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Filing# 163016647 E-Filed 12/14/2022 10:55:25 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
PLAINTIFF'S FIRST AMENDED EXHIBIT LIST
COMES NOW, the Plaintiff,EXPERT NETWORK, INC. (a/a/oJorge Baro Suarez),by
and through their undersigned counsel, and pursuant to the Court's Trial Order, hereby files their
First Amended Exhibit List and state as follows:
EXHIBIT LIST
1. All reports provided by Plaintiff' s expert: Synergyn, LLC.
2. All reports provided by Plaintiff' s expert Drakon Group
3 CorporateRepresentativeof Citizens Property Insurance Corporation.
4. Records Custodian of Citizens Property Insurance Corporation.
5. Citizens Property Insurance Corporation Field Adjuster, Santo Biddix's
photographs.
6. Public Adjuster, Louis Deslouches of Premiere Estimating and Appraisal
Consultants, LLC's photographs.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/14/2022 10:55:25 AM.****
7. Public Adjuster Louis Deslouches of Premiere Estimating and Appraisal
Consultants, LLC's estimate.
8 Public Adjuster Louis Deslouches of Premiere Estimating and Appraisal
Consultants,LLC's documents (emails,correspondence,
etc)to any party related to this loss/claim.
9. All correspondence from Plaintiff to any party related to this loss/claim.
10. All correspondence from Expert Network, Inc. to any party related to this
loss/claim.
11. Expert Network ProjectManagement Agreement.
12. iTest Environmental Testing & InspectionInvoice.
13. iTest Environmental Testing & Inspection'sEnvironmental Report.
14. iTest Environmental Testing & Inspection'sMold Laboratory Report.
15. iTest Environmental Testing& Inspection's
Invoice.
16. iTest Environmental Testing & InspectionFlorida Required Notice Agreement.
17. Plaintiff's Proof ofLoss.
18. Policy of Insurance pertaining
to this loss.
19. All documents produced by Defendant during the course of discovery.
20. All correspondencebetween Defendant and Plaintiff sent duringthe adjustmentof
the claim.
21. photographs, and invoices submitted on behalf of Plaintiff.
All repairestimate(s),
22. exhibits listed in Defendant's Exhibit List.
All non-objectionable
23. All Pleadingsin this matter.
24. All exhibits attached to any pleadingsin the instant matter.
25. All other written submissions filed in the instant action.
26. All Requests for Admissions and Responses to Requests for Admissions filed in
this matter.
27. and Answers to Interrogatories
All Interrogatories filed in this matter, including
any attachments to the Answers.
28. All Requests for Production and Responses to Requests for Production filed in this
matter, includingall responsivedocuments produced.
29. All documents received in response to any subpoena served in this matter.
30. for any depositionstaken in the instant case as well as the
All depositiontranscripts
exhibits attached thereto.
31. All documents or picturesrelied on by any of the experts in this case, regardlessof
which party named the expert.
32. Impeachment exhibits as necessary.
33. Rebuttal exhibits as necessary.
34. As discoveryis ongoing, Plaintiff reserves the rightto amend and/or supplement
this Exhibit List as warranted.
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 December 14, 2022 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.,
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
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Filing# 163016647 E-Filed 12/14/2022 10:55:25 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 PLAINTIFF'S FIRST AMENDED EXHIBIT LIST COMES NOW, the Plaintiff,EXPERT NETWORK, INC. (a/a/oJorge Baro Suarez),by and through their undersigned counsel, and pursuant to the Court's Trial Order, hereby files their First Amended Exhibit List and state as follows: EXHIBIT LIST 1. All reports provided by Plaintiff' s expert: Synergyn, LLC. 2. All reports provided by Plaintiff' s expert Drakon Group 3 CorporateRepresentativeof Citizens Property Insurance Corporation. 4. Records Custodian of Citizens Property Insurance Corporation. 5. Citizens Property Insurance Corporation Field Adjuster, Santo Biddix's photographs. 6. Public Adjuster, Louis Deslouches of Premiere Estimating and Appraisal Consultants, LLC's photographs. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/14/2022 10:55:25 AM.**** 7. Public Adjuster Louis Deslouches of Premiere Estimating and Appraisal Consultants, LLC's estimate. 8 Public Adjuster Louis Deslouches of Premiere Estimating and Appraisal Consultants,LLC's documents (emails,correspondence, etc)to any party related to this loss/claim. 9. All correspondence from Plaintiff to any party related to this loss/claim. 10. All correspondence from Expert Network, Inc. to any party related to this loss/claim. 11. Expert Network ProjectManagement Agreement. 12. iTest Environmental Testing & InspectionInvoice. 13. iTest Environmental Testing & Inspection'sEnvironmental Report. 14. iTest Environmental Testing & Inspection'sMold Laboratory Report. 15. iTest Environmental Testing& Inspection's Invoice. 16. iTest Environmental Testing & InspectionFlorida Required Notice Agreement. 17. Plaintiff's Proof ofLoss. 18. Policy of Insurance pertaining to this loss. 19. All documents produced by Defendant during the course of discovery. 20. All correspondencebetween Defendant and Plaintiff sent duringthe adjustmentof the claim. 21. photographs, and invoices submitted on behalf of Plaintiff. All repairestimate(s), 22. exhibits listed in Defendant's Exhibit List. All non-objectionable 23. All Pleadingsin this matter. 24. All exhibits attached to any pleadingsin the instant matter. 25. All other written submissions filed in the instant action. 26. All Requests for Admissions and Responses to Requests for Admissions filed in this matter. 27. and Answers to Interrogatories All Interrogatories filed in this matter, including any attachments to the Answers. 28. All Requests for Production and Responses to Requests for Production filed in this matter, includingall responsivedocuments produced. 29. All documents received in response to any subpoena served in this matter. 30. for any depositionstaken in the instant case as well as the All depositiontranscripts exhibits attached thereto. 31. All documents or picturesrelied on by any of the experts in this case, regardlessof which party named the expert. 32. Impeachment exhibits as necessary. 33. Rebuttal exhibits as necessary. 34. As discoveryis ongoing, Plaintiff reserves the rightto amend and/or supplement this Exhibit List as warranted. 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 December 14, 2022 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., 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