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Filing # 149009285 E-Filed 05/05/2022 10:56:16 AM
UP-17739
SJC/emm IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA
ALBERTO SERFATY,
CASE NO.: 2021-013619-CA-01 (13)
Plaintiff,
v.
UNIVERSAL PROPERTY &
CASUALTY INSURANCE COMPANY,
Defendant.
_______________________________/
DEFENDANT, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY’S
EXPERT WITNESS REQUEST TO PRODUCE
COMES NOW, the Defendant, UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY, by and through undersigned counsel, pursuant to Florida Rules
of Civil Procedure, Rule 1.350, and hereby serves its Expert Witness Request for
Production to Plaintiff, ALBERTO SERFATY, and respectfully requests that Plaintiff
produce the following within thirty (30) days from the date of this Request:
1. The Retainer Agreements by which your experts are rendering their services.
2. Your experts' complete billing files for this case including, but not limited to,
the charges for service rendered, invoices or statements rendered, evidence of payment
and records of all time spent on this case.
3. Copies of all invoices, documents, records, checks, receipts, tax records or
any other form of financial information evidencing payment or compensation paid by your
or any other party for services provided by each of your identified and retained expert
witnesses in this case.
4. Your identified and retained expert witnesses' current Curriculum Vitae.
CASE NO: 2021-013619-CA-01 (13)
5. All reports and/or writings setting forth the opinions and/or observations of
your retained and identified expert witnesses in this case.
6. Copies of all written materials prepared by your expert witnesses or at its
direction, including but not limited to notes, drafts of reports, final reports, memoranda, and
correspondence in any way referencing and/or pertaining to the Project that is the subject
of this litigation.
7. Copies of all written materials provided by you to any expert witnesses
retained by you in this case, including but not limited to all correspondence between you
and your expert witnesses.
8. All materials your experts, their agents and/or employees reviewed in this
matter including, but not limited to, depositions, correspondence, photographs, reports,
books, articles, literature, films, tests, samples, experiments, statements, correspondence
or other documents or other reference materials that were used or relied upon in their
analysis.
9. All notes, work papers, writings, memoranda, calculations, measurements,
which your experts, their employees or agents have prepared regarding the Project that is
the subject of this litigation and/or with respect to any issue in this action.
10. Copies of all articles or literature which your experts relied upon or reviewed
in reaching their opinions and conclusions in connection with this lawsuit.
11. Copies of any transcript of prior deposition testimony or trial testimony given
by your experts.
12. Copies of any brochure or advertisement which would reflect your experts'
availability to review cases for attorneys.
13. A list of cases in which your experts were named as a Defendant in any civil
or criminal proceeding.
14. Copies of any written contract, agreements, proposals and invoices reflecting
your experts' fee arrangement for providing consulting services in this case.
15. Any and all reports prepared or furnished by your experts, their agents and/or
employees, in this case, whether interim, final, or otherwise; and whether sent or not.
16. Any and all reports which were furnished to your experts, their agents and/or
employees, by any other person or entity in this case.
17. All electronically stored information responsive to requests 1 - 6.
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has
been sent by e-mail on this the 5 th day of May, 2022, to: Stephanie P. Williams, Esq.,
Attorney for Plaintiff, spw@spwlawfirm.com.
BERNSTEIN, CHACKMAN, LISS
Attorneys for Defendant Universal
4000 Hollywood Blvd., Suite 610 North
Hollywood, FL 33021
(954) 986-9600 - Broward
(305) 940-1900 - Dade
(954) 929-1166 - Fax
By: /s/ Steven J. Chackman
Steven J. Chackman
Florida Bar No.: 376851
Michael B. Chackman
Florida Bar No.: 105797
schackman@bernstein-chackman.com
mchackman@bernstein-chackman.com
G:\WP\UP-17739\rtp exp plt.wpd
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Filing # 149009285 E-Filed 05/05/2022 10:56:16 AM UP-17739 SJC/emm IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI- DADE COUNTY, FLORIDA ALBERTO SERFATY, CASE NO.: 2021-013619-CA-01 (13) Plaintiff, v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. _______________________________/ DEFENDANT, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY’S EXPERT WITNESS REQUEST TO PRODUCE COMES NOW, the Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by and through undersigned counsel, pursuant to Florida Rules of Civil Procedure, Rule 1.350, and hereby serves its Expert Witness Request for Production to Plaintiff, ALBERTO SERFATY, and respectfully requests that Plaintiff produce the following within thirty (30) days from the date of this Request: 1. The Retainer Agreements by which your experts are rendering their services. 2. Your experts' complete billing files for this case including, but not limited to, the charges for service rendered, invoices or statements rendered, evidence of payment and records of all time spent on this case. 3. Copies of all invoices, documents, records, checks, receipts, tax records or any other form of financial information evidencing payment or compensation paid by your or any other party for services provided by each of your identified and retained expert witnesses in this case. 4. Your identified and retained expert witnesses' current Curriculum Vitae. CASE NO: 2021-013619-CA-01 (13) 5. All reports and/or writings setting forth the opinions and/or observations of your retained and identified expert witnesses in this case. 6. Copies of all written materials prepared by your expert witnesses or at its direction, including but not limited to notes, drafts of reports, final reports, memoranda, and correspondence in any way referencing and/or pertaining to the Project that is the subject of this litigation. 7. Copies of all written materials provided by you to any expert witnesses retained by you in this case, including but not limited to all correspondence between you and your expert witnesses. 8. All materials your experts, their agents and/or employees reviewed in this matter including, but not limited to, depositions, correspondence, photographs, reports, books, articles, literature, films, tests, samples, experiments, statements, correspondence or other documents or other reference materials that were used or relied upon in their analysis. 9. All notes, work papers, writings, memoranda, calculations, measurements, which your experts, their employees or agents have prepared regarding the Project that is the subject of this litigation and/or with respect to any issue in this action. 10. Copies of all articles or literature which your experts relied upon or reviewed in reaching their opinions and conclusions in connection with this lawsuit. 11. Copies of any transcript of prior deposition testimony or trial testimony given by your experts. 12. Copies of any brochure or advertisement which would reflect your experts' availability to review cases for attorneys. 13. A list of cases in which your experts were named as a Defendant in any civil or criminal proceeding. 14. Copies of any written contract, agreements, proposals and invoices reflecting your experts' fee arrangement for providing consulting services in this case. 15. Any and all reports prepared or furnished by your experts, their agents and/or employees, in this case, whether interim, final, or otherwise; and whether sent or not. 16. Any and all reports which were furnished to your experts, their agents and/or employees, by any other person or entity in this case. 17. All electronically stored information responsive to requests 1 - 6. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been sent by e-mail on this the 5 th day of May, 2022, to: Stephanie P. Williams, Esq., Attorney for Plaintiff, spw@spwlawfirm.com. BERNSTEIN, CHACKMAN, LISS Attorneys for Defendant Universal 4000 Hollywood Blvd., Suite 610 North Hollywood, FL 33021 (954) 986-9600 - Broward (305) 940-1900 - Dade (954) 929-1166 - Fax By: /s/ Steven J. Chackman Steven J. Chackman Florida Bar No.: 376851 Michael B. Chackman Florida Bar No.: 105797 schackman@bernstein-chackman.com mchackman@bernstein-chackman.com G:\WP\UP-17739\rtp exp plt.wpd