On June 11, 2021 a
Trial Materials
was filed
involving a dispute between
Serfaty, Alberto,
Sp Flia Corp,
and
Universal Property & Casualty Insurance Company,
for Insurance Claim
in the District Court of Miami-Dade County.
Preview
Filing # 144149341 E-Filed 02/17/2022 04:13:27 PM
IN THE CIRCUIT COURT OF THE 11TH JUDICIAL
CIRCUIT IN AND FOR MIAMI DADE COUNTY,
FLORIDA
CASE NO. 2021-014441-CA-01
NANCY FABELO,
Plaintiff,
v.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S WITNESS LIST AND EXHIBIT LIST
Plaintiff, NANCY FABELO, by and through her undersigned counsel and pursuant to the
Order Setting the Jury Trial and Directing Pre-trial and Mediation Procedures submits the
following:
WITNESS LIST
1. Nancy Fabelo
5342 SW 159th Ave.
Miami, FL 33185
2. JSEBASA Consultant
Javier Alvarez
1416 SW 150th Ave.
Miami, FL 33194
3. Nichol Lewis
Universal Claims Examiner
954-958-1200
4. Al Brizuela Engineering, Inc.
Alfredo Brizuela - President
13309 SW 124 Street
Miami, Florida 33186
305-908-8733
2
5. All records custodian for non-parties who produced records in this suit.
6. All witnesses on Defendant’s Witness List.
7. All rebuttal witnesses.
8. The Plaintiff have not identified any testifying experts at this time but will
properly disclose all testifying experts as identified and pursuant to the trial order.
EXHIBIT LIST
1. Plaintiff’s estimate prepared by JSEBASA Consultant.
2. Plaintiff’s estimate prepared by Alfredo Brizuela.
3. Photographs taken by Plaintiff.
4. Photographs taken by JSEBASA Consultant.
5. Photographs taken by Alfredo Brizuela.
6. Reports prepared by Alfredo Brizuela.
7. Affidavit prepared in support of Plaintiff’s claim.
8. Universal Property & Casualty Insurance Company Policy No. 1501-1500-7766.
9. Any and all correspondence from Plaintiff and/or their representatives to Universal Property
& Casualty Insurance Company
10. Any and all correspondence from Universal Property & Casualty Insurance Company to
Plaintiff and their representatives.
11. Sworn Statement in Proof of Loss.
12. The entire file from JSEBASA Consultant, including but not limited to, all reports,
proposals, invoices, estimates, and photographs for the property located at 5342 SW 159th
Ave., Miami, FL 33185.
13. Any and all letters, emails, faxes, and other correspondence exchanged between Universal
Property & Casualty Insurance Company and the Plaintiff and their respective agents,
including all attachments.
3
14. Photographs taken by Nichol Lewis Warren.
15. All estimates prepared by Nichol Lewis Warren.
16. Any and all photographs taken of the risk.
17. All estimates prepared on behalf of Defendant.
18. All estimates prepared on behalf of Universal Property & Casualty Insurance Company.
19. All impeachment material.
20. Any and all exhibits produced by any person pursuant to a subpoena duces tecum or by any
other party pursuant to a Notice of Non-Party Production, including request for production.
21. Any and all pertinent ordinances, municipal provisions, Florida Statutes, relevant to any of
the allegations of the Plaintiff’s Complaint and Defendant’s Answers and Affirmative
Defenses.
22. Any and all bills, receipts, or otherwise pertaining to the Plaintiff’s risk.
23. Any and all photographs, videotapes, demonstrative material of any sort performed by any
of the experts retained by any of the parties herein with respect to the case.
24. Any and all statements, including but not limited to recorded statements, affidavits,
deposition transcripts and exhibits thereto, videotaped depositions and any other transcripts
taken in connection with this lawsuit.
25. Any and all exhibits attached to pleadings, statements, deposition transcripts, videotaped
depositions and any other transcripts taken in connection with this lawsuit.
26. Any non-objectionable exhibits listed by any other party.
27. Any and all answers to the parties’ Interrogatories.
28. Any and all responses to the parties’ Request for Production.
29. Any and all answers to the parties’ Request for Admissions.
30. Any and all exhibits, newly discovered after the filing hereof, upon prompt and reasonable
notice of the Plaintiff.
4
31. Any and all exhibits listed on the Defendant's Exhibit List.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
by email service generated by the Florida E-filing Portal Service to all parties of record this 17th day
of February 2022.
SPW LAW FIRM
Counsel for Plaintiff
8950 SW 74 Court, Suite 2201
Miami, FL 33156
305-714-2114
By: /S/ Stephanie Williams
Stephanie Williams Florida Bar
No.: 103202
spw@spwlawfirm.com
5
Document Filed Date
February 17, 2022
Case Filing Date
June 11, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 144149341 E-Filed 02/17/2022 04:13:27 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI DADE COUNTY, FLORIDA CASE NO. 2021-014441-CA-01 NANCY FABELO, Plaintiff, v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / PLAINTIFF’S WITNESS LIST AND EXHIBIT LIST Plaintiff, NANCY FABELO, by and through her undersigned counsel and pursuant to the Order Setting the Jury Trial and Directing Pre-trial and Mediation Procedures submits the following: WITNESS LIST 1. Nancy Fabelo 5342 SW 159th Ave. Miami, FL 33185 2. JSEBASA Consultant Javier Alvarez 1416 SW 150th Ave. Miami, FL 33194 3. Nichol Lewis Universal Claims Examiner 954-958-1200 4. Al Brizuela Engineering, Inc. Alfredo Brizuela - President 13309 SW 124 Street Miami, Florida 33186 305-908-8733 2 5. All records custodian for non-parties who produced records in this suit. 6. All witnesses on Defendant’s Witness List. 7. All rebuttal witnesses. 8. The Plaintiff have not identified any testifying experts at this time but will properly disclose all testifying experts as identified and pursuant to the trial order. EXHIBIT LIST 1. Plaintiff’s estimate prepared by JSEBASA Consultant. 2. Plaintiff’s estimate prepared by Alfredo Brizuela. 3. Photographs taken by Plaintiff. 4. Photographs taken by JSEBASA Consultant. 5. Photographs taken by Alfredo Brizuela. 6. Reports prepared by Alfredo Brizuela. 7. Affidavit prepared in support of Plaintiff’s claim. 8. Universal Property & Casualty Insurance Company Policy No. 1501-1500-7766. 9. Any and all correspondence from Plaintiff and/or their representatives to Universal Property & Casualty Insurance Company 10. Any and all correspondence from Universal Property & Casualty Insurance Company to Plaintiff and their representatives. 11. Sworn Statement in Proof of Loss. 12. The entire file from JSEBASA Consultant, including but not limited to, all reports, proposals, invoices, estimates, and photographs for the property located at 5342 SW 159th Ave., Miami, FL 33185. 13. Any and all letters, emails, faxes, and other correspondence exchanged between Universal Property & Casualty Insurance Company and the Plaintiff and their respective agents, including all attachments. 3 14. Photographs taken by Nichol Lewis Warren. 15. All estimates prepared by Nichol Lewis Warren. 16. Any and all photographs taken of the risk. 17. All estimates prepared on behalf of Defendant. 18. All estimates prepared on behalf of Universal Property & Casualty Insurance Company. 19. All impeachment material. 20. Any and all exhibits produced by any person pursuant to a subpoena duces tecum or by any other party pursuant to a Notice of Non-Party Production, including request for production. 21. Any and all pertinent ordinances, municipal provisions, Florida Statutes, relevant to any of the allegations of the Plaintiff’s Complaint and Defendant’s Answers and Affirmative Defenses. 22. Any and all bills, receipts, or otherwise pertaining to the Plaintiff’s risk. 23. Any and all photographs, videotapes, demonstrative material of any sort performed by any of the experts retained by any of the parties herein with respect to the case. 24. Any and all statements, including but not limited to recorded statements, affidavits, deposition transcripts and exhibits thereto, videotaped depositions and any other transcripts taken in connection with this lawsuit. 25. Any and all exhibits attached to pleadings, statements, deposition transcripts, videotaped depositions and any other transcripts taken in connection with this lawsuit. 26. Any non-objectionable exhibits listed by any other party. 27. Any and all answers to the parties’ Interrogatories. 28. Any and all responses to the parties’ Request for Production. 29. Any and all answers to the parties’ Request for Admissions. 30. Any and all exhibits, newly discovered after the filing hereof, upon prompt and reasonable notice of the Plaintiff. 4 31. Any and all exhibits listed on the Defendant's Exhibit List. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by email service generated by the Florida E-filing Portal Service to all parties of record this 17th day of February 2022. SPW LAW FIRM Counsel for Plaintiff 8950 SW 74 Court, Suite 2201 Miami, FL 33156 305-714-2114 By: /S/ Stephanie Williams Stephanie Williams Florida Bar No.: 103202 spw@spwlawfirm.com 5