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DOCKET NO. UWY-CV18-6040486-S : SUPERIOR COURT
UWY-CV18-6040487-S
MSCI 2006-HQ10 SCOVILL STREET, LLC, : JUDICIAL DISTRICT
ET AL : OF WATERBURY
VS. : AT WATERBURY
CITY OF WATERBURY : DECEMBER 16, 2022
DEFENDANT’S DISCLOSURE OF EXPERT WITNESS
The Defendant, City of Waterbury, hereby discloses the following expert witness it expects to
call to testify as an expert at the trial of the above matter.
1. NAME OF EXPERT:
Peter A. Vimini is a real estate appraiser in the Real Estate Appraisal and Consulting Firm of
Vimini Valuation Services located at 1067 Broad Street, Bridgeport, Ct 06604.
Mr. Vimini is a Certified Real Estate Appraiser with the State of Connecticut-Certification
No.0000605. He is also a member of the Appraisal Institute, MAI Designation No. 9586.
2. SUBJECT MATTER OF TESTIMONY:
Mr. Vimini is expected to testify regarding his opinion of fair market value of the subject
premises known as 95 Scovil Street, Waterbury, Connecticut as of October 1, 2017, originally two
separate parcels, 20 South Elm Street and 83 Scovil Street, which were combined on July 7, 2021 into
95 Scovil Street, as well as describe his methodologies and data used in determining his opinion. This
may include describing various attributes of the subject property. Mr. Vimini may also testify as to
OFFICE OF THE CORPORATION COUNSEL
235 GRAND STREET, 3RD FLOOR, WATERBURY, CT 06702
203-574-6731 • JURIS NO. 066300
aspects of the Plaintiffs’ case including rebutting the testimony and/or written appraisals of any expert
witness(es) called by the Plaintiffs. Mr. Vimini may also testify about the City assessor’s valuation of
said property for the October 1, 2017 tax revaluation and any changes made to value as a result of
combining the two separate parcels, 20 South Elm Street and 83 Scovil Street, into 95 Scovil Street on
July 7, 2021.
3. SUBSTANCE OF FACTS AND OPINIONS:
Mr. Vimini will testify in support of his findings of value in his appraisal dated November 12,
2022 regarding the said property, which will be provided to Plaintiffs’ counsels. Mr. Vimini may also
testify about the findings of experts or non-experts used by Plaintiffs in determining the value of said
property, including providing his opinion on the methods used, assumptions made, or conclusions drawn
by Plaintiffs’ witnesses in regards to their finding on value.
4. GROUNDS FOR OPINION:
Mr. Vimini will base his testimony on his inspection of the property, his review of
applicable records, including information and documentation regarding the property supplied by
Defendant, and available from public sources, his research regarding market conditions, and his
review of relevant references, surveys, tables commonly used by appraisers, as well as his knowledge
gained through his experience as an appraiser. Additional information indicating grounds for his opinion
may be found in his appraisal report dated November 12, 2022 on the subject property. Any rebuttal
testimony will be based upon a review of the Plaintiffs’ experts’ testimony on the property and a
OFFICE OF THE CORPORATION COUNSEL
235 GRAND STREET, 3RD FLOOR, WATERBURY, CT 06702
203-574-6731 • JURIS NO. 066300
review of any appraisal performed by said expert(s).
5. AMEND OR SUPPLEMENT
The Defendant reserves the right to amend and/or supplement this disclosure and file
additional disclosures of expert witnesses.
DEFENDANTS,
CITY OF WATERBURY
By ________/306888/___________
Kevin J Daly Jr, Esq.
Office of the Corporation Counsel
235 Grand Street, 3rd Floor
Waterbury, CT 06702
203-574-6731/Fax 203-574-8340
Juris No. 066300
CERTIFICATION
The undersigned hereby certifies that copies of the foregoing have been mailed, postage prepaid,
and/or electronically forwarded on the above written date to:
Elliot B. Pollack, Esq. Ford & Paulekas LLP
Pullman & Comley, LLC 280 Trumbull Street
90 State House Square Hartford, CT 06103
Hartford, CT 06103 jstetson@fllp.com
ebpollack@pullcom.com
By ________/306888/___________
Kevin J Daly Jr, Esq.
Office of the Corporation Counsel
OFFICE OF THE CORPORATION COUNSEL
235 GRAND STREET, 3RD FLOOR, WATERBURY, CT 06702
203-574-6731 • JURIS NO. 066300
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DOCKET NO. UWY-CV18-6040486-S : SUPERIOR COURT UWY-CV18-6040487-S MSCI 2006-HQ10 SCOVILL STREET, LLC, : JUDICIAL DISTRICT ET AL : OF WATERBURY VS. : AT WATERBURY CITY OF WATERBURY : DECEMBER 16, 2022 DEFENDANT’S DISCLOSURE OF EXPERT WITNESS The Defendant, City of Waterbury, hereby discloses the following expert witness it expects to call to testify as an expert at the trial of the above matter. 1. NAME OF EXPERT: Peter A. Vimini is a real estate appraiser in the Real Estate Appraisal and Consulting Firm of Vimini Valuation Services located at 1067 Broad Street, Bridgeport, Ct 06604. Mr. Vimini is a Certified Real Estate Appraiser with the State of Connecticut-Certification No.0000605. He is also a member of the Appraisal Institute, MAI Designation No. 9586. 2. SUBJECT MATTER OF TESTIMONY: Mr. Vimini is expected to testify regarding his opinion of fair market value of the subject premises known as 95 Scovil Street, Waterbury, Connecticut as of October 1, 2017, originally two separate parcels, 20 South Elm Street and 83 Scovil Street, which were combined on July 7, 2021 into 95 Scovil Street, as well as describe his methodologies and data used in determining his opinion. This may include describing various attributes of the subject property. Mr. Vimini may also testify as to OFFICE OF THE CORPORATION COUNSEL 235 GRAND STREET, 3RD FLOOR, WATERBURY, CT 06702 203-574-6731 • JURIS NO. 066300 aspects of the Plaintiffs’ case including rebutting the testimony and/or written appraisals of any expert witness(es) called by the Plaintiffs. Mr. Vimini may also testify about the City assessor’s valuation of said property for the October 1, 2017 tax revaluation and any changes made to value as a result of combining the two separate parcels, 20 South Elm Street and 83 Scovil Street, into 95 Scovil Street on July 7, 2021. 3. SUBSTANCE OF FACTS AND OPINIONS: Mr. Vimini will testify in support of his findings of value in his appraisal dated November 12, 2022 regarding the said property, which will be provided to Plaintiffs’ counsels. Mr. Vimini may also testify about the findings of experts or non-experts used by Plaintiffs in determining the value of said property, including providing his opinion on the methods used, assumptions made, or conclusions drawn by Plaintiffs’ witnesses in regards to their finding on value. 4. GROUNDS FOR OPINION: Mr. Vimini will base his testimony on his inspection of the property, his review of applicable records, including information and documentation regarding the property supplied by Defendant, and available from public sources, his research regarding market conditions, and his review of relevant references, surveys, tables commonly used by appraisers, as well as his knowledge gained through his experience as an appraiser. Additional information indicating grounds for his opinion may be found in his appraisal report dated November 12, 2022 on the subject property. Any rebuttal testimony will be based upon a review of the Plaintiffs’ experts’ testimony on the property and a OFFICE OF THE CORPORATION COUNSEL 235 GRAND STREET, 3RD FLOOR, WATERBURY, CT 06702 203-574-6731 • JURIS NO. 066300 review of any appraisal performed by said expert(s). 5. AMEND OR SUPPLEMENT The Defendant reserves the right to amend and/or supplement this disclosure and file additional disclosures of expert witnesses. DEFENDANTS, CITY OF WATERBURY By ________/306888/___________ Kevin J Daly Jr, Esq. Office of the Corporation Counsel 235 Grand Street, 3rd Floor Waterbury, CT 06702 203-574-6731/Fax 203-574-8340 Juris No. 066300 CERTIFICATION The undersigned hereby certifies that copies of the foregoing have been mailed, postage prepaid, and/or electronically forwarded on the above written date to: Elliot B. Pollack, Esq. Ford & Paulekas LLP Pullman & Comley, LLC 280 Trumbull Street 90 State House Square Hartford, CT 06103 Hartford, CT 06103 jstetson@fllp.com ebpollack@pullcom.com By ________/306888/___________ Kevin J Daly Jr, Esq. Office of the Corporation Counsel OFFICE OF THE CORPORATION COUNSEL 235 GRAND STREET, 3RD FLOOR, WATERBURY, CT 06702 203-574-6731 • JURIS NO. 066300