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Filing # 116924227 E-Filed 11/18/2020 08:17:57 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA CIVIL DIVISON
DORIS M. SWIDER By and through
Attorney-in-Fact Mary Swider-Spresser,
Plaintiff,
v. Case No: 2019-CA-1883
UNIVERSAL INSURANCE COMPANY
OF NORTH AMERICA,
Defendant,
/
PLAINTIFF’S RESPONSES TO DEFENDANT’S EXPERT
BOECHER/SPRINGER REQUEST FOR PRODUCTION OF DOCUMENTS
COMES NOW, the Plaintiff, DORIS M. SWIDER by and through Attorney in Fact
MARY SWIDER SPRESSER, by and through the undersigned counsel and filed this, it’s
Response to Defendants Request for Production dated July 24, 2020, as follows:
GENERAL OBJECTIONS
General Objection: Plaintiff specifically objects to any assertion by STATE FARM FLORIDA
INSURANCE COMPANY (hereinafter “State Farm”), that it is in need of ALL or each and every
document or material requested in this Request for Production, as State Farm has not met its burden
to prove State Farm has need of said documents or materials in the preparation of its case, and that
State Farm is unable without undue hardship to obtain the substantial equivalent of the materials
by other means.
General Objection: Plaintiff objects to each instruction, definition, and document request to the
extent that it purports to impose any requirement or discovery obligation greater than or different
from those under the Fla. Rules of Civil Procedure and the applicable Rules and Orders of the
Court.
General Objection: Plaintiff objects to each document request and interrogatory that is overly
broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible
evidence.
General Objection: Plaintiff objects to each document request to the extent that it calls for
production of a privilege log for documents of Plaintiffs. A request for such a log is unreasonable
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 11/18/2020 08:17:57 PMand unduly burdensome in light of the attorney client privilege, and other privileges protecting such
documents from discovery.
General Objection: Plaintiff objects to each instruction, definition, and document request to the
extent that it seeks documents protected from disclosure by the attorney-client privilege,
deliberative process privilege, attorney work product doctrine, or any other applicable privilege.
Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of
any privilege.
General Objection: Plaintiff objects to each instruction, definition, and document request as
overbroad and unduly burdensome to the extent it seeks documents or information that are readily
or more accessible to Defendant from Defendant's own files, from documents or information in
Defendant's possession, or from documents or information that Defendant previously produced to
Plaintiff. Responding to such requests and interrogatory would be oppressive, unduly burdensome,
and unnecessarily expensive, and the burden of responding to such requests is substantially the same
or less for Defendant as for Plaintiffs. This objection encompasses, but is not limited to, documents
previously produced by Defendant to Plaintiffs in the course of State Farm’s, investigation of the
claim, all correspondence between the Plaintiffs and Defendant, all other information provided by
Defendant to Plaintiffs, and all information produced by Plaintiffs to Defendant in response to
discovery requests of Defendant. All such documents and information will not be produced.
General Objection: Defendant's document requests call for the production of documents and
information that were produced to the Plaintiffs by other entities and that may contain confidential,
proprietary, or trade secret information.
General Objection: To the extent any of Defendant's document requests that include expert
material, including but not limited to survey materials, Plaintiffs object to any such requests as
premature and expressly reserves the right to supplement, clarify, revise, or correct any or all
responses to such requests, and to assert additional objections or privileges, in one or more
subsequent supplemental response(s) in accordance with the time period for exchanging expert
reports set by the Court.
General Objection: Plaintiff incorporates by reference every general objection set forth above
into each specific response set forth below. A specific response may repeat a general objection for
emphasis or some other reason. The failure to include any general objection in any specific
response does not waive any general objection to that request. Moreover, Plaintiffs do not waive
their right to amend their responses.RESPONSES TO DOCUMENTS REQUESTED
1. All documents or tangible items of whatsoever nature pertaining to the following:
a. The scope of the employment of your expert(s) in this case and the compensation for
such services.
RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead
to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs
responses to Defendant’s Request for Production.
b. The general litigation experience of your expert(s) including the percentage of work
performed for plaintiff and defendant.
RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead
to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs
responses to Defendant’s Request for Production.
c. The identity of any other insurance claims or legal actions in which your expert(s)
has/have rendered opinions or evaluations for you during the last three (3) years.
RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead
to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs
responses to Defendant’s Request for Production.
d. The identity of other cases, including the style of the case, case number, and venue,
in which your expert(s) has/have testified by deposition or at trial for you during
the last three (3) years.RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead
to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs
responses to Defendant’s Request for Production.
e. Any approximation of the portion of your expert(s) involvement as an expert witness,
which may be based on the number of hours, percentage of hours, or percentage of the
experts’ professional time.
RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to
the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiff's
responses to Defendant’s Request for Production.
2. Copies of any and all invoices, records, memorabilia, checks, check stubs, receipts, 1099s, tax
records or any other form of financial information evidencing payment or compensation paid
by Plaintiffs (as defined herein) for services provided by your expert(s) for the last three (3)
years.
RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to
the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs
responses to Defendant’s Request for Production.
3. Copies of deposition and trial transcripts for testimony provided by your expert(s) as identified
in Request 1(d) above.RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to
the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs
responses to Defendant’s Request for Production.
4. Your expert(s) most current curriculum vitae or resume.
RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead
to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs
responses to Defendant’s Request for Production.
5. Any and all writings by your expert’s relating in any way to this case, including but not limited
to reports, handwritten notes, charts, diagrams, tables, measurements, or other written material.
RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead
to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiff's
responses to Defendant’s Request for Production.
6. Any and all reports by your expert(s) prepared in connection with other cases and claims in
which your expert(s) has/have been hired by you (as defined herein) during the past three (3)
years. In order to sufficiently address the privacy concerns raised by Graham v. Dacheikh,
991 So. 2 932 (Fla. 2d DCA 2008), you are to redact all personally identifying information
from the reports.RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead
to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the
following is set forth:
Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive
relevant documents contained in Plaintiff's Production File and referred to in Plaintiff's
responses to Defendant’s Request for Production.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon
Defendant and all interested persons listed on the myflcourtaccess.com e-filing portal through that
portal on November 18, 2020
By:/s/ Brittany Panter
Brittany Panter, Esq.
Florida Bar Number 115779
VishioForry Insurance Lawyers
1300 Goodlette-Frank Rd N.,
Suite 202
Naples, FL 34103
(239) 703-7210
(239) 900-1993 (Fax)
Service at service@vishioforry.com
BPanter@vishioforry.com
Attorneys for PlaintiffCurriculum Vitae ofMs: Kimberly Ward-Skeel
Specialist Field Construction Estimator &
Property Rehabilitation
On Behalf of Mary Swider (Plaintiff)
Prepared for Lee County, Circuit Civil Division
Claim number 1702FL24003876
Ms. Kimberly Ward-Skeel
Curriculum Vitae
Qualifications, Training, Accreditation
University of Indianapolis, A.S. Paralegal Studies 1989
University of Indianapolis, B.S. International Trade & Business Administration 1994
Independent Adjuster, P&C & Workers Compensation
Ladder Now Senior Inspector & Consultant, Roof Systems & Property Inspection Certification, Maestro Certification
HAAG Certified Inspector
Xactimate Level 3 Certification
Edimate Reconstruction Building Software Certification & Corporate Trainer
Past and Present Positions
Present: Independent Adjuster & Loss Consultant, The Avant Garde Group, LLC (2015-2019)
Partner, Distressed Property Acquisition, AGG Properties LLC (2017-2019)
Past: Ladder Now Senior Inspector & Consultant (2011-2017)
Owner’s Liaison & Project Manager for Commercial / Multifamily Property Development, SBV, Inc. (2010 - 2013)
Property Investigator, Foreclosure Property Winterization, The Legal Concierge (2006 — 2010)
Director of Contracts, Intellectual Property & Facilities, Legal Department, John Wiley & Sons, Inc. (2001 — 2005)
International Trade Consultant, Bose McKinney & Evans, LLP. (2000- 2001)
Merger & Acquisitions Legal Associate, International Trade Consultant, The Dow Chemical Company (1990 — 2000)
Paralegal, Intellectual Property & International Trade Regulation, Barnes & Thornburg, (1985 — 1990)
Principal Professional Specialties
| specialize in material and costs analysis of catastrophic damage to residential and commercial properties. On-site assessment of
damages to real property, including costs analysis of material and man hours, environmental, safety and governmental compliance
costs, supply and demand of labor and material resources, interpretation of plans and drawings for new builds and project
rehabilitation, identify the required materials, while considering the required code upgrades/compliance, to restore a dwelling to its
original state, unless otherwise deemed unrepairable or inhabitable.
Professional Responsibilities & Projects
Over 6,000 onsite inspections and estimates of residential and commercial properties.
Acquisition and rehabilitation of more than 30 residential properties, most with catastrophic damage, determine rebuild plan,
required materials and labor needs and costs.
Served on the Development Team for the land (over 300 acres) and facility development (45,400 sf) of the national headquarters
and research facility of the joint venture between Eli Lilly & Company and The Dow Chemical.
Acquisition of real property and associated plants and offices nationwide, conducted due diligence, managed environmental
conditions, determined property and equipment valuations, retrofitting and rehabilitation costs of plants, research facilities and
office buildings.
1|Page Kimberly Ward-Skeel Curriculum VitaeCurriculum Vitae of
Specialist Field
On Behalf of
Prepared for
Claim number
: Ms. Kimberly Ward-Skeel
Construction Estimator &
Property Rehabilitation
Mary Swider (Plaintiff)
Collier County, Circuit Civil Div.
1702FL24003876
Project Manger for major destination hotel renovation. Renovation taken down to studs, materials lists for all trades of the rebuild.
Project Manager for metropolitan apartment complex renovation consisting of 24 buildings, multiple trades and superintendents,
mold remediation, large equipment contract negotiation, bulk material acquisition, progress inspections, management and approval
of completion/occupancy certifications and unit turnover to management company.
Continuing Education
Meet 24 month continuing education requirements for my Adjuster license and HAAG Certification through various organizations.
Member and annual attendance of Windstorm Conference.
Xactimate continuous training.
Currently studying for Florida General Contractor Licensing Exam.
2|Page Kimberly Ward-Skeel
Curriculum Vitaeci
FORGE
ENGINE EMINGs
INNOVATIVE ENGINEERING SOLUTIONS
CURRICULUM VITAE
JUNE 2020
Matt H. Nolton, P.E.
Professional Registrations:
Florida, Number 44081, Civil Engineering — March 1991
Florida, Number CG -C045302, General Contractor — Class “A”, December 1988
Education:
Bachelor of Science Civil Engineering, 1986, University of South Florida - Tampa
(Areas of study Construction Materials and Geotechnical Studies)
Lely High School, 1979, Naples, Collier County, Florida
Employment:
2011- Present: Forge Engineering, Inc., CEO/Senior Principal Engineer
1996 - 2011: Forge Engineering, Inc., Vice President/Principal Engineer
Specializing in Forensic Engineering Studies, Building Sciences, Roofing, Marine,
and Geotechnical Engineering, Construction Specifications/Management, and Legal
Case Support.
1986 - 1996: Law Engineering and Environmental Services, Inc.
1994 - 1996: Southwest Florida Operations Manager/Principal Engineer, Law
Engineering, Inc. Specializing in Forensic Engineering
1990 - 1994: Southwest Florida Operations Manager/Senior Project Engineer, Law
Engineering, Inc. Specializing in Forensic Engineering
1987 - 1990: Construction Services Department Manager/Project Engineer, Law
Engineering, Inc.
1986 - 1987: Project Engineer, Law Engineering, Inc.
1990-2019: Contractor (part time), Nsquare, Inc., Naples, Florida. CEO and 40%
owner of a local construction company. This company specialized in repair,
renovation, and remodel work on existing structures including the construction of a
few single-family residences. This Company switched its focus in October of 2005
and now specializes in foundation repairs, marine construction, and damp proofing of
foundations/crawlspaces.
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.comCURRICULUM VITAE — JUNE 2020 Matt H. Nolton, P.E.
1985 - 1986: Engineering Technician, Soil and Material Engineers, Inc., Tampa,
Florida. Performed engineering inspection and quality control on large construction
projects.
1983 - 1985: Carpenter, The Columbus Company, Tampa, Florida. Performed
carpentry work on various road and bridge projects.
1978 - 1980: Carpenter, Boran Craig Schreck Construction Company, Inc.
Performed carpentry work on various residential and commercial projects in Collier
County.
Relevant Experience:
Forensic — Failure Analysis evaluation, Design, Specification Preparation,
and Construction Management of:
Forensic engineering and expert testimony on various projects including:
Coating failures and application,
Concrete restoration,
Bulkhead Walls/Seawalls,
Materials Engineering,
Metallurgy,
Water intrusion damage,
Roofing damage/deterioration/failures,
Fire damage,
Blasting/vibration damage,
Construction vibration damage,
Vibration prevention methods and techniques,
Asphaltic pavements,
Concrete construction,
Sound Studies,
Property Condition Surveys on numerous commercial properties throughout the
United States,
¢ Construction materials and
¢ Geotechnical related issues.
Project Management of over 2,000 forensic engineering studies relating to
investigation of construction component failures on small single story buildings, 30-
plus story structures, bridges and roads.
Project Management of over 3,000 construction materials projects ranging from small
single story buildings to 30-plus story structures to bridges and roads with
construction costs ranging from $200,000 to $50 million.
Extensive experience with construction materials, geotechnical and facilities
engineering.
Construction Engineering and Inspection (CEI) project management on Florida
Department of Transportation (FDOT) projects.
Project Engineer for FDOT district wide (District 1) materials testing contract,
including extensive testing and evaluation of crushed limestone base material.
Technical and liability review of other Professionals work.
Page 2 of 4
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.com
=CURRICULUM VITAE — JUNE 2020 Matt H. Nolton, P.E.
Relevant Experience (cont.):
e Review and negotiation of contracts including dealing with the Consultants
Competitive Negotiation Act.
¢ Quality assurance of engineering operations.
Development of project budgets.
Preparation of proposals and engineering reports.
Construction/Construction Management
e Have personally been responsible for the estimating, contracting, permitting, billing
and managing of over 200 construction projects ranging from small
renovations/additions to million dollar plus single-family residences also including all
phases of concrete restoration and rehabilitation of exterior coatings.
e Have performed plan and construction cost reviews on over 200 projects for lending
institutions ranging in scope from 2 million-dollar residences to 40 million-dollar
resorts/condominiums.
e Have performed construction loan draw inspections on over 100 projects for lending
institutions ranging in scope from 2 million-dollar residences to 40 million-dollar
resorts.
Professional Associations:
National Academy of Forensic Engineers
American College of Forensic Examiners
American Society of Civil Engineers (Past Branch President and Director)
Technical Council on Forensic Engineering, ASCE
American Concrete Institute (Past Branch Director)
Florida Engineering Society
National Society of Professional Engineers
American Society for Testing of Materials
Building Managers International
Qualified Expert Witness
e Circuit Court, Collier County, Florida
e Circuit Court, Lee County, Florida
Certifications/Training:
The Genesis of Toxic Mold
Structural Condition Assessment of Existing Structures
Solving Water Intrusion and Mold Problems in Florida
Forensic Engineering, Florida Engineering Society
Advanced Contracts
Advanced Loss and Liability
Page 3 of 4
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.comCURRICULUM VITAE — JUNE 2020 Matt H. Nolton, P.E.
Certifications/Trai
Proposal Writing
Introduction to Professional Practice
Coating Systems
Roofing Basics
Concrete Repair Basics
Concrete Plant Inspector
Asphalt Pavements
Trouble Shooting Concrete Problems
Florida Building Code 2004
Florida Building Code 2004 Advanced
Wind Mitigation Methodology: Retrofits for Existing Homes
Reinforced Concrete Tilt-Up Panel Construction
Precast Concrete Erection Procedures
Preventing Accidents in the Construction Industry
Construction Arbitration: An Overview
Construction Mediation: An Overview
Achievable Barrier Removal & Accessibility
ASCE 7-02 Basic Wind Loads
Awards:
e Young Engineer of the Year, 1990, American Society of Civil Engineers, Southwest
Florida Branch
e Engineer of the Year, 1999, American Society of Civil Engineers, Southwest Florida
Branch
e Engineer of the Year, 1999, American Society of Civil Engineers, South Florida
Section
e Recognition for being President of the Naples Pelican Bay Rotary Club, 2008-2009
e Rotarian of the Year, 2012-2013 Naples Pelican Bay Rotary Club
Page 4 of 4
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.comci
FORGE
eG Niele Gs
INNOVATIVE ENGINEERING SOLUTIONS
December 10, 2018
MS. MARY SWIDER
9376 Sweetgrass Way
Naples, FL 34112
Phone: 248.515.1024
Email: me.swider@gmail.com
Subject: Report for Forensic Engineering Consulting Services
After Irma - Roof Inspection
9376 SWEETGRASS WAY
Naples, Collier County, Florida
Forge Engineering Proposal Number 4813-001.01
Forge Engineering Inc. (FORGE) is pleased to present this report of engineering consulting
services for the subject building. These services were completed in general accordance with
our proposal No. 4813-001.01P dated November 13, 2018 and authorized by you on November
21, 2018. This report has been generated as requested by you and presents our opinion of the
conditions encountered on the subject roof.
FORGE has endeavored to conduct the services identified herein in a manner consistent with
that level of care and skill ordinarily exercised by members of the same profession currently
practicing in the same locality and under similar conditions as this project. No other
representation, express or implied, is included or intended in this document.
Project Information
Our understanding of your needs for this project is based on the information provided by you,
along with our experience on similar projects. We understand the concrete tile roof system at
your residence was damaged during Hurricane Irma and that currently your insurance company
is denying coverage of the loss. Therefore, you have engaged FORGE to complete a post
Hurricane Irma exterior roof evaluation to document any observed damages.
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01
9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018
Site Observation
Engineering personnel from our office visited the subject building on November 29, 2018 to
observe and document the condition of the roof at the subject site. We have listed below
information or observations obtained during our site visit.
e The subject site includes one-story single-family residential building.
¢ We understand the roof was installed circa 1997.
« The concrete roof tiles have a low double-S profile. The existing tiles are “Lifetile” and
are no longer manufactured.
¢ Concrete tiles in the field areas are attached with one fastener per tile with exception to
hip and ridge tiles, which are attached to the wooden board anchors with one fastener.
e The roof underlayment is assumed to consist of a two-ply hot-mop system, which
typically consists of a 90-pound cap sheet, adhered to a mechanically fastened base
sheet (30/90 underlayment system) over plywood sheathing supported by pre-
engineered wood trusses.
¢ The slope of the roof covering system varies from 4:12 to 8:12.
e In general, all of the concrete tiles at the low-sloped (4:12) roof were loose and their
adhesive foam attachment was noted to have experienced complete failure due to wind
uplift.
e The majority of the concrete tiles at the steeper sloped roof were observed to have lifted
during the storm and are no longer properly secured to the roof deck. Pull up testing
revealed that over 70% of the concrete tiles uplifted between 3- to 4-inches.
e Numerous hip and ridge tiles were noted to be loose and not properly secured to the roof
wooden board anchors.
¢ Various field tiles were noted to be loose and/or displaced.
¢ Several roof tiles were observed to be broken or cracked (roughly 1%).
e Numerous misaligned/displaced field tiles were observed on the roof.
¢ We noted cracked, broken, and separated mortar along the majority of the ridges.
The following photographs were taken at the time of our site visit and are representative of the
conditions observed.
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PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.com
cuReport of Engineering Consulting Services FORGE Project No. 4813-001.01
9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018
8) 10 11
ee
Teg Ou eu
View of typical concrete roof tile “LifeTile” (no longer manufactured).
Page 3 of 9
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01
9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018
View of typical tile uplift.
Page 4of9
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01
9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018
View of group of uplifted tiles.
Page 5o0f9
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01
9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018
View of group of loose /displaced field tiles.
Page 6 of 9
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01
9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018
View of group of broken and loose /displaced field tiles.
Page 7 of 9
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.com
cuReport of Engineering Consulting Services FORGE Project No. 4813-001.01
9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018
Evaluation and Recommendations
Our evaluation is based on the project information provided to us, our field observations, and
our experience with similar projects. Our inspection did not include destructive testing and only
included an evaluation of visible roof components. Should new information become available or
the conditions encountered during future remediation be substantially different from the
information presented in this report, please contact us so we may evaluate the new information.
It is evident that the concrete tile roof system for the subject building show signs of hurricane-
related damages. The hurricane damage is largely evident through broken tiles, displaced tiles,
and loose / uplifted tiles. The loose tiles appear to have uplifted during the storm and are no
longer properly attached to the roof deck. In a letter provided by the Tile Roofing Institute (TRI)
following Hurricane Irma, it states that, in general, roof tiles that are able to be lifted greater than
or equal to 2-inches are considered to be uplifted and are no longer properly secured to the roof
deck (see Attachment). In addition, when the tiles uplifted, the fasteners utilized to attach the
tiles experienced partial pullout, which results in the seal at the fastener / roof membrane
interface to become compromised and allows potential avenues for water intrusion to occur.
It is important to note, that some of the distress observed is associated with hips and ridges.
Typically, hips and ridges are one of the most vulnerable components of the sloped roofing
system against the attack of the wind forces.
The 2017 Florida Building Code Existing Building states the following as it pertains to roof
repairs. “Not more than 25 percent of the total roof area or roof section of any existing building
or structure shall be repaired, replaced or recovered in any 12-month period unless the entire
roofing system or roof section conforms to requirements of this code”. Therefore, if the damage
sustained to the roof exceeds 25 percent of the total roof area, then complete replacement of
the roof is required per the Florida Building Code.
It is our professional engineering opinion that the roof of the subject residence has sustained
damage greater than 25 percent of the total roof area. Therefore, the roof cannot be repaired
per the Florida Building Code. It should also be noted that the existing roof tiles are no longer
manufactured and are no longer available to match the existing roof tiles. Therefore, any
replacement tiles installed on this roof will not match or properly interlock with the existing tile
profile. Therefore, any remediation to the roof would result in a roof without a proper Florida
Page 8 of 9
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.com
cuReport of Engineering Consulting Services FORGE Project No. 4813-001.01
9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018
Building Code approved and tested assembly in conflict with the building code. It is our opinion
that due to the amount of damage sustained to the roof during Hurricane Irma, total replacement
of the roof is required per the Florida Building Code.
Closing
We trust the information contained herein is suitable for your needs and appreciate the
opportunity to have been of service to you. Should you have any questions or if we can be of
further assistance, please call us.
Sincerely,
Forge Engineering, Inc.
Florida Cert. of Auth. No. 7544
Felix M. Anton, P.E., S.1.
Senior Engineer
Florida Registration No. 77755
Attachment: Letter from Tile Roofing Institute: “Evaluation of Tile Systems after Wind Events”
Distribution: | 1— Addressee (via email),
1 -File
Page 9 of 9
PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161
www.ForgeEng.com
cuATTACHMENTTO: Whom It\co
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Rick Olson | |
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Filing # 116924227 E-Filed 11/18/2020 08:17:57 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL DIVISON DORIS M. SWIDER By and through Attorney-in-Fact Mary Swider-Spresser, Plaintiff, v. Case No: 2019-CA-1883 UNIVERSAL INSURANCE COMPANY OF NORTH AMERICA, Defendant, / PLAINTIFF’S RESPONSES TO DEFENDANT’S EXPERT BOECHER/SPRINGER REQUEST FOR PRODUCTION OF DOCUMENTS COMES NOW, the Plaintiff, DORIS M. SWIDER by and through Attorney in Fact MARY SWIDER SPRESSER, by and through the undersigned counsel and filed this, it’s Response to Defendants Request for Production dated July 24, 2020, as follows: GENERAL OBJECTIONS General Objection: Plaintiff specifically objects to any assertion by STATE FARM FLORIDA INSURANCE COMPANY (hereinafter “State Farm”), that it is in need of ALL or each and every document or material requested in this Request for Production, as State Farm has not met its burden to prove State Farm has need of said documents or materials in the preparation of its case, and that State Farm is unable without undue hardship to obtain the substantial equivalent of the materials by other means. General Objection: Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than or different from those under the Fla. Rules of Civil Procedure and the applicable Rules and Orders of the Court. General Objection: Plaintiff objects to each document request and interrogatory that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. General Objection: Plaintiff objects to each document request to the extent that it calls for production of a privilege log for documents of Plaintiffs. A request for such a log is unreasonable FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 11/18/2020 08:17:57 PMand unduly burdensome in light of the attorney client privilege, and other privileges protecting such documents from discovery. General Objection: Plaintiff objects to each instruction, definition, and document request to the extent that it seeks documents protected from disclosure by the attorney-client privilege, deliberative process privilege, attorney work product doctrine, or any other applicable privilege. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. General Objection: Plaintiff objects to each instruction, definition, and document request as overbroad and unduly burdensome to the extent it seeks documents or information that are readily or more accessible to Defendant from Defendant's own files, from documents or information in Defendant's possession, or from documents or information that Defendant previously produced to Plaintiff. Responding to such requests and interrogatory would be oppressive, unduly burdensome, and unnecessarily expensive, and the burden of responding to such requests is substantially the same or less for Defendant as for Plaintiffs. This objection encompasses, but is not limited to, documents previously produced by Defendant to Plaintiffs in the course of State Farm’s, investigation of the claim, all correspondence between the Plaintiffs and Defendant, all other information provided by Defendant to Plaintiffs, and all information produced by Plaintiffs to Defendant in response to discovery requests of Defendant. All such documents and information will not be produced. General Objection: Defendant's document requests call for the production of documents and information that were produced to the Plaintiffs by other entities and that may contain confidential, proprietary, or trade secret information. General Objection: To the extent any of Defendant's document requests that include expert material, including but not limited to survey materials, Plaintiffs object to any such requests as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to such requests, and to assert additional objections or privileges, in one or more subsequent supplemental response(s) in accordance with the time period for exchanging expert reports set by the Court. General Objection: Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. A specific response may repeat a general objection for emphasis or some other reason. The failure to include any general objection in any specific response does not waive any general objection to that request. Moreover, Plaintiffs do not waive their right to amend their responses.RESPONSES TO DOCUMENTS REQUESTED 1. All documents or tangible items of whatsoever nature pertaining to the following: a. The scope of the employment of your expert(s) in this case and the compensation for such services. RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs responses to Defendant’s Request for Production. b. The general litigation experience of your expert(s) including the percentage of work performed for plaintiff and defendant. RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs responses to Defendant’s Request for Production. c. The identity of any other insurance claims or legal actions in which your expert(s) has/have rendered opinions or evaluations for you during the last three (3) years. RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs responses to Defendant’s Request for Production. d. The identity of other cases, including the style of the case, case number, and venue, in which your expert(s) has/have testified by deposition or at trial for you during the last three (3) years.RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs responses to Defendant’s Request for Production. e. Any approximation of the portion of your expert(s) involvement as an expert witness, which may be based on the number of hours, percentage of hours, or percentage of the experts’ professional time. RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiff's responses to Defendant’s Request for Production. 2. Copies of any and all invoices, records, memorabilia, checks, check stubs, receipts, 1099s, tax records or any other form of financial information evidencing payment or compensation paid by Plaintiffs (as defined herein) for services provided by your expert(s) for the last three (3) years. RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs responses to Defendant’s Request for Production. 3. Copies of deposition and trial transcripts for testimony provided by your expert(s) as identified in Request 1(d) above.RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs responses to Defendant’s Request for Production. 4. Your expert(s) most current curriculum vitae or resume. RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiffs responses to Defendant’s Request for Production. 5. Any and all writings by your expert’s relating in any way to this case, including but not limited to reports, handwritten notes, charts, diagrams, tables, measurements, or other written material. RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiff's responses to Defendant’s Request for Production. 6. Any and all reports by your expert(s) prepared in connection with other cases and claims in which your expert(s) has/have been hired by you (as defined herein) during the past three (3) years. In order to sufficiently address the privacy concerns raised by Graham v. Dacheikh, 991 So. 2 932 (Fla. 2d DCA 2008), you are to redact all personally identifying information from the reports.RESPONSE: Objection, 1.280 (5) (a) (iii), overly broad, or not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiver of the foregoing, the following is set forth: Pursuant to Fla. R. Civ. P. 1.340 (c) Option to Produce Records, please see all responsive relevant documents contained in Plaintiff's Production File and referred to in Plaintiff's responses to Defendant’s Request for Production. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon Defendant and all interested persons listed on the myflcourtaccess.com e-filing portal through that portal on November 18, 2020 By:/s/ Brittany Panter Brittany Panter, Esq. Florida Bar Number 115779 VishioForry Insurance Lawyers 1300 Goodlette-Frank Rd N., Suite 202 Naples, FL 34103 (239) 703-7210 (239) 900-1993 (Fax) Service at service@vishioforry.com BPanter@vishioforry.com Attorneys for PlaintiffCurriculum Vitae ofMs: Kimberly Ward-Skeel Specialist Field Construction Estimator & Property Rehabilitation On Behalf of Mary Swider (Plaintiff) Prepared for Lee County, Circuit Civil Division Claim number 1702FL24003876 Ms. Kimberly Ward-Skeel Curriculum Vitae Qualifications, Training, Accreditation University of Indianapolis, A.S. Paralegal Studies 1989 University of Indianapolis, B.S. International Trade & Business Administration 1994 Independent Adjuster, P&C & Workers Compensation Ladder Now Senior Inspector & Consultant, Roof Systems & Property Inspection Certification, Maestro Certification HAAG Certified Inspector Xactimate Level 3 Certification Edimate Reconstruction Building Software Certification & Corporate Trainer Past and Present Positions Present: Independent Adjuster & Loss Consultant, The Avant Garde Group, LLC (2015-2019) Partner, Distressed Property Acquisition, AGG Properties LLC (2017-2019) Past: Ladder Now Senior Inspector & Consultant (2011-2017) Owner’s Liaison & Project Manager for Commercial / Multifamily Property Development, SBV, Inc. (2010 - 2013) Property Investigator, Foreclosure Property Winterization, The Legal Concierge (2006 — 2010) Director of Contracts, Intellectual Property & Facilities, Legal Department, John Wiley & Sons, Inc. (2001 — 2005) International Trade Consultant, Bose McKinney & Evans, LLP. (2000- 2001) Merger & Acquisitions Legal Associate, International Trade Consultant, The Dow Chemical Company (1990 — 2000) Paralegal, Intellectual Property & International Trade Regulation, Barnes & Thornburg, (1985 — 1990) Principal Professional Specialties | specialize in material and costs analysis of catastrophic damage to residential and commercial properties. On-site assessment of damages to real property, including costs analysis of material and man hours, environmental, safety and governmental compliance costs, supply and demand of labor and material resources, interpretation of plans and drawings for new builds and project rehabilitation, identify the required materials, while considering the required code upgrades/compliance, to restore a dwelling to its original state, unless otherwise deemed unrepairable or inhabitable. Professional Responsibilities & Projects Over 6,000 onsite inspections and estimates of residential and commercial properties. Acquisition and rehabilitation of more than 30 residential properties, most with catastrophic damage, determine rebuild plan, required materials and labor needs and costs. Served on the Development Team for the land (over 300 acres) and facility development (45,400 sf) of the national headquarters and research facility of the joint venture between Eli Lilly & Company and The Dow Chemical. Acquisition of real property and associated plants and offices nationwide, conducted due diligence, managed environmental conditions, determined property and equipment valuations, retrofitting and rehabilitation costs of plants, research facilities and office buildings. 1|Page Kimberly Ward-Skeel Curriculum VitaeCurriculum Vitae of Specialist Field On Behalf of Prepared for Claim number : Ms. Kimberly Ward-Skeel Construction Estimator & Property Rehabilitation Mary Swider (Plaintiff) Collier County, Circuit Civil Div. 1702FL24003876 Project Manger for major destination hotel renovation. Renovation taken down to studs, materials lists for all trades of the rebuild. Project Manager for metropolitan apartment complex renovation consisting of 24 buildings, multiple trades and superintendents, mold remediation, large equipment contract negotiation, bulk material acquisition, progress inspections, management and approval of completion/occupancy certifications and unit turnover to management company. Continuing Education Meet 24 month continuing education requirements for my Adjuster license and HAAG Certification through various organizations. Member and annual attendance of Windstorm Conference. Xactimate continuous training. Currently studying for Florida General Contractor Licensing Exam. 2|Page Kimberly Ward-Skeel Curriculum Vitaeci FORGE ENGINE EMINGs INNOVATIVE ENGINEERING SOLUTIONS CURRICULUM VITAE JUNE 2020 Matt H. Nolton, P.E. Professional Registrations: Florida, Number 44081, Civil Engineering — March 1991 Florida, Number CG -C045302, General Contractor — Class “A”, December 1988 Education: Bachelor of Science Civil Engineering, 1986, University of South Florida - Tampa (Areas of study Construction Materials and Geotechnical Studies) Lely High School, 1979, Naples, Collier County, Florida Employment: 2011- Present: Forge Engineering, Inc., CEO/Senior Principal Engineer 1996 - 2011: Forge Engineering, Inc., Vice President/Principal Engineer Specializing in Forensic Engineering Studies, Building Sciences, Roofing, Marine, and Geotechnical Engineering, Construction Specifications/Management, and Legal Case Support. 1986 - 1996: Law Engineering and Environmental Services, Inc. 1994 - 1996: Southwest Florida Operations Manager/Principal Engineer, Law Engineering, Inc. Specializing in Forensic Engineering 1990 - 1994: Southwest Florida Operations Manager/Senior Project Engineer, Law Engineering, Inc. Specializing in Forensic Engineering 1987 - 1990: Construction Services Department Manager/Project Engineer, Law Engineering, Inc. 1986 - 1987: Project Engineer, Law Engineering, Inc. 1990-2019: Contractor (part time), Nsquare, Inc., Naples, Florida. CEO and 40% owner of a local construction company. This company specialized in repair, renovation, and remodel work on existing structures including the construction of a few single-family residences. This Company switched its focus in October of 2005 and now specializes in foundation repairs, marine construction, and damp proofing of foundations/crawlspaces. PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.comCURRICULUM VITAE — JUNE 2020 Matt H. Nolton, P.E. 1985 - 1986: Engineering Technician, Soil and Material Engineers, Inc., Tampa, Florida. Performed engineering inspection and quality control on large construction projects. 1983 - 1985: Carpenter, The Columbus Company, Tampa, Florida. Performed carpentry work on various road and bridge projects. 1978 - 1980: Carpenter, Boran Craig Schreck Construction Company, Inc. Performed carpentry work on various residential and commercial projects in Collier County. Relevant Experience: Forensic — Failure Analysis evaluation, Design, Specification Preparation, and Construction Management of: Forensic engineering and expert testimony on various projects including: Coating failures and application, Concrete restoration, Bulkhead Walls/Seawalls, Materials Engineering, Metallurgy, Water intrusion damage, Roofing damage/deterioration/failures, Fire damage, Blasting/vibration damage, Construction vibration damage, Vibration prevention methods and techniques, Asphaltic pavements, Concrete construction, Sound Studies, Property Condition Surveys on numerous commercial properties throughout the United States, ¢ Construction materials and ¢ Geotechnical related issues. Project Management of over 2,000 forensic engineering studies relating to investigation of construction component failures on small single story buildings, 30- plus story structures, bridges and roads. Project Management of over 3,000 construction materials projects ranging from small single story buildings to 30-plus story structures to bridges and roads with construction costs ranging from $200,000 to $50 million. Extensive experience with construction materials, geotechnical and facilities engineering. Construction Engineering and Inspection (CEI) project management on Florida Department of Transportation (FDOT) projects. Project Engineer for FDOT district wide (District 1) materials testing contract, including extensive testing and evaluation of crushed limestone base material. Technical and liability review of other Professionals work. Page 2 of 4 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.com =CURRICULUM VITAE — JUNE 2020 Matt H. Nolton, P.E. Relevant Experience (cont.): e Review and negotiation of contracts including dealing with the Consultants Competitive Negotiation Act. ¢ Quality assurance of engineering operations. Development of project budgets. Preparation of proposals and engineering reports. Construction/Construction Management e Have personally been responsible for the estimating, contracting, permitting, billing and managing of over 200 construction projects ranging from small renovations/additions to million dollar plus single-family residences also including all phases of concrete restoration and rehabilitation of exterior coatings. e Have performed plan and construction cost reviews on over 200 projects for lending institutions ranging in scope from 2 million-dollar residences to 40 million-dollar resorts/condominiums. e Have performed construction loan draw inspections on over 100 projects for lending institutions ranging in scope from 2 million-dollar residences to 40 million-dollar resorts. Professional Associations: National Academy of Forensic Engineers American College of Forensic Examiners American Society of Civil Engineers (Past Branch President and Director) Technical Council on Forensic Engineering, ASCE American Concrete Institute (Past Branch Director) Florida Engineering Society National Society of Professional Engineers American Society for Testing of Materials Building Managers International Qualified Expert Witness e Circuit Court, Collier County, Florida e Circuit Court, Lee County, Florida Certifications/Training: The Genesis of Toxic Mold Structural Condition Assessment of Existing Structures Solving Water Intrusion and Mold Problems in Florida Forensic Engineering, Florida Engineering Society Advanced Contracts Advanced Loss and Liability Page 3 of 4 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.comCURRICULUM VITAE — JUNE 2020 Matt H. Nolton, P.E. Certifications/Trai Proposal Writing Introduction to Professional Practice Coating Systems Roofing Basics Concrete Repair Basics Concrete Plant Inspector Asphalt Pavements Trouble Shooting Concrete Problems Florida Building Code 2004 Florida Building Code 2004 Advanced Wind Mitigation Methodology: Retrofits for Existing Homes Reinforced Concrete Tilt-Up Panel Construction Precast Concrete Erection Procedures Preventing Accidents in the Construction Industry Construction Arbitration: An Overview Construction Mediation: An Overview Achievable Barrier Removal & Accessibility ASCE 7-02 Basic Wind Loads Awards: e Young Engineer of the Year, 1990, American Society of Civil Engineers, Southwest Florida Branch e Engineer of the Year, 1999, American Society of Civil Engineers, Southwest Florida Branch e Engineer of the Year, 1999, American Society of Civil Engineers, South Florida Section e Recognition for being President of the Naples Pelican Bay Rotary Club, 2008-2009 e Rotarian of the Year, 2012-2013 Naples Pelican Bay Rotary Club Page 4 of 4 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.comci FORGE eG Niele Gs INNOVATIVE ENGINEERING SOLUTIONS December 10, 2018 MS. MARY SWIDER 9376 Sweetgrass Way Naples, FL 34112 Phone: 248.515.1024 Email: me.swider@gmail.com Subject: Report for Forensic Engineering Consulting Services After Irma - Roof Inspection 9376 SWEETGRASS WAY Naples, Collier County, Florida Forge Engineering Proposal Number 4813-001.01 Forge Engineering Inc. (FORGE) is pleased to present this report of engineering consulting services for the subject building. These services were completed in general accordance with our proposal No. 4813-001.01P dated November 13, 2018 and authorized by you on November 21, 2018. This report has been generated as requested by you and presents our opinion of the conditions encountered on the subject roof. FORGE has endeavored to conduct the services identified herein in a manner consistent with that level of care and skill ordinarily exercised by members of the same profession currently practicing in the same locality and under similar conditions as this project. No other representation, express or implied, is included or intended in this document. Project Information Our understanding of your needs for this project is based on the information provided by you, along with our experience on similar projects. We understand the concrete tile roof system at your residence was damaged during Hurricane Irma and that currently your insurance company is denying coverage of the loss. Therefore, you have engaged FORGE to complete a post Hurricane Irma exterior roof evaluation to document any observed damages. PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01 9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018 Site Observation Engineering personnel from our office visited the subject building on November 29, 2018 to observe and document the condition of the roof at the subject site. We have listed below information or observations obtained during our site visit. e The subject site includes one-story single-family residential building. ¢ We understand the roof was installed circa 1997. « The concrete roof tiles have a low double-S profile. The existing tiles are “Lifetile” and are no longer manufactured. ¢ Concrete tiles in the field areas are attached with one fastener per tile with exception to hip and ridge tiles, which are attached to the wooden board anchors with one fastener. e The roof underlayment is assumed to consist of a two-ply hot-mop system, which typically consists of a 90-pound cap sheet, adhered to a mechanically fastened base sheet (30/90 underlayment system) over plywood sheathing supported by pre- engineered wood trusses. ¢ The slope of the roof covering system varies from 4:12 to 8:12. e In general, all of the concrete tiles at the low-sloped (4:12) roof were loose and their adhesive foam attachment was noted to have experienced complete failure due to wind uplift. e The majority of the concrete tiles at the steeper sloped roof were observed to have lifted during the storm and are no longer properly secured to the roof deck. Pull up testing revealed that over 70% of the concrete tiles uplifted between 3- to 4-inches. e Numerous hip and ridge tiles were noted to be loose and not properly secured to the roof wooden board anchors. ¢ Various field tiles were noted to be loose and/or displaced. ¢ Several roof tiles were observed to be broken or cracked (roughly 1%). e Numerous misaligned/displaced field tiles were observed on the roof. ¢ We noted cracked, broken, and separated mortar along the majority of the ridges. The following photographs were taken at the time of our site visit and are representative of the conditions observed. Page 20f9 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.com cuReport of Engineering Consulting Services FORGE Project No. 4813-001.01 9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018 8) 10 11 ee Teg Ou eu View of typical concrete roof tile “LifeTile” (no longer manufactured). Page 3 of 9 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01 9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018 View of typical tile uplift. Page 4of9 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01 9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018 View of group of uplifted tiles. Page 5o0f9 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01 9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018 View of group of loose /displaced field tiles. Page 6 of 9 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.comReport of Engineering Consulting Services FORGE Project No. 4813-001.01 9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018 View of group of broken and loose /displaced field tiles. Page 7 of 9 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.com cuReport of Engineering Consulting Services FORGE Project No. 4813-001.01 9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018 Evaluation and Recommendations Our evaluation is based on the project information provided to us, our field observations, and our experience with similar projects. Our inspection did not include destructive testing and only included an evaluation of visible roof components. Should new information become available or the conditions encountered during future remediation be substantially different from the information presented in this report, please contact us so we may evaluate the new information. It is evident that the concrete tile roof system for the subject building show signs of hurricane- related damages. The hurricane damage is largely evident through broken tiles, displaced tiles, and loose / uplifted tiles. The loose tiles appear to have uplifted during the storm and are no longer properly attached to the roof deck. In a letter provided by the Tile Roofing Institute (TRI) following Hurricane Irma, it states that, in general, roof tiles that are able to be lifted greater than or equal to 2-inches are considered to be uplifted and are no longer properly secured to the roof deck (see Attachment). In addition, when the tiles uplifted, the fasteners utilized to attach the tiles experienced partial pullout, which results in the seal at the fastener / roof membrane interface to become compromised and allows potential avenues for water intrusion to occur. It is important to note, that some of the distress observed is associated with hips and ridges. Typically, hips and ridges are one of the most vulnerable components of the sloped roofing system against the attack of the wind forces. The 2017 Florida Building Code Existing Building states the following as it pertains to roof repairs. “Not more than 25 percent of the total roof area or roof section of any existing building or structure shall be repaired, replaced or recovered in any 12-month period unless the entire roofing system or roof section conforms to requirements of this code”. Therefore, if the damage sustained to the roof exceeds 25 percent of the total roof area, then complete replacement of the roof is required per the Florida Building Code. It is our professional engineering opinion that the roof of the subject residence has sustained damage greater than 25 percent of the total roof area. Therefore, the roof cannot be repaired per the Florida Building Code. It should also be noted that the existing roof tiles are no longer manufactured and are no longer available to match the existing roof tiles. Therefore, any replacement tiles installed on this roof will not match or properly interlock with the existing tile profile. Therefore, any remediation to the roof would result in a roof without a proper Florida Page 8 of 9 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.com cuReport of Engineering Consulting Services FORGE Project No. 4813-001.01 9376 Sweetgrass Way — Post-Irma Roof Consulting Services December 10, 2018 Building Code approved and tested assembly in conflict with the building code. It is our opinion that due to the amount of damage sustained to the roof during Hurricane Irma, total replacement of the roof is required per the Florida Building Code. Closing We trust the information contained herein is suitable for your needs and appreciate the opportunity to have been of service to you. Should you have any questions or if we can be of further assistance, please call us. Sincerely, Forge Engineering, Inc. Florida Cert. of Auth. No. 7544 Felix M. Anton, P.E., S.1. Senior Engineer Florida Registration No. 77755 Attachment: Letter from Tile Roofing Institute: “Evaluation of Tile Systems after Wind Events” Distribution: | 1— Addressee (via email), 1 -File Page 9 of 9 PO Box 113040 ~ Naples, FL 34108 ~ 239.514.4100 ~ Fax 239.514.4161 www.ForgeEng.com cuATTACHMENTTO: Whom It\co Reason: Evaluation E ROOFING ' $s IT UTE ncerns; { September 29, 2017 of Tile Systems After Wind Events The TRI has been asked to provide considerations with regard to reviewing installed tile systems after wind events. Whil for actual condit I Asan industry determine faste: County NOA| manuals reflect fi it aS ion: , here is the history of thi opr vals, FBC approvals and exposure, speeds and mean roof height. ‘| In simplistic terns, we found that once the b allowed to lift 2! and prevent the tile from properly securing t uplift resistance! Th 7 failure mechani { As roof inspecti tile fastening condit for future perforce. The formal test protocols w ms for tile approvals. nn occur, the roofing profess As always, the local building official has the allowed in a spe ' cific jurisdiction. e each roof will need to be inspected wind uplift resistance research. we performed extensive wind tunnel and physical uplift tests to ing, recommendations for various wind speeds. The Miami Dade our FRSA/TRI industry installation those results for anticipated uplift resistance at various wind ttom edge (downslope) of the tile is / the wind will have sufficient access to withdraw the tile fastener tq the sub straight for the design wind re reflective of a 2” lift as one of the onal should consider inspecting the ion post storm, to determine if there has been any compromise final authority for what may be For any questions or additional information, please feel free to contact me. Sincerely | Riex CO | Rick Olson | | President & Te ‘ec Tile Roofing | Th It hnical Director titute P.O, Box 40337\Bugene, OR 97404-0049 P: : 541.689.0366 F:541.689.5530