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Filing # 142380517 E-Filed 01/21/2022 08:05:31 AM
IN THE CIRCUIT COURT OF THE
EIGHTEENTH JUDICIAL CIRCUIT IN
AND FOR BREVARD COUNTY, FL
CASE NO. 052020CA024628XXXXXX
ANTHONY DAVIS JR.,
Plaintiff,
Vv.
SECURITY FIRST INSURANCE COMPANY DBA SECURITY FIRST FLORIDA,
Defendant.
/
PLAINTIFF'S DISCLOSURE OF EXPERT WITNESSES
COMES NOW the Plaintiff, ANTHONY DAVIS JR., by and through the undersigned
attorney, and pursuant to this Court's Order Setting Cut-Off Dates, Mediation, and Trial Date
dated June 22, 2021, Plaintiff hereby disclose the following expert witnesses:
1 Expert Witnesses
A Edward “Joe” Jaremko
Arko Plumbing Corp.
8306 Mills Drive, #569
Miami, FL 33183
(i) The subject matter about which the expert is expected to testify: Mr.
Jaremko is expected to testify that the cast iron pipe plumbing system
at Plaintiffs’ home has failed, has caused the damage complained of at
Plaintiffs’ home, caused damage to the structural backfill under the
home, and the entire system needs to be dug out and replaced. He will
also testify about the method of tearing out and replacing the cast iron
pipe system. He will also testify that other potential causes of loss at
the home are not plausible, and are not the cause of the loss at
Plaintiffs’ home. He will testify that alternative methods of repair of the
cast iron pipe system are not appropriate.
Mr. Jaremko’s opinion is supported and further explained by the
moisture meter readings, hydrostatic test, camera inspection and the
photos/videos of Arko Plumbing Corp and photos of Triad Restoration
Filing 142380517 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
Services, as well as the reports of Triad Restoration Services.
(ii) The substance of the facts and opinions about which the expert is
expected to testify: See (i) above.
(iii) A summary of the grounds for each opinion: See (i) above.
(iv) Acopy of any written reports issued by the expert regarding this case:
Plaintiffs will produce under separate cover.
(v) A copy of the expert's curriculum vitae: Plaintiffs will produce under
separate cover.
(vi) Proposed deposition dates: 4/5/2022 at 1:00 PM, 4/8/2022 at 11:00
AM, 4/20/2022 at 1:00 PM
Dennis James
Triad Restoration Services (“Triad”)
2801 Alt 19
Dunedin, FL 34698
(i) The subject matter about which the expert is expected to testify: Mr.
James is a General Contractor and will testify as to the repair costs and
what the estimate is intended to repair/replace, and how he arrived at
those figures. He is also expected to testify that the cast iron pipe
plumbing system at Plaintiffs’ home has failed, has caused the damage
complained of at Plaintiffs’ home, caused damage to the structural
backfill under the home and the entire system needs to be dug out and
replaced. He will also testify about the costs and the repairs
necessitated by tearing out and replacing the cast iron pipe system. He
will testify that other potential causes of loss at the home are not
plausible, and are not the cause of the loss at Plaintiffs’ home. He will
testify that alternative methods of repair of the home are not
appropriate.
Mr. James will testify that the cost to perform the work described above
is $102,516.36 (RCV) and $96,574.08 (ACV), what the estimates are
intended to repair/replace, and how he arrived at those figures. Mr.
James will also testify that the cost to perform the work described
above is $93,938.70 (RCV) and $88,799.12 (ACV), if matching costs
are excluded from the estimate. Mr. James’ opinion is supported and
further explained by the moisture meter readings, and the
photos/videos of Arko Plumbing Corp and photos of Triad Restoration
Services, as well as the reports of Arko Plumbing Corp.
(ii) The substance of the facts and opinions about which the expert is
Filing 142380517 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
expected to testify: See (i) above.
(iii) A summary of the grounds for each opinion: See (i) above.
(vii) Acopy of any written reports issued by the expert regarding this case:
Plaintiffs will produce under separate cover.
(iv) A copy of the expert’s curriculum vitae: Plaintiffs will produce under
separate cover.
viii) Proposed deposition dates: 4/5/2022 at 1:00 PM, 4/8/2022 at 11:00
AM, 4/20/2022 at 1:00 PM
Out of an abundance of caution, Plaintiff also discloses the following who
performed testing at Plaintiff's home and/or took photographs and/or videos at
Plaintiff's home. The following are not expected to give expert opinions, but
may be called to authenticate videos/photos and, if applicable, to describe the
testing performed:
A. Brent Caporusso (for authentication and introduction of photographs, if
necessary)
Triad Restoration Services (“Triad”)
2801 Alt 19
Dunedin, FL 34698
*The undersigned will inquire into whether Defendant will stipulate to the
admissibility of all photos taken by the individual named above.
Alejandro Naranjo
Arko Plumbing Corp.
8306 Is Drive, #569
Miami, FL 33183
Performed a camera inspection, hydrostatic test and moisture readings at
Plaintiff's home on September 11, 2020 and took videos during the camera
inspection and moisture readings performed at Plaintiff's home on September
11, 2020 upon which he bases his opinions. Mr. Naranjo will testify as to the
elevated moisture readings taken on September 11, 2020. Mr. Naranjo is also
listed for authentication and introduction of videos, pictures and videoscopes, if
necessary. The undersigned will inquire into whether Defendant will stipulate
to the admissibility of all photos and videos taken by the individual named
above.
e Any and all expert witnesses listed by the Defendants.
Filing 142380517 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
Any witness listed or called the Defendant for any purpose so listed.
Any witnesses necessary for impeachment and/or rebuttal.
Any Records Custodian(s) as necessary.
All witnesses identified in discovery, now or in the future, including Answers to
Interrogatories, Responses to Request to Produce and depositions.
Discovery is ongoing and Plaintiffs reserve the right to amend this witness list.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by electronic mail to Ashley Ward-Singleton, Esquire; Jennifer L. Velazco,
Esquire; [iniv.ashley.wardsingleton@qpwblaw.com; jvelazco@qpwblaw.com;
cynthia.mejias@qpwblaw.com] Quintairos, Prieto, Wood & Boyer, P.A., 1410 North
Westshore Boulevard Suite 200, Tampa, FL 33607, this 21% day of January, 2022.
/s/_ Gi Kimmel
GINA KIMMEL, ESQ., Esquire
Florida Bar No. 0121929
Morgan & Morgan, P.A.
20 N. Orange Avenue, 4" Floor
Post Office Box 4979
Orlando, Florida 32802-4979
Telephone: (407) 420-1414
Facsimile: (407) 245-3414
Primary email: GKimmel@forthepeople.com
Secondary email:SFloresrivera@forthepeople.com
LRolon@forthepeople.com
Attorneys for Plaintiff
Gk/sfr
Filing 142380517 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
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Filing # 142380517 E-Filed 01/21/2022 08:05:31 AM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FL CASE NO. 052020CA024628XXXXXX ANTHONY DAVIS JR., Plaintiff, Vv. SECURITY FIRST INSURANCE COMPANY DBA SECURITY FIRST FLORIDA, Defendant. / PLAINTIFF'S DISCLOSURE OF EXPERT WITNESSES COMES NOW the Plaintiff, ANTHONY DAVIS JR., by and through the undersigned attorney, and pursuant to this Court's Order Setting Cut-Off Dates, Mediation, and Trial Date dated June 22, 2021, Plaintiff hereby disclose the following expert witnesses: 1 Expert Witnesses A Edward “Joe” Jaremko Arko Plumbing Corp. 8306 Mills Drive, #569 Miami, FL 33183 (i) The subject matter about which the expert is expected to testify: Mr. Jaremko is expected to testify that the cast iron pipe plumbing system at Plaintiffs’ home has failed, has caused the damage complained of at Plaintiffs’ home, caused damage to the structural backfill under the home, and the entire system needs to be dug out and replaced. He will also testify about the method of tearing out and replacing the cast iron pipe system. He will also testify that other potential causes of loss at the home are not plausible, and are not the cause of the loss at Plaintiffs’ home. He will testify that alternative methods of repair of the cast iron pipe system are not appropriate. Mr. Jaremko’s opinion is supported and further explained by the moisture meter readings, hydrostatic test, camera inspection and the photos/videos of Arko Plumbing Corp and photos of Triad Restoration Filing 142380517 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX Services, as well as the reports of Triad Restoration Services. (ii) The substance of the facts and opinions about which the expert is expected to testify: See (i) above. (iii) A summary of the grounds for each opinion: See (i) above. (iv) Acopy of any written reports issued by the expert regarding this case: Plaintiffs will produce under separate cover. (v) A copy of the expert's curriculum vitae: Plaintiffs will produce under separate cover. (vi) Proposed deposition dates: 4/5/2022 at 1:00 PM, 4/8/2022 at 11:00 AM, 4/20/2022 at 1:00 PM Dennis James Triad Restoration Services (“Triad”) 2801 Alt 19 Dunedin, FL 34698 (i) The subject matter about which the expert is expected to testify: Mr. James is a General Contractor and will testify as to the repair costs and what the estimate is intended to repair/replace, and how he arrived at those figures. He is also expected to testify that the cast iron pipe plumbing system at Plaintiffs’ home has failed, has caused the damage complained of at Plaintiffs’ home, caused damage to the structural backfill under the home and the entire system needs to be dug out and replaced. He will also testify about the costs and the repairs necessitated by tearing out and replacing the cast iron pipe system. He will testify that other potential causes of loss at the home are not plausible, and are not the cause of the loss at Plaintiffs’ home. He will testify that alternative methods of repair of the home are not appropriate. Mr. James will testify that the cost to perform the work described above is $102,516.36 (RCV) and $96,574.08 (ACV), what the estimates are intended to repair/replace, and how he arrived at those figures. Mr. James will also testify that the cost to perform the work described above is $93,938.70 (RCV) and $88,799.12 (ACV), if matching costs are excluded from the estimate. Mr. James’ opinion is supported and further explained by the moisture meter readings, and the photos/videos of Arko Plumbing Corp and photos of Triad Restoration Services, as well as the reports of Arko Plumbing Corp. (ii) The substance of the facts and opinions about which the expert is Filing 142380517 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX expected to testify: See (i) above. (iii) A summary of the grounds for each opinion: See (i) above. (vii) Acopy of any written reports issued by the expert regarding this case: Plaintiffs will produce under separate cover. (iv) A copy of the expert’s curriculum vitae: Plaintiffs will produce under separate cover. viii) Proposed deposition dates: 4/5/2022 at 1:00 PM, 4/8/2022 at 11:00 AM, 4/20/2022 at 1:00 PM Out of an abundance of caution, Plaintiff also discloses the following who performed testing at Plaintiff's home and/or took photographs and/or videos at Plaintiff's home. The following are not expected to give expert opinions, but may be called to authenticate videos/photos and, if applicable, to describe the testing performed: A. Brent Caporusso (for authentication and introduction of photographs, if necessary) Triad Restoration Services (“Triad”) 2801 Alt 19 Dunedin, FL 34698 *The undersigned will inquire into whether Defendant will stipulate to the admissibility of all photos taken by the individual named above. Alejandro Naranjo Arko Plumbing Corp. 8306 Is Drive, #569 Miami, FL 33183 Performed a camera inspection, hydrostatic test and moisture readings at Plaintiff's home on September 11, 2020 and took videos during the camera inspection and moisture readings performed at Plaintiff's home on September 11, 2020 upon which he bases his opinions. Mr. Naranjo will testify as to the elevated moisture readings taken on September 11, 2020. Mr. Naranjo is also listed for authentication and introduction of videos, pictures and videoscopes, if necessary. The undersigned will inquire into whether Defendant will stipulate to the admissibility of all photos and videos taken by the individual named above. e Any and all expert witnesses listed by the Defendants. Filing 142380517 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX Any witness listed or called the Defendant for any purpose so listed. Any witnesses necessary for impeachment and/or rebuttal. Any Records Custodian(s) as necessary. All witnesses identified in discovery, now or in the future, including Answers to Interrogatories, Responses to Request to Produce and depositions. Discovery is ongoing and Plaintiffs reserve the right to amend this witness list. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic mail to Ashley Ward-Singleton, Esquire; Jennifer L. Velazco, Esquire; [iniv.ashley.wardsingleton@qpwblaw.com; jvelazco@qpwblaw.com; cynthia.mejias@qpwblaw.com] Quintairos, Prieto, Wood & Boyer, P.A., 1410 North Westshore Boulevard Suite 200, Tampa, FL 33607, this 21% day of January, 2022. /s/_ Gi Kimmel GINA KIMMEL, ESQ., Esquire Florida Bar No. 0121929 Morgan & Morgan, P.A. 20 N. Orange Avenue, 4" Floor Post Office Box 4979 Orlando, Florida 32802-4979 Telephone: (407) 420-1414 Facsimile: (407) 245-3414 Primary email: GKimmel@forthepeople.com Secondary email:SFloresrivera@forthepeople.com LRolon@forthepeople.com Attorneys for Plaintiff Gk/sfr Filing 142380517 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX