On September 24, 2022 a
Witness & Exhibit List
was filed
involving a dispute between
Loo, Guifong,
Loo, Sandra,
Sandra And Guifong Loo,,
and
Universal Property & Casualty Insurance Company,
for 3
in the District Court of Broward County.
Preview
Filing# 176740700 E-Filed 07/05/2023 03:39:27 PM
IN THE CIRCUITCOURT OF THE 17'TH
i
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
SANDRA AND GUIFONG LOO, CASE NO.: CACE-22-014362
Plaintiffs,
V
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
PLAINTIFFS' WITNESS AND EXHIBIT LIST
Plaintiff,SANDRA LOO and GUIFONG LOO or "Insureds"),by and
("Plaintiffs"
through undersigned counsel, pursuant to the Uniform Order SettingCause for Jury Trial,Pre-
Trial Conference, and Pre-Trial Instructions,
submit the following:
I. WITNESSES PLAINTIFFS EXPECT TO CALL AT TRIAL
i. Fact Witnesses:
1. Sandra Loo and Guifong Loo
c/o De Osa Damage Lawyers P.A.
la
7550 S Red Road Suite 208
Miami, FL 33143
2. Person with the most knowledge/Records Custodian/and/or
Corporate Representative
MG4 Services LLC
2780 NE 183rd ST
Aventura, FL 33160
3. Person with the most knowledge/Records Custodian/and/or
Corporate Representative
FirstClaim
2500 NW
79th Ave
Doral, Fl 33122
4. Corporate representativeof Defendant regarding the claim and
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/05/2023 03:39:27 PM.****
incident allegedwithin Plaintiffs' Complaint
5. Corporate representativeof Defendant regarding the Plaintiffs'
underwritingfile materials
6. All witnesses for impeachment or rebuttal purposes.
7. All witnesses on Defendant's Witness List.
8. All witnesses, includingexperts, discovered between now and trial.
9. Plaintiffs reserve the rightto supplement and/or amend her witness
list with reasonable notice to Defendant.
ii. Expert Witnesses:
1. Eduard C. Badiu
CEBB Engineering& TestingCo.
7450 Griffin Road, Suite 140
Ft. Lauderdale, FL 33314
Mr. Eduard C. Badiu a licensed professionalengineer and general contractor. He is
is
expected to testifyin regards to his evaluation and inspectionof the damage to the Insureds'
property. He is expected to testify in regardsto his evaluation and inspectionof the damage to
the Insureds' property, as well as to any opinionshe may have formulated while conducting his
investigation. Mr. Badiu will testifyregarding causation of the damages. His opinions may also
be based on his review of various documents, includingbut not limited to, property renovation
documents, photographic evidence, depositiontestimony, research, literature, and his own
experienceand training.
2. Danny Bello
10689 NW 123 Street Road
Medley, Florida 33178
305-962-6363
Mr. Bello is a licensed General Contractor in the State of Florida. He
expected to
is
in
testify regardsto his evaluationand inspectionof the damage to the Insureds' property. He
is also expected to testify in regardsto the estimate prepared relating to the damage to the
Insureds' home. A copy of Mr. Bello's report and/or estimate will be provided to Counsel if
one is created and a copy has not been previouslyprovided.
3. Any and all expert witnesses listed by Defendant in its Expert
Witness List.
4. Plaintiffs reserve the rightto objectto any and all expert witnesses
listed by Defendant.
II. EXHIBITS TO BE USED AT TRIAL:
1. Composite: Any and all documents produced or obtained
duringdiscoveryin this matter.
2. Defendant's responses to Plaintiffs' interrogatories.
3. Defendant's responses to Plaintiffs' Request for Production.
4. Any all photographs, reports, statements or written opinions
which may be preparedby First Claim.
5. Any all photographs, reports, statements or written opinions
which may be prepared by Danny Bello.
6. Any and all photographs,reports, statements or written opinions
which may be prepared by Eduard C. Badiu and/or CEBB
Engineering & TestingCo.
7. Any architectural floor plansfor the subjectproperty.
8. Any and all permits and permit applicationsfor any renovations
performed to the subjectproperty.
9. Any documents related to the renovations performed to the
subjectproperty.
10. Any photographs or videos related to the renovations performed
to the subjectproperty.
11. Any photographs or videos taken by the Insured, her agents or
in connection with the instant claim for damage.
representatives
12. Any and all inspectionreports performed on the subjectproperty
before Defendant agreed to insure the property.
13. Any and all insurance applicationssubmitted before Defendant
agreed to insure the property.
14. Any and all photographs or videos contained within Defendant's
underwritingfile materials before it agreed to insure the property.
15. Any and all underwriting file materials submitted before
Defendant agreedto insure the property
16. All documents designatedon Defendant's Exhibit List.
17. Impeachment and Rebuttal Exhibits.
18. Plaintiffs reserve the right to supplement and/or amend this
Exhibit List with reasonable notice to Defendant.
Plaintiffs reserve the right to call and/or produce any and all witnesses and or
documentary evidence listed to any and
by the parties, all impeachment and/or rebuttal witnesses
and exhibits necessary, and to call and/or produce any and all newly discovered witnesses and/or
documentary evidence upon notice to the parties.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas served on
counsel o f record for De fendant via the Florida E-FilingPortal on this 5tb day of July 2023.
DE PRADO IDE LA OSA
7550 South Red Road Suite 208
Miami, Florida 33143
Phone No.: (786) 977-5802
Email: eservice@ddlawyers.com
Secondary Email: paralegall@ddlawyers.com
By: /sl Edward de la Osa
Edward De La Osa, Esq.
Florida Bar No. 1010022
Document Filed Date
July 05, 2023
Case Filing Date
September 24, 2022
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Filing# 176740700 E-Filed 07/05/2023 03:39:27 PM IN THE CIRCUITCOURT OF THE 17'TH i JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION SANDRA AND GUIFONG LOO, CASE NO.: CACE-22-014362 Plaintiffs, V UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i PLAINTIFFS' WITNESS AND EXHIBIT LIST Plaintiff,SANDRA LOO and GUIFONG LOO or "Insureds"),by and ("Plaintiffs" through undersigned counsel, pursuant to the Uniform Order SettingCause for Jury Trial,Pre- Trial Conference, and Pre-Trial Instructions, submit the following: I. WITNESSES PLAINTIFFS EXPECT TO CALL AT TRIAL i. Fact Witnesses: 1. Sandra Loo and Guifong Loo c/o De Osa Damage Lawyers P.A. la 7550 S Red Road Suite 208 Miami, FL 33143 2. Person with the most knowledge/Records Custodian/and/or Corporate Representative MG4 Services LLC 2780 NE 183rd ST Aventura, FL 33160 3. Person with the most knowledge/Records Custodian/and/or Corporate Representative FirstClaim 2500 NW 79th Ave Doral, Fl 33122 4. Corporate representativeof Defendant regarding the claim and *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/05/2023 03:39:27 PM.**** incident allegedwithin Plaintiffs' Complaint 5. Corporate representativeof Defendant regarding the Plaintiffs' underwritingfile materials 6. All witnesses for impeachment or rebuttal purposes. 7. All witnesses on Defendant's Witness List. 8. All witnesses, includingexperts, discovered between now and trial. 9. Plaintiffs reserve the rightto supplement and/or amend her witness list with reasonable notice to Defendant. ii. Expert Witnesses: 1. Eduard C. Badiu CEBB Engineering& TestingCo. 7450 Griffin Road, Suite 140 Ft. Lauderdale, FL 33314 Mr. Eduard C. Badiu a licensed professionalengineer and general contractor. He is is expected to testifyin regards to his evaluation and inspectionof the damage to the Insureds' property. He is expected to testify in regardsto his evaluation and inspectionof the damage to the Insureds' property, as well as to any opinionshe may have formulated while conducting his investigation. Mr. Badiu will testifyregarding causation of the damages. His opinions may also be based on his review of various documents, includingbut not limited to, property renovation documents, photographic evidence, depositiontestimony, research, literature, and his own experienceand training. 2. Danny Bello 10689 NW 123 Street Road Medley, Florida 33178 305-962-6363 Mr. Bello is a licensed General Contractor in the State of Florida. He expected to is in testify regardsto his evaluationand inspectionof the damage to the Insureds' property. He is also expected to testify in regardsto the estimate prepared relating to the damage to the Insureds' home. A copy of Mr. Bello's report and/or estimate will be provided to Counsel if one is created and a copy has not been previouslyprovided. 3. Any and all expert witnesses listed by Defendant in its Expert Witness List. 4. Plaintiffs reserve the rightto objectto any and all expert witnesses listed by Defendant. II. EXHIBITS TO BE USED AT TRIAL: 1. Composite: Any and all documents produced or obtained duringdiscoveryin this matter. 2. Defendant's responses to Plaintiffs' interrogatories. 3. Defendant's responses to Plaintiffs' Request for Production. 4. Any all photographs, reports, statements or written opinions which may be preparedby First Claim. 5. Any all photographs, reports, statements or written opinions which may be prepared by Danny Bello. 6. Any and all photographs,reports, statements or written opinions which may be prepared by Eduard C. Badiu and/or CEBB Engineering & TestingCo. 7. Any architectural floor plansfor the subjectproperty. 8. Any and all permits and permit applicationsfor any renovations performed to the subjectproperty. 9. Any documents related to the renovations performed to the subjectproperty. 10. Any photographs or videos related to the renovations performed to the subjectproperty. 11. Any photographs or videos taken by the Insured, her agents or in connection with the instant claim for damage. representatives 12. Any and all inspectionreports performed on the subjectproperty before Defendant agreed to insure the property. 13. Any and all insurance applicationssubmitted before Defendant agreed to insure the property. 14. Any and all photographs or videos contained within Defendant's underwritingfile materials before it agreed to insure the property. 15. Any and all underwriting file materials submitted before Defendant agreedto insure the property 16. All documents designatedon Defendant's Exhibit List. 17. Impeachment and Rebuttal Exhibits. 18. Plaintiffs reserve the right to supplement and/or amend this Exhibit List with reasonable notice to Defendant. Plaintiffs reserve the right to call and/or produce any and all witnesses and or documentary evidence listed to any and by the parties, all impeachment and/or rebuttal witnesses and exhibits necessary, and to call and/or produce any and all newly discovered witnesses and/or documentary evidence upon notice to the parties. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas served on counsel o f record for De fendant via the Florida E-FilingPortal on this 5tb day of July 2023. DE PRADO IDE LA OSA 7550 South Red Road Suite 208 Miami, Florida 33143 Phone No.: (786) 977-5802 Email: eservice@ddlawyers.com Secondary Email: paralegall@ddlawyers.com By: /sl Edward de la Osa Edward De La Osa, Esq. Florida Bar No. 1010022