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Filing# 166165770 E-Filed 02/06/2023 09:22:56 AM
IN THE CIRCUITCOURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO: CACE-21-007773
MARCIA SAMPSON AND HERMAN
FEAR-IN,
Plaintiff(s),
V
CITIZENS PROPERTY INSURANCE
CORPORATION
Defendant.
i
DEFENDANT'S EXPERT WITNESS DISCLOSURE
COMES NOW, Defendant, Citizens Property Insurance Corporation,("Citizens"),
by and through Law Offices of Hoffman and Hoffman, P.A, and files Defendant's Expert
Witness Disclosure in order to comply with the current Trial order in this matter, and as
follows:
1. Christine Alfano,
Professional Engineer,
Haag
2224 East 117th St.
Burnsville, MN 55337
HaagGlobal.com
Ms. Alfano is a licensed senior professionalengineer and certified consulting
meteorologist with Haag. Ms. Alfano was retained by the Defendant to do an
of the reportedloss and allegeddamages
investigation to the subjectproperty. Ms. Alfano
inspectionof the property is currentlybeing coordinated.
It is that Ms. Alfano will testify
anticipated without limitation as to the damages
allegedby the Plaintiffs and condition of the roofingsystem//other structural components
LAW OFFICE OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 - Telephone: 305.372.2877 Fax: 305.372.2875
Filed by eFileMadEEh*ItafD?: IBIMEWMED@@EEHfitEImrBIuc]*INENIBAG1/(AZERI2[KN;0(I:11BWWDES)6/2023 09:22:56 AM.****
of the residence in lightwith her experience as a professionalengineer and certified
consultingmeteorologist.
Ms. Alfano's findingswill be derived from, among other things,inspectionof the
property, review of photographs, measurements, sketches, estimates, and other
information received with regards to the subject loss. Additionally,her educational
training,experience,expertise,and other relevant factors and materials in this case
assisted him in formulatingher opinion.Pursuant to Fla. R. Civ. P.
a) The scope of employment in the pending and the compensation for such
services.
Ms. Alfano, as a State of Florida licensed Professional Engineer with Haag, was retained
by Citizens to which
perform an evaluation of the property via an inspection, is currently
being coordinated. To date,Ms. Alfano has not been paid for her work on this case.
b) The expert's general litigationexperience, including the percentage of
work performed for plaintiffs
and defendants.
Please refer to Ms. Alfano's Record o f Depositionand Expert Testimony at Trial attached
"
as Exhibit "A. Approximately 90% of the work performed by Ms. Alfano is for
defendants.
c) The identity other cases, within a reasonable time period, in which the
expert has testified by deposition or at trial.
Please refer to Ms. Alfano' s Record o f Depositionand Expert Testimony at Trial attached
as Exhibit "A."
d) Anapproximation of the portion of the expert's involvement as an expert
witness, which may be based on the number of hours, percentage of hours, or
percentage of earned income derived from serving as an expert witness;
however, the expert shall not be required to disclose his or her earnings as an
expert witness or income derived from other services.
LAW OFFICE OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 - Telephone: 305.372.2877 Fax: 305.372.2875
Ms. Alfano, as a State of Florida licensed Professional Engineer with Haag, was retained
by Defendant to inspectPlaintiffs' property and provide an opinion as to the cause and
origin of the alleged damages reportedly caused by Tropical Storm Eta. For more
information, please refer to Ms. Alfano's Professional Resume attached as Exhibit "B."
Approximately 50-60% of the work performed by Ms. Alfano is related to serving as an
expert witness.
2. Defendant reserves the right to supplement this Expert Witness Disclosure as
discovery progresses.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoingwas
served via email, on February 6,2023 to:
Alex Stern, Esq. alex@LRLC.legal; service@LRLC.legal
Litigation& Recovery Law Center, P.L.
16375 NE 18th Ave, Ste 321
North Miami Beach, FL 33162
LAW OFFICES OF HOFFMAN & HOFFMAN, P.A.
66 West FlaglerStreet,Suite 200, Miami, Florida 33130
Telephone: 305.372.2877 / Facsimile: 305.372.2875
EService E-mail: eservice@hoffmanpa.com
By: /s/ Tatyana Krimus, Esq.
John D. Hoffman, Esq.
Board CerttftedCivil Trial Lawyer
Florida Bar No. 825859 / E-mail: john@hoffmanpa.corn
Jennifer Valiyi,Esq.
Board CerttftedCivil Trial Lawyer
Florida Bar No. 116079 / E-mail: jennifer@hoffmanpa.com
Tatyana Krimus, Esq.
Florida Bar No. 1018299 / E-mail: tkrimus@hoffmanpa.com
LAW OFFICE OF HOFFMAN & HOFFMAN, P.A.
66 W. Flagler Street, Suite 200, Miami, Florida 33130 - Telephone: 305.372.2877 Fax: 305.372.2875
Exhibit A
No. Depo Date Trial Date Name Court Case No.
United States District
Malka v. Geovera Court Southern District
1 9/4/2019 N/A 0:18-cv-61905-DPG
Specialty Insurance of Florida Fort
Lauderdale Division
Maria Mesa and Roxana
Circuit Court of the 11th
De Leon v Citizens
2 4/14/2020 11/1/2021 Judicial Circuit in and for 2017-026083-CA-01
Property Insurance
Miami-Dade County, FL
Corporation
Arteaga, Barbara and Circuit Court of the 11th
3 5/29/2020 N/A Alexa v. Citizens Judicial Circuit in and for 2019-004580-CA-01
Property Insurance Miami-Dade County, FL
Beatriz Lopez-Gross v. Circuit Court of the 11th
4 9/4/2020 N/A Citizens Property Judicial Circuit in and for 2019-037125-CA-01
Insurance Corporation Miami-Dade County, FL
American Rockwool
Manufacturing LLC vs District Court of the
5 9/24/2020 N/A Markel American 146th Judicial District 313,559-B
Insurance and Insurica Bell County, Texas
TX Insurance Services
Gary and Candida
Circuit Court of the 11th
Chesman v. Citizens
6 10/19/2020 N/A Judicial Circuit in and for 2016-003466-CA-01 (22)
Property Insurance
Miami-Dade County, FL
Corporation
Mark and Tali Hirsch v.
Circuit Court of the 11th
Homeowners Choice
7 12/10/2020 N/A Judicial Circuit in and for 2019-021589--CA-01
Property and Casualty
Miami-Dade County, FL
Insurance Company
James and Annette
Circuit Court of the 20th
Coleman v. Family
8 3/15/2021 N/A Judicial Circuit in and for 20-CA-000200
Security Insurance
Lee County, FL
Company
Hector Hernandez v. Circuit Court of the 11th
9 3/31/2021 N/A Citizens Property Judicial Circuit in and for 2019-000285-CA-01
Insurance Miami-Dade County, FL
Janine Coutrier and Circuit Court for the
Pauline Thomas v. Seventeenth Judicial
10 10/22/2021 N/A CACE-21-002623(09)
Citizens Property Circuit in and for
Insurance Corporation Broward County, Florida
No. Depo Date Trial Date Name Court Case No.
Ivette Hernandez and Circuit Court of the 11th
11 11/15/2021 N/A Luis Velzaquez v Citizens Judicial Circuit in and for 2016-015721 CA 01
Property Insurance Corp Miami-Dade County, FL
Angel Rabelo and
Circuit Court of the 17th
Iluminada Rivero v
12 12/3/2021 N/A Judicial Circuit in and for CACE-20-014394(04)
Citizens Property
Broward County, FL
Insurance Corp
Circuit Court of Ozaukee
Mrotek v American
13 1/10/2022 N/A County, State of 21-CV-33
Family Mutual Insurance
Wisconsin
Edna Sibila and Erik Circuit Court of the 11th
14 1/12/2022 N/A Sibila v. Citizens Property Judicial Circuit in and for 19-035172 CA 01
Insurance Corp Miami-Dade County, FL
Terry Thompson v. State of Wisconsin
15 1/21/2022 N/A American Family Circuit Court Fond du Lac 19-CV-518
Insurance Company County
Dale and Margaret State of Wisconsin
16 2/25/2022 N/A Hamann v. Erie Circuit Court Ozaukee 21-CV-135
Insurance Company County
Circuit Court for the
Sheryll Wilson v Citizens
Seventeenth Judicial
17 4/1/2022 N/A Property Insurance CACE 20-011579
Circuit in and for
Corporation
Broward County, Florida
Circuit Court for the
Nancy Eustache v
Seventeenth Judicial
18 4/4/2022 N/A Citizens Property CACE -21-000431
Circuit in and for
Insurance Corporation
Broward County, Florida
Neil Hernandez v Circuit Court of the 11th
19 4/26/2022 N/A Citizens Property Judicial Circuit in and for 2021-000906-CA-01
Insurance Corporation Miami-Dade County, FL
Benjamin Schiff v Circuit Court of the 17th
20 7/25/2022 N/A Citizens Property Judicial Circuit in and for CACE-20-019648
Insurance Corporation Broward County, FL
Carlos Cabrera v Citizens Circuit Court of the 11th
21 8/25/2022 N/A Property Insurance Judicial Circuit in and for 2021-020416-CA-01
Corporation Miami-Dade County, FL
No. Depo Date Trial Date Name Court Case No.
Magaly Hernandez and Circuit Court of the 11th
22 8/26/2022 N/A Oris Rodriguez v Security Judicial Circuit in and for 21-14693 CA 01
First Insurance Company Miami-Dade County, FL
Pedro Quesada v Circuit Court of the 11th
23 8/29/2022 N/A Citizens Property Judicial Circuit in and for 2020-017045-CA-01
Insurance Corporation Miami-Dade County, FL
Warehouse Investors,
LLC, Dixon Properties
-
United States District
3811, LLC, and 51st Court for the Southern
24 9/22/2022 N/A 4:21-cv-00174-HCA
Street Properties, LLC v District of Iowa Central
Affiliated FM Insurance Division
Company
Sherene Thomas and Circuit Court of the 15th
Nicholas Coke v Citizens Judicial Circuit in and for 50-2020-CC-005161-
25 10/28/2022 N/A
Property Insurance Palm Beach County, XXXX-SB
Corporation Florida
Exhibit B
AVA' Christine Standohar-Alfano,Ph.D.,
RE., CCM
Director of Forensic Meteorology, Forensic Engineer
Dr. Standohar-Alfano isthe Director of Forensic Meteorologyand Forensic Engineer with
Haag Engineering Co. Dr. Alfano has achieved the Certified Consulting Meteorologist
(CCM) designation from the American Meteorological Society and is the only RE. in
the U.S. with a CCM designation. She has inspected and assessed damage to hundreds
of roofs including asphalt composition, tile, and various commercial roofing systems.
She has written and published many articles on tornadoes and resultant damage in
peer-reviewed literature and she has presented her results at numerous national and
international conferences. Additionally, she has participated in several large-scale post-
disaster surveys for tornadoes and hurricanes.
Dr. Standohar-Alfano has provided expert testimony as both a meteorologist and
engineer in cases involving roof and building envelope performance. She has also
Contact
taught several continuing education courses for Haag Education and for Haag's Certified
CAIfano@HaagGIobal.com Inspector programs for residential and wind damage certification. Priorto joining Haag,
214-614-6500 main Dr. Standohar-Alfano was a research engineer and was involved in testing small- and
800-527-0168 toll free full-scale building components and systems against wind, wind-driven rain, wildfire,
and hail.
2224 East 117th St.
Burnsville, MN 55337
HaagGIobal.com
Primary Areasof Consulting
Roofing Systems
Academic Background . Commercial and residential
Doctor of Philosophy in Civil Wind/hail damage evaluations
Quality of manufacture and installation
Engineering, Dissertation: Damage
Wood- Building Envelope Systems
Analysis and Mitigation for
. Commercial and residential
frame Structures Subjected to
Wind/hail damage evaluations
Tornado Loading, Colorado State
Quality of manufacture and installation
University, Fort Collins, Colorado
Evaluation of Wind Damage to Structures
2016 . Commercial and residential
. Hurricane, tornado, and straight-line wind evaluations
Master of Science in Meteorology Construction Defect Evaluations
and Physical Oceanography, Thesis: . Commercial and residential
Impact of Upper Ocean Warming . Moisture intrusion evaluations
on Hurricane Intensity, University of .
Building code compliance
Miami, Miami, Florida Meteorological Investigations
2012 . Severe weather events
Storm surveys
Bachelor of Science Precipitation/temperature/wind analysis
in Meteorology,
Valparaiso University, Valparaiso,
Indiana, Graduated Summa cum
Laude Professional Licensure
2009
Registered Professional Engineer: Minnesota, Wisconsin, Iowa, North Carolina, South
2022 Carolina, Tennessee, Florida, Virginia, and Georgia
Updated Oct. 14,
Page 1
AVA' Christine Standohar-Alfano, Ph.D., RE., CCM
Director of Forensic Meteorology, Forensic Engineer
Memberships/ Employment Background
Certifications
Haag Engineering Co.
ASCE Wind Speed Estimation Director of Forensic Meteorology 2022 to Present
in Tornadoes Committee Forensic Engineer 2017 to Present
- Associate Member and . See Areas of Expertise
Secretary
Certified Consulting Insurance Institute of Business and Home Safety
Meteorologist (CCM) Research Engineer 2015 to 2017
.
Society of Women Engineers
. American Meteorological Valparaiso University, Department of Mechanical Engineering
Society Visiting Assistant Professor 2014 to 2015
American Society of Civil
Engineers
Chi Epsilon Pi Meteorology
Honor Society
Lectures & Publications (Partial)
Haag Certified Inspector -
Haag Certified Inspector- Residential Roofing; Instructor and Course Co-Developer,
Residential Roofs
- online and classroom versions
Haag Certified Inspector
Haag Certified Roofing; Instructor and Course Co-
Commercial Roofs
- Developer, online and classroom versions
Haag Certified Inspector
Wind Damage Haag Certified Inspector-Wind Damage; Instructor and Course Co-Developer,
online and classroom versions
. van de Lindt, John W., Masoomi, Hassan, Attary, Navid, and Standohar-Alfano,
Christine D., 2019. Tornado damage modeling: Single buildings, communities, and
regions. Routledge Handbook of Sustainable and Resilient Infrastructure.
Standohar-Alfano, Christine D., van de Lindt, John W., and Holt, Eric M., 2017.
Comparative Residential Property Loss Estimation for the April 25-28, 2011 Tornado
Outbreak. Journal of Architectural Engineering.
Standohar-Alfano, Christine D., van de Lindt, John W., and Ellingwood, Bruce
R., 2017: Vertical Load Path Failure Risk Analysis of Residential Wood-Frame
Construction in Tornadoes. Journal of Structural Engineering.
Standohar-Alfano, Christine D., and van de Lindt, John W., 2015: Tornado Risk
Analysis for Residential Wood-frame Roof Damage Across the United States. Journal
of Structural Engineering.
Standohar-Alfano, Christine D., Freyne, Seamus, Graettinger, Andrew J., Floyd,
Royce W., Dao, Thang N., 2014: Performance of Residential Shelters in the May
20th, 2013 Moore, Oklahoma Tornado. Journal of the Performance of Constructed
Facilities.
Standohar-Alfano, Christine D., and van de Lindt, John W., 2014: An Empirically-
Based Probabilistic Tornado Hazard Analysis of the U.S. Using 1973-2011 Data.
Natural Hazards Review, 10.
Updated Oct. 14, 2022
Page 2
AVA' Christine Standohar-Alfano, Ph.D., RE., CCM
Director of Forensic Meteorology, Forensic Engineer
Honors Damage Surveys
. Journal of Architectural Engi- Nashville, Tennessee -EB, March 3,2020
Assisted the NashvilleNWS with their survey of the long-track tornado that
neering, Best Paper of 2018
impacted north Nashville and adjacent suburbs. Our emphasis was inspecting
Federal Alliance for Safe Homes
buildings where they were uncertain of the most appropriate damage indicator (DI)
International Code Council
or quality of construction. We also focused on collecting damage information on
Scholarship, 2014 DI's being introduced in the newest iteration of the EF Scale, specificallylight poles,
Colorado State University Dr. metal building systems, and churches.
Jack E. Cermak Wind Engineer-
2014 Hurricane Harvey -Category 4, August 25, 2018
ing Scholarship,
IBHS team performed a post-disaster wind investigation of various neighborhoods
University of Alabama Graduate
impacted by Hurricane Harvey including Holiday Beach, Rockport, Port Aransas,
Council Fellowship, 2012-2013
Aransas Pass, Ingleside,and Portland, Texas. Focus was on residential construction
. American Meteorological Soci-
performance including roof cover,wall cladding, and windows, doors, and garage
ety Graduate Fellow, 2009-2010 doors. The data was compiled into a report and available to the public.
. American Meteorological Soci-
ety Undergraduate Scholarship, Moore, Oklahoma - EP5, May 20, 2013
Funded by a NSF RAPID grant, the University of Alabama teamed with members
2008
from the University of Florida, the University of Oklahoma, Oklahoma State
Valparaiso University Lumina
University, Mississippi State University, Oregon State University, Rose-Hulman
Award for Academic Achieve-
Institute of Technology, and Simpson Strong Tie to assess damage. Focus was paid
ment, 2008 to roof-to-wall connections, wall-to-foundation connections, and storm shelter
Member of Chi Epsilon Pi
performance. Transects were completed across the path to obtain a variation of
Meteorology Honor Society, wind speed and damage across a tornado's width. The data was compiled into a
2007-2009 website and available to the public.
Testimony history available upon request.
Updated Oct. 14, 2022
Page 3
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Filing# 166165770 E-Filed 02/06/2023 09:22:56 AM IN THE CIRCUITCOURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE-21-007773 MARCIA SAMPSON AND HERMAN FEAR-IN, Plaintiff(s), V CITIZENS PROPERTY INSURANCE CORPORATION Defendant. i DEFENDANT'S EXPERT WITNESS DISCLOSURE COMES NOW, Defendant, Citizens Property Insurance Corporation,("Citizens"), by and through Law Offices of Hoffman and Hoffman, P.A, and files Defendant's Expert Witness Disclosure in order to comply with the current Trial order in this matter, and as follows: 1. Christine Alfano, Professional Engineer, Haag 2224 East 117th St. Burnsville, MN 55337 HaagGlobal.com Ms. Alfano is a licensed senior professionalengineer and certified consulting meteorologist with Haag. Ms. Alfano was retained by the Defendant to do an of the reportedloss and allegeddamages investigation to the subjectproperty. Ms. Alfano inspectionof the property is currentlybeing coordinated. It is that Ms. Alfano will testify anticipated without limitation as to the damages allegedby the Plaintiffs and condition of the roofingsystem//other structural components LAW OFFICE OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 - Telephone: 305.372.2877 Fax: 305.372.2875 Filed by eFileMadEEh*ItafD?: IBIMEWMED@@EEHfitEImrBIuc]*INENIBAG1/(AZERI2[KN;0(I:11BWWDES)6/2023 09:22:56 AM.**** of the residence in lightwith her experience as a professionalengineer and certified consultingmeteorologist. Ms. Alfano's findingswill be derived from, among other things,inspectionof the property, review of photographs, measurements, sketches, estimates, and other information received with regards to the subject loss. Additionally,her educational training,experience,expertise,and other relevant factors and materials in this case assisted him in formulatingher opinion.Pursuant to Fla. R. Civ. P. a) The scope of employment in the pending and the compensation for such services. Ms. Alfano, as a State of Florida licensed Professional Engineer with Haag, was retained by Citizens to which perform an evaluation of the property via an inspection, is currently being coordinated. To date,Ms. Alfano has not been paid for her work on this case. b) The expert's general litigationexperience, including the percentage of work performed for plaintiffs and defendants. Please refer to Ms. Alfano's Record o f Depositionand Expert Testimony at Trial attached " as Exhibit "A. Approximately 90% of the work performed by Ms. Alfano is for defendants. c) The identity other cases, within a reasonable time period, in which the expert has testified by deposition or at trial. Please refer to Ms. Alfano' s Record o f Depositionand Expert Testimony at Trial attached as Exhibit "A." d) Anapproximation of the portion of the expert's involvement as an expert witness, which may be based on the number of hours, percentage of hours, or percentage of earned income derived from serving as an expert witness; however, the expert shall not be required to disclose his or her earnings as an expert witness or income derived from other services. LAW OFFICE OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 - Telephone: 305.372.2877 Fax: 305.372.2875 Ms. Alfano, as a State of Florida licensed Professional Engineer with Haag, was retained by Defendant to inspectPlaintiffs' property and provide an opinion as to the cause and origin of the alleged damages reportedly caused by Tropical Storm Eta. For more information, please refer to Ms. Alfano's Professional Resume attached as Exhibit "B." Approximately 50-60% of the work performed by Ms. Alfano is related to serving as an expert witness. 2. Defendant reserves the right to supplement this Expert Witness Disclosure as discovery progresses. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoingwas served via email, on February 6,2023 to: Alex Stern, Esq. alex@LRLC.legal; service@LRLC.legal Litigation& Recovery Law Center, P.L. 16375 NE 18th Ave, Ste 321 North Miami Beach, FL 33162 LAW OFFICES OF HOFFMAN & HOFFMAN, P.A. 66 West FlaglerStreet,Suite 200, Miami, Florida 33130 Telephone: 305.372.2877 / Facsimile: 305.372.2875 EService E-mail: eservice@hoffmanpa.com By: /s/ Tatyana Krimus, Esq. John D. Hoffman, Esq. Board CerttftedCivil Trial Lawyer Florida Bar No. 825859 / E-mail: john@hoffmanpa.corn Jennifer Valiyi,Esq. Board CerttftedCivil Trial Lawyer Florida Bar No. 116079 / E-mail: jennifer@hoffmanpa.com Tatyana Krimus, Esq. Florida Bar No. 1018299 / E-mail: tkrimus@hoffmanpa.com LAW OFFICE OF HOFFMAN & HOFFMAN, P.A. 66 W. Flagler Street, Suite 200, Miami, Florida 33130 - Telephone: 305.372.2877 Fax: 305.372.2875 Exhibit A No. Depo Date Trial Date Name Court Case No. United States District Malka v. Geovera Court Southern District 1 9/4/2019 N/A 0:18-cv-61905-DPG Specialty Insurance of Florida Fort Lauderdale Division Maria Mesa and Roxana Circuit Court of the 11th De Leon v Citizens 2 4/14/2020 11/1/2021 Judicial Circuit in and for 2017-026083-CA-01 Property Insurance Miami-Dade County, FL Corporation Arteaga, Barbara and Circuit Court of the 11th 3 5/29/2020 N/A Alexa v. Citizens Judicial Circuit in and for 2019-004580-CA-01 Property Insurance Miami-Dade County, FL Beatriz Lopez-Gross v. Circuit Court of the 11th 4 9/4/2020 N/A Citizens Property Judicial Circuit in and for 2019-037125-CA-01 Insurance Corporation Miami-Dade County, FL American Rockwool Manufacturing LLC vs District Court of the 5 9/24/2020 N/A Markel American 146th Judicial District 313,559-B Insurance and Insurica Bell County, Texas TX Insurance Services Gary and Candida Circuit Court of the 11th Chesman v. Citizens 6 10/19/2020 N/A Judicial Circuit in and for 2016-003466-CA-01 (22) Property Insurance Miami-Dade County, FL Corporation Mark and Tali Hirsch v. Circuit Court of the 11th Homeowners Choice 7 12/10/2020 N/A Judicial Circuit in and for 2019-021589--CA-01 Property and Casualty Miami-Dade County, FL Insurance Company James and Annette Circuit Court of the 20th Coleman v. Family 8 3/15/2021 N/A Judicial Circuit in and for 20-CA-000200 Security Insurance Lee County, FL Company Hector Hernandez v. Circuit Court of the 11th 9 3/31/2021 N/A Citizens Property Judicial Circuit in and for 2019-000285-CA-01 Insurance Miami-Dade County, FL Janine Coutrier and Circuit Court for the Pauline Thomas v. Seventeenth Judicial 10 10/22/2021 N/A CACE-21-002623(09) Citizens Property Circuit in and for Insurance Corporation Broward County, Florida No. Depo Date Trial Date Name Court Case No. Ivette Hernandez and Circuit Court of the 11th 11 11/15/2021 N/A Luis Velzaquez v Citizens Judicial Circuit in and for 2016-015721 CA 01 Property Insurance Corp Miami-Dade County, FL Angel Rabelo and Circuit Court of the 17th Iluminada Rivero v 12 12/3/2021 N/A Judicial Circuit in and for CACE-20-014394(04) Citizens Property Broward County, FL Insurance Corp Circuit Court of Ozaukee Mrotek v American 13 1/10/2022 N/A County, State of 21-CV-33 Family Mutual Insurance Wisconsin Edna Sibila and Erik Circuit Court of the 11th 14 1/12/2022 N/A Sibila v. Citizens Property Judicial Circuit in and for 19-035172 CA 01 Insurance Corp Miami-Dade County, FL Terry Thompson v. State of Wisconsin 15 1/21/2022 N/A American Family Circuit Court Fond du Lac 19-CV-518 Insurance Company County Dale and Margaret State of Wisconsin 16 2/25/2022 N/A Hamann v. Erie Circuit Court Ozaukee 21-CV-135 Insurance Company County Circuit Court for the Sheryll Wilson v Citizens Seventeenth Judicial 17 4/1/2022 N/A Property Insurance CACE 20-011579 Circuit in and for Corporation Broward County, Florida Circuit Court for the Nancy Eustache v Seventeenth Judicial 18 4/4/2022 N/A Citizens Property CACE -21-000431 Circuit in and for Insurance Corporation Broward County, Florida Neil Hernandez v Circuit Court of the 11th 19 4/26/2022 N/A Citizens Property Judicial Circuit in and for 2021-000906-CA-01 Insurance Corporation Miami-Dade County, FL Benjamin Schiff v Circuit Court of the 17th 20 7/25/2022 N/A Citizens Property Judicial Circuit in and for CACE-20-019648 Insurance Corporation Broward County, FL Carlos Cabrera v Citizens Circuit Court of the 11th 21 8/25/2022 N/A Property Insurance Judicial Circuit in and for 2021-020416-CA-01 Corporation Miami-Dade County, FL No. Depo Date Trial Date Name Court Case No. Magaly Hernandez and Circuit Court of the 11th 22 8/26/2022 N/A Oris Rodriguez v Security Judicial Circuit in and for 21-14693 CA 01 First Insurance Company Miami-Dade County, FL Pedro Quesada v Circuit Court of the 11th 23 8/29/2022 N/A Citizens Property Judicial Circuit in and for 2020-017045-CA-01 Insurance Corporation Miami-Dade County, FL Warehouse Investors, LLC, Dixon Properties - United States District 3811, LLC, and 51st Court for the Southern 24 9/22/2022 N/A 4:21-cv-00174-HCA Street Properties, LLC v District of Iowa Central Affiliated FM Insurance Division Company Sherene Thomas and Circuit Court of the 15th Nicholas Coke v Citizens Judicial Circuit in and for 50-2020-CC-005161- 25 10/28/2022 N/A Property Insurance Palm Beach County, XXXX-SB Corporation Florida Exhibit B AVA' Christine Standohar-Alfano,Ph.D., RE., CCM Director of Forensic Meteorology, Forensic Engineer Dr. Standohar-Alfano isthe Director of Forensic Meteorologyand Forensic Engineer with Haag Engineering Co. Dr. Alfano has achieved the Certified Consulting Meteorologist (CCM) designation from the American Meteorological Society and is the only RE. in the U.S. with a CCM designation. She has inspected and assessed damage to hundreds of roofs including asphalt composition, tile, and various commercial roofing systems. She has written and published many articles on tornadoes and resultant damage in peer-reviewed literature and she has presented her results at numerous national and international conferences. Additionally, she has participated in several large-scale post- disaster surveys for tornadoes and hurricanes. Dr. Standohar-Alfano has provided expert testimony as both a meteorologist and engineer in cases involving roof and building envelope performance. She has also Contact taught several continuing education courses for Haag Education and for Haag's Certified CAIfano@HaagGIobal.com Inspector programs for residential and wind damage certification. Priorto joining Haag, 214-614-6500 main Dr. Standohar-Alfano was a research engineer and was involved in testing small- and 800-527-0168 toll free full-scale building components and systems against wind, wind-driven rain, wildfire, and hail. 2224 East 117th St. Burnsville, MN 55337 HaagGIobal.com Primary Areasof Consulting Roofing Systems Academic Background . Commercial and residential Doctor of Philosophy in Civil Wind/hail damage evaluations Quality of manufacture and installation Engineering, Dissertation: Damage Wood- Building Envelope Systems Analysis and Mitigation for . Commercial and residential frame Structures Subjected to Wind/hail damage evaluations Tornado Loading, Colorado State Quality of manufacture and installation University, Fort Collins, Colorado Evaluation of Wind Damage to Structures 2016 . Commercial and residential . Hurricane, tornado, and straight-line wind evaluations Master of Science in Meteorology Construction Defect Evaluations and Physical Oceanography, Thesis: . Commercial and residential Impact of Upper Ocean Warming . Moisture intrusion evaluations on Hurricane Intensity, University of . Building code compliance Miami, Miami, Florida Meteorological Investigations 2012 . Severe weather events Storm surveys Bachelor of Science Precipitation/temperature/wind analysis in Meteorology, Valparaiso University, Valparaiso, Indiana, Graduated Summa cum Laude Professional Licensure 2009 Registered Professional Engineer: Minnesota, Wisconsin, Iowa, North Carolina, South 2022 Carolina, Tennessee, Florida, Virginia, and Georgia Updated Oct. 14, Page 1 AVA' Christine Standohar-Alfano, Ph.D., RE., CCM Director of Forensic Meteorology, Forensic Engineer Memberships/ Employment Background Certifications Haag Engineering Co. ASCE Wind Speed Estimation Director of Forensic Meteorology 2022 to Present in Tornadoes Committee Forensic Engineer 2017 to Present - Associate Member and . See Areas of Expertise Secretary Certified Consulting Insurance Institute of Business and Home Safety Meteorologist (CCM) Research Engineer 2015 to 2017 . Society of Women Engineers . American Meteorological Valparaiso University, Department of Mechanical Engineering Society Visiting Assistant Professor 2014 to 2015 American Society of Civil Engineers Chi Epsilon Pi Meteorology Honor Society Lectures & Publications (Partial) Haag Certified Inspector - Haag Certified Inspector- Residential Roofing; Instructor and Course Co-Developer, Residential Roofs - online and classroom versions Haag Certified Inspector Haag Certified Roofing; Instructor and Course Co- Commercial Roofs - Developer, online and classroom versions Haag Certified Inspector Wind Damage Haag Certified Inspector-Wind Damage; Instructor and Course Co-Developer, online and classroom versions . van de Lindt, John W., Masoomi, Hassan, Attary, Navid, and Standohar-Alfano, Christine D., 2019. Tornado damage modeling: Single buildings, communities, and regions. Routledge Handbook of Sustainable and Resilient Infrastructure. Standohar-Alfano, Christine D., van de Lindt, John W., and Holt, Eric M., 2017. Comparative Residential Property Loss Estimation for the April 25-28, 2011 Tornado Outbreak. Journal of Architectural Engineering. Standohar-Alfano, Christine D., van de Lindt, John W., and Ellingwood, Bruce R., 2017: Vertical Load Path Failure Risk Analysis of Residential Wood-Frame Construction in Tornadoes. Journal of Structural Engineering. Standohar-Alfano, Christine D., and van de Lindt, John W., 2015: Tornado Risk Analysis for Residential Wood-frame Roof Damage Across the United States. Journal of Structural Engineering. Standohar-Alfano, Christine D., Freyne, Seamus, Graettinger, Andrew J., Floyd, Royce W., Dao, Thang N., 2014: Performance of Residential Shelters in the May 20th, 2013 Moore, Oklahoma Tornado. Journal of the Performance of Constructed Facilities. Standohar-Alfano, Christine D., and van de Lindt, John W., 2014: An Empirically- Based Probabilistic Tornado Hazard Analysis of the U.S. Using 1973-2011 Data. Natural Hazards Review, 10. Updated Oct. 14, 2022 Page 2 AVA' Christine Standohar-Alfano, Ph.D., RE., CCM Director of Forensic Meteorology, Forensic Engineer Honors Damage Surveys . Journal of Architectural Engi- Nashville, Tennessee -EB, March 3,2020 Assisted the NashvilleNWS with their survey of the long-track tornado that neering, Best Paper of 2018 impacted north Nashville and adjacent suburbs. Our emphasis was inspecting Federal Alliance for Safe Homes buildings where they were uncertain of the most appropriate damage indicator (DI) International Code Council or quality of construction. We also focused on collecting damage information on Scholarship, 2014 DI's being introduced in the newest iteration of the EF Scale, specificallylight poles, Colorado State University Dr. metal building systems, and churches. Jack E. Cermak Wind Engineer- 2014 Hurricane Harvey -Category 4, August 25, 2018 ing Scholarship, IBHS team performed a post-disaster wind investigation of various neighborhoods University of Alabama Graduate impacted by Hurricane Harvey including Holiday Beach, Rockport, Port Aransas, Council Fellowship, 2012-2013 Aransas Pass, Ingleside,and Portland, Texas. Focus was on residential construction . American Meteorological Soci- performance including roof cover,wall cladding, and windows, doors, and garage ety Graduate Fellow, 2009-2010 doors. The data was compiled into a report and available to the public. . American Meteorological Soci- ety Undergraduate Scholarship, Moore, Oklahoma - EP5, May 20, 2013 Funded by a NSF RAPID grant, the University of Alabama teamed with members 2008 from the University of Florida, the University of Oklahoma, Oklahoma State Valparaiso University Lumina University, Mississippi State University, Oregon State University, Rose-Hulman Award for Academic Achieve- Institute of Technology, and Simpson Strong Tie to assess damage. Focus was paid ment, 2008 to roof-to-wall connections, wall-to-foundation connections, and storm shelter Member of Chi Epsilon Pi performance. Transects were completed across the path to obtain a variation of Meteorology Honor Society, wind speed and damage across a tornado's width. The data was compiled into a 2007-2009 website and available to the public. Testimony history available upon request. Updated Oct. 14, 2022 Page 3