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Filing # 145264885 E-Filed 03/08/2022 11:03:27 AM
IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL
CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA
CASE NO. 2020-CA-002067
JOHN VALIS,
PLAINTIFF,
V.
CHRISTINE HITCHCOCK AND
USAA CASUALTY INSURANCE COMPANY,
DEFENDANTS.
/
NOTICE OF SERVICE OF EXPERT INTERROGATORIES TO PLAINTIFF
Defendant by and through its undersigned attorneys, hereby propounds to Plaintiff, JOHN
VALIS, pursuant to Rule 1.340 of the Fla. R. Civ. P., the attached Expert Interrogatories,
numbered 1-8, the answers of which will be due within thirty (30) days from the date of service
hereof.
CERTIFICATE OF SERVICE
The document contains no confidential or sensitive information or that any such
confidential or sensitive language has been properly protected by complying with the provisions
of Rule 2.420 and 2.425. I HEREBY CERTIFY that a true and correct copy of the foregoing has
been furnished by electronic filing to Michael D. Marrese, Esquire, 76 South Laura Street, Ste.
110, Jacksonville, FL 32202, Mmarrese@forthepeople.com; jlow@forthepeople.com;
pceallaremi@forthepeople.com, Kathleen A. Carlson, Esquire, 200 West Forsyth St., Suite 1400,
Jacksonville, FL 32202, KACarlson@MDWCG.com; hahildebrand@MDWCG.com on this 8th
day of March, 2022.
PAUL M. EZA, ESQUIRE
Fla. Bar No. 68708
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 03/08/2022 11:27:14 AM
Law Offices of Sonya S. Wesner
200 East Robinson Street, Suite 510
Orlando, FL 32801
Telephone: (407) 393-9100
Direct Dial: (904) 489-6585
Secretary: (407) 393-9410
Paralegal: (407) 393-9097
Fax: (877) 499-6079
Primary EMail:JAXSMAIL@nationwide.com
Attorneys for Defendants
DEFENDANT’s EXPERT
INTERROGATORIES TO PLAINTIFF
Specify the subject matter about which each of Plaintiffs experts have knowledge in
relation to this lawsuit and their relationship to the Plaintiff.
Please state whether any item or object relevant to this lawsuit has been tested,
analyzed, examined or inspected by any of the experts listed in Interrogatory No. 1. If so,
please state:
a. In detail, sufficient to identify each item or object that was tested, analyzed,
examined, or inspected, and the name of the expert.
The facts or information you were seeking in having these tests, examinations or
inspections made.
The steps used in each test, examination, or inspection of any object or item
material to this lawsuit.
Please state the findings resulting from each test, examination, or inspection
conducted.
The facts or opinions derived from the tests.
Please state the date of each test, the name and address of the person conducting the
test and the name of each test performed.
Please state whether you have retained any other experts who are not expected to testify at
trial, but who are advising you on matters material to this lawsuit. If so, please state the
following information for each expert listed:
a. Name and present business and residence address.
b Profession or occupation and the field in which he/she is allegedly an expert.
For each expert listed in Interrogatory No. | above, please state all cases including the style
of the case; the case number and the court in which the expert(s) listed in No. 1 above were
retained as an expert by any of the attorneys presently employed at the law firm or in the
past employed at that law firm, during the past three years.
5 Based on the information provided in Numbers | through 4 above, please identify those
cases in which the experts listed in No. 1 above, have provided testimony in the form of a
deposition.
6 Based on the information provided in Numbers | through 4 above, please identify those
cases in which the experts listed in No. 1 above, have provided testimony at trial.
Please state the total amount of expert fees or other payments paid to the expert(s) listed in
No. 1 above, by and/or on behalf of any of the attorneys presently employed at the law firm
or in the past employed at that law firm, during the past three (3) years.
Excluding the information provided in Numbers 5 through 7 above, please list all cases in
which any other associate of the expert(s) listed in these Answers have been retained by
Michael Mareese, Esquire, Morgan & Morgan, and/or any of its associates or attorneys
within the last three (3) years.
JOHN VALIS
STATE OF )
COUNTY OF )
The foregoing instrument was acknowledged before me _ this day of
, 2022, by JOHN VALIS, who is:
(Please check below)
1 personally known to me
2. produced as identification
-and-
a. —__ who did not take an oath
b who did take an oath
Given under my hand and official seal this day of. » 2022.
Notary Public
Notary Public, State of
(NOTARY SEAL)
Type or Print Name of Notary
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Filing # 145264885 E-Filed 03/08/2022 11:03:27 AM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA CASE NO. 2020-CA-002067 JOHN VALIS, PLAINTIFF, V. CHRISTINE HITCHCOCK AND USAA CASUALTY INSURANCE COMPANY, DEFENDANTS. / NOTICE OF SERVICE OF EXPERT INTERROGATORIES TO PLAINTIFF Defendant by and through its undersigned attorneys, hereby propounds to Plaintiff, JOHN VALIS, pursuant to Rule 1.340 of the Fla. R. Civ. P., the attached Expert Interrogatories, numbered 1-8, the answers of which will be due within thirty (30) days from the date of service hereof. CERTIFICATE OF SERVICE The document contains no confidential or sensitive information or that any such confidential or sensitive language has been properly protected by complying with the provisions of Rule 2.420 and 2.425. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic filing to Michael D. Marrese, Esquire, 76 South Laura Street, Ste. 110, Jacksonville, FL 32202, Mmarrese@forthepeople.com; jlow@forthepeople.com; pceallaremi@forthepeople.com, Kathleen A. Carlson, Esquire, 200 West Forsyth St., Suite 1400, Jacksonville, FL 32202, KACarlson@MDWCG.com; hahildebrand@MDWCG.com on this 8th day of March, 2022. PAUL M. EZA, ESQUIRE Fla. Bar No. 68708 ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 03/08/2022 11:27:14 AM Law Offices of Sonya S. Wesner 200 East Robinson Street, Suite 510 Orlando, FL 32801 Telephone: (407) 393-9100 Direct Dial: (904) 489-6585 Secretary: (407) 393-9410 Paralegal: (407) 393-9097 Fax: (877) 499-6079 Primary EMail:JAXSMAIL@nationwide.com Attorneys for Defendants DEFENDANT’s EXPERT INTERROGATORIES TO PLAINTIFF Specify the subject matter about which each of Plaintiffs experts have knowledge in relation to this lawsuit and their relationship to the Plaintiff. Please state whether any item or object relevant to this lawsuit has been tested, analyzed, examined or inspected by any of the experts listed in Interrogatory No. 1. If so, please state: a. In detail, sufficient to identify each item or object that was tested, analyzed, examined, or inspected, and the name of the expert. The facts or information you were seeking in having these tests, examinations or inspections made. The steps used in each test, examination, or inspection of any object or item material to this lawsuit. Please state the findings resulting from each test, examination, or inspection conducted. The facts or opinions derived from the tests. Please state the date of each test, the name and address of the person conducting the test and the name of each test performed. Please state whether you have retained any other experts who are not expected to testify at trial, but who are advising you on matters material to this lawsuit. If so, please state the following information for each expert listed: a. Name and present business and residence address. b Profession or occupation and the field in which he/she is allegedly an expert. For each expert listed in Interrogatory No. | above, please state all cases including the style of the case; the case number and the court in which the expert(s) listed in No. 1 above were retained as an expert by any of the attorneys presently employed at the law firm or in the past employed at that law firm, during the past three years. 5 Based on the information provided in Numbers | through 4 above, please identify those cases in which the experts listed in No. 1 above, have provided testimony in the form of a deposition. 6 Based on the information provided in Numbers | through 4 above, please identify those cases in which the experts listed in No. 1 above, have provided testimony at trial. Please state the total amount of expert fees or other payments paid to the expert(s) listed in No. 1 above, by and/or on behalf of any of the attorneys presently employed at the law firm or in the past employed at that law firm, during the past three (3) years. Excluding the information provided in Numbers 5 through 7 above, please list all cases in which any other associate of the expert(s) listed in these Answers have been retained by Michael Mareese, Esquire, Morgan & Morgan, and/or any of its associates or attorneys within the last three (3) years. JOHN VALIS STATE OF ) COUNTY OF ) The foregoing instrument was acknowledged before me _ this day of , 2022, by JOHN VALIS, who is: (Please check below) 1 personally known to me 2. produced as identification -and- a. —__ who did not take an oath b who did take an oath Given under my hand and official seal this day of. » 2022. Notary Public Notary Public, State of (NOTARY SEAL) Type or Print Name of Notary