 10/22/2021 03:37:12 PM IN THE CIRCUIT COURT OF THE ,th 17' DISTRICT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: CACE-20-017319 LUIS MORENO and MARY BEATRICE RAMOS, a married couple, Plaintiffs, VS. BANTA PROPERTIES, INC., a Florida Profit Corporation,and COLONIAL PARK APARTMENTS, LLC, a Florida Limited Liability Company, Defendants. i PLAINTIFF'S NOTICE OF SERVING EXPERT WITNESS INTERROGATORIES TO DEFENDANT BANTA PROPERTIES, INC. Plaintiffs by and through their undersigned counsel,hereby propound the followingExpert Witness Interrogatories to Defendant BANTA PROPERTIES, INC. to be answered in the time requiredin accordance with F.R.Civ.P. 1.340. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true copy ofthe above and foregoingwas E-Filed and E-Mailed this 22Ind day of October 2021 to: Genevieve P. Rupelli,Esq. and Lindsay A. Adler, Esq., Cole, Scott & Kissane, P.A. (Genevieve.rupelli@csklegal.com;Lindsay.adler@csklegal.com; Annette.habersham@csklegal.com). *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/22/2021 03:37:12 PM.**** Respectfullysubmitted, THE LAW FIRM OF STUART H. SHARE, P.A. Attorneysfor Plaintiffs 1000 Brickell Avenue Suite 600 Miami, Florida 33131 Telephone: (305) 371-8700 Facsimile: (305) 749-8573 Stuart@sharelawpa.com Josh@sharelawpa.com amanda@sharelawpa.com BY: /s/ Stuart H. Share STUART H. SHARE Fla. Bar No: 511579 For the Firm EXPERT WITNESS INTERROGATORIES TO DEFENDANT 1) Please state the name, professionand professionaladdress of each person whom you or your attorney(s)will or may call to testifyas an expert witness at the trial of this matter, and as to each person state the following: a. His/her educational background, givingthe names of the institutions attended and degrees earned with dates thereof. b. His/her specialty within his/her profession. C His experienceswithin the field,givingthe dates,names and address of institutions associated with, if any, and any other experienceindicatingdates and places. d. The names of all professionalassociates or societies with which he/she is related or is a member, statingthe status of each and the inclusive dates of such status. e. The title,names of publications, name of publisher,and the date of publicationof any publishedbooks, articles, etc., authored by each such person. f. Whether he/she has ever been a witness any other lawsuit and, if so, for each lawsuit,give the name of the suit,and kind of suit involved, the name of the Court, the approximatedate ofthe testimony,and the name and address of the partiesor attorneys for whom he/she gave evidence. go Whether he has ever been retained by your counsel and/or his firm,in the past. If so, pleasespecifythe name or styleof the case and the name of the Court. 2) State in detail, the subject matter on which each person named in Answer to Interrogatory#1 above is expectedto testify. 3) State the opinionthat each such person will testify to at trial. 4) State in detail,the facts upon which each opinion set forth in Answer to Interrogatory#1 above is based, and as to each fact that is in any way relied upon by such person in arrivingat his opinion,state: a. The names and addresses of the person supplying such facts. b. The form in which such facts were suppliedto him. 5) If any person named in Answer to Interrogatory#1 above has submitted a written report or opinionrelated to the subjectmatter ofthis case, state: a. The name of the person submittingsuch a written report or opinion,and b. The date (ordates if more than one) of such written report or opinion,and C The name and address of the person to whom such written report or opinionwas submitted. 6) Please attach a copy of each such written report or opinion set forth in your Answer to Interrogatory #5 above. You are requestedto attach a copy of the report to these Answers to Interrogatoriesand supply a copy of the report to the undersigned attorney by mail at the time the Answers to Interrogatoriesare required to be filed and served under the applicableRules of Civil Procedure. 7) As to each expert consulted by you or your attorney relative to the subjectmatter of this case, but whom you do not expect to call to testify at trial, state: a. His name, professionand professionaladdress. b. The subjectmatter about which he was consulted. C If he has submitted any written reports or opinionsrelative to the subjectmatter about which he was consulted,indicate the date or dates of such report and the name and address of the person to whom such report was submitted. d. State any and all facts upon which said expert relies in any opinionshe has expressedin said reports. e. State any and all documents upon which he relies in renderingsaid reports, identifyingthe same with sufficient particularity to be set forth in Request for Production. 8) Please state within the last three (3) years, how many cases Defense counsel has had with each of the listed experts. I have read the foregoingAnswers s to Plaintiffs' Expert Witness Interrogatories and do swear that they are true and correct to the best of my knowledge and belief. Affiant STATE OF FLORIDA ) SS COUNTY OF MIAMI-DADE) BEFORE ME, the undersignedauthority,personallyappeared who , is (personallyknown to me) (orhas produced ),as identification, and who after first being duly sworn by me deposes and says that he/she executed the foregoinganswers to interrogatories and that the answers contained therein are true and correct to the best of his/her knowledge and belief. SWORN to and SUBSCRIBED before me this dayor ,2021. NOTARY PUBLIC, State ofFlorida My commission expires: