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Filing # 126197791 E-Filed 05/05/2021 11:03:02 AM
IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT, IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
YVETTE BONHEUR, as Personal CASE NO.: 18-34416 CA 01
Representative of the Estate of LEGITIME
ELISBRUN,
Plaintiff,
vs.
FLORIDA POWER & LIGHT COMPANY,
and LEWIS TREE SERVICE, INC.
Defendants.
__________________________________/
PLAINTIFF’S EXHIBIT LIST
Plaintiff, YVETTE BONHEUR, as Personal Representative of the Estate of LEGITIME
ELISBRUN, by and through undersigned counsel, hereby files this Exhibit List and lists the
following exhibits for trial:
1. Photographs, video tapes, depictions and/or drawings or enlargements of Plaintiff's Injuries
2. Any and all answers to Interrogatories
3. Any and all responses to Requests for Admission
4. Any and all responses to Requests for Production
5. Any and all depositions taken in this matter and corresponding exhibits
6. Any and all records of or relating to medical treatment rendered to Plaintiff, Legitime
Elisbrun, including but not limited to medical records, radiology records, radiology
images/films, pharmacy records, pathology reports, pathology specimen(s), medical bills,
and nursing notes, from any healthcare provider, including but not limited to the Aventura
Hospital records.
7. Mortality Tables
8. Medical Bills
F R E ID IN BR O W N , P .A.
One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725
9. Medical Liens
10. Paystubs and Tax Returns
11. Miami-Dade Fire Rescue Report
12. Death Certificate
13. Any and all exhibits listed by Defendants.
14. Any and all records produced by non-parties pursuant to subpoena served by any party in
this case.
15. Resumes or curricula vitae for any expert witness identified by Plaintiffs or Defendants.
16. Any text books, notes, summaries, reports, tables, data or other documents used, relied
upon, or testified by expert witnesses at trial.
17. Any and all reports prepared by expert witnesses.
18. Anatomical models, diagrams and medical illustrations.
19. Any exhibit which subsequently becomes known and information with regard to which is
disclosed to the parties within a reasonable time before trial.
20. Any and all impeachment or rebuttal exhibits.
21. Any and all records, charts, films, or other materials generated by the expert witnesses.
22. ANSI 300
23. Photographs and videos taken of the subject property.
24. Maps and aerial images of the subject property.
25. Video of Carrie Shuster
26. Shuster Email regarding Critical Palm Logs
27. FPL Distribution Vegetation Management Program Expectations
28. Electric Utility Report
29. FPL Document tiled “Clearances”
30. 2017 Florida Power & Light Company Distribution Reliability Report
F R E ID IN BR O W N , P .A.
One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725
31. FPL Verified Better Answer to Interrogatory No. 15 to Plaintiff’s First Set of
Interrogatories & In Compliance with Court Order Dated October 21, 2015 from Zaldana
v. FPL
32. City of Coral Gables Standard Procedures for FPL Pruning Trees and Removing Palms
Away from Electric Wires
33. ISA 300 Companion Best Management Practices
34. ANSI Z133.1 – Safety Requirements
35. FPL Caring for Trees and Your Service
36. Trees and Power Lines. A “Growing” Concern.
37. FPL Safety 6
38. Job Package for Feeder 806733
39. Contracts between FPL and Lewis Tree (and attachments)
40. Event Query Report
41. Photographs and videos of Legitime Elisbrun and family
42. Police Report and Photographs
43. Transcripts of depositions taken in this matter
44. Prior depositions of the witnesses in this matter
45. All Injuries are Preventable Sign
46. Applicable statutes and regulations
47. Ladder (in possession of FPL) and videos/photographs of same
48. Pole Saw (in possession of FPL) and videos/photographs of same
Plaintiff reserves the right to supplement and/or amend her Exhibit List with exhibits as
they become known to Plaintiff upon proper notice to the other parties.
Plaintiff preserves any and all objections to any and all exhibits listed by any other party
in this matter.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
F R E ID IN BR O W N , P .A.
One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725
furnished by Electronic Mail on this 5th day of May, 2021 to the following recipients:
Robert E. Boan, Esquire Michael K. Wilensky, Esquire
Angelica Torrents Roque, Esquire CONROY SIMBERG
FLORIDA POWER & LIGHT COMPANY 3440 Hollywood Boulevard
LAW DEPARTMENT 2nd Floor
4200 West Flagler Street Hollywood, Florida 33021
LAW/SCS – Second Floor Telephone: (954) 518-1221
Miami, Florida 33134 mwilensky@conroysimberg.com
Telephone: (305) 442-5115 ddemarais@conroysimberg.com
robert.boan@fpl.com Counsel for Lewis Tree Services, Inc.
angelica.roque@fpl.com
miriam.corzo.garcia@fpl.com
Counsel for Florida Power & Light
Steven M. Singer, Esquire
STEVEN M. SINGER, P.A.
7901 SW 6th Court
Suite 305
Plantation, FL 33324
steven.m.singerpa@gmail.com
Co-counsel for Plaintiff
FREIDIN BROWN P.A.
Counsel for Plaintiff
One Biscayne Tower, Suite 3100
2 South Biscayne Boulevard
Miami, FL 33131
Phone (305) 371-3666
Facsimile: (305) 371-6725
By: /s/ Jonathan E. Freidin
JOEL H. BROWN
Florida Bar No.: 131231
JONATHAN FREIDIN
Florida Bar No: 098955
jhb@fblawyers.net
jf@fblawyners.net
ya@fblawyers.net
pleadings@fblawyers.net
F R E ID IN BR O W N , P .A.
One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725
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Filing # 126197791 E-Filed 05/05/2021 11:03:02 AM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA YVETTE BONHEUR, as Personal CASE NO.: 18-34416 CA 01 Representative of the Estate of LEGITIME ELISBRUN, Plaintiff, vs. FLORIDA POWER & LIGHT COMPANY, and LEWIS TREE SERVICE, INC. Defendants. __________________________________/ PLAINTIFF’S EXHIBIT LIST Plaintiff, YVETTE BONHEUR, as Personal Representative of the Estate of LEGITIME ELISBRUN, by and through undersigned counsel, hereby files this Exhibit List and lists the following exhibits for trial: 1. Photographs, video tapes, depictions and/or drawings or enlargements of Plaintiff's Injuries 2. Any and all answers to Interrogatories 3. Any and all responses to Requests for Admission 4. Any and all responses to Requests for Production 5. Any and all depositions taken in this matter and corresponding exhibits 6. Any and all records of or relating to medical treatment rendered to Plaintiff, Legitime Elisbrun, including but not limited to medical records, radiology records, radiology images/films, pharmacy records, pathology reports, pathology specimen(s), medical bills, and nursing notes, from any healthcare provider, including but not limited to the Aventura Hospital records. 7. Mortality Tables 8. Medical Bills F R E ID IN BR O W N , P .A. One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725 9. Medical Liens 10. Paystubs and Tax Returns 11. Miami-Dade Fire Rescue Report 12. Death Certificate 13. Any and all exhibits listed by Defendants. 14. Any and all records produced by non-parties pursuant to subpoena served by any party in this case. 15. Resumes or curricula vitae for any expert witness identified by Plaintiffs or Defendants. 16. Any text books, notes, summaries, reports, tables, data or other documents used, relied upon, or testified by expert witnesses at trial. 17. Any and all reports prepared by expert witnesses. 18. Anatomical models, diagrams and medical illustrations. 19. Any exhibit which subsequently becomes known and information with regard to which is disclosed to the parties within a reasonable time before trial. 20. Any and all impeachment or rebuttal exhibits. 21. Any and all records, charts, films, or other materials generated by the expert witnesses. 22. ANSI 300 23. Photographs and videos taken of the subject property. 24. Maps and aerial images of the subject property. 25. Video of Carrie Shuster 26. Shuster Email regarding Critical Palm Logs 27. FPL Distribution Vegetation Management Program Expectations 28. Electric Utility Report 29. FPL Document tiled “Clearances” 30. 2017 Florida Power & Light Company Distribution Reliability Report F R E ID IN BR O W N , P .A. One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725 31. FPL Verified Better Answer to Interrogatory No. 15 to Plaintiff’s First Set of Interrogatories & In Compliance with Court Order Dated October 21, 2015 from Zaldana v. FPL 32. City of Coral Gables Standard Procedures for FPL Pruning Trees and Removing Palms Away from Electric Wires 33. ISA 300 Companion Best Management Practices 34. ANSI Z133.1 – Safety Requirements 35. FPL Caring for Trees and Your Service 36. Trees and Power Lines. A “Growing” Concern. 37. FPL Safety 6 38. Job Package for Feeder 806733 39. Contracts between FPL and Lewis Tree (and attachments) 40. Event Query Report 41. Photographs and videos of Legitime Elisbrun and family 42. Police Report and Photographs 43. Transcripts of depositions taken in this matter 44. Prior depositions of the witnesses in this matter 45. All Injuries are Preventable Sign 46. Applicable statutes and regulations 47. Ladder (in possession of FPL) and videos/photographs of same 48. Pole Saw (in possession of FPL) and videos/photographs of same Plaintiff reserves the right to supplement and/or amend her Exhibit List with exhibits as they become known to Plaintiff upon proper notice to the other parties. Plaintiff preserves any and all objections to any and all exhibits listed by any other party in this matter. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been F R E ID IN BR O W N , P .A. One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725 furnished by Electronic Mail on this 5th day of May, 2021 to the following recipients: Robert E. Boan, Esquire Michael K. Wilensky, Esquire Angelica Torrents Roque, Esquire CONROY SIMBERG FLORIDA POWER & LIGHT COMPANY 3440 Hollywood Boulevard LAW DEPARTMENT 2nd Floor 4200 West Flagler Street Hollywood, Florida 33021 LAW/SCS – Second Floor Telephone: (954) 518-1221 Miami, Florida 33134 mwilensky@conroysimberg.com Telephone: (305) 442-5115 ddemarais@conroysimberg.com robert.boan@fpl.com Counsel for Lewis Tree Services, Inc. angelica.roque@fpl.com miriam.corzo.garcia@fpl.com Counsel for Florida Power & Light Steven M. Singer, Esquire STEVEN M. SINGER, P.A. 7901 SW 6th Court Suite 305 Plantation, FL 33324 steven.m.singerpa@gmail.com Co-counsel for Plaintiff FREIDIN BROWN P.A. Counsel for Plaintiff One Biscayne Tower, Suite 3100 2 South Biscayne Boulevard Miami, FL 33131 Phone (305) 371-3666 Facsimile: (305) 371-6725 By: /s/ Jonathan E. Freidin JOEL H. BROWN Florida Bar No.: 131231 JONATHAN FREIDIN Florida Bar No: 098955 jhb@fblawyers.net jf@fblawyners.net ya@fblawyers.net pleadings@fblawyers.net F R E ID IN BR O W N , P .A. One Biscayne Tower, Suite 3100, 2 South Biscayne Boulevard, Miami, FL 33131, Phone: 305.371.3666, Fax: 305.371.6725