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Filing # 105617048 E-Filed 03/30/2020 02:37:18 PM
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
GUILLERMO DOMINGUEZ CASE NUMBER: 2019-016161 CA 01 (11)
and INGRID DOMINGUEZ,
CIRCUIT CIVIL DIVISION
Plaintiffs,
v.
CITIZENS PROPERTY
INSURANCE CORPORATION,
Defendant.
____________________________________/
PLAINTIFFS’ RESPONSES TO DEFENDANT’S EXPERT REQUEST TO PRODUCE
Plaintiffs respond to Defendant’s Expert Request to Produce as follows:
1. Curriculum Vitae for each expert listed on your witness list(s).
Plaintiffs state that any documents responsive to these items of the request in their
possession are enclosed.
2. Reports, correspondence, invoices, bills, statements, documents and materials relative
to this lawsuit received by Plaintiff or Plaintiff’s counsel from each expert listed on
your witness list.
Plaintiffs state that any documents responsive to these items of the request in their
possession are enclosed.
3. Reports, correspondence, documents and materials relative to this lawsuit sent or
transmitted to each expert listed on your witness list(s), by Plaintiff’s counsel, Plaintiff,
or any other person on Plaintiff’s behalf.
Plaintiffs state that any documents responsive to these items of the request in their
possession are enclosed.
4. A complete copy of the file(s) maintained by each expert listed on your witness
list(s), relative to the subject lawsuit, including all documents and materials created
by each expert, received by or transmitted to each expert, and upon which each
expert relies for his or her respective opinions.
www.YourAttorneys.com
J.P.Gonzalez-Sirgo,P.A., 814 Ponce de Leon Boulevard, Suite 504, Coral Gables, FL 33134
Phone (305) 461-1095
Plaintiffs state that any documents responsive to these items of the request in their
possession are enclosed.
5. All photographs and videotapes viewed and/or taken by or for each expert in
connection with this case.
Plaintiffs state that any documents responsive to these items of the request in their
possession are enclosed.
6. Copies of all witness statements, written or recorded, which each expert has
examined in connection with this case.
Plaintiffs state that they are unaware of any documents responsive to these items of the
request in their possession.
7. Any drawings, graphs, charts, illustrations or plans prepared by each expert in
connection with this matter.
Plaintiffs state that any documents responsive to these items of the request in their
possession are enclosed.
8. Copies of any and all notes, calculations or other data prepared by each expert in
formulating his or her opinions in connection with this case.
Plaintiffs state that any documents responsive to these items of the request in their
possession are enclosed.
9. Office records indicating time spent on each expert’s undertaking and hourly charges
therefore in connection with this case.
Plaintiffs state that they are unaware of any documents responsive to these items of the
request in their possession.
10. Reports of other experts which each expert has read in formulating any
opinions in connection with this case.
None.
11. Any publications, treatises, manuals, textbooks or other documents used as a
reference by each expert in connection with this case or considered authoritative by
each expert in support of his or her opinions.
Plaintiffs state that they are unaware of any documents responsive to these items of the
request in their possession.
www.YourAttorneys.com
J.P.Gonzalez-Sirgo,P.A., 814 Ponce de Leon Boulevard, Suite 504, Coral Gables, FL 33134
Phone (305) 461-1095
12. Copies of any correspondence written by each expert or received from others with
whom each expert has consulted in connection with this case.
Plaintiffs state that they are unaware of any documents responsive to these items of the
request in their possession.
13. Any memoranda reviewed which was prepared by the Plaintiff’s attorneys engaging
each expert, investigator, paralegal or adjuster in connection with this case.
Plaintiffs state that they are unaware of any documents responsive to these items of the
request in their possession.
14. Any other document in writing, film, photograph, object or information of any
kind or description which each expert has viewed in formulating or which each
expert contends supports his or her opinion(s) in connection with this case.
Plaintiffs state that they are unaware of any documents responsive to these items of the
request in their possession.
15. All documents each expert reviewed, referred to or relied upon in arriving at any of
his or her opinions or conclusions concerning the issues involved in this case,
including but not limited to all scientific and technical articles, publications,
codes, standards and other literature.
Plaintiffs state that any documents responsive to these items of the request in their
possession are enclosed.
16. All models, illustrations, photographs or other exhibits or documents of any kind
which each expert intends or contemplates using to explain, illustrate or support his
or her testimony at trial.
Plaintiffs state that any documents responsive to these items of the request in their
possession are enclosed.
CERTIFICATE OF SERVICE
I CERTIFY that the foregoing document has been furnished to:
Counsel for Defendant:
William E. Peters, Jr.
Michelle R. Musa, Esq.
Boyd Richards Parker & Colonnelli, P.L.
1600 W. Commercial Boulevard
Suite 201
Fort Lauderdale, FL 33309
www.YourAttorneys.com
J.P.Gonzalez-Sirgo,P.A., 814 Ponce de Leon Boulevard, Suite 504, Coral Gables, FL 33134
Phone (305) 461-1095
Telephone: (954) 848-2460
Fax: (954) 848-2470
E-mail: serviceFLL@boydlawgroup.com; mmusa@boydlawgroup.com;
tbush@boydlawgroup.com; khawkins@boydlawgroup.com;
wpeters@boydlawgroup.com
By E-mail / Mail / Hand Delivery / Facsimile on this 30th day of March, 2020.
Jorge A. Calil, Esq.
Attorney at Law
J. P. Gonzalez-Sirgo, P.A.
814 Ponce de Leon Boulevard
Suite 504
Coral Gables, Florida 33134
Jorge Direct: (786) 272-5846
Office: (305) 461-1095
Jorge Email: jcalil@yourattorneys.com
Assistant Email: tatiana@yourattorneys.com
Email Service: eservice@yourattorneys.com
/s/ Jorge A. Calil, Esq.
F.B.N. 685321
Counsel for Plaintiffs
www.YourAttorneys.com
J.P.Gonzalez-Sirgo,P.A., 814 Ponce de Leon Boulevard, Suite 504, Coral Gables, FL 33134
Phone (305) 461-1095
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Filing # 105617048 E-Filed 03/30/2020 02:37:18 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GUILLERMO DOMINGUEZ CASE NUMBER: 2019-016161 CA 01 (11) and INGRID DOMINGUEZ, CIRCUIT CIVIL DIVISION Plaintiffs, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. ____________________________________/ PLAINTIFFS’ RESPONSES TO DEFENDANT’S EXPERT REQUEST TO PRODUCE Plaintiffs respond to Defendant’s Expert Request to Produce as follows: 1. Curriculum Vitae for each expert listed on your witness list(s). Plaintiffs state that any documents responsive to these items of the request in their possession are enclosed. 2. Reports, correspondence, invoices, bills, statements, documents and materials relative to this lawsuit received by Plaintiff or Plaintiff’s counsel from each expert listed on your witness list. Plaintiffs state that any documents responsive to these items of the request in their possession are enclosed. 3. Reports, correspondence, documents and materials relative to this lawsuit sent or transmitted to each expert listed on your witness list(s), by Plaintiff’s counsel, Plaintiff, or any other person on Plaintiff’s behalf. Plaintiffs state that any documents responsive to these items of the request in their possession are enclosed. 4. A complete copy of the file(s) maintained by each expert listed on your witness list(s), relative to the subject lawsuit, including all documents and materials created by each expert, received by or transmitted to each expert, and upon which each expert relies for his or her respective opinions. www.YourAttorneys.com J.P.Gonzalez-Sirgo,P.A., 814 Ponce de Leon Boulevard, Suite 504, Coral Gables, FL 33134 Phone (305) 461-1095 Plaintiffs state that any documents responsive to these items of the request in their possession are enclosed. 5. All photographs and videotapes viewed and/or taken by or for each expert in connection with this case. Plaintiffs state that any documents responsive to these items of the request in their possession are enclosed. 6. Copies of all witness statements, written or recorded, which each expert has examined in connection with this case. Plaintiffs state that they are unaware of any documents responsive to these items of the request in their possession. 7. Any drawings, graphs, charts, illustrations or plans prepared by each expert in connection with this matter. Plaintiffs state that any documents responsive to these items of the request in their possession are enclosed. 8. Copies of any and all notes, calculations or other data prepared by each expert in formulating his or her opinions in connection with this case. Plaintiffs state that any documents responsive to these items of the request in their possession are enclosed. 9. Office records indicating time spent on each expert’s undertaking and hourly charges therefore in connection with this case. Plaintiffs state that they are unaware of any documents responsive to these items of the request in their possession. 10. Reports of other experts which each expert has read in formulating any opinions in connection with this case. None. 11. Any publications, treatises, manuals, textbooks or other documents used as a reference by each expert in connection with this case or considered authoritative by each expert in support of his or her opinions. Plaintiffs state that they are unaware of any documents responsive to these items of the request in their possession. www.YourAttorneys.com J.P.Gonzalez-Sirgo,P.A., 814 Ponce de Leon Boulevard, Suite 504, Coral Gables, FL 33134 Phone (305) 461-1095 12. Copies of any correspondence written by each expert or received from others with whom each expert has consulted in connection with this case. Plaintiffs state that they are unaware of any documents responsive to these items of the request in their possession. 13. Any memoranda reviewed which was prepared by the Plaintiff’s attorneys engaging each expert, investigator, paralegal or adjuster in connection with this case. Plaintiffs state that they are unaware of any documents responsive to these items of the request in their possession. 14. Any other document in writing, film, photograph, object or information of any kind or description which each expert has viewed in formulating or which each expert contends supports his or her opinion(s) in connection with this case. Plaintiffs state that they are unaware of any documents responsive to these items of the request in their possession. 15. All documents each expert reviewed, referred to or relied upon in arriving at any of his or her opinions or conclusions concerning the issues involved in this case, including but not limited to all scientific and technical articles, publications, codes, standards and other literature. Plaintiffs state that any documents responsive to these items of the request in their possession are enclosed. 16. All models, illustrations, photographs or other exhibits or documents of any kind which each expert intends or contemplates using to explain, illustrate or support his or her testimony at trial. Plaintiffs state that any documents responsive to these items of the request in their possession are enclosed. CERTIFICATE OF SERVICE I CERTIFY that the foregoing document has been furnished to: Counsel for Defendant: William E. Peters, Jr. Michelle R. Musa, Esq. Boyd Richards Parker & Colonnelli, P.L. 1600 W. Commercial Boulevard Suite 201 Fort Lauderdale, FL 33309 www.YourAttorneys.com J.P.Gonzalez-Sirgo,P.A., 814 Ponce de Leon Boulevard, Suite 504, Coral Gables, FL 33134 Phone (305) 461-1095 Telephone: (954) 848-2460 Fax: (954) 848-2470 E-mail: serviceFLL@boydlawgroup.com; mmusa@boydlawgroup.com; tbush@boydlawgroup.com; khawkins@boydlawgroup.com; wpeters@boydlawgroup.com By E-mail / Mail / Hand Delivery / Facsimile on this 30th day of March, 2020. Jorge A. Calil, Esq. Attorney at Law J. P. Gonzalez-Sirgo, P.A. 814 Ponce de Leon Boulevard Suite 504 Coral Gables, Florida 33134 Jorge Direct: (786) 272-5846 Office: (305) 461-1095 Jorge Email: jcalil@yourattorneys.com Assistant Email: tatiana@yourattorneys.com Email Service: eservice@yourattorneys.com /s/ Jorge A. Calil, Esq. F.B.N. 685321 Counsel for Plaintiffs www.YourAttorneys.com J.P.Gonzalez-Sirgo,P.A., 814 Ponce de Leon Boulevard, Suite 504, Coral Gables, FL 33134 Phone (305) 461-1095