On September 24, 2022 a
Disclosure of Expert Witness
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# 176757429 E-Filed 07/05/2023 05:16:35 PM
INTHE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
SANDRA LOO
GUIFONG LOO, CASE NO.: CACE-22-014362
Plaintiffs,
VS.
UNIVERSAL PROPERTY &
CASUALTY INSURANCE COMPANY,
Defendant.
I
DEFENDANT, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY'S
PRELIMINARY EXPERT DISCLOSURE
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by
and through the undersigned counsel and hereby files the followingPreliminaryExpert Disclosure,
pursuant to the Court's Uniform Trial Order dated February 14, 2023.
EXPERT DISCLOSURE1
1. Robert A. Swift, P.E.
Rimkus ConsultingGroup, Inc.
6374 NW 97th Avenue
Doral, FL 33178
Defendant reserves the rightto call Mr. Swift as its expert witness at trial in this
matter. Mr. Swift is a licensed professionalengineer and is expected to testify
as an
expert concerning the issues of causation and damages related to the purported
property damage claim allegedin the Complaint in this matter. The substance of
the facts and opinions,and grounds for the opinions,include,but are not necessarily
limited to, whether Plaintiffs' allegeddamages were caused by the allegedcause of
lossduring the subjectpolicyperiod and whether the allegeddamages were caused
by excluded events and/or Plaintiffs' failure to protect and preserve the property at
and after the time of loss. Additionally,Mr. Swift is expected to providetestimony
concerning matters relatingto the amount and value of repair costs (ifany) in
connection with the allegedloss,the amount of time needed to complete repairs(if
1
This Expert Disclosure is submitted in accordance with the February 14, 2023, Uniform, Trial Order which contains
a Deadline for Expert Disclosure.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/05/2023 05:16:34 PM.****
Sandra Loo et al vs. UPCIC
CASE NO.: CACE-22-014362
Page 2
any) in connection with the allegedloss, industrystandards, and assessment of
Plaintiffs' claimed damages.
2. Any expert witnesses any disclosures, depositions, and/or discovery
identified in
responses and documents produced in this action.
responses, includinginterrogatory
3. Any impeachment and/or rebuttal expert witnesses permittedby the Court for good cause
or to prevent manifest injustice.
4. Any and all expert witnesses listed by Plaintiffs.
RESERVATION
Universal reserves the rightto seek leave to supplement and/or amend this expert witness
list as deemed necessary as discoveryin this matter is ongoing. Universal reserves the right
to call and/or challengeany witness subsequentlydisclosed by Plaintiffs after applicable
Court deadlines or for any other reason under the Florida Rules of Civil Procedure and
Florida law.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E-
Service to: Edward De La Osa, Esq., De La Osa Damages Lawyers, P.A.,
(eservice@ddlawvers.com; assist@ddlawvers.com) on the 5th day of July,2023.
AttorneyMDefendant
Universal Property & CasualtyIns. Co.
PO Box 9388
Fort Lauderdale, Florida 33310
Legal Assistant: 754-755-2472
Receptionist:954-958-3319
Toll Free: 1-833-658-8594 (JudgesOnly)
Facsimile: 954-958-1262
By-. /s/ Paola Dukes
Paola Dukes, Esq.
Florida Bar No. 84274
For Service of Court Documents Onlv:
Primary upciceserviceO1@universalproperty.com
Secondary: kg0222@universalproperty.com
Tertiary:
pd0614@universalproperty.com
For Scheduling Matters:
kg0222@universalproperty.com
Document Filed Date
July 05, 2023
Case Filing Date
September 24, 2022
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing# 176757429 E-Filed 07/05/2023 05:16:35 PM INTHE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA SANDRA LOO GUIFONG LOO, CASE NO.: CACE-22-014362 Plaintiffs, VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. I DEFENDANT, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY'S PRELIMINARY EXPERT DISCLOSURE Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by and through the undersigned counsel and hereby files the followingPreliminaryExpert Disclosure, pursuant to the Court's Uniform Trial Order dated February 14, 2023. EXPERT DISCLOSURE1 1. Robert A. Swift, P.E. Rimkus ConsultingGroup, Inc. 6374 NW 97th Avenue Doral, FL 33178 Defendant reserves the rightto call Mr. Swift as its expert witness at trial in this matter. Mr. Swift is a licensed professionalengineer and is expected to testify as an expert concerning the issues of causation and damages related to the purported property damage claim allegedin the Complaint in this matter. The substance of the facts and opinions,and grounds for the opinions,include,but are not necessarily limited to, whether Plaintiffs' allegeddamages were caused by the allegedcause of lossduring the subjectpolicyperiod and whether the allegeddamages were caused by excluded events and/or Plaintiffs' failure to protect and preserve the property at and after the time of loss. Additionally,Mr. Swift is expected to providetestimony concerning matters relatingto the amount and value of repair costs (ifany) in connection with the allegedloss,the amount of time needed to complete repairs(if 1 This Expert Disclosure is submitted in accordance with the February 14, 2023, Uniform, Trial Order which contains a Deadline for Expert Disclosure. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/05/2023 05:16:34 PM.**** Sandra Loo et al vs. UPCIC CASE NO.: CACE-22-014362 Page 2 any) in connection with the allegedloss, industrystandards, and assessment of Plaintiffs' claimed damages. 2. Any expert witnesses any disclosures, depositions, and/or discovery identified in responses and documents produced in this action. responses, includinginterrogatory 3. Any impeachment and/or rebuttal expert witnesses permittedby the Court for good cause or to prevent manifest injustice. 4. Any and all expert witnesses listed by Plaintiffs. RESERVATION Universal reserves the rightto seek leave to supplement and/or amend this expert witness list as deemed necessary as discoveryin this matter is ongoing. Universal reserves the right to call and/or challengeany witness subsequentlydisclosed by Plaintiffs after applicable Court deadlines or for any other reason under the Florida Rules of Civil Procedure and Florida law. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E- Service to: Edward De La Osa, Esq., De La Osa Damages Lawyers, P.A., (eservice@ddlawvers.com; assist@ddlawvers.com) on the 5th day of July,2023. AttorneyMDefendant Universal Property & CasualtyIns. Co. PO Box 9388 Fort Lauderdale, Florida 33310 Legal Assistant: 754-755-2472 Receptionist:954-958-3319 Toll Free: 1-833-658-8594 (JudgesOnly) Facsimile: 954-958-1262 By-. /s/ Paola Dukes Paola Dukes, Esq. Florida Bar No. 84274 For Service of Court Documents Onlv: Primary upciceserviceO1@universalproperty.com Secondary: kg0222@universalproperty.com Tertiary: pd0614@universalproperty.com For Scheduling Matters: kg0222@universalproperty.com