On April 09, 2021 a
Miscellaneous
was filed
involving a dispute between
Baro, Christie,
Baro, Zachary,
Suarez, Jorge Baro,
and
Citizens Property Insurance Corporation,
for 3
in the District Court of Broward County.
Preview
Filing# 166751857 E-Filed 02/14/2023 11:16:07 AM
TH
INTHE CIRCUIT COURT OF THE 17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA (22-443)
CIVIL DIVISION
CASE NO. CACE-21-007300 (21)
EXPERT NETWORK, INC. (a/a/oJorge Baro Suarez),
Plaintiff, Consolidated with
CACE-22-011832
V COCE-21-028858
CITIZENS PROPERTY INSURANCE CORPORATION,
Defendant.
i
NOTICE OF FILING PLAINTIFF'S AMENDED PROPOSED VERDICT FORM
COMES NOW, Plaintiff,EXPERT NETWORK, INC. (a/a/oJorge Baro Suarez),by and
through undersigned counsel, and hereby files Plaintiff's Amended Proposed Verdict Form.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that in accordance with the Supreme Court of Florida's
Administrative Order No. AOSC13-49, a true and correct copy of the foregoing has been filed
with the Florida Courts E-FilingPortal on February 14, 2023 and a copy of same will be sent
by the E-FilingPortal via E-Mail
directly to: PAULETTE RENEE FOUTS, ESQ., Vernis &
Bowling of Broward, P.A., Attorney for Defendant, 5812 Hollywood Boulevard, Hollywood, FL
33021. PFouts@Florida-Law.com; and AYost@Florida-Law.com and KARINA RIOS, ESQ.,
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/14/2023 11:16:06 AM.****
The Professional Law Group, PLLC, Attorneys for Plaintiffs,
Jorge Baro Suarez, Christie Baro
and Zachary Baro, 4600 Sheridan Street, Suite 303, Hollywood, FL 33021.
krios@theprolawgroup.com and karinaservice@theprolawgroup.com.
LAW OFFICE OF JOSE C. LEON PLLC
/s/Jose C. Leon, Esq.
Josd C. Ledn, Esq.
FBN: 125553
2915 Biscayne Boulevard, Suite 300
Miami, FL 33137-4197
Telephone: 305-300-2839
Email: jleon@jleonlaw.com
Email:
Attorneyfor Plaintiff
VERDICT FORM
WE, THE JURY RETURN THE FOLLOWING VERDICT:
1. Did windstorm contribute to causing an opening in the roof of the Plaintiff's
property to allow rain to enter the building?
YES NO
Ifyour answer to Question #1 is YES, then you proceed to Question # 2.
Ifyour answer to Question [t 1 is NO, then your verdict is in favor of DEFENDANT.
Proceed no furtherthan to sign and date this Verdict form and return it to the Courtroom.
2. Was it reasonable for the Insured to perform the environmental and mold
testingthat Plaintiff conducted?
Ifyour answer to Question # 2 is YES, then you proceed to Question # 3.
Ifyour answer to Question [t 2 is NO, then your verdict is in favor of DEFENDANT.
Proceed no furtherthan to sign and date this Verdict form and return it to the Courtroom.
3. How much are Plaintiff's services worth?
$
SO, SAY WE ALL this day of February,2023.
FOREPERSON (Signature)
Document Filed Date
February 14, 2023
Case Filing Date
April 09, 2021
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