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Filing# 158329653 E-Filed 09/29/2022 04:02:02 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.: CACE-21-007201
ANTONIO ALFARO and DIANAALFARO,
Plaintiffs,
V
TYPTAP INSURANCE COMPANY,
Defendant.
DEFENDANT'S FIRST EXPERT REQUEST FOR PRODUCTION TO PLAINTIFFS
Defendant, TYPTAP INSURANCE COMPANY, by and through its undersigned
counsel and pursuant to Rule 1.350, Florida Rules of Civil Procedure, requests the
ANTONIO
Plaintiffs, ALFARO and DIANA ALFARO, to produce and permit the inspection
and copying, within thirty(30) days of service hereof, the following documents, writings
and other data, at the offices of the undersigned:
EXPERT REQUEST FOR PRODUCTION
1. All files maintained by any expert you have listed to testifyregarding this matter.
2. Any and all materials your experts have reviewed in this matter, including, but not
limited to, correspondence, photographs, reports, books, articles,literature,films,
tests, experiments, statements, or other reference materials that you used or are
relying on.
3. Any and all reports prepared or furnished to you or your counsel by any expert in
this case.
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 -
(561) 683-8977 FAX
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/29/2022 04:02:02 PM.****
CACE-21-007201
4. Any and all reports which were furnished to your experts by other experts in this
case.
5. Curriculum vitae for all retained experts.
6. Any and all test results and/or experiments conducted in this case by any retained
experts.
7. Any and all results of tests your experts, agents, servants or employees conducted
in this case.
8. Complete billingfiles maintained by any retained expert in this case, including, but
not limited to, the charges rendered, the statements rendered, the time spent on
this case, on
and other relevant materials concerning the time and billing this case.
9. Any and all notes, writings,memoranda, etc. which have prepared on this case by
any retained expert.
10. Any and all computer printouts from computers used by any retained experts,
agents, servants or employees which were prepared for this case.
11. Any and all notes taken or prepared by any experts, agents, servants or employees
which were prepared for this case.
12.Any and all literature written by any retained expert.
13. A list of all cases in which any retained expert has been retained to testifyin the
past five years, including the name of the attorney who retained the expert, the
name of the case which the expert reviewed, the court and judicialcircuit in which
the case was filed and the case number.
Page 2
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING -
222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200
-
(561) 683-8977 FAX
CACE-21-007201
14. A copy of any and all written correspondence either directed to the expert from
counsel or written by the expert to Plaintiff(s)
Plaintiff(s) counsel.
15. All textbooks, journals or similar literature which any expert has consulted and for
which any expert has relied upon in order to arrive at any opinions which they will
render in this case.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 29th day of September, 2022, a true and correct
copy of the foregoing was filed with the Clerk of Broward County by using the Florida
Courts e-Filing Portal, which will send an automatic e-mail message to the following
parties registered with the e-Filing Portal system: Maximo A. Santiago, Esq, Your
Insurance Attorney, PLLC, yia3@yourinsuranceattorney.com;
eservice@yourinsuranceattorney.com, 2601 South Bayshore Drive, 18th Floor, Coconut
Grove, FL 33133, (888) 570-5677/(888) 745-5677 (F), Attorney for Plaintiffs,Diana
Arevalo and Antonio Alfaro.
COLE, SCOTT & KISSANE, P.A.
Counse/ for Defendant TYPTAP INSURANCE
COMPANY
Esperante Building
222 Lakeview Avenue, Suite 120
West Palm Beach, Florida 33401
Telephone (561) 383-9233
Facsimile (561) 683-8977
Primary e-mail: stephen.harber@csklegal.corn
Secondary e-mail: jacqueline.meyer@csklegal.corn
Alternate e-mail: wpbfirstparty@csklegal.com
By: s/ Jacqueline P. Meyer
STEPHEN N. HARBER
Florida Bar No.: 96374
JACQUELINE P. MEYER
Florida Bar No.: 1010785
0365.1428-00
Page 3
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING -
222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200
-
(561) 683-8977 FAX
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Filing# 158329653 E-Filed 09/29/2022 04:02:02 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-007201 ANTONIO ALFARO and DIANAALFARO, Plaintiffs, V TYPTAP INSURANCE COMPANY, Defendant. DEFENDANT'S FIRST EXPERT REQUEST FOR PRODUCTION TO PLAINTIFFS Defendant, TYPTAP INSURANCE COMPANY, by and through its undersigned counsel and pursuant to Rule 1.350, Florida Rules of Civil Procedure, requests the ANTONIO Plaintiffs, ALFARO and DIANA ALFARO, to produce and permit the inspection and copying, within thirty(30) days of service hereof, the following documents, writings and other data, at the offices of the undersigned: EXPERT REQUEST FOR PRODUCTION 1. All files maintained by any expert you have listed to testifyregarding this matter. 2. Any and all materials your experts have reviewed in this matter, including, but not limited to, correspondence, photographs, reports, books, articles,literature,films, tests, experiments, statements, or other reference materials that you used or are relying on. 3. Any and all reports prepared or furnished to you or your counsel by any expert in this case. COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/29/2022 04:02:02 PM.**** CACE-21-007201 4. Any and all reports which were furnished to your experts by other experts in this case. 5. Curriculum vitae for all retained experts. 6. Any and all test results and/or experiments conducted in this case by any retained experts. 7. Any and all results of tests your experts, agents, servants or employees conducted in this case. 8. Complete billingfiles maintained by any retained expert in this case, including, but not limited to, the charges rendered, the statements rendered, the time spent on this case, on and other relevant materials concerning the time and billing this case. 9. Any and all notes, writings,memoranda, etc. which have prepared on this case by any retained expert. 10. Any and all computer printouts from computers used by any retained experts, agents, servants or employees which were prepared for this case. 11. Any and all notes taken or prepared by any experts, agents, servants or employees which were prepared for this case. 12.Any and all literature written by any retained expert. 13. A list of all cases in which any retained expert has been retained to testifyin the past five years, including the name of the attorney who retained the expert, the name of the case which the expert reviewed, the court and judicialcircuit in which the case was filed and the case number. Page 2 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX CACE-21-007201 14. A copy of any and all written correspondence either directed to the expert from counsel or written by the expert to Plaintiff(s) Plaintiff(s) counsel. 15. All textbooks, journals or similar literature which any expert has consulted and for which any expert has relied upon in order to arrive at any opinions which they will render in this case. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 29th day of September, 2022, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Maximo A. Santiago, Esq, Your Insurance Attorney, PLLC, yia3@yourinsuranceattorney.com; eservice@yourinsuranceattorney.com, 2601 South Bayshore Drive, 18th Floor, Coconut Grove, FL 33133, (888) 570-5677/(888) 745-5677 (F), Attorney for Plaintiffs,Diana Arevalo and Antonio Alfaro. COLE, SCOTT & KISSANE, P.A. Counse/ for Defendant TYPTAP INSURANCE COMPANY Esperante Building 222 Lakeview Avenue, Suite 120 West Palm Beach, Florida 33401 Telephone (561) 383-9233 Facsimile (561) 683-8977 Primary e-mail: stephen.harber@csklegal.corn Secondary e-mail: jacqueline.meyer@csklegal.corn Alternate e-mail: wpbfirstparty@csklegal.com By: s/ Jacqueline P. Meyer STEPHEN N. HARBER Florida Bar No.: 96374 JACQUELINE P. MEYER Florida Bar No.: 1010785 0365.1428-00 Page 3 COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX