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Filing# 158054135 E-Filed 09/23/2022 03:45:18 PM
IN THE CIRCUITCOURT OF THE 17
iTH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JERRY CANNIS AND
PEGGY CANNIS,
CASE NO.: CACE-21-016611 (09)
Plaintiffs,
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT'S NOTICE OF SERVING
EXPERT INTERROGATORIES TO PLAINTIFFS
Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY
pursuant to
("Universal"), Fla. R. Civ. P. 1.280, gives Notice of Serving its Expert Witness
JERRY
to Plaintiffs,
Interrogatories CANNIS AND PEGGY CANNIS to be answered under oath
within 30 days from date of service.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E-
Service to: Maximo A. Santiago, Esq., Ariana Rubio Di Natale, Esq., Robert Ibarra, Esq.,
Your Insurance Attorney, PLLC., (YIA3@Yourinsuranceattorney.com;
rd
on
eservice@yourinsuranceattomey.com) this 23 day of September, 2022.
Attorney M
Defendant
&
Universal Property Casualty Company
P.O. Box 9388
Fort Lauderdale, Florida 33309
Telephone: (954) 958-3319
Toll-Free: 1-833-658-8594 6Judges Only)
Facsimile: (954) 958-1262
By-. /s/ Jennifer Harley
Jennifer Harley, Esq.
Florida Bar No. 962821
For Service of Court Documents onlv:
Primary: upciceservice03(*universalproperty.com
Secondary: ci0419@universalproperty.com
Tertiary:jhl 130@universalproperty.com
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/23/2022 03:45:17 PM.****
Jerry Cannis, et at. vs. UPCIC
CASE NO.: CACE-21-016611 (09)
Page 2 of 9
EXPERT WITNESS INTERROGATORIES TO THE PLAINTIFFS
Pursuant to the Florida Rules of Civil Procedure, you are requiredto answer the following
expert interrogatories in writingand under oath within 30 days from the date of service hereof.
1. Please identifyeach person expected to be called by the Plaintiffs as an expert
witness at trial and with regard to each such expert, pleaseprovide the following information:
a. The full name and business address of the expert.
b. The field of expertiseof said expert.
C The subjectmatter on which the expert is expected to testify.
d. The substance of the facts and opinionsto which the expert is expected to testify.
e. A summary of the grounds for each opinion.
f. Please attach a current resume or curriculum vitae for each identified expert.
2. any expert named in the preceding interrogatorysubmitted any report,
If
memorandum, note or other such writing,pleasestate the name and address ofthe person to whom
the report or writingwas addressed or directed,and the present location of the originaland all
copies of such writing.
Jerry Cannis, et at. vs. UPCIC
CASE NO.: CACE-21-016611 (09)
Page 3 of 9
3 With regardto each expert whose name is given in response to any ofthe foregoing
and if this information is not included on the CV. or the CV is not attached,please
interrogatories
provide the followinginformation:
a. The formal education of said expert in his field of and
expertise in preparationfor
study in his/her field of expertise.
b. Other trainingof the said expert in his/her field of expertiseor related fields.
4. For each person listed in your answer to questionnumber one (1),pleasestate the
date the expert was hired, if applicable.
5. For each person listed in yours answer to questionnumber one (1),who has given
you any opinion,state who that opinionwas given to, when it was given,and whether it was written
or oral. If no opinion has been received from any person listed in your answer to interrogatory
number one (1),please state for each person when you expect to receive an opinion from that
person.
6. For each witness to any of the facts or circumstances surroundingthe loss that you
are currentlyaware of,please list their names, addresses and telephonenumbers, and whether they
are lay witnesses or professionals.If they are professionals,please list their professions.
Jerry Cannis, et at. vs. UPCIC
CASE NO.: CACE-21-016611 (09)
Page 4 of 9
7. If any witnesses to any of the facts or circumstances surrounding this accident and
lawsuit, and whom you are currentlyaware of,has any expertisethat may be relevant to the issues
of this lawsuit,pleaselist that witnesses name, current address, phone number, area o f expertise,
and subjectmatter about which they are expectedto testify.
8 Please state whether the above described expert witnesses have ever testified for
you or your attorneys in the last three (3)years and if so, pleasestate the following:
a. Circumstances for such testimony.
b. Date, styleof case, court and subjectmatter on which said expert witness testified.
9- Please state the names, business and residence addresses and business and residence
phone numbers of any expert witnesses who have been retained or speciallyemployed by you or
your attorneys in anticipation of preparationfor trial or who you have retained/employed but not
yet determined whether or not they will testify.
Jerry Cannis, et at. vs. UPCIC
CASE NO.: CACE-21-016611 (09)
Page 5 of 9
10. Please state the field of expertiseof any expert you have retained/employedin this
case to render opinions or as a consultant,regardlessof whether said person is expected to testify
at trial.
11. As to number one (1),pleaseprovide
experts listed in response to interrogatory
all
the followinginformation:
a. The scope of employment in the pending case and the compensation for such
service.
b. experience,including the percentage of work
The expert'sgeneral litigation
performed for Plaintiffs/Petitioner and Defendant/Respondent.
C The identityof other cases, within a reasonable time period in which the expert has
testified by depositionor at trial.
d. An approximationof the portionof the expert'sinvolvement as an expert witness,
which may be based on the number ofhours, percentage of hours, or percentage of
earned income derived from serving as an expert witness.
Jerry Cannis, et at. vs. UPCIC
CASE NO.: CACE-21-016611 (09)
Page 6 of 9
12. As to the individual who signed these answers to indicate the
interrogatories,
capacityin which he/she signed the same, where he/she obtained such information, whether he/she
will be a witness at trial and if so whether said person will be called upon to appear in court as a
representative of some firm, partnershipor corporationso as to be seated at counsel table during
the trial of this cause.
13. Please state the number oftimes your expert was deposed between January 1,2015
and the present.
14. For each matter in which your expert was deposed in response to Question No. 13,
and the name of the attorney who
pleaseidentifythe styleof the case, case number jurisdiction,
retained the expert.
15. number of times your expert appeared in court to testify
Please state the in the last
was called to testifyin more than one (1) courtroom on a
ten years. (In the event that your expert
particulardate, each time your expert testified should be counted separatelywhere your expert
appeared).
Jerry Cannis, et at. vs. UPCIC
CASE NO.: CACE-21-016611 (09)
Page 7 of 9
16. For each matter in which your expert testified in response to Question No. 15,
and the name of the attorney who
pleaseidentifythe styleof the case, case number jurisdiction,
retained the expert.
17. For each expert listed in number one (1)pleasestate:
response to interrogatory
a. The rate o f compensation for services provided by the expert;
b. The amount billed to date by the expert, and paid;
C The amount billed to date which remains unpaid;
d. The amount oftime for which the expert has worked, which has not yet been billed.
e. His/her fees for depositiontestimony,whether travel time is included, and whether
there is a minimum fee;and
f. His/her fees for trial testimony,whether travel time is included, and whether there
is a minimum fee.
Jerry Cannis, et at. vs. UPCIC
CASE NO.: CACE-21-016611 (09)
Page 8 of 9
JERRY CANNIS
STATE OF FLORIDA
S.S.)
COUNTY OF
BEFORE ME, the foregoing instrument was acknowledged by JERRY CANNIS who is
personallyknown to me or have produced identification in the form of and
who executed the foregoing instrument for the purposes therein expressed.
IN WITNESS WHEREOF, I have hereto set my hand and official seal this dayor
,2022.
SignatureofNotary Public
Name ofNotary Typed, Printed or Stamped
Commission Number
Jerry Cannis, et at. vs. UPCIC
CASE NO.: CACE-21-016611 (09)
Page 9 of 9
PEGGY CANNIS
STATE OF FLORIDA
S.S.)
COUNTY OF
BEFORE ME, the foregoinginstrument was acknowledged by PEGGY CANNIS who is
personallyknown to me or have produced identification in the form of and
who executed the foregoing instrument for the purposes therein expressed.
IN WITNESS WHEREOF, I have hereto set my hand and official seal this dayor
,2022.
SignatureofNotary Public
Name ofNotary Typed, Printed or Stamped
Commission Number
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Filing# 158054135 E-Filed 09/23/2022 03:45:18 PM IN THE CIRCUITCOURT OF THE 17 iTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JERRY CANNIS AND PEGGY CANNIS, CASE NO.: CACE-21-016611 (09) Plaintiffs, VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i DEFENDANT'S NOTICE OF SERVING EXPERT INTERROGATORIES TO PLAINTIFFS Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY pursuant to ("Universal"), Fla. R. Civ. P. 1.280, gives Notice of Serving its Expert Witness JERRY to Plaintiffs, Interrogatories CANNIS AND PEGGY CANNIS to be answered under oath within 30 days from date of service. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas furnished via E- Service to: Maximo A. Santiago, Esq., Ariana Rubio Di Natale, Esq., Robert Ibarra, Esq., Your Insurance Attorney, PLLC., (YIA3@Yourinsuranceattorney.com; rd on eservice@yourinsuranceattomey.com) this 23 day of September, 2022. Attorney M Defendant & Universal Property Casualty Company P.O. Box 9388 Fort Lauderdale, Florida 33309 Telephone: (954) 958-3319 Toll-Free: 1-833-658-8594 6Judges Only) Facsimile: (954) 958-1262 By-. /s/ Jennifer Harley Jennifer Harley, Esq. Florida Bar No. 962821 For Service of Court Documents onlv: Primary: upciceservice03(*universalproperty.com Secondary: ci0419@universalproperty.com Tertiary:jhl 130@universalproperty.com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/23/2022 03:45:17 PM.**** Jerry Cannis, et at. vs. UPCIC CASE NO.: CACE-21-016611 (09) Page 2 of 9 EXPERT WITNESS INTERROGATORIES TO THE PLAINTIFFS Pursuant to the Florida Rules of Civil Procedure, you are requiredto answer the following expert interrogatories in writingand under oath within 30 days from the date of service hereof. 1. Please identifyeach person expected to be called by the Plaintiffs as an expert witness at trial and with regard to each such expert, pleaseprovide the following information: a. The full name and business address of the expert. b. The field of expertiseof said expert. C The subjectmatter on which the expert is expected to testify. d. The substance of the facts and opinionsto which the expert is expected to testify. e. A summary of the grounds for each opinion. f. Please attach a current resume or curriculum vitae for each identified expert. 2. any expert named in the preceding interrogatorysubmitted any report, If memorandum, note or other such writing,pleasestate the name and address ofthe person to whom the report or writingwas addressed or directed,and the present location of the originaland all copies of such writing. Jerry Cannis, et at. vs. UPCIC CASE NO.: CACE-21-016611 (09) Page 3 of 9 3 With regardto each expert whose name is given in response to any ofthe foregoing and if this information is not included on the CV. or the CV is not attached,please interrogatories provide the followinginformation: a. The formal education of said expert in his field of and expertise in preparationfor study in his/her field of expertise. b. Other trainingof the said expert in his/her field of expertiseor related fields. 4. For each person listed in your answer to questionnumber one (1),pleasestate the date the expert was hired, if applicable. 5. For each person listed in yours answer to questionnumber one (1),who has given you any opinion,state who that opinionwas given to, when it was given,and whether it was written or oral. If no opinion has been received from any person listed in your answer to interrogatory number one (1),please state for each person when you expect to receive an opinion from that person. 6. For each witness to any of the facts or circumstances surroundingthe loss that you are currentlyaware of,please list their names, addresses and telephonenumbers, and whether they are lay witnesses or professionals.If they are professionals,please list their professions. Jerry Cannis, et at. vs. UPCIC CASE NO.: CACE-21-016611 (09) Page 4 of 9 7. If any witnesses to any of the facts or circumstances surrounding this accident and lawsuit, and whom you are currentlyaware of,has any expertisethat may be relevant to the issues of this lawsuit,pleaselist that witnesses name, current address, phone number, area o f expertise, and subjectmatter about which they are expectedto testify. 8 Please state whether the above described expert witnesses have ever testified for you or your attorneys in the last three (3)years and if so, pleasestate the following: a. Circumstances for such testimony. b. Date, styleof case, court and subjectmatter on which said expert witness testified. 9- Please state the names, business and residence addresses and business and residence phone numbers of any expert witnesses who have been retained or speciallyemployed by you or your attorneys in anticipation of preparationfor trial or who you have retained/employed but not yet determined whether or not they will testify. Jerry Cannis, et at. vs. UPCIC CASE NO.: CACE-21-016611 (09) Page 5 of 9 10. Please state the field of expertiseof any expert you have retained/employedin this case to render opinions or as a consultant,regardlessof whether said person is expected to testify at trial. 11. As to number one (1),pleaseprovide experts listed in response to interrogatory all the followinginformation: a. The scope of employment in the pending case and the compensation for such service. b. experience,including the percentage of work The expert'sgeneral litigation performed for Plaintiffs/Petitioner and Defendant/Respondent. C The identityof other cases, within a reasonable time period in which the expert has testified by depositionor at trial. d. An approximationof the portionof the expert'sinvolvement as an expert witness, which may be based on the number ofhours, percentage of hours, or percentage of earned income derived from serving as an expert witness. Jerry Cannis, et at. vs. UPCIC CASE NO.: CACE-21-016611 (09) Page 6 of 9 12. As to the individual who signed these answers to indicate the interrogatories, capacityin which he/she signed the same, where he/she obtained such information, whether he/she will be a witness at trial and if so whether said person will be called upon to appear in court as a representative of some firm, partnershipor corporationso as to be seated at counsel table during the trial of this cause. 13. Please state the number oftimes your expert was deposed between January 1,2015 and the present. 14. For each matter in which your expert was deposed in response to Question No. 13, and the name of the attorney who pleaseidentifythe styleof the case, case number jurisdiction, retained the expert. 15. number of times your expert appeared in court to testify Please state the in the last was called to testifyin more than one (1) courtroom on a ten years. (In the event that your expert particulardate, each time your expert testified should be counted separatelywhere your expert appeared). Jerry Cannis, et at. vs. UPCIC CASE NO.: CACE-21-016611 (09) Page 7 of 9 16. For each matter in which your expert testified in response to Question No. 15, and the name of the attorney who pleaseidentifythe styleof the case, case number jurisdiction, retained the expert. 17. For each expert listed in number one (1)pleasestate: response to interrogatory a. The rate o f compensation for services provided by the expert; b. The amount billed to date by the expert, and paid; C The amount billed to date which remains unpaid; d. The amount oftime for which the expert has worked, which has not yet been billed. e. His/her fees for depositiontestimony,whether travel time is included, and whether there is a minimum fee;and f. His/her fees for trial testimony,whether travel time is included, and whether there is a minimum fee. Jerry Cannis, et at. vs. UPCIC CASE NO.: CACE-21-016611 (09) Page 8 of 9 JERRY CANNIS STATE OF FLORIDA S.S.) COUNTY OF BEFORE ME, the foregoing instrument was acknowledged by JERRY CANNIS who is personallyknown to me or have produced identification in the form of and who executed the foregoing instrument for the purposes therein expressed. IN WITNESS WHEREOF, I have hereto set my hand and official seal this dayor ,2022. SignatureofNotary Public Name ofNotary Typed, Printed or Stamped Commission Number Jerry Cannis, et at. vs. UPCIC CASE NO.: CACE-21-016611 (09) Page 9 of 9 PEGGY CANNIS STATE OF FLORIDA S.S.) COUNTY OF BEFORE ME, the foregoinginstrument was acknowledged by PEGGY CANNIS who is personallyknown to me or have produced identification in the form of and who executed the foregoing instrument for the purposes therein expressed. IN WITNESS WHEREOF, I have hereto set my hand and official seal this dayor ,2022. SignatureofNotary Public Name ofNotary Typed, Printed or Stamped Commission Number