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Filing# 145084189 E-Filed 03/04/2022 11:45:00 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
AMER JERDANA,
CASE NO.: CACE-21-007460
Plaintiff,
V
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
DEFENDANT'S WITNESS LIST
COMES NOW Defendant, CITIZENS PROPERTY INSURANCE CORPORATION,
by and through its undersigned counsel, and pursuant to the operative Case Management
Plan and Order, hereby files its Witness List as follows:
1.
Corporate Representative of Citizens Property Insurance Corporation
c/o Cole, Scott & Kissane, RA.
The Corporate Representative intends to testifyas to the policy information,
coverages, the subject claim, and applicable dates.
2.
Ronald Jenkins
Filed Adjuster
c/o Cole, Scott & Kissane, RA.
Ronald Jenkins will testifyas to his involvement in the claim, including as to
any reports, photos, and/or estimates created as a result of his inspection of
the subject property.
3.
Amer Jerdana
Insured will testifyas to the subject claim, priordamage, alleged damage for
the subject claim, and all repairs before and after the date of loss.
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
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/04/2022 11:44:59 AM.****
CASE NO.: CACE-21-007460
4.
Janeece Perona of Ademar, The Public Adjusting Firm
Ademar, The Public Adjusting Firm
13055 Bird Road, Ste. 204
Miami, Florida 33175
Janeece Perona of Ademar, The Public Adjusting Firm will testifyas to their
involvement in this claim, including as to any inspections, photos, and
estimates.
5.
Corporate Representative of Ademar, The Public Adjusting Firm
Ademar, The Public Adjusting Firm
13055 Bird Road, Ste. 204
Miami, Florida 33175
The Corporate Representative ofAdemar, The Public Adjusting Firm will testify
as to their involvement in this claim, includingas to any reports,photos, and
estimates created as a result of any inspections of the subject property.
6.
Records Custodian of Ademar, The Public Adjusting Firm
Ademar, The Public Adjusting Firm
13055 Bird Road, Ste. 204
Miami, Florida 33175
The Records Custodian ofAdemar, The Public Adjusting Firm will authenticate
applicable documents such as any reports,photographs, and estimates.
7.
Any residents that have resided at the subject property.
8.
Any and all witnesses listed by Plaintiff,
without waiving objection thereto.
9.
The respective records custodians for all companies identified above.
10.
Any impeachment or rebuttal witnesses.
11.
Any and all individuals who are deposed and who will be deposed priorto trial.
12.
Records custodians from any buildingdepartments that might have knowledge
as to the subject property.
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
13.
Any insurance agents and/or representatives associated with the subject
insurance policyor any insurance policy in reference to the subject property.
14.
All other witnesses determined through future discovery.
15.
Any contractors who have visited the property.
16.
Defendant reserves the rightto amend this fact witness list.
EXHIBITS
1.
Policy Number 03754708 with effective dates of February 20, 2019 through
February 20,2020, including Declaration Page(s) and all attachments, and/or
endorsements, and/or renewals thereto, and/or application.
2.
Coverage Determination Letter from Defendant to Plaintiff dated December 10,
2020.
3.
Estimate prepared by Ademar, The Public Adjusting Firm in the amount of
$27,623.68.
4. All correspondence from Plaintiff,or Plaintiff's representatives or agents, to
Defendant.
5.
All correspondence from Defendant or Defendant's representatives or agents,
to Plaintiff or Plaintiff's representatives or agents.
6.
Resumes or curriculum vitae for Defendant's expert witnesses called by
Defendant.
7.
Defendant's responses to discovery.
8.
All
documents produced by the parties in response to any request for
production or other discovery requests.
9.
Any and all documents produced in response to subpoenas from Plaintiff or
Defendant.
10. Defendant reserves the rightto listand/or produce additional exhibits.
11. Any and all exhibits listed on Plaintiff's Exhibit List filed under separate cover.
12.All transcriptsof depositions taken in this case.
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
CASE NO.: CACE-21-007460
13.All documents relied upon by witnesses.
14.All photographs taken by Plaintiff in relation to the subject property.
15.The entire file of all experts in Defendant's Expert Witness List, including
photographs and reports.
16.The entire file of all experts listed in Plaintiff's Expert Witness List,including
photographs and reports.
17.All estimates prepared on behalf of the Plaintiff.
18.Any engineering reports prepared on behalf of the Plaintiff.
19.All aerial photographs of the subject property.
20.All permits relatingto the subject property.
21.All
correspondence
between
Defendant
and
Plaintiff, including
their
representatives.
22.All licenses associated with the subject property.
23.All deposition transcriptsand attached exhibits.
24.Any and all exhibits listed by Plaintiff,
without waiving objection thereto.
25.Any and all documents and correspondence not yet discovered.
[CERTIFICATE OF SERVICE IS ON THE FOLLOWING PAGE]
4
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 4th day of March, 2022, a true and correct copy
of the foregoing was filed with the Clerk of Broward County by using the Florida Courts
e-Filing Portal, 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
5
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# 145084189 E-Filed 03/04/2022 11:45:00 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA AMER JERDANA, CASE NO.: CACE-21-007460 Plaintiff, V CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. DEFENDANT'S WITNESS LIST COMES NOW Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by and through its undersigned counsel, and pursuant to the operative Case Management Plan and Order, hereby files its Witness List as follows: 1. Corporate Representative of Citizens Property Insurance Corporation c/o Cole, Scott & Kissane, RA. The Corporate Representative intends to testifyas to the policy information, coverages, the subject claim, and applicable dates. 2. Ronald Jenkins Filed Adjuster c/o Cole, Scott & Kissane, RA. Ronald Jenkins will testifyas to his involvement in the claim, including as to any reports, photos, and/or estimates created as a result of his inspection of the subject property. 3. Amer Jerdana Insured will testifyas to the subject claim, priordamage, alleged damage for the subject claim, and all repairs before and after the date of loss. 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 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/04/2022 11:44:59 AM.**** CASE NO.: CACE-21-007460 4. Janeece Perona of Ademar, The Public Adjusting Firm Ademar, The Public Adjusting Firm 13055 Bird Road, Ste. 204 Miami, Florida 33175 Janeece Perona of Ademar, The Public Adjusting Firm will testifyas to their involvement in this claim, including as to any inspections, photos, and estimates. 5. Corporate Representative of Ademar, The Public Adjusting Firm Ademar, The Public Adjusting Firm 13055 Bird Road, Ste. 204 Miami, Florida 33175 The Corporate Representative ofAdemar, The Public Adjusting Firm will testify as to their involvement in this claim, includingas to any reports,photos, and estimates created as a result of any inspections of the subject property. 6. Records Custodian of Ademar, The Public Adjusting Firm Ademar, The Public Adjusting Firm 13055 Bird Road, Ste. 204 Miami, Florida 33175 The Records Custodian ofAdemar, The Public Adjusting Firm will authenticate applicable documents such as any reports,photographs, and estimates. 7. Any residents that have resided at the subject property. 8. Any and all witnesses listed by Plaintiff, without waiving objection thereto. 9. The respective records custodians for all companies identified above. 10. Any impeachment or rebuttal witnesses. 11. Any and all individuals who are deposed and who will be deposed priorto trial. 12. Records custodians from any buildingdepartments that might have knowledge as to the subject property. 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 13. Any insurance agents and/or representatives associated with the subject insurance policyor any insurance policy in reference to the subject property. 14. All other witnesses determined through future discovery. 15. Any contractors who have visited the property. 16. Defendant reserves the rightto amend this fact witness list. EXHIBITS 1. Policy Number 03754708 with effective dates of February 20, 2019 through February 20,2020, including Declaration Page(s) and all attachments, and/or endorsements, and/or renewals thereto, and/or application. 2. Coverage Determination Letter from Defendant to Plaintiff dated December 10, 2020. 3. Estimate prepared by Ademar, The Public Adjusting Firm in the amount of $27,623.68. 4. All correspondence from Plaintiff,or Plaintiff's representatives or agents, to Defendant. 5. All correspondence from Defendant or Defendant's representatives or agents, to Plaintiff or Plaintiff's representatives or agents. 6. Resumes or curriculum vitae for Defendant's expert witnesses called by Defendant. 7. Defendant's responses to discovery. 8. All documents produced by the parties in response to any request for production or other discovery requests. 9. Any and all documents produced in response to subpoenas from Plaintiff or Defendant. 10. Defendant reserves the rightto listand/or produce additional exhibits. 11. Any and all exhibits listed on Plaintiff's Exhibit List filed under separate cover. 12.All transcriptsof depositions taken in this case. 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 CASE NO.: CACE-21-007460 13.All documents relied upon by witnesses. 14.All photographs taken by Plaintiff in relation to the subject property. 15.The entire file of all experts in Defendant's Expert Witness List, including photographs and reports. 16.The entire file of all experts listed in Plaintiff's Expert Witness List,including photographs and reports. 17.All estimates prepared on behalf of the Plaintiff. 18.Any engineering reports prepared on behalf of the Plaintiff. 19.All aerial photographs of the subject property. 20.All permits relatingto the subject property. 21.All correspondence between Defendant and Plaintiff, including their representatives. 22.All licenses associated with the subject property. 23.All deposition transcriptsand attached exhibits. 24.Any and all exhibits listed by Plaintiff, without waiving objection thereto. 25.Any and all documents and correspondence not yet discovered. [CERTIFICATE OF SERVICE IS ON THE FOLLOWING PAGE] 4 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 4th day of March, 2022, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Courts e-Filing Portal, 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 5 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