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  • HODGES BORTHERS INC vs. Defendant Not Entered CONTRACTS document preview
  • HODGES BORTHERS INC vs. Defendant Not Entered CONTRACTS document preview
  • HODGES BORTHERS INC vs. Defendant Not Entered CONTRACTS document preview
  • HODGES BORTHERS INC vs. Defendant Not Entered CONTRACTS document preview
  • HODGES BORTHERS INC vs. Defendant Not Entered CONTRACTS document preview
  • HODGES BORTHERS INC vs. Defendant Not Entered CONTRACTS document preview
  • HODGES BORTHERS INC vs. Defendant Not Entered CONTRACTS document preview
  • HODGES BORTHERS INC vs. Defendant Not Entered CONTRACTS document preview
						
                                

Preview

Filing # 172957303 E-Filed 05/11/2023 02:12:52 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA HODGES BROTHERS, INC., Plaintiff, vs. Case No.: 2018-CA-004003 CLARDY A. MALUGEN, as Trustee of The CLARDY A. MALUGEN FAMILY TRUST, and CLARDY A. MALUGEN, individually, Defendants. _____________________________________/ PLAINTIFF/COUNTERDEFENDANT HODGES BROTHERS INC.’S DISCLOSURE OF EXPERTS AND DOCUMENTS PLAINTIFF/COUNTERDEFENDANT HODGES BROTHERS INC. serves this disclosure of experts and their documents. Witnesses: 1. Ray Nugent * Senior Appraiser Nugent Appraisal Services Fort Lauderdale FL (888) 353-7152 (damages –expert) Appraisal of Dali print -- attached 2. Lee M. Walters, AIC – damages * 11927 Imaginary Way Orlando, FL 32832 (407) 973-4020 Expert – repair cost estimate attached 3. Gerald Massa, CPCU, ARM -- damages * Page 1 of 4 Integrated Claims Solutions 668 Maitland Avenue Altamonte Springs FL 32701 (407) 834-5555 Expert --repair cost estimate attached 4. David D. Zimpel, P.E. – liability* Rimkus Consulting Group, Inc. 277 Douglas Avenue, Suite 1008 Altamonte Springs FL 32714 (407) 661-1245 Expert -- report attached 5. Brian Harding – damages * Sky Disaster restoration, Inc. 3718 Vineland Avenue Orlando FL 32811 407-900-9989 Expert -- repair cost estimate attached 6. Representative of Strike Check who performed evaluation described in 3/6/2018 report – liability * 101 South Tryon St. Charlotte NC 28280 888-980-8544 Expert – report attached 7. Gregory Bosseler – damages * ServPro of South Brevard, Inc. P.O. Box 361155 (321) 953-8600 Expert – not engaged – has not provided a report. Other parties are already in possession of his repair estimate. Mr. Bosseler is expect to testify it was not necessary to replace the dishwasher, refrigerator, oven, and kitchen island. 8. Robert J. Whitcomb, AIA, RRC, CBECxP, CDT, CIT, IIBEC, NCARB C.B. Goldsmith & Assocs. 2555 Nursery Road Clearwater, Florida 33764 (727) 540-0456 Mr. Whitcomb has no report. Mr. Whitcomb is expected to testify that leaks in the roof were caused by rodents or animals chewing through air conditioner duct work in the attic. Page 2 of 4 HODGES BROS. does not believe this is expert testimony but discloses this information nonetheless. 9. Persons who may be identified after the date of this disclosure (discovery is not complete) 10. Rebuttal and impeachment witnesses. * Persons marked with an asterisk are listed and will be offered only on the defense of the counterclaims and setoff defenses, if any evidence is offered on the counterclaims or setoff defenses. THOMAS F. NEAL Florida Bar Number 603368 TNeal@dsklawgroup.com LNovak@dsklawgroup.com de Beaubien, Simmons, Knight, Mantzaris & Neal, L.L.P. 332 North Magnolia Avenue Post Office Box 87 Orlando, Florida 32802-0087 Telephone: (407) 422-2454 Facsimile: (407) 849-1845 Attorney for Hodges Bros. Inc. HILL, RUGH, KELLER & MAIN, P.L. _/s/ Andrew V. Showen___________________ ANDREW V. SHOWEN Florida Bar No. 0476153 Board Certified Construction Lawyer 390 North Orange Avenue, Suite 1610 Orlando, FL 32801 (407) 926-7460 (407) 926-7461 (facsimile) filings@hrkmlaw.com Attorney for Hodges Bros. Inc. (only as to counterclaim) CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11th day of May 2023, I electronically filed the foregoing with the Clerk of the Courts by using the E-Portal System pursuant to Florida Rule of Judicial Administration 2.516 (a), which E-Portal will provide service upon: Thomas F. Neal, Esq., 332 N. Magnolia Ave., P.O. Box. 87, Orlando, FL 32802 at e-mails: Page 3 of 4 tneal@dsklawgroup.com and lnovak@dsklawgroup.com(Counsel for Plaintiff), Clardy A. Malugen, individually, via email to clardyclardym.com, and Daniel M. Greene, Esq., Daniel M. Greene, P.A., P.O. Box 3092, Orlando, FL 32802 at e-mails: dangreenelaw@gmail.com and dan@dangreenelaw.com (Counsel for Gail Stedronsky Bove). HILL, RUGH, KELLER & MAIN, P.L. _/s/ Andrew V. Showen___________________ ANDREW V. SHOWEN Florida Bar No. 0476153 Board Certified Construction Lawyer 390 North Orange Avenue, Suite 1610 Orlando, FL 32801 (407) 926-7460 (407) 926-7461 (facsimile) filings@hrkmlaw.com Attorney for Hodges Bros. Inc. (only as to counterclaim) Page 4 of 4 (888) 353-7152 Intended Use: Insurance Purpose Type of Value: Pre-Damage Fair Market Value Effective Date of Valuation: November 12, 2018 Date of Report Issue: December 5, 2018 Prepared for client: Clardy Malugen 214 Celebration Blvd Celebration, FL 34747 Prepared for intended user: Westfield Insurance Prepared by: Ray Nugent - Senior Appraiser Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes TABLE OF CONTENTS TITLE PAGE 1 TABLE OF CONTENTS 2 AGGREGATE VALUE STATEMENT 3 CONFIDENTIALITY 3 TYPE AND DEFINITION OF VALUE 4 APPROACH TO VALUE DEFINITIONS & UTILIZATION RATIONALE 4 ITEM CONDITIONS 5 EXTRAORDINARY ASSUMPTIONS, LIMITING AND HYPOTHETICAL CONDITIONS 6 CERTIFICATION OF APPRAISER 8 SCOPE OF WORK 9 SOURCES FOR MARKET COMPARABLE DATA 10 BIBLIOGRAPHY 11 DESCRIPTION AND VALUE QUALIFICATIONS Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes December 5, 2018 Clardy Malugen 214 Celebration Blvd Celebration, FL 34747 Fair Market Value of Personal Property Enclosed is the appraisal report for the items of personal property that you asked us to evaluate. We examined the items for the purpose of determining the fair market value for Insurance Purpose; any other use renders the report null and void. For your information, we have included the following value for the items appraised: FAIR MARKET VALUE: $2,000 (Two Thousand Dollars) The report explains the basis for the valuation, a list of limiting and qualifying conditions concerning use of the report, the appraisal of the item, and qualifications of the appraisers. If any other professional consultants contributed significantly to the report, their qualifications are also included. The report should be used in its entirety. The value set for the appraised property is based on comparisons to similar items found in their appropriate markets. The value conclusions may be subject to limiting conditions set forth in the body of the accompanying report. CONFIDENTIALITY We have retained a copy of this report and the original notes used in its preparation. These records are confidential. No one will have access to this report without your permission; parties specifically authorized by you; state appraiser regulatory agencies; third parties as may be authorized by due process of law; or a duly authorized professional peer review committee except when such disclosure to a committee would violate applicable law or regulation. Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes TYPE AND DEFINITION OF VALUE The report includes the following value for the item appraised. “FAIR MARKET VALUE”, as used herein, has been defined by the Department of Treasury, Internal Revenue Service as: The price that the property would sell for on the open market. It is the price that would be agreed on between a willing buyer and a willing seller, neither being required to act, and both having reasonable knowledge of the facts. It takes into account all of the many factors that affect the price of the property on the valuation date. APPROACH TO VALUE DEFINITIONS AND UTILIZATION RATIONALE COST APPROACH TO VALUE: The research and analysis of the cost of a substitute property with equivalent function and desirability, providing an estimate of the depreciated reproduction, reproduction new or replacement cost new of the property. The appraiser chose not to utilize the Cost Approach to Value on this assignment because it was determined that credible cost data was not available. INCOME APPROACH TO VALUE: The research and analysis of the present worth of anticipated income. The appraiser chose not to utilize the Income Approach to Value on this assignment because it was determined that credible income data was not available. MARKET SALES COMPARISON APPROACH TO VALUE: The research and analysis comparing sales of property similar enough to the property being appraised to permit detailed comparison, estimating value by comparison with properties sold in the relevant market, with adjustments made for all difference which affect value, such as differences in characteristics of value and in time. The appraiser is utilizing the Market Sales Comparison Approach to Value on this assignment because valid data is available to render a credible opinion of value. Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes ITEM CONDITIONS Because item condition is a heavily weighted factor in the determination of value, the appraiser has included an indication of condition for each item. The conditions are defined as: MINT Unblemished, perfect EXCELLENT Like new, near original condition GOOD Typical for its type and age with normal wear and tear FAIR Generally acceptable condition, but which exhibit more wear than normal or preferred, below average POOR Restoration is needed and may exceed the restored value Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes EXTRAORDINARY ASSUMPTIONS, LIMITING AND HYPOTHETICAL CONDITIONS By acceptance of the report and payment thereof, the client(s), owner(s), and their authorized representative(s) agree to the subject of the Limiting Conditions included. 1. Use of this report by the named client(s), or their authorized representative(s) is restricted to the appraisal purpose and use stated. Any other use of the report renders it null and void. The report must be used in its entirety including the appraiser’s qualifications and aggregate value statement page. The appraiser assumes no responsibility for any unauthorized use. 2. Values are expressed in U.S. Dollars, are rounded off, and are based on current information on the date of valuation. The values are based on the appraiser’s best judgment and opinion and are not a representation or warranty that the items will realize that value if offered for sale. 3. Change of the value or description of any item in the appraisal report shall not be made by anyone other than the appraiser and the appraiser shall have no responsibility for any unauthorized change. 4. Possession of this report or any copy does not carry with it the right of publication. The report may not be copied for any purpose by anyone but the named client(s), their authorized representative(s), intended user(s), and then is restricted to the appraisal purpose and use stated. All rights reserved. 5. Legal matters are not the responsibility of the appraiser, nor does the appraiser render any opinion as to ownership of the item(s) appraised. The property is appraised as though under responsible ownership and is assumed to be marketable. Information provided by the client or authorized representative is assumed accurate. 6. Testimony or attendance in court or at any other hearing if required must be arranged a reasonable time in advance, and compensated at the current expert witness rate. 7. Dimensions and weights are approximate. 8. Framed items and items under glass were not removed from their frame unless otherwise noted in the item description section of the Schedule of Appraised Property. There could be valuation factors hidden from the appraiser in the matting and framing of an item. 9. Authorship has not been verified except where noted and is subject to further examination, as are unsigned works with incomplete or illegible signatures. 10. Ivory, Jade, and other materials have not been tested and are subject to further examination. 11. Fragile items have not been examined for repairs or hidden damage and are considered in good condition unless otherwise noted. 12. Electronics and appliance have not been tested and are assumed to be operable unless otherwise noted. 13. Authentication is not stated or declared. The appraiser renders an opinion on values, not authenticity or origination. The Principle of Identification states that if a subject property possesses the same characteristics as an acknowledged genuine property then the subject property is assumed to be genuine. No further claim of authenticity is implied or intended. Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes 14. Extraordinary Assumption presumes as fact otherwise uncertain information about the physical, legal or economic characteristics of the subject property, or about conditions external to the property, such as market conditions or trends; or about the integrity of the data used in an analysis. The use of an Extraordinary Assumption might affect the assignment results. 15. Hypothetical Condition is a condition that is contrary to what is known by the appraiser to exist on the effective date of the assignment results, but is used for the purpose of analysis. The use of a Hypothetical Condition might affect the assignment results. 16. This appraisal report has been transmitted electronically to my client and includes my signature in electronic form. I affirm that I maintain sole personal control over the use of the electronic signature appended hereto. Electronically affixing my signature to this report carries the same level of authenticity and responsibility for this report’s content, analyses and conclusions as would appending an original ink signature on a paper copy of this report. Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes CERTIFICATION OF APPRAISER I certify that to the best of my knowledge and belief: • The statements of fact contained in this report are true and correct. • The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions, and are my personal unbiased professional analyses, opinions and conclusions. • I have no present or prospective interest in the property that is the subject of this report, and I have no personal interest or bias with respect to the parties involved. • I have performed no services, as an appraiser or in any other capacity, regarding the property that is the subject of this report within the three-year period immediately preceding acceptance of this assignment. • I have no bias with respect to the property that is the subject of this report or to the parties involved with this assignment. • My engagement in this assignment was not contingent upon developing or reporting predetermined results. • My compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction I value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal. • My analyses, opinions, and conclusions were developed, and this report has been prepared, in conformity with the Uniform Standards of Professional Appraisal Practice. • I have made a personal inspection of the property that is the subject of this report. • No one provided significant personal property appraisal assistance to the person signing this certification. Respectfully, Ray Nugent Senior Appraiser Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes SCOPE OF WORK At your request, appraiser Kristi Mercer of Nugent Appraisal LLC performed an onsite examination of the items listed in this report. I utilized the Market Comparison Approach to Value methodology for the purpose of rendering an opinion of fair market value as of November 12, 2018. This appraisal is subject to the basic assumptions and limiting conditions contained herein. A Hypothetical Condition pertains to this assignment in that the appraiser is rendering an opinion of value of the asset in a Pre-Damage condition, which is contrary to what is known by the appraiser to exist on the effective date of the assignment results. The use of a Hypothetical Condition might affect the assignment results. PROPERTY DESCRIPTION AND VALUE Attached at the end of the report. Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes SOURCES FOR MARKET COMPARABLE DATA ArtPrice.com AskArt.com LiveAuctioneers.com WorthPoint.com Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes BIBLIOGRAPHY American Society of Appraisers, The Appraisal of Personal Property, Washington, D.C.: The American Society of Appraisers. Appraisal Standards Board, The Appraisal Foundation. Uniform Standards Of Professional Appraisal Practice and Advisory Opinions 2016-2017 Edition, The Appraisal Foundation Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes Table of Contents Living Room Contents (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Powered by Encircle 2 of 7 Living Room CONTENTS: Living Room Artwork Estimated Value: $2,000 Notes: Lithograph on paper by Salvador Dalí (Spanish, 1904–1989), titled in French SINDBAD LA MARIN (Sinbad the Sailor), pencil signed lower right ”Salvador Dali”, and numbered on the lower left ”E.A.” as an Artist Proof in French, Framed under glass. Overall Size 26” x 20” in. approx. Fair Condition: The paper is warped along the matting all the way around and is bulging in the center. Needs the intervention of a Professional Paper Conservator. Appraised in Pre-Damage Good Condition. Item 1 2018-11-12 ITEM PHOTO NOTE: Note Comp #1 ”SALVADOR DALI Alice in Wonderland ”The Pool of Tears” Limited Edition Lithograph Artist Pencil Signed and Num- bered 139/300 Framed and Matted. Comes with Certificate of Authenticity.” Source: worthpoint.com, Price sold: $1,100 USD 2018-11-15 ITEM PHOTO NOTE: Note Powered by Encircle 3 of 7 Comp #3; Salvador Dali. Medium: Original lithograph. Title: Le Chevalier de la Mort (Cavalier of Death). From the set titled: Dalinean Horses. Certificate of authenticity from the gallery. Overall size: 21” x 29” in. Source: Liveauctioneers.com, Esti- mate $15,000 - $17,500. Sold for $2,250 2018-11-30 ITEM PHOTO NOTE: Note Comp # 2: Salvador DALI (1904-1989) ”Simbah le Marin”, Lithograph in colors, Overall Size: 29 7/8 x 21 1/4 in Source: Four Seasons Auction Gallery Gainesville, GA, US, Sold Date September 30, 2018. Lot 145. Estimate: $8,000 - $12,000 Sold: $525 2018-11-30 ITEM PHOTO NOTE: Picture Note 2018-11-12 2018-11-12 2018-11-12 Powered by Encircle 4 of 7 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 Powered by Encircle 5 of 7 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 ITEM PHOTO NOTE: Picture Note 2018-11-12 2018-11-12 2018-11-12 Powered by Encircle 6 of 7 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 2018-11-12 Powered by Encircle 7 of 7 (888) 353-7152 Ray E. Nugent Personal Property Appraiser Naples – Miami – Ft. Lauderdale - Palm Beach - Orlando – Tampa – Boston – New York – San Francisco – Las Vegas (888) 353-7152 www.nugentappraisal.com ray@nugentappraisal.com Last updated 2/1/18 QUALIFICATIONS STATEMENT PROFESSIONAL ASSOCIATIONS American Society of Appraisers – Member, since 2007 Association of Online Appraisers – Member, since 2005 American Philatelic Society – Member, since 2012 EDUCATION, TRAINING AND ACADEMIC STUDY Undergraduate Education University of Georgia, Athens, GA, Bachelor of Science 1986, Education Professional Appraisal Study About ASA The American Society of Appraisers (ASA) is a world renowned and respected international organization devoted to the appraisal profession. As the oldest and only major appraisal organization representing all appraisal specialists, ASA is devoted to providing the highest possible standards in all areas of ethics, professionalism, education and designation criteria. American Society of Appraisers – Core Education Introduction to Personal Property Valuation (PP/GJ201); Naples, Florida, in September, 2006 Personal Property Valuation Methodology – Research and Analysis (PP/GJ202); University of Georgia, in February, 2007 Personal Property Valuation – Report Writing (PP/GJ203); Northwestern University, in March, 2007 Personal Property Valuation – The Legal & Commercial Environment (PP/GJ204); University of Georgia, in May, 2007 Professional Continuing Education American Society of Appraisers – USPAP Certification Completed in February 2017, effective through February 2019 American Society of Appraisers – Reasoning and Logic for Valuation Professionals Completed 1/16/15 Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes American Society of Appraisers – What Examiners are looking for in Reviewing Appraisals, Completed 8/19/15 American Society of Appraisers – Luxury or Lie? A prequel to Correctly Appraising Wristwatches, Completed 6/4/16 Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes SELECTED COMMERCIAL AND INSTITUTIONAL CLIENTS; AND EXAMPLES OF SPECIAL COLLECTIONS AND ITEMS APPRAISED Special Collections: - 5758 books and musical score from movie and television writer - Booker T. Washington authentic personal correspondence - Authentic Manuscript of development of MRI technology - Author Alfred Lewis’ typescript drafts of unpublished and published works - Thomas Edison’s authentic work notes - 49 linear feet of late 19th to 20th century medical research ephemera - 1200 hard and paperback art genre books - 3000+ Erotica books, magazines, video, comics, and art - 1401 accordion music manuscripts written by Arthur Metzler - 10000 items of literature with emphasis on poetry - Opera vocal scores and songs, Metropolitan Opera, 1924-2001 - Civil War era Slave Bills of Sale, Indetures, Photos, Letters, Drawings - 10000+ historical smoking advertisments - 9000+ collection of art books - 30+ NASCAR trophies first issued - 225 Studio Art collection for insurance scheduling - HIV/AIDS Pulitzer Prize Author’s Archives - 14000+ Foreign/Domestic Stamp Collection - Kitchen Cabinets/Appliances for Charitable Donation - 2,000+ Collection of excess inventory DVD/CD/Books for Donation - Parts inventory and equipment of Refrigeration Contractor business - $1.6M in Gold and Silver Coins and Bars - 19,000 specimen Herbaria collection - 500+ UnitedWay Memorabilia Items - Marine Dredging Equipment - Stanford University; 20,000+ Tobacco Advertisments Banks: - Colonial Bank - SunTrust - Regions Bank - Northern Trust - Bank of Florida Trust Co. - Glens Falls National Bank & Trust - Fifth Third Bank - Wilmington Trust, N.A. - Bessemer Trust - RBC Wealth Management Foundations & Organizations: - Claude Pepper Foundation - Harvey S. Firestone Foundation - New England Conservancy of Music - Quest Foundation - Green Demolitions - Advocates for World Health Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes Colleges & Universities: - Florida Interational University - University of Michigan - UMass Dartmouth - Nova Southeastern University - Armstrong State University - Florida State University - University of Florida - University of Houston - University of Wyoming - Florida Institute of Technology - Indiana University - Harvard Law School - Stanford University Companies: - At Your Service Moving & Storage - Blackmon Mooring - CH2M Hill - ServPro - Waste Management - Insurance Claims Management, Inc. - United Water Restoration - Asset Verification, Inc. - Harless & Associates Accounting - G&E Florida Contractors - Onshore Construction, Jupiter, FL - The Boston Globe - MaxSold - Green Demolitions - Renovation Angel Insurance Companies: - Allstate Insurance Company - Chubb Insurance Company - Farm Bureau Insurance Company - Farmer’s Insurance Group - Fireman’s Fund - Safeco Insurance Company - State Farm Insurance - UniGroup - CNA Insurance - Nationwide Insurance - Liberty Mutual Insurance Law & Accounting Firms: - Andres, Quintero & Associates, P.A., Miami - McFarlane, Dolan & Barnett, Coral Springs, FL - Cohen & Grigsby, P.C., Naples, FL - Hahn, Loeser & Parks, LLP, Naples, FL Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes - Silverio & Hall, Naples, FL - Wochok & Associates, LTD, Paoli, PA - Hightower & Partners, PA, St. Petersburg, FL - Quarles & Brady, LLP, Naples, FL - Herman, Herman, Katz & Cotlar, New Orleans - Porter, Wright, Morris & Arthur, LLP - VanNess & VanNess, P.A., Crystal River, FL - Banker, Lopez, Gassler, P.A., Ft. Myers, FL - Feldman & Schneiderman, P.L., Boca Raton, FL - Fine and Block, Atlanta, GA - Dorband & Schneider, LLP, Lafayette, CA - Kulicki Draper, FL - Law Offices of Geoffrey Ittleman, P.A., Ft. Lauderdale, FL - Salvatori, Wood & Buckel, PL, Naples, FL - Fuchs and Jones, P.A., Wellington, FL - WilliamsParker, Sarasota, FL - Reinhart, Boerner Van Deuren, Waukesha, WI - Holland & Knight, West Palm Beach, FL - Davis Friedman, Chicago, IL - Gunster Private Wealth Services, Tampa, FL - Greensfelder, Hemker & Gale, P.C., St. Louis, MO - K&L Gates, Miami, FL - Woodward, Pires & Lombardo, Naples, FL - HMS Law Group, LLP, Sacramento, CA - The Karp Law Firm, P.A., Palm Beach Gardens, FL - Devine Goodman, Miami, FL - Bush Ross, P.A., Tampa, FL - Andrew B. Peretz, P.A., Fort Lauderdale, FL - Kirschbaum Birnbaum Lippman & Gregoire, Ft. Lauderdale, FL - Christopher G. Price, P.A., Naples, FL - Broad and Cassel, Orlando, FL - Hinman, Howard & Kattell, LLP, Boynton Beach, FL - Law Firm of Charles D. Jamieson, P.A., West Palm Beach, FL - Pignato & Underwood CPA, Delray Beach, FL - Smyth & Hauck CPA, North Palm Beach, FL - Weltman, Weinberg & Reis Co., LPA, Cincinnati, OH Museums, Libraries and Historical Societies: - Still National Osteopathic Museum - Magale Memorial Library - Astronaut Hall of Fame - Collier Automotive Museum - United States Historical Office - American History Museum – Smithsonian - NASCAR Hall of Fame - Edison & Ford Museum Others: - United States Postal Service - Family Service Society of Yonkers Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes - Federal Bureau of Investigation - Internal Revenue Service - U.S. Marshal’s Service - Drug Enforcement Administration - FDIC - United States Special Operations Command - Florida State Archives - City of Orlando - North Carolina State Archives - The Boston Globe - National Aeronautics and Space Administration (NASA) - General Services Administration Works of Art by Noted Artists Appraised in Last 48 Months Marc Chagall - Abstract Erte – Art Deco Robert Wyland - Marine Carlos Merida - Abstract LeRoy Neiman – Athletic B. Prabha – Portrait/Figure Pablo Picasso – Cubist Charles Parks – Portrait/Figure Norman Rockwell – Portrait/Figure Alberto Vargas - Illustrations Joan Miro - Abstract Ida Kohlmeyer - Abstract Andy Warhol – Pop/Mondernist Roy Lichtenstein – Pop/Cartoon Lee Krasner – Abstract Experssion Camille Pissarro - Impressionist Jean Dubuffet – Modern Charles M. Russell - Frontier Marie Laurencin – Ethereal Figure Milton Clark Avery - Abstract Joaquin Torres Garcia - Constructivist Paul Gauguin - Post Impressionist Robert Rauschenberg – Assemblage Marsden Hartley - Modern Wilfredo Lam - Figurative Thomas Sully – Portrait/Landscape Anthony Thieme – Landscape John James Audubon – Wildlife Portrait Jamali - Expressionist Emile Gruppe’ – Landscape/Marine Kasimir Malevich - Suprematism Yuri Annenkov - Portrait Jose Maria Sicilia - Modern Richard Diebenkorn - Expressionist Earl Biss – Modern Figuritive Itzchak Tarkay – Landscape/Figure Frederick Hart – Figure Sculpture Bill Mack – Figure Sculpture Salvador Dali – Surrealist Andreas Schelfhout - Townscape Dale Chihuly – Abstract Glass Helen Dryden - Illustrator Figure Alfred Sisley – Impressionist Jean-Michel Basquiat - Graffiti Alex Katz – Post Modern Anatjari Tjakamarra - Aboriginal Alejandro Obregon – Cubist/Expressionist Edgar Degas - Figure Jackson Pollock – Abstract Expressionist Reuben Moulthrop - Portrait Louis Ritman – Impressionist William Sonntag - Landscape Sanford Gifford - Landscape Charles Burchfield – Modern Botanic Montague Dawson - Marine Bernard Buffet – Abstract Figural Jean-Paul Riopelle – Abstract Expressionist Suzanne Eisendieck – Figure, Seascape Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes Claude Venard – Post Cubist Henri Le Sidaner – Impressionist Jean Dufy – City and Theatre Sets Maurice de Vlaminck – Fauve Landscape Suzor-Cote – Landscape & Still-Life Emile Othon Friesz – Landscape, Figure Dietz Edzard – Figure, Still Life Eugene Boudin – Marine, Coastal Cornelius Krieghoff – Frontier Genre Andre Hambourg – Post Impressionist John Little – Urban Life, Townscape Auguste Rodin – Figural Sculpture Dietz Edzard – Figure, Cityscape Beihong Xu – Chinese Motif Zhao Shao’ang – Chinese Motif Pan Tianshou – Chinese Painting Wu Changshuo – Chinese Painting Yayoi Kusama – Collage, Sculpture C.N. Liew – Painting, Calligrapher Ding Yanyong – Chinese Painting Jiang Shuo – Chinese Sculpture Zhang Kehe – Scroll Painting Jim Dine – Pop Expression Robert William Vonnoh – Impressionist Marsden Hartley – Modernist Imagery John Alexander – Modernist Frederic Remington – Western Christopher Wool – Imagery Robert Vonnoh – Landscape, Portrait Uwe Kowski – Contemporary Arthur Osver – Abstract Marc-Aurele Fortin – Landscape Nora Collyer – Landscape Albert Robinson – Figure Painting William Goodridge Roberts – Portrait Rene Jean Richard – Landscape Alexander Young Jackson – Landscape Toshiko Takaezu - Ceramic David Maass – Wildlife Illustrator Wendell Castle – Sculptor-mod furniture Peter Max – Illustrations – Pop James Rizzi – Cartoon Clarence A. Gagnon – Landscape Cornelius Krieghoff – Frontier Genre Toulouse-Lautrec – Demimonde Marshall M. Fredericks – Sculpture Homer D. Martin – Impressionist Henri Matisse – Modernist, Sculpture Joan Mitchell – Abstract Expression Milton Clark Avery - Abstract Thomas Benton – American Scene Jannis Kounellis – Found Objects Martha Walter – Impressionist Larry Poons – Abstract Expression Tom Wesselman – Pop Nude Figure Anitjri Tjakamarra – Aboriginal Kenny Scharf – Mod-Pop Whimsy Keith Haring – Mod-Pop, Figure Crash – John Matos – Mod Graffiti Romero Britto – Pop Art Cassandre – Art Deco Pierre De Belay– Figure Mathurin Meheut – Sea and Nature Alice Halicka – Cubist William Bradford – Marine, Arctic Astrid Preston – Modernist Landscape Cesar Baldaccini – Nouveau Sculpture H. Claude Pissarro – Genre and Seascape Jacques Martin-Ferrieres – Figure Tom Blackwell – Urban Scene Painting Fernando Botero – Rotund Figure Fernand Leger – Cubist Jaume Plensa – Public Sculpture Francois-Xavier Lalanne – Sculpture Richard Diebenkorn – Expressionist Javacheff Christo – Environmental Art Robert Cottingham – Real Facades Gil Elvgren – Illustration Pin-Up Pierre Fernandez Arman – Assemblage Anish Kapoor – Mod Object Sculpture Janet Fish – Modernist Glitz Sam Francis – Splatter-Stain Imagery Mel Ramos – Pop Icon Nude Damien Hirst – Conceptual Themes Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes David Hockney – Pop Art Robert Indiana – Pop Objects, Sculpture Jasper Johns – Mod Flags, Sculptor Sarah Morris – Abstract Text Painting Robert Motherwell – Abstract Expressionist Claes Oldenburg – Whimsical Pop Art Arnaldo Pomodoro – Abstract Sculpture Ed Ruscha – Pop-Word Illusions Frank Stella – Geometric Painting Sam Lewis Francis – Splatter-Stain Donald Sultan – Modernist Landscape Victor Vasarely – Geometric Images Bernar Venet - Painting and Sculpture Lowell Nesbitt – Super Real Object Robert Longo – Mod Figure Chris Ofili – Mod Nigerian Figure Paul Morrison – Monochromatic Botanical Hao Hong – Illusion, Preconception Peter Driben – Illustration- Female Figure Robert C. Kauffmann – Mod Sculpture Mort Kunslter – Illustrative US Civil War Tom Lovell – Western Genre William Medcalf – Illustrator-Story Fritz Willis – Pin-Up Girl Illustration Raoul Dufy – Fauve Painting Serge Poliakoff – Abstract Painting Dennis Hopper – Acting, Painting Henri-Jean Martin - Neo-Impressionist Carl Hantman – Indian-Western Genre Nicola Simbari – Landscape and Figure Harry Schaare – Pulp Magazine Illustration Noel Mahaffey – Urbanscape, Nocturne Pieter Neefs II – Flemish Painter George Wesley Bellows – Genre, Portrait Brad Howe – Abstract Sculpture, Mobiles Peter Wegner – Paintings, Collages Jim Sanborn – Monumental Sculptures Keith Haring – Pop-Modern Mark di Suvero – Geometric Sculpture Raul Anguiano – Mexican Historical Jose Luis Cuevas – Grotesque, Neo-Figurative Leonardo Nierman – Expressionist Diego Rivera – Social Realist Mural Jesus Urbieta – Abstract Lawrence Weiner – Sculptor, Word Imagery Hans Hofmann – Abstract Expressionist David Hockney – Pop Art Frank Lloyd Wright – Abstract Drawing Jorinde Voigt – Abstract Drawing Harry Bertoia – Sculpture-Kinetic John Chamberlain – Crushed Automobile Agnes Bernice Martin – Grid Images George Rickey – Sculptor-Kinetic Alexander Calder – Sculptor-Kinetic Robert Lenkiewicz – Portrait, Figure David Remfry – Modernist Figure Leslie Hawk – Sculpture Jun Kaneko – Ceramic Sculptural Alex Katz – Post Modernist Figure Frank Stella – Geometric, Collage Jacob Adriaensz Backer – Figure Edouard Cortes – Street Scene Oleg Zhivetin – Abstract Robert Henri – Portrait, Realist Maurice Prendergast – Modernist Robert Havell – Engraving, Wildlife Winslow Homer – Genre, Marine Jesse Talbot – Inspiring Landscapes Carl Clemens Moritz Rungius – Wildlife Jasper Francis Cropsey - Landscapes Newell Convers Wyeth – Illustrator, Murals Emile-Antoine Bourdelle – Sculpture Dennis Collier – Wood Carving, Wildlife Adolph Alexander Weinman – Sculpture Julius Theodore Melchers – Sculpture Albert Bierstadt – Western Landscapes John Ford Clymer – Genre-West, Wildlife George Catlin – Indian Genre-Figure George Copeland Ault – Precisionist George Cope – Trompe Still Life Richard Edward Miller – Figure-Female Everett Shinn – Urban Genre, Mural Thomas Sully – Portrait, Historical John Ferguson Weir – Portrait, Genre Edward Henry Potthast – Shorescape Childe Hassam – Impressionist Arthur Burdett Frost – Genre-Outdoor, Illustrator Jean-Gabriel Domergue – Parisien Alec Monopoly – Urban Art Peter Tunney – Graphic Art Bernard Buffet – Abstract Figural John Lennon – Illustrator Milton Avery – Abstract Sea-Landscape, Nudes Egon Schiele – Landscapes, Portraits Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes Some Items and Collections Appraised (updated, March 2017) - Oscar Wilde hand written letters - Viola, attributed to Laurentius Guadagnini, 18th century - 16 Faberge Eggs - 77 carved ivory figurines - Lowery Director LC35 organ - Thomas Jefferson signed personal letter - 75 assorted signed Sports Memorabilia items - 1945 C.F. Martin & Co. model 000-28 acoustic guitar - 25,600 pair of designer flip flop sandals - 41 assorted shot guns, rifles, and hand guns - Yamaha C-7 concert grand piano - Peters, Cragg & Co. 1872 grand piano - “The Bill of Rights”, Property of State of North Carolina - 1977 Gibson Les Paul Custom guitar - 19th century carousel horse - 1860 Colt Army 44 caliber revolver - 20” Bebe original doll with Jumeau labeled body - Log book and flag, S.S. Roanoke steamship (19th century) - Salvi Arianna Concert Grand Pedal Harp - Men’s Rolex Oyster Explorer II watch, model 16570 - 1929 Ford Model A auto, restored - 1956 Gibson Les Paul Junior vintage sunburst guitar - Abraham Lincoln hand written letter - King George II 1734 Indenture - Thomas Percival signed mantle clock, circa 1800 - Baldwin model C152 Baby Grand Piano, circa 1926-27 - NY Islanders season tickets and VIP parking passes - “True Companion” (two people) mausoleum crypt - Bronze Astrolabe, maker Sabastia De Goes, dated 1656 - Hand-blown 30 ft. long glass replica of Churchhill Downs - SciFi author Harlan Ellison’s typewriter - Massachusetts Land Grant from 1646 - Baccarat bronze and crystal chandelier, circa 1890 - 1965 Fender Stratocaster, custom Olympic White - George Washington signed letter, dated 24 September 1781 - Rolex Submariner watch, model 16610 - Civil War Medal of Honor - 19th Century Naval Victory Medal - 19th Century Plantation Canoe - 5,000+ Sports Memorabilia Collection - Furnishings of 200+ Unit Apartment Complex - Tiffany Studios, NY Table Lamp - Lamborghini Diablo VT Automobile - Freighliner 30 Ft. Diesel RV/Motor Home - Marine Technology 39 Ft. High Performance Boat - Custom-Built Chopper Motorcycle - Kenworth Company 7.2L Truck - $750K of Gold Bullion - Pele signed World Cup Jersey Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes - 10,000+ Stamp Collection in 12 volumes - Commerical Grade Washers/Dryers in Laundromat - Luxury Safe Solitaire by Buben & Zorweg - Mihaly Remenyi Violin - Intellectual Property for Published Non-Fiction Books - 150 Vintage/Antique Metal Advertising Signs - 2004 MLB World Series Ring - John Lennon Original Ink/Paper Drawing - Exterior Building Mural - 12,136 Kilograms of Titanium - Renault Billancourt Carrosserie Auto (Original from set of Titanic Movie) - 1928 Stutz Automobile, Vertical Eight Duck Tail Model - Nobel Peace Prize Expert Witness Assignments Circuit Court, 11th Judicial Circuit, Miami-Dade Co., FL, Case #12-26673 CA 10, Partnership Dissolution, Al Copeland Investments, Inc v. Jeffrey Soffer, expert for Al Copeland Investments, 9/12/14 Circuit Court, 17th Judicial Circuit, Broward Co., FL, Case #FMCE14-000003, Marital Dissolution, Rosaler v. Rosaler, expert for Sharon Rosaler (Mark London, Esq.), 12/22/14 Circuit Court, 17th Judicial Circuit, Broward Co., FL Case #FMCE 13-000123 (44), Marital Dissolution, Meli v. Meli, expert for Paul Meli (Joel Kirschbaum, Esq.), 4/29/15 Circuit Court, 15th Judicial Circuit, Palm Beach Co., FL Case #502014DR008045XXXXSB, Marital Dissolution, Gatz v. Gatz, expert for Bart Gatz (Adam Jacobson, Esq.), 6/5/15 Circuit Court, 17th Judicial Circuit, Broward Co., FL Case #FMCE 12-014787 (38/90), Marital Dissolution, Goodman v. Goodman, expert for Ornella Goodman (Katherine Birnbaum, Esq.), 6/26/15 Circuit Court, 6th Judicial Circuit, Pinellas Co. FL, Case #09-012156-CI-19, Leasehold Dissolution, Park Place Property, LLP v. Gregory W. Nestor MD LLC, expert for Park Place Property, (Bush Ross) 8/10/15 Circuit Court, 10th Judicial Circuit, Highlands Co. FL, Case #FC-13-1319, Marital Dissolution, Compton v. Compton, expert for Hosmer Lee Compton, (Rafool & Hernandez), 9/22/15 Circuit Court, 17th Judicial Circuit, Broward Co. FL, Case #14 CA 006668 (09), Damage Dispute, Tiffani Fleagane v. Carpen, expert for Tiffani Fleagane, 4/8/16 Circuit Court, 20th Judicial Circuit, Charlotte Co., FL Case #14-3005-CA, Grabin v. Grabin, Marital Dissolution, expert for Gary Grabin (Charles T. Boyle, Esq.), 6/28/16 Olivia Nugent (888) 353-7152, info@nugentappraisal.com, Pre-Damage FMV for Insurance Purposes Universal North America 101 Paramount Dr. Ste 220 Sarasota, FL 34232 DATE: 10/18/2018 Attn.: Rebecca DeCramer RE: Insured: CLARDY MALUGEN Claim #: 1802FL22000059 Policy #: UIBD0010450 Type of Loss: WATER D.O.L: 2/5/2018 Loss Location: 214 CELEBRATION BLVD CELEBRATION, FL 34747 FIRST & FINAL REVISED SUPPLEMENT REPORT UPDATED 10/17/2018: Received email from DA requesting the following: Please update the estimate to include the hallway and the foyer for the walls and ceilings. Rebecca DeCramer Items added to estimate and highlighted in bold. Task completed 10/18/2018. Dwelling reserve revised below.*** Prior payment of $10,746.07 has been added to the estimate. UPDATED 3/2/18: Received email from DA requesting the following: Lee, I left you a message regarding this claim today. I paid the insured based on the original estimate however, she sent me the attached photo showing ceiling texture which we did not account for in the estimate. Please revise and include kitchen/family room as I believe the ceiling is continuous in these 2 areas. She h