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Filing# 151134993 E-Filed 06/08/2022 06:49:55 PM
IN THE CIRCUITCOURT OF THE 17
7TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
ALEJANDRA GOMEZ AND CHRISTOPHER CASE NO. CACE-21-007582
GOMEZ,
Plaintiff.
VS.
SCOTTSDALE INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S NOTICE OF SERVICE OF EXPERT INTERROGATORIES
Defendant, SCOTTSDALE INSURANCE COMPANY, hereby requests the Plaintiff,
ALEJANDRA GOMEZ AND CHRISTOPHER GOMEZ answer under oath, in writing,the
within the time prescribedin accordance with the Florida Rules of
attached Expert Interrogatories
Civil Procedure.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoingdocument is being served on June 8,2022 via an
automatic e-mail generatedby the Florida E-FilingPortal to all counsel of record.
HINSHAW & CULBERTSON LLP
/s/ Francesco J. Palanda
Francesco Palanda, Esquire
J.
Florida Bar No. 809071
fpalanda@hinshawlaw.com
ellampallas@hinshawlaw.com,
ihodges@hinshawlaw.com
th
2525 Ponce de Leon Boulevard, 4 Floor
Coral Gables, Florida 33134
Telephone: (305) 358-7747
Facsimile: (305) 577-1063
COUNSEL FOR DEFENDANT
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/08/2022 06:49:54 PM.****
EXPERT INTERROGATORIES
1. Please state the name, profession,specialty,business address, and telephone
number o f each person whom you as an expert witness at
or your attorneys intend to call to testify
the trial o f this matter.
ANSWER:
2. For each expert identified in response to InterrogatoryNumber 1 above, state, in
detail,the scope of his/her employment, includingbut not limited to, when they were retained,by
whom they were retained,what they were provided when they were retained in relation to the
subjectclaim, what they were requestedto do or what service they were requestedto provide,what
documents or materials related to the subjectmatter of this case they were provided when they
were retained,and the scope of their compensation for such service in this case.
ANSWER:
3 Please state the hourly rate charged by the above-named expert for (a) services
(e)trial,and (f)the
rendered in this case; (b) review of material, (c)travel,(d) deposition, total
amount paid or owed to each expert at the time o f your response to this request.
ANSWER:
4. Number 1
If any person identified in response to Interrogatory above has submitted
a written report or opinion related to the subjectmatter of this case.
ANSWER:
5. As Number 1, pleasegive a
to each expert identified in response to Interrogatory
descriptionof your expert's general litigation
experience, including but not limited to the
percentage of work performed for plaintiffs
and for defendants.
ANSWER:
6. As to each expert identified in response to Interrogatory number 1, please state
whether the expert has ever been retained by Plaintiffs counsel (includingany law firm counsel
worked for)in the last five (5)years to provideexpert services or opinions.If so, as to each expert,
please state how many times and the total amount that has been paid to the expert.
ANSWER:
7. As to each expert identified in response to number 1, pleasestate
Interrogatories
how many times each expert has testified in the last five (5) years on behalf of Plaintiff/or
Plaintiff's counsel (includingany law firm counsel for Defendant worked for) by way of
affidavits,
interrogatories, or
deposition, at in court, and/or before an administrative body or
trial,
tribunal trial,
court.
ANSWER:
8. As to each expert identified in response to Interrogatorynumber 1, provide an
approximationofthe portionofthe expert'sinvolvement as an expert witness,which may be based
on the number ofhours, percentage ofhours or percentage of earned income derived from serving
as an expert witness.
ANSWER:
9. As to please state whether said
each expert designatedin these Interrogatories,
expert has ever had their testimony or opinion limited in any way by any judge, court, or
administrative body In providing this response, please specifythe specificcase or proceeding,
includingcase number, in which their testimony or opinionwas limited and specifythe nature and
extent of the limitation placed on said expert'stestimony or opinion
ANSWER:
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Filing# 151134993 E-Filed 06/08/2022 06:49:55 PM IN THE CIRCUITCOURT OF THE 17 7TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ALEJANDRA GOMEZ AND CHRISTOPHER CASE NO. CACE-21-007582 GOMEZ, Plaintiff. VS. SCOTTSDALE INSURANCE COMPANY, Defendant. i DEFENDANT'S NOTICE OF SERVICE OF EXPERT INTERROGATORIES Defendant, SCOTTSDALE INSURANCE COMPANY, hereby requests the Plaintiff, ALEJANDRA GOMEZ AND CHRISTOPHER GOMEZ answer under oath, in writing,the within the time prescribedin accordance with the Florida Rules of attached Expert Interrogatories Civil Procedure. CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoingdocument is being served on June 8,2022 via an automatic e-mail generatedby the Florida E-FilingPortal to all counsel of record. HINSHAW & CULBERTSON LLP /s/ Francesco J. Palanda Francesco Palanda, Esquire J. Florida Bar No. 809071 fpalanda@hinshawlaw.com ellampallas@hinshawlaw.com, ihodges@hinshawlaw.com th 2525 Ponce de Leon Boulevard, 4 Floor Coral Gables, Florida 33134 Telephone: (305) 358-7747 Facsimile: (305) 577-1063 COUNSEL FOR DEFENDANT *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/08/2022 06:49:54 PM.**** EXPERT INTERROGATORIES 1. Please state the name, profession,specialty,business address, and telephone number o f each person whom you as an expert witness at or your attorneys intend to call to testify the trial o f this matter. ANSWER: 2. For each expert identified in response to InterrogatoryNumber 1 above, state, in detail,the scope of his/her employment, includingbut not limited to, when they were retained,by whom they were retained,what they were provided when they were retained in relation to the subjectclaim, what they were requestedto do or what service they were requestedto provide,what documents or materials related to the subjectmatter of this case they were provided when they were retained,and the scope of their compensation for such service in this case. ANSWER: 3 Please state the hourly rate charged by the above-named expert for (a) services (e)trial,and (f)the rendered in this case; (b) review of material, (c)travel,(d) deposition, total amount paid or owed to each expert at the time o f your response to this request. ANSWER: 4. Number 1 If any person identified in response to Interrogatory above has submitted a written report or opinion related to the subjectmatter of this case. ANSWER: 5. As Number 1, pleasegive a to each expert identified in response to Interrogatory descriptionof your expert's general litigation experience, including but not limited to the percentage of work performed for plaintiffs and for defendants. ANSWER: 6. As to each expert identified in response to Interrogatory number 1, please state whether the expert has ever been retained by Plaintiffs counsel (includingany law firm counsel worked for)in the last five (5)years to provideexpert services or opinions.If so, as to each expert, please state how many times and the total amount that has been paid to the expert. ANSWER: 7. As to each expert identified in response to number 1, pleasestate Interrogatories how many times each expert has testified in the last five (5) years on behalf of Plaintiff/or Plaintiff's counsel (includingany law firm counsel for Defendant worked for) by way of affidavits, interrogatories, or deposition, at in court, and/or before an administrative body or trial, tribunal trial, court. ANSWER: 8. As to each expert identified in response to Interrogatorynumber 1, provide an approximationofthe portionofthe expert'sinvolvement as an expert witness,which may be based on the number ofhours, percentage ofhours or percentage of earned income derived from serving as an expert witness. ANSWER: 9. As to please state whether said each expert designatedin these Interrogatories, expert has ever had their testimony or opinion limited in any way by any judge, court, or administrative body In providing this response, please specifythe specificcase or proceeding, includingcase number, in which their testimony or opinionwas limited and specifythe nature and extent of the limitation placed on said expert'stestimony or opinion ANSWER: