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Filing# 158577279 E-Filed 10/04/2022 03:40:31 PM
IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
EDDIE & MEREDITH CASE NO.: CACE-22-014354
GREATHOUSE
Plaintiffs,
VS.
TYPTAP INSURANCE COMPANY
Defendant.
i
PLAINTIFFS' EXPERT REQUEST FOR
PRODUCTION TO DEFENDANT
EDDIE
Pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, Plaintiff,
& MEREDITH GREATHOUSE hereby serves
("Plaintiff'), its Expert Request for
Production to Defendant ("Defendant")and hereby requests that Defendant produce all of
the followingitems within its possession,custody or control,within thirty(30) days after
the service of this Trial Expert Request for Production, in the office of the undersigned
and copying.
attorneys for inspection
DEFINITIONS
You" and"your" means Defendant TYPTAP INSURANCE COMPANY.
A. The Term "documents" means all and
writingsof any kind, includingthe originals all
non- identical copies,whether different from the originalby reason of any notation made
on such copiesor otherwise, including(withoutlimitations) memoranda,
correspondence,
notes, diaries,statistics,
letters,telegrams, minutes, contracts, reports, studies,checks,
statements, rece*ts, returns, summaries, pamphlets,books, prospectuses, inter-office and
intra-office communications, offers, notations of any sort of conversation, telephone
calls,meetings or other communications, bulletins,printedmatter, computer print-outs,
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/04/2022 03:40:30 PM.****
telefax,invoices,worksheets and
teletypes, all drafts,alterations,
modifications, changes,
and amendments of any of the foregoing, graphic or aural writs, records or
of any kind, including(withoutlimitations)
representations photographs,charts,graphs,
microfiche, microfilm, videotape,recordings,motion pictures;and electronic,mechanical
of any kind, including(without limitation)
or electric records or representations tapes,
cassettes, computer magnetic or opticaldisc media and disc recordings.
B. The term "relatingto" as used herein is defined to mean evidencing, referringto,
concerning,or in any
pertainingto, consistingof, reflecting, way logicallyor factually
connected with the instant matter discussed.
C. As used in this Discovery request, the phrases "describe and explain",and "state" are
to request a full and
intended to and shall be interpreted fair statement of the fact or
matter being described and explained,including a statement of all facts, statements,
events and circumstances necessary to understand and evaluate the fact or matter being
described and explained.
D. Each of the followingdiscovery requests seeking an identification of documents is
intended to be interpreted
to request and require:
1. The date ofthe document;
2. The originatorofthe document;
3. The type of document;
4. The addressee of the document, if any;
5. Identification ofpersons to whom copies ofthe documents were furnished;
6. Details as to the custody of the document on the date the Interrogatories
are answered;
7. Specificpage numbers where the information requestedmay be found, if appropriate;
or, documents
alternatively, may be identified by numbering each such document and
to the number
referring in the answer and providinga true copy of each such numbered
document with the Answers to Trial Expert Request for Production and Trial Expert
Interrogatories.
E. Each of the followingDiscovery Requests requestingthe identification of persons is
intended to be interpretedto request and require for each witness known to the
Defendant.
1. The name ofthe individual;
2. The last known address and phone number of the individual;
3. The place of employment of the individual and the person'slast known address;
4. The substance of the witnesses' knowledge or information relatingto the information
requested.
F. The term "Expert" indicates any person whom defendant intends to use to provide
specialskills and knowledge regardingany factual or legalissue in this case whether in
regardto or in the form of (a)Trial Testimony or (b)Trial Preparation.
INSTRUCTIONS
1. All documents which are to be produced shall be produced as they are kept in the
ordinary and usual course of business or shall be organized and labeled in a manner
clearly identifyingand indicating the documents or tangible things that are being
produced in response to the particular
request.
2. If any document cannot be produced in full or in part, you shall state, in writing,the
reasons for your inability
to produce all or any portion of the requested document and
serve those reasons with your response.
3. If any of the documents herein are withheld under a claim of privilege,identifyeach
such document and state the date of the document, identifyits author and addressee, each
person to whom copies of the document were furnished or to whom the contents thereof
were communicated, a summary of the subject matter of the document, its present
location and custodian, the basis upon which the asserted privilegeis claimed and the
requests to which the document is responsive.
4. If any of the documents requestedherein have been destroyed,furnish a list identifying
each such document, its author and addressee, each person to whom copies of the
document were furnished or to whom the contents thereof were communicated, a
summary of the substance of the document, the date upon which it was destroyedand the
reason it was destroyed.
5. This request is deemed to be continuingin nature, and in the event that you become
aware of or acquire in your possession, custody or control additional responsive
documents, you are requested promptly to produce such additional documents to the
undersigned counsel.
EXPERT REQUEST FOR PRODUCTION
1. Current curriculum vitae of all experts identified in your expert disclosure.
2. Current case list of all experts identified in your expert disclosure.
3. Current expert witness fee rate sheet of all experts identified in your expert
disclosure.
4. Complete copies of all reports prepared or generatedby all experts identified in
your expert disclosure.
5. Complete copies of all reports, includingdrafts,revisions, and final versions,
exchanged between Defendant and all experts identified in your expert disclosure.
6. Complete copies of all documents, records, correspondence, communications,
notes, photographs,or materials produced by Defendant to all experts identified in
your expert disclosure.
7. Complete copies of all correspondence and communications exchanged between
Defendant and all experts identified in your expert disclosure,includingbills for
services rendered and copies of any payments issued.
8. All documents or tangibleevidence that support, reflect or in any way related to
or inspection
any expert opinion,summary, report, testingexamination, analysis,
identified in Defendant's Answers to Updated Trial Expert Witness
Interrogatories.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoingwas served by email
via the Court's E-filingPortal per Fla. R. Jud. Administration 2.516 to the Defendant's
counsel.
DATED 10/4/2022
RespectfullySubmitted,
/s/ Neil V. Singh,Esq.
NEIL V. SINGH, ESQ.
Florida Bar No: 696501
Co-Counsel for Plaintiffs
LAW OFFICES OF NEIL V. SINGH PA
10100 W. Sample Road, Third Floor
Coral Springs FL 33065
Office: 954-603-0568
Fax: 954-827-2261
PRIMARY DESIGNATED EMAIL-.
Claims@nvslaw.com
SECONDARY EMAIL-.
NEIL.SINGH@LAW.NYU.EDU
THIRD DESIGNATED EMAIL-.
NVSLAW1@gmail.com
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Filing# 158577279 E-Filed 10/04/2022 03:40:31 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA EDDIE & MEREDITH CASE NO.: CACE-22-014354 GREATHOUSE Plaintiffs, VS. TYPTAP INSURANCE COMPANY Defendant. i PLAINTIFFS' EXPERT REQUEST FOR PRODUCTION TO DEFENDANT EDDIE Pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, Plaintiff, & MEREDITH GREATHOUSE hereby serves ("Plaintiff'), its Expert Request for Production to Defendant ("Defendant")and hereby requests that Defendant produce all of the followingitems within its possession,custody or control,within thirty(30) days after the service of this Trial Expert Request for Production, in the office of the undersigned and copying. attorneys for inspection DEFINITIONS You" and"your" means Defendant TYPTAP INSURANCE COMPANY. A. The Term "documents" means all and writingsof any kind, includingthe originals all non- identical copies,whether different from the originalby reason of any notation made on such copiesor otherwise, including(withoutlimitations) memoranda, correspondence, notes, diaries,statistics, letters,telegrams, minutes, contracts, reports, studies,checks, statements, rece*ts, returns, summaries, pamphlets,books, prospectuses, inter-office and intra-office communications, offers, notations of any sort of conversation, telephone calls,meetings or other communications, bulletins,printedmatter, computer print-outs, *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/04/2022 03:40:30 PM.**** telefax,invoices,worksheets and teletypes, all drafts,alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or of any kind, including(withoutlimitations) representations photographs,charts,graphs, microfiche, microfilm, videotape,recordings,motion pictures;and electronic,mechanical of any kind, including(without limitation) or electric records or representations tapes, cassettes, computer magnetic or opticaldisc media and disc recordings. B. The term "relatingto" as used herein is defined to mean evidencing, referringto, concerning,or in any pertainingto, consistingof, reflecting, way logicallyor factually connected with the instant matter discussed. C. As used in this Discovery request, the phrases "describe and explain",and "state" are to request a full and intended to and shall be interpreted fair statement of the fact or matter being described and explained,including a statement of all facts, statements, events and circumstances necessary to understand and evaluate the fact or matter being described and explained. D. Each of the followingdiscovery requests seeking an identification of documents is intended to be interpreted to request and require: 1. The date ofthe document; 2. The originatorofthe document; 3. The type of document; 4. The addressee of the document, if any; 5. Identification ofpersons to whom copies ofthe documents were furnished; 6. Details as to the custody of the document on the date the Interrogatories are answered; 7. Specificpage numbers where the information requestedmay be found, if appropriate; or, documents alternatively, may be identified by numbering each such document and to the number referring in the answer and providinga true copy of each such numbered document with the Answers to Trial Expert Request for Production and Trial Expert Interrogatories. E. Each of the followingDiscovery Requests requestingthe identification of persons is intended to be interpretedto request and require for each witness known to the Defendant. 1. The name ofthe individual; 2. The last known address and phone number of the individual; 3. The place of employment of the individual and the person'slast known address; 4. The substance of the witnesses' knowledge or information relatingto the information requested. F. The term "Expert" indicates any person whom defendant intends to use to provide specialskills and knowledge regardingany factual or legalissue in this case whether in regardto or in the form of (a)Trial Testimony or (b)Trial Preparation. INSTRUCTIONS 1. All documents which are to be produced shall be produced as they are kept in the ordinary and usual course of business or shall be organized and labeled in a manner clearly identifyingand indicating the documents or tangible things that are being produced in response to the particular request. 2. If any document cannot be produced in full or in part, you shall state, in writing,the reasons for your inability to produce all or any portion of the requested document and serve those reasons with your response. 3. If any of the documents herein are withheld under a claim of privilege,identifyeach such document and state the date of the document, identifyits author and addressee, each person to whom copies of the document were furnished or to whom the contents thereof were communicated, a summary of the subject matter of the document, its present location and custodian, the basis upon which the asserted privilegeis claimed and the requests to which the document is responsive. 4. If any of the documents requestedherein have been destroyed,furnish a list identifying each such document, its author and addressee, each person to whom copies of the document were furnished or to whom the contents thereof were communicated, a summary of the substance of the document, the date upon which it was destroyedand the reason it was destroyed. 5. This request is deemed to be continuingin nature, and in the event that you become aware of or acquire in your possession, custody or control additional responsive documents, you are requested promptly to produce such additional documents to the undersigned counsel. EXPERT REQUEST FOR PRODUCTION 1. Current curriculum vitae of all experts identified in your expert disclosure. 2. Current case list of all experts identified in your expert disclosure. 3. Current expert witness fee rate sheet of all experts identified in your expert disclosure. 4. Complete copies of all reports prepared or generatedby all experts identified in your expert disclosure. 5. Complete copies of all reports, includingdrafts,revisions, and final versions, exchanged between Defendant and all experts identified in your expert disclosure. 6. Complete copies of all documents, records, correspondence, communications, notes, photographs,or materials produced by Defendant to all experts identified in your expert disclosure. 7. Complete copies of all correspondence and communications exchanged between Defendant and all experts identified in your expert disclosure,includingbills for services rendered and copies of any payments issued. 8. All documents or tangibleevidence that support, reflect or in any way related to or inspection any expert opinion,summary, report, testingexamination, analysis, identified in Defendant's Answers to Updated Trial Expert Witness Interrogatories. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoingwas served by email via the Court's E-filingPortal per Fla. R. Jud. Administration 2.516 to the Defendant's counsel. DATED 10/4/2022 RespectfullySubmitted, /s/ Neil V. Singh,Esq. NEIL V. SINGH, ESQ. Florida Bar No: 696501 Co-Counsel for Plaintiffs LAW OFFICES OF NEIL V. SINGH PA 10100 W. Sample Road, Third Floor Coral Springs FL 33065 Office: 954-603-0568 Fax: 954-827-2261 PRIMARY DESIGNATED EMAIL-. Claims@nvslaw.com SECONDARY EMAIL-. NEIL.SINGH@LAW.NYU.EDU THIRD DESIGNATED EMAIL-. NVSLAW1@gmail.com