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Filing# 146898477 E-Filed 04/01/2022 02:38:03 PM
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 EXPERT WITNESS DISCLOSURE
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 Defendant's Expert Witness Disclosure:
EXPERT WITNESSES
1.
Mr. William Wareham
Wareham Construction, Inc.
1063 Shotgun Road
Sunrise, FL 33326
Defendant experts to call Mr. Wareham as an expert witness at trial. Mr.
Wareham is a licensed General Contractor. Mr. Wareham will provide testimony
concerning his inspectionof the insured property,includinghis observations and opinions
regarding the cause, duration, and extent of the loss. Mr. Wareham's testimony will also
be based upon his review of all redacted photographs from the field adjuster,all estimates
prepared in the case, and all photographs taken by anyone who visited the property on
behalf of the Defendant and Plaintiff for this loss.
A copy of Mr. Wareham's Curriculum Vitae will be filed at a later time.
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 04/01/2022 02:38:03 PM.****
CASE NO.: CACE-21-007460
2.
Mr. Joe Hernandez
Roofer
AKG Roofing
12914 SW 133rd Court A
Miami, Florida 33186
Mr. Hernandez is a licensed roofer and will testifyas to the cause, originand
duration of the alleged loss and damages. Mr. Hernandez will relyupon the substance of
the facts in this case, the inspection of the subject property, his photographs, file
materials, educational training,experience, expertise, and other relevant factors and
materials in this case to form his opinion.
A copy of Mr. Hernandez's Curriculum Vitae will be filed at a later time.
3.
Rebuttal Expert Witnesses: Any and all expert or rebuttal witnesses whom the
Defendant may retain as to any party'stendered expert, ifany when the Defendant
learns of any and all of the stated opinions and grounds of the Plaintiff's experts.
At this time, the Plaintiff has not disclosed any expert witnesses.
4.
Impeachment Expert Witnesses: All expert witnesses whose purpose is to
impeach the testimony proffered by a fact or expert witness.
5.
Defendant reserves the rightto supplement this Disclosure as discovery in this
matter may reveal or requirethe subsequent filingof same.
6.
Defendant reserves the rightto call as an expert witness, any and all expert
witnesses listed in any expert witness disclosure and/or pretrialcatalogue filed in
this matter.
7.
Defendant reserves the rightto call as expert witnesses, any and all persons who
have been deposed or noticed of deposition in this suit.
8.
Defendant reserves the rightto object to any and all expert witnesses listed by any
other party.
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
9.
Defendant reserves the right to call any and all additional expert witnesses in
rebuttal and/or for impeachment purposes.
10. Defendant reserves the rightto amend this expert witness disclosure.
[CERTIFICATE OF SERVICE IS ON THE FOLLOWING PAGE]
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
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1st 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-
Filing Portal, which will send an automatic e-mail message to the following parties
registeredwith 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
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
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Filing# 146898477 E-Filed 04/01/2022 02:38:03 PM 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 EXPERT WITNESS DISCLOSURE 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 Defendant's Expert Witness Disclosure: EXPERT WITNESSES 1. Mr. William Wareham Wareham Construction, Inc. 1063 Shotgun Road Sunrise, FL 33326 Defendant experts to call Mr. Wareham as an expert witness at trial. Mr. Wareham is a licensed General Contractor. Mr. Wareham will provide testimony concerning his inspectionof the insured property,includinghis observations and opinions regarding the cause, duration, and extent of the loss. Mr. Wareham's testimony will also be based upon his review of all redacted photographs from the field adjuster,all estimates prepared in the case, and all photographs taken by anyone who visited the property on behalf of the Defendant and Plaintiff for this loss. A copy of Mr. Wareham's Curriculum Vitae will be filed at a later time. 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 04/01/2022 02:38:03 PM.**** CASE NO.: CACE-21-007460 2. Mr. Joe Hernandez Roofer AKG Roofing 12914 SW 133rd Court A Miami, Florida 33186 Mr. Hernandez is a licensed roofer and will testifyas to the cause, originand duration of the alleged loss and damages. Mr. Hernandez will relyupon the substance of the facts in this case, the inspection of the subject property, his photographs, file materials, educational training,experience, expertise, and other relevant factors and materials in this case to form his opinion. A copy of Mr. Hernandez's Curriculum Vitae will be filed at a later time. 3. Rebuttal Expert Witnesses: Any and all expert or rebuttal witnesses whom the Defendant may retain as to any party'stendered expert, ifany when the Defendant learns of any and all of the stated opinions and grounds of the Plaintiff's experts. At this time, the Plaintiff has not disclosed any expert witnesses. 4. Impeachment Expert Witnesses: All expert witnesses whose purpose is to impeach the testimony proffered by a fact or expert witness. 5. Defendant reserves the rightto supplement this Disclosure as discovery in this matter may reveal or requirethe subsequent filingof same. 6. Defendant reserves the rightto call as an expert witness, any and all expert witnesses listed in any expert witness disclosure and/or pretrialcatalogue filed in this matter. 7. Defendant reserves the rightto call as expert witnesses, any and all persons who have been deposed or noticed of deposition in this suit. 8. Defendant reserves the rightto object to any and all expert witnesses listed by any other party. 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 9. Defendant reserves the right to call any and all additional expert witnesses in rebuttal and/or for impeachment purposes. 10. Defendant reserves the rightto amend this expert witness disclosure. [CERTIFICATE OF SERVICE IS ON THE FOLLOWING PAGE] 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 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 1st 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- Filing Portal, which will send an automatic e-mail message to the following parties registeredwith 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 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