Preview
Filing# 165428220 E-Filed 01/25/2023 11:56:40 AM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE-21-007806
CAROL PICKERING AND JEFFREY
PICKERING,
Plaintiff,
VS.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
AMENDED JOINT PRE-TRIAL STIPULATION
(Amended as to E-Signature for Plaintiff's Counsel Only)
The pursuant to the Court's Uniform
Parties hereby file their Joint Pretrial Stipulation
Pretrial Order and state as follows:
1. Statement of the Facts: This case arises from a contractual dispute between
Plaintiffs and Defendant for purported damages to Plaintiffs Property allegedlycaused by a
windstorm on September 10, 2017.
2. Stipulated Facts:
a) That this Court has jurisdiction.
b) That venue is proper.
c) That the insurance policy between the parties was in effect on the date of the
alleged loss.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/25/2023 11:56:40 AM.****
3. Statements of Disputed Law & Fact:
a) The extent and nature of the alleged damages.
b) Whether Plaintiffs' claim is excluded from coverage for a failure to comply with
their Duties After a Loss and the prejudice caused to Defendant by the late notice of the
claim.
c) Whether Plaintiffs claim is excluded from coverage as Defendant does not
insure for loss caused by wear and tear and deterioration.
d) Whether the Defendant breached the insurance policy.
e) Whether Plaintiff failed to fulfilltheir obligations under the policy,relieving
Defendant of any of its obligationsunder the policyas set forth in their affirmative defenses.
4- Exhibit Lists:
a) The Plaintiffs exhibit listis attached as Exhibit A.
b) The Defendant's exhibit list is attached as Exhibit B.
5- Witness List:
a) The Plaintiffs witness listis attached as Exhibit A.
b) The Defendant's witness listis attached as Exhibit B.
6. Jury Instructions:
Proposed Jury Instructions are still being discussed by the parties and will be
submitted shortly under separate cover.
7- Verdict Form:
The proposed verdict form is stillbeing discussed by the partiesand will be submitted shortly
under separate cover.
8- Peremptory Challenges:
Three (3) for each side.
9- Pending Motions:
Defendant's Motion to Strike Plaintiffs' experts,
Defendant's Motion to Compel Mediation,
Defendant's Motion for Final Summary Judgment
10. Trial Estimate:
Three (3) to Four (4) days.
DATED this 25th day of January, 2023.
YOUR INSURANCE ATTORNEY, PLLC PETERSON BERNARD
Attorneys for Plaintiffs Attorneys for Defendant
2601 South Bayshore Drive 707 S.E. 3rd Avenue, Suite 500
18th Floor Fort Lauderdale, FL 33316
Coconut Grove, FL 33133 (954) 763-3200
(888) 570-5677 hollv.miller@petersonbernard.com
Yia3@via.com d iane. nielsen@peterson bernard.com
eservice@vourinsuranceattornev.com
By /s/ Jonathan J. Manov
n A.i
Jonathan J. Manoy Holly K. Miller
Florida Bar #1024808 Florida Bar #40185
HKM/dn
123.36265
Filing# 153220146 E-Filed 07/13/2022 09:35:04 AM
EXHIBIT "A
',
IN THE CIRCUIT COURT FOR THE ,TH
17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CAROL PICKERING AND CASE NO. CACE-21-007806
JEFFREY PICKERING,
Plaintiffs,
V
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
PLAINTIFF'S WITNESS AND EXHIBIT LIST
CAROL
Plaintiff, PICKERING AND JEFFREY PICKERING, by and throughundersigned
counsel, pursuant to the Uniform Order SettingCause for Jury Trial,Mediation, and Pre-Trial
submits the following:
Instructions,
I. WITNESSES PLAINTIFF EXPECTS TO CALL AT TRIAL
i. Fact Witnesses:
1. Carol Pickering
CO Your Insurance Attorney,PLLC
2601 S. Bayshore Drive, 18th Floor
Coconut Grove, FL 33133
2. JeffreyPickering
CO Your Insurance Attorney,PLLC
2601 S. Bayshore Drive, 18th Floor
Coconut Grove, FL 33133
3. / Records Custodian
Corporate representative / PMWK
Pelican Property Solutions,Inc.
210 Oregon Lane
Boca Raton, FL 33487
4. / Records Custodian
Corporate representative / PMWK
Truview Mold LLC
7990 SW 117 Ave. Suite 204
Miami, FL 33183
5. / Records Custodian
Corporate representative / PMWK
InspectorLab
3301 NW 55th St
Ft. Lauderdale, FL 33309
6. / Records Custodian
Corporate representative / PMWK
Dri-Max Restoration
8306 Mills Dr Suite 113
Miami, FL 33183
7. / Records Custodian
Corporate representative / PMWK
Restoration Doctor, LLC.
2097 S Sheridan Street
Fort Lauderdale, FL 33332
8. Corporate representative ofDefendant regardingthe claim and incident alleged
within Plaintiff' s Complaint.
9. of Defendant regardingthe
Corporaterepresentative Plaintiff's underwriting
file materials.
10. Field Adjuster of Defendant regardingthe claim and incident allegedwithin
Plaintiff' s Complaint.
11. Desk Adjusterof Defendant regardingthe claim and incident allegedwithin
Plaintiff' s Complaint.
12. All witnesses for impeachment or rebuttal purposes.
13. All witnesses on Defendant's Witness List.
14. All witnesses,includingexperts, discovered between now and trial.
15. Plaintiff reserves the rightto supplement and/or amend its witness list with
reasonable notice to Defendant.
ii. Expert Witnesses:
1. Don Wilcox
Pelican Property Solutions
2650 NW 1 st Ave., Suite 9
Boca Raton, FL 33431
Mr. Wilcoxa licensed Insurance Adjuster in the State of Florida. He is expected to
is
testifyregarding his evaluation and inspectionof the damage to the insured's property. He is
further expected to testifyregardingthe estimate prepared and photographs captured,relating to
the damage to the insured' s home and the extent of repairs necessary to restore the property to
its pre-losscondition.
2. Jose F. Uz.
Caribbean Inspectors & Consultants, Inc.
14411 Commerce Way, No. 320
Miami Lakes, FL 33016
Mr. Uz is holding multiple licenses and
a professionalexpert forensic inspector/analyst
certifications related to buildinginspections, mold, wood destroyingorganisms, and roofing,
among various other concentrations. He is expected to testify in regardsto his evaluation and
inspection of the damage to the Insureds' property, as well as to any opinionshe may have
formulated while conducting his investigation. Mr. Uz will testify regarding causation of the
damages and any mold testingand remediation that was performed. Mr. Uz's opinions may also
be based on his review of photographic evidence, depositiontestimony,research,literature, and
his own experience and training. Mr. Uz will also testifyto everything contained in his expert
report, if one is prepared.A copy ofMr. Uz's report will be providedto counsel if one is prepared
after Mr. Uz inspectsthe property.
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:
3. Composite: Any and all documents produced or obtained during discoveryin
this matter.
4. Defendant's responses to Plaintiff' s interrogatories.
5. Defendant's responses to Plaintiff' s Request for Production.
6. Any all reports, estimates,invoices,photographs,videos, statements or
written opinionswhich may be preparedby Pelican Property Solutions,Inc.
7. Any all reports, estimates,invoices,photographs,videos, statements or
written opinionswhich may be prepared by Truview Mold, LLC.
8 Any all reports, estimates,invoices,photographs,videos, statements or
written opinionswhich may be prepared by Inspector Lab
9- Any all reports, estimates,invoices,photographs,videos, statements or
written opinionswhich may be prepared by Dri-Max Restoration
10. Any all reports, estimates,invoices,photographs,videos, statements or
written opinionswhich may be preparedby Restoration Doctor, LLC.
11. Any all reports, estimates,invoices,photographs,videos, statements or written
opinionswhich may be preparedby Caribbean Inspectors & Consultants,Inc.
12. Any photographs taken by the Insured, their agents, or representativesin
connection with the instant claim for damage.
13. Any and all inspection reports performed on the subject property before
Defendant agreed to insure the property.
14. Any and all submitted before Defendant agreed to insure
insurance applications
the property.
15. Any and all photographs or videos contained within Defendant's underwriting
file materials before it agreed to insure the property.
16. Any and all underwritingfile materials submitted before Defendant agreed to
insure the property.
17. All documents designatedon Defendant's Exhibit List.
18. Impeachment and Rebuttal Exhibits.
19. Plaintiff reserves the rightto 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 of record for Defendant via the Florida E-FilingPortal on this 13th day of July,2022.
Your Insurance Attorney, PLLC.
2601 South Bayshore Drive 18th Floor
Coconut Grove, FL 33133
Phone No.: 1-888-570-5677
Fax: 1-888-745-5677
Email:YIA3@Yourinsuranceattorney.com
Secondary Email: Eservice@Yourinsuranceattomey.com
By: Maximo A. Santiago
/s/
Maximo A. Santiago,Esq.
Florida Bar No. 669733
Ariana Rubio Di Natale, Esq.
Florida Bar No. 1025882
Filing# 159155630 E-Filed 10/13/2022 11:09:17 AM
EXHIBIT "B
',
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE-21-007806
CAROL PICKERING AND JEFFREY
PICKERING,
Plaintiffs,
VS.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
DEFENDANT'S DISCLOSURE OF FACT WITNESSES
COMES NOW, the Defendant UNITED PROPERTY & CASUALTY INSURANCE
COMPANY ("UNITED"), pursuant to this Court's Uniform Trial Order, and files its
Disclosure of Fact Witnesses as follows:
FACT WITNESSES
1. All partiesto this action or legalrepresentative.
2. Jeffrey Pickering
c/o Plaintiffs' counsel
3. Carol Pickering
c/o Plaintiffs' counsel
4. Records Custodian/Corporate Representative/PWMK
Pelican Property Solutions, Inc.
210 Oregon Lane
Boca Raton, FL 33487
5. Records Custodian/Corporate Representative/PWMK from
Dri-Max Restoration
8603 Mills Drive, Suite 113
6. Records Custodian/Corporate Representative/PWMK from
Restoration Doctor, LLC
2097 S. Sheridan Street
Fort Lauderdale, FL 33332
7. Records Custodian/Corporate Representative/PWMK from
Truview Mold, LLC
7990 SW 117th Avenue, Suite 204
Miami, FL 33183
8. Records Custodian/Corporate Representative/PWMK from
Inspector Lab
3301 NW 55th Street
Fort Lauderdale, FL 33309
9. Records Custodian/Corporate Representative/PWMK from
King Cobra Plumbing
10. Records Custodian/Corporate Representative/PWMK from
Mold Man of South Florida, LLC
11. EM P Restoration
P.O.BOX 970760
Coconut Creek, FL 33097
12.Sheldon Wright, Field Adjuster
United Property &
Casualty Insurance Company
do undersigned counsel
13. Corporate Representative
United Property & Casualty Insurance Company
do undersigned counsel
14.All persons noticed for deposition.
15. Representatives of all entities subpoenaed and/or noticed for deposition in this
matter.
16.All persons necessary to authenticate or render United's exhibits admissible as
offered by United at trial.
17.All persons who have been identified in Answers to Interrogatories,
Responses
to Request for Production and/or any other discovery produced in this matter.
18. Records Custodians of Broward County Building Department/ Permit Division
19. Records Custodians of Pembroke Pines Building Department/ Permit Division
20.Any and all witnesses for the purpose of impeachment and/or rebuttal.
21. Records Custodian of Towngate and/or any Property Management Company
22. Defendant reserves the rightto supplement and/or amend this list as discovery
is ongoing.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was filed via
the Florida Court E-Filing Portal pursuant to Rule 2.516 Fla. R. Jud. Admin Upon Maximo
A. Santiago, YIA3@vourinsuranceattornev.comi eservice@vourinsurance attorney.com
Your Insurance Attorney, PLLC., and All Counsel of Record 2601 South Bayshore Drive,
18th Floor, Coconut Grove, FL 33133, this 13th day of October, 2022.
By /s/ Hollv K .Miller
HOLLY K. MILLER
Florida Bar # 40185
PETERSON BERNARD
Attorneys for Defendant
707 S.E. 3rd Avenue, Suite 500
33316
Fort Lauderdale, Florida
(954) 763-3200
(954) 728-9019 facsimile
hollv.miller@petersonbernard.com
diane. nielsen@petersonbernard.com
HKM/dn
123.36265
Filing# 161450905 E-Filed 11/17/2022 01:59:06 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE-21-007806
CAROL PICKERING AND JEFFREY
PICKERING,
Plaintiffs,
VS.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
DEFENDANT'S EXHIBIT LIST
COMES NOW, Defendant, UNITED PROPERTY & CASUALTY INSURANCE
COMPANY, by and through its undersigned counsel and pursuant to this Honorable Court's
Uniform Order settingTrial,and hereby files its Exhibit List as follows:
1. A Certified Copy of UNITED PROPERTY & CASUALTY INSURANCE COMPANY'S,
Policy of Insurance issued to Plaintiffs;
2. All Answers to Interrogatories(includingany and all amendments to same);
3. All Responses to Request for Production (includingany and all amendments to same);
4. Any and all records, documents, reports,and/or correspondence produced through
discovery;
5. All records subpoenaed in this cause and/or produced during discovery;
6. Any and all correspondence between UNITED PROPERTY & CASUALTY
INSURANCE COMPANY, and the Plaintiffs and/or their agents and/or representatives;
7. All photographs produced during discovery;
8. Any and all documents identified during depositions taken in this cause;
9. All depositions taken in this matter and any and all exhibits attached thereto;
10. Any and all records from the Broward County BuildingDivision,includingall permits on
the property;
11. All photographs taken by Field Adjuster;
12. Any and all Geomni Photographs of the property;
13. Any and all Eagleview Photographs of the property;
14. Any and all Notices of Commencement and/or inspection reports for the subject
property;
15. Any and all Recorded Statements of Plaintiffs
16. Documents produced by the Plaintiffs in response to any and all Requests for
Production;
17. Documents produced by Defendant in response to all Requests for Production;
18. Photographs of the subject property taken by the Defendant, its agents, employees,
and/or Field Adjuster;
19. All correspondence and/or documents exchanged between the Defendant, the
and/or their agents or representatives relatingto the subject incident;
Plaintiffs,
20. Demonstrative exhibits to be prepared for trial;
21. Any and all documents relied upon by Defendant's experts in formulating any opinions
in this cause;
22. All records, photographs, source materials,buildingcodes, standards, reports,studies,
together with any other documents reviewed or relied upon by Defendant's expert in
formulating any opinions in this matter;
23. Any and all documents to be utilized for the purposed of impeachment and rebuttal;
24. Any and all photographs, video, film,slides, graphs, charts, and other documentary
evidence of the subject property;
25. Any and all records received in response to subpoenas duces tecum;
26. Defendant reserves its rightto supplement and/or amend its Exhibit List as discovery
in this cause is ongoing.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was filed via
the Florida Court E-FilingPortal pursuant to Rule 2.516 Fla. R. Jud. Admin Upon Maximo
A. Santiago, YIA3@vourinsuranceattornev.comi eservice@vourinsurance attorney.com
Your Insurance Attorney, PLLC., and All Counsel of Record 2601 South Bayshore Drive,
18th Floor, Coconut Grove, FL 33133, this 17th day of November, 2022.
By /s/ Holly K .Miller
HOLLY K. MILLER
Florida Bar # 40185
PETERSON BERNARD
Attorneys for Defendant
707 S.E. 3rd Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
hollv.miller@petersonbernard.com
diane. nielsen@petersonbernard.com
HKM/dn
123.36265
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Filing# 165428220 E-Filed 01/25/2023 11:56:40 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE-21-007806 CAROL PICKERING AND JEFFREY PICKERING, Plaintiff, VS. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. AMENDED JOINT PRE-TRIAL STIPULATION (Amended as to E-Signature for Plaintiff's Counsel Only) The pursuant to the Court's Uniform Parties hereby file their Joint Pretrial Stipulation Pretrial Order and state as follows: 1. Statement of the Facts: This case arises from a contractual dispute between Plaintiffs and Defendant for purported damages to Plaintiffs Property allegedlycaused by a windstorm on September 10, 2017. 2. Stipulated Facts: a) That this Court has jurisdiction. b) That venue is proper. c) That the insurance policy between the parties was in effect on the date of the alleged loss. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/25/2023 11:56:40 AM.**** 3. Statements of Disputed Law & Fact: a) The extent and nature of the alleged damages. b) Whether Plaintiffs' claim is excluded from coverage for a failure to comply with their Duties After a Loss and the prejudice caused to Defendant by the late notice of the claim. c) Whether Plaintiffs claim is excluded from coverage as Defendant does not insure for loss caused by wear and tear and deterioration. d) Whether the Defendant breached the insurance policy. e) Whether Plaintiff failed to fulfilltheir obligations under the policy,relieving Defendant of any of its obligationsunder the policyas set forth in their affirmative defenses. 4- Exhibit Lists: a) The Plaintiffs exhibit listis attached as Exhibit A. b) The Defendant's exhibit list is attached as Exhibit B. 5- Witness List: a) The Plaintiffs witness listis attached as Exhibit A. b) The Defendant's witness listis attached as Exhibit B. 6. Jury Instructions: Proposed Jury Instructions are still being discussed by the parties and will be submitted shortly under separate cover. 7- Verdict Form: The proposed verdict form is stillbeing discussed by the partiesand will be submitted shortly under separate cover. 8- Peremptory Challenges: Three (3) for each side. 9- Pending Motions: Defendant's Motion to Strike Plaintiffs' experts, Defendant's Motion to Compel Mediation, Defendant's Motion for Final Summary Judgment 10. Trial Estimate: Three (3) to Four (4) days. DATED this 25th day of January, 2023. YOUR INSURANCE ATTORNEY, PLLC PETERSON BERNARD Attorneys for Plaintiffs Attorneys for Defendant 2601 South Bayshore Drive 707 S.E. 3rd Avenue, Suite 500 18th Floor Fort Lauderdale, FL 33316 Coconut Grove, FL 33133 (954) 763-3200 (888) 570-5677 hollv.miller@petersonbernard.com Yia3@via.com d iane. nielsen@peterson bernard.com eservice@vourinsuranceattornev.com By /s/ Jonathan J. Manov n A.i Jonathan J. Manoy Holly K. Miller Florida Bar #1024808 Florida Bar #40185 HKM/dn 123.36265 Filing# 153220146 E-Filed 07/13/2022 09:35:04 AM EXHIBIT "A ', IN THE CIRCUIT COURT FOR THE ,TH 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CAROL PICKERING AND CASE NO. CACE-21-007806 JEFFREY PICKERING, Plaintiffs, V UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. PLAINTIFF'S WITNESS AND EXHIBIT LIST CAROL Plaintiff, PICKERING AND JEFFREY PICKERING, by and throughundersigned counsel, pursuant to the Uniform Order SettingCause for Jury Trial,Mediation, and Pre-Trial submits the following: Instructions, I. WITNESSES PLAINTIFF EXPECTS TO CALL AT TRIAL i. Fact Witnesses: 1. Carol Pickering CO Your Insurance Attorney,PLLC 2601 S. Bayshore Drive, 18th Floor Coconut Grove, FL 33133 2. JeffreyPickering CO Your Insurance Attorney,PLLC 2601 S. Bayshore Drive, 18th Floor Coconut Grove, FL 33133 3. / Records Custodian Corporate representative / PMWK Pelican Property Solutions,Inc. 210 Oregon Lane Boca Raton, FL 33487 4. / Records Custodian Corporate representative / PMWK Truview Mold LLC 7990 SW 117 Ave. Suite 204 Miami, FL 33183 5. / Records Custodian Corporate representative / PMWK InspectorLab 3301 NW 55th St Ft. Lauderdale, FL 33309 6. / Records Custodian Corporate representative / PMWK Dri-Max Restoration 8306 Mills Dr Suite 113 Miami, FL 33183 7. / Records Custodian Corporate representative / PMWK Restoration Doctor, LLC. 2097 S Sheridan Street Fort Lauderdale, FL 33332 8. Corporate representative ofDefendant regardingthe claim and incident alleged within Plaintiff' s Complaint. 9. of Defendant regardingthe Corporaterepresentative Plaintiff's underwriting file materials. 10. Field Adjuster of Defendant regardingthe claim and incident allegedwithin Plaintiff' s Complaint. 11. Desk Adjusterof Defendant regardingthe claim and incident allegedwithin Plaintiff' s Complaint. 12. All witnesses for impeachment or rebuttal purposes. 13. All witnesses on Defendant's Witness List. 14. All witnesses,includingexperts, discovered between now and trial. 15. Plaintiff reserves the rightto supplement and/or amend its witness list with reasonable notice to Defendant. ii. Expert Witnesses: 1. Don Wilcox Pelican Property Solutions 2650 NW 1 st Ave., Suite 9 Boca Raton, FL 33431 Mr. Wilcoxa licensed Insurance Adjuster in the State of Florida. He is expected to is testifyregarding his evaluation and inspectionof the damage to the insured's property. He is further expected to testifyregardingthe estimate prepared and photographs captured,relating to the damage to the insured' s home and the extent of repairs necessary to restore the property to its pre-losscondition. 2. Jose F. Uz. Caribbean Inspectors & Consultants, Inc. 14411 Commerce Way, No. 320 Miami Lakes, FL 33016 Mr. Uz is holding multiple licenses and a professionalexpert forensic inspector/analyst certifications related to buildinginspections, mold, wood destroyingorganisms, and roofing, among various other concentrations. He is expected to testify in regardsto his evaluation and inspection of the damage to the Insureds' property, as well as to any opinionshe may have formulated while conducting his investigation. Mr. Uz will testify regarding causation of the damages and any mold testingand remediation that was performed. Mr. Uz's opinions may also be based on his review of photographic evidence, depositiontestimony,research,literature, and his own experience and training. Mr. Uz will also testifyto everything contained in his expert report, if one is prepared.A copy ofMr. Uz's report will be providedto counsel if one is prepared after Mr. Uz inspectsthe property. 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: 3. Composite: Any and all documents produced or obtained during discoveryin this matter. 4. Defendant's responses to Plaintiff' s interrogatories. 5. Defendant's responses to Plaintiff' s Request for Production. 6. Any all reports, estimates,invoices,photographs,videos, statements or written opinionswhich may be preparedby Pelican Property Solutions,Inc. 7. Any all reports, estimates,invoices,photographs,videos, statements or written opinionswhich may be prepared by Truview Mold, LLC. 8 Any all reports, estimates,invoices,photographs,videos, statements or written opinionswhich may be prepared by Inspector Lab 9- Any all reports, estimates,invoices,photographs,videos, statements or written opinionswhich may be prepared by Dri-Max Restoration 10. Any all reports, estimates,invoices,photographs,videos, statements or written opinionswhich may be preparedby Restoration Doctor, LLC. 11. Any all reports, estimates,invoices,photographs,videos, statements or written opinionswhich may be preparedby Caribbean Inspectors & Consultants,Inc. 12. Any photographs taken by the Insured, their agents, or representativesin connection with the instant claim for damage. 13. Any and all inspection reports performed on the subject property before Defendant agreed to insure the property. 14. Any and all submitted before Defendant agreed to insure insurance applications the property. 15. Any and all photographs or videos contained within Defendant's underwriting file materials before it agreed to insure the property. 16. Any and all underwritingfile materials submitted before Defendant agreed to insure the property. 17. All documents designatedon Defendant's Exhibit List. 18. Impeachment and Rebuttal Exhibits. 19. Plaintiff reserves the rightto 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 of record for Defendant via the Florida E-FilingPortal on this 13th day of July,2022. Your Insurance Attorney, PLLC. 2601 South Bayshore Drive 18th Floor Coconut Grove, FL 33133 Phone No.: 1-888-570-5677 Fax: 1-888-745-5677 Email:YIA3@Yourinsuranceattorney.com Secondary Email: Eservice@Yourinsuranceattomey.com By: Maximo A. Santiago /s/ Maximo A. Santiago,Esq. Florida Bar No. 669733 Ariana Rubio Di Natale, Esq. Florida Bar No. 1025882 Filing# 159155630 E-Filed 10/13/2022 11:09:17 AM EXHIBIT "B ', IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE-21-007806 CAROL PICKERING AND JEFFREY PICKERING, Plaintiffs, VS. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. DEFENDANT'S DISCLOSURE OF FACT WITNESSES COMES NOW, the Defendant UNITED PROPERTY & CASUALTY INSURANCE COMPANY ("UNITED"), pursuant to this Court's Uniform Trial Order, and files its Disclosure of Fact Witnesses as follows: FACT WITNESSES 1. All partiesto this action or legalrepresentative. 2. Jeffrey Pickering c/o Plaintiffs' counsel 3. Carol Pickering c/o Plaintiffs' counsel 4. Records Custodian/Corporate Representative/PWMK Pelican Property Solutions, Inc. 210 Oregon Lane Boca Raton, FL 33487 5. Records Custodian/Corporate Representative/PWMK from Dri-Max Restoration 8603 Mills Drive, Suite 113 6. Records Custodian/Corporate Representative/PWMK from Restoration Doctor, LLC 2097 S. Sheridan Street Fort Lauderdale, FL 33332 7. Records Custodian/Corporate Representative/PWMK from Truview Mold, LLC 7990 SW 117th Avenue, Suite 204 Miami, FL 33183 8. Records Custodian/Corporate Representative/PWMK from Inspector Lab 3301 NW 55th Street Fort Lauderdale, FL 33309 9. Records Custodian/Corporate Representative/PWMK from King Cobra Plumbing 10. Records Custodian/Corporate Representative/PWMK from Mold Man of South Florida, LLC 11. EM P Restoration P.O.BOX 970760 Coconut Creek, FL 33097 12.Sheldon Wright, Field Adjuster United Property & Casualty Insurance Company do undersigned counsel 13. Corporate Representative United Property & Casualty Insurance Company do undersigned counsel 14.All persons noticed for deposition. 15. Representatives of all entities subpoenaed and/or noticed for deposition in this matter. 16.All persons necessary to authenticate or render United's exhibits admissible as offered by United at trial. 17.All persons who have been identified in Answers to Interrogatories, Responses to Request for Production and/or any other discovery produced in this matter. 18. Records Custodians of Broward County Building Department/ Permit Division 19. Records Custodians of Pembroke Pines Building Department/ Permit Division 20.Any and all witnesses for the purpose of impeachment and/or rebuttal. 21. Records Custodian of Towngate and/or any Property Management Company 22. Defendant reserves the rightto supplement and/or amend this list as discovery is ongoing. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was filed via the Florida Court E-Filing Portal pursuant to Rule 2.516 Fla. R. Jud. Admin Upon Maximo A. Santiago, YIA3@vourinsuranceattornev.comi eservice@vourinsurance attorney.com Your Insurance Attorney, PLLC., and All Counsel of Record 2601 South Bayshore Drive, 18th Floor, Coconut Grove, FL 33133, this 13th day of October, 2022. By /s/ Hollv K .Miller HOLLY K. MILLER Florida Bar # 40185 PETERSON BERNARD Attorneys for Defendant 707 S.E. 3rd Avenue, Suite 500 33316 Fort Lauderdale, Florida (954) 763-3200 (954) 728-9019 facsimile hollv.miller@petersonbernard.com diane. nielsen@petersonbernard.com HKM/dn 123.36265 Filing# 161450905 E-Filed 11/17/2022 01:59:06 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE-21-007806 CAROL PICKERING AND JEFFREY PICKERING, Plaintiffs, VS. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. DEFENDANT'S EXHIBIT LIST COMES NOW, Defendant, UNITED PROPERTY & CASUALTY INSURANCE COMPANY, by and through its undersigned counsel and pursuant to this Honorable Court's Uniform Order settingTrial,and hereby files its Exhibit List as follows: 1. A Certified Copy of UNITED PROPERTY & CASUALTY INSURANCE COMPANY'S, Policy of Insurance issued to Plaintiffs; 2. All Answers to Interrogatories(includingany and all amendments to same); 3. All Responses to Request for Production (includingany and all amendments to same); 4. Any and all records, documents, reports,and/or correspondence produced through discovery; 5. All records subpoenaed in this cause and/or produced during discovery; 6. Any and all correspondence between UNITED PROPERTY & CASUALTY INSURANCE COMPANY, and the Plaintiffs and/or their agents and/or representatives; 7. All photographs produced during discovery; 8. Any and all documents identified during depositions taken in this cause; 9. All depositions taken in this matter and any and all exhibits attached thereto; 10. Any and all records from the Broward County BuildingDivision,includingall permits on the property; 11. All photographs taken by Field Adjuster; 12. Any and all Geomni Photographs of the property; 13. Any and all Eagleview Photographs of the property; 14. Any and all Notices of Commencement and/or inspection reports for the subject property; 15. Any and all Recorded Statements of Plaintiffs 16. Documents produced by the Plaintiffs in response to any and all Requests for Production; 17. Documents produced by Defendant in response to all Requests for Production; 18. Photographs of the subject property taken by the Defendant, its agents, employees, and/or Field Adjuster; 19. All correspondence and/or documents exchanged between the Defendant, the and/or their agents or representatives relatingto the subject incident; Plaintiffs, 20. Demonstrative exhibits to be prepared for trial; 21. Any and all documents relied upon by Defendant's experts in formulating any opinions in this cause; 22. All records, photographs, source materials,buildingcodes, standards, reports,studies, together with any other documents reviewed or relied upon by Defendant's expert in formulating any opinions in this matter; 23. Any and all documents to be utilized for the purposed of impeachment and rebuttal; 24. Any and all photographs, video, film,slides, graphs, charts, and other documentary evidence of the subject property; 25. Any and all records received in response to subpoenas duces tecum; 26. Defendant reserves its rightto supplement and/or amend its Exhibit List as discovery in this cause is ongoing. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was filed via the Florida Court E-FilingPortal pursuant to Rule 2.516 Fla. R. Jud. Admin Upon Maximo A. Santiago, YIA3@vourinsuranceattornev.comi eservice@vourinsurance attorney.com Your Insurance Attorney, PLLC., and All Counsel of Record 2601 South Bayshore Drive, 18th Floor, Coconut Grove, FL 33133, this 17th day of November, 2022. By /s/ Holly K .Miller HOLLY K. MILLER Florida Bar # 40185 PETERSON BERNARD Attorneys for Defendant 707 S.E. 3rd Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile hollv.miller@petersonbernard.com diane. nielsen@petersonbernard.com HKM/dn 123.36265