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Filing# 147893195 E-Filed 04/18/2022 05:51:57 PM
IN
THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND
FOR
BROWARD
COUNTY,
FLORIDA
CASE NO.: CACE-21-007460
AMER JERDANA,
Plaintiff,
V
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF
COMES NOW Defendant, CITIZENS PROPERTY INSURANCE CORPORATION,
by and through its undersigned counsel, and hereby notifies this Court and counsel of
record that it has served the attached Boecher Request For Production upon Amer
Jerdana ("Plaintiff')
to be answered under oath in writing within thirty(30) days, in
accordance with the Florida Rules of Civil Procedure.
Page 1
COLE, SCOTT & KISSANE, P.A.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/18/2022 05:51:56 PM.****
CASE NO.: CACE-21-007460
DEFENDANT'S BOECHER REQUEST FOR PRODUCTION TO PLAINTIFF
1.
All files maintained by any expert Plaintiff has listed to testifyregarding this matter.
2.
Any and all materials Plaintiff's experts have reviewed in this matter, including,but not
limited to, correspondence, photographs, reports, books, articles,literature,films,
tests, experiments, statements, or other reference materials that Plaintiffs used or are
relyingon.
3.
Any and all reports prepared or furnished to Plaintiffor Plaintiffs counsel by any expert
in this case.
4.
Any and all reports which were furnished to Plaintiffs experts by other experts in this
case.
5.
Curriculum vitae for all experts that Plaintiff plans to call at trial.
6.
Any and all test results and/or experiments conducted in this case by any experts.
7.
Any and all results of tests which any experts, agents, servants or employees
conducted in this case.
8.
Complete billingfiles maintained by any expert in this case, including,but not limited
to, the charges rendered, the statements rendered, the time spent on this case, and
other relevant materials concerning the time and billingon this case.
9.
Any and all notes, writings,memoranda, etc. which have been made or prepared for
this case by any experts, agents, servants or employees.
10.Any and all computer printoutsfrom computers used by any experts, agents, servants
or employees which were prepared for this case.
11.Any and all literature written by any expert listed in this case.
12. A list of all cases in which any expert has been retained to testifyin the past five years,
including the name of the attorney who retained the expert, the name of the case
which the expert testified,the court and judicialcircuit in which the case was filed and
the case number.
13. A copy of any and all written correspondence either directed to any expert listed in this
case from Plaintiffs counsel or written by any expert listed in this case to Plaintiffs
counsel.
14.All textbooks, journals or similar literature which any expert listed in this case has
consulted and for which any expert listed in this case has relied upon in order to arrive
at any opinions which he/she/they will render in this case.
-2-
COLE, SCOTT & KISSANE, P.A.
110 TOWER - 110 S.E. 6TH STREET, SUITE 2700 - FT. LAUDERDALE, FLORIDA 33301 (954) 703-3700 (954) 703-3701 FAX
CASE NO.: CACE-21-007460
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18th day of April,2022, a true and correct copy
of the foregoing was filed with the Clerk of Broward County by using the Florida Courts
e-FilingPortal, which will send an automatic e-mail message to the following parties
registered with the e-FilingPortal system: Teresa J. Urda, Esq., Law Offices of Marcote
&
Marcote
De
Moya,
PLLC,
urda@insurancelawadvocate.com;matthew.corrons@insurancelawadvocate.com,
12595 S.W. 137th Avenue, Miami, FL 33186, (305) 256-2616/(305) 256-2446 (F),
Attorney for Plaintiff,
Amer Jerdana.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant CITIZENS PROPERTY
INSURANCE CORPORATION
110 Tower
110 S.E. 6th Street, Suite 2700
Fort Lauderdale, Florida 33301
Telephone (954) 703-3706
Facsimile (954) 703-3701
Primary e-mail: jose.campos@csklegal.corn
Secondary e-mail: jake.roth@csklegal.corn
Alternate e-mail:
francesca.orellana@csklegal.com
By:
s/ Jake A. Roth
JOSE F. CAMPOS
Florida Bar No.- 110733
JAKE A. ROTH
Florida Bar No.- 1025881
3228.6626-00
-3.
COLE, SCOTT & KISSANE, P.A.
110 TOWER - 110 S.E. 6TH STREET, SUITE 2700 - FT. LAUDERDALE, FLORIDA 33301 (954) 703-3700 (954) 703-3701 FAX
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Filing# 147893195 E-Filed 04/18/2022 05:51:57 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-007460 AMER JERDANA, Plaintiff, V CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. DEFENDANT'S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF COMES NOW Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by and through its undersigned counsel, and hereby notifies this Court and counsel of record that it has served the attached Boecher Request For Production upon Amer Jerdana ("Plaintiff') to be answered under oath in writing within thirty(30) days, in accordance with the Florida Rules of Civil Procedure. Page 1 COLE, SCOTT & KISSANE, P.A. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/18/2022 05:51:56 PM.**** CASE NO.: CACE-21-007460 DEFENDANT'S BOECHER REQUEST FOR PRODUCTION TO PLAINTIFF 1. All files maintained by any expert Plaintiff has listed to testifyregarding this matter. 2. Any and all materials Plaintiff's experts have reviewed in this matter, including,but not limited to, correspondence, photographs, reports, books, articles,literature,films, tests, experiments, statements, or other reference materials that Plaintiffs used or are relyingon. 3. Any and all reports prepared or furnished to Plaintiffor Plaintiffs counsel by any expert in this case. 4. Any and all reports which were furnished to Plaintiffs experts by other experts in this case. 5. Curriculum vitae for all experts that Plaintiff plans to call at trial. 6. Any and all test results and/or experiments conducted in this case by any experts. 7. Any and all results of tests which any experts, agents, servants or employees conducted in this case. 8. Complete billingfiles maintained by any expert in this case, including,but not limited to, the charges rendered, the statements rendered, the time spent on this case, and other relevant materials concerning the time and billingon this case. 9. Any and all notes, writings,memoranda, etc. which have been made or prepared for this case by any experts, agents, servants or employees. 10.Any and all computer printoutsfrom computers used by any experts, agents, servants or employees which were prepared for this case. 11.Any and all literature written by any expert listed in this case. 12. A list of all cases in which any expert has been retained to testifyin the past five years, including the name of the attorney who retained the expert, the name of the case which the expert testified,the court and judicialcircuit in which the case was filed and the case number. 13. A copy of any and all written correspondence either directed to any expert listed in this case from Plaintiffs counsel or written by any expert listed in this case to Plaintiffs counsel. 14.All textbooks, journals or similar literature which any expert listed in this case has consulted and for which any expert listed in this case has relied upon in order to arrive at any opinions which he/she/they will render in this case. -2- COLE, SCOTT & KISSANE, P.A. 110 TOWER - 110 S.E. 6TH STREET, SUITE 2700 - FT. LAUDERDALE, FLORIDA 33301 (954) 703-3700 (954) 703-3701 FAX CASE NO.: CACE-21-007460 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 18th day of April,2022, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Courts e-FilingPortal, which will send an automatic e-mail message to the following parties registered with the e-FilingPortal system: Teresa J. Urda, Esq., Law Offices of Marcote & Marcote De Moya, PLLC, urda@insurancelawadvocate.com;matthew.corrons@insurancelawadvocate.com, 12595 S.W. 137th Avenue, Miami, FL 33186, (305) 256-2616/(305) 256-2446 (F), Attorney for Plaintiff, Amer Jerdana. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant CITIZENS PROPERTY INSURANCE CORPORATION 110 Tower 110 S.E. 6th Street, Suite 2700 Fort Lauderdale, Florida 33301 Telephone (954) 703-3706 Facsimile (954) 703-3701 Primary e-mail: jose.campos@csklegal.corn Secondary e-mail: jake.roth@csklegal.corn Alternate e-mail: francesca.orellana@csklegal.com By: s/ Jake A. Roth JOSE F. CAMPOS Florida Bar No.- 110733 JAKE A. ROTH Florida Bar No.- 1025881 3228.6626-00 -3. COLE, SCOTT & KISSANE, P.A. 110 TOWER - 110 S.E. 6TH STREET, SUITE 2700 - FT. LAUDERDALE, FLORIDA 33301 (954) 703-3700 (954) 703-3701 FAX