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Filing# 149536770 E-Filed 05/13/2022 10:56:35 AM
IN THE CIRCUIT COURT OF THE 17 IH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
ADRIANA HINCAPIE and NICOLAS HINCAPIE, CIVIL DIVISION
Plaintiffs, CASE NO.: CACE-21-016648
V
JOSEPH BERNARD WEZKIEWICZ,
Defendant.
i
PLAINTIFFS' NOTICE OF SERVING EXPERT WITNESS INTERROGATORIES TO
DEFENDANT, JOSEPH BERNARD WEZKIEWICZ, III
ADRIANA
The Plaintiffs, HINCAPIE and NICOLAS HINCAPIE, by and through the
undersigned counsel and pursuant to Fla. R. Civ. P. § 1.280(b)(4),hereby give notice of
propounding Expert Witness Interrogatories
upon the Defendant, JOSEPH BERNARD
WEZKIEWICZ, III.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically
submitted on this 13th day ofMay, 2022, to: Sheri L. Critelli,
Esq.,Nicholas J. Ryan &
Associates,
110 SE 6th Street, Suite 2100, Fort Lauderdale, FL 33301; flor.law-
shericritelli.2980 19@statefarm.com.
RUBENSTEIN LAW, P.A.
Attorneys for Plaintiffs
261 N. UniversityDrive, Suite 700
Plantation,FL 33324
Phone: (305) 661-6000
Fax: (305) 670-7555
Email: mfagrait@rubensteinlaw.corn
lbanciella@rubensteinlaw.com
com
eservice(*rubensteinlaw.
By-. /sl Miriam Fresco Agrait
MIRIAM FRESCO AGRAIT
Florida Bar No.. 91428
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/13/2022 10:56:35 AM.****
PLAINTIFFS' EXPERT WITNESS INTERROGATORIES
TO DEFENDANT, JOSEPH BERNARD WEZKIEWICZ, III
1. Please identifyeach person whom you expect to call as an expert witness at the trial,
providing his/her name, street address and telephone number and (a) state the subjectmatter on
which each expert identified is expected to testify,
(b) the substance of the facts and opinionsto
which each expert is expected to testify
and a summary of the grounds for each opinion.
a. The subjectmatter to which each expert will testify.
b. The substance of the facts and opinions to which each expert will testify
C A summary of the grounds for each opinion.
2. State in detail,the educational background, training,and/or experience,of each person
identifiedabove which qualifies him/her as an expert and identifyfor each person listed above the
field oftheir professionand occupation. (You
expertise, may attach a Curriculum Vitae in lieu of
answering the question).
3 Please give a detailed list of all publicationsin which each expert identified above has
authored, or co-authored and the name of the publicationin which the article has appeared,or the
name ofthe publisherwho has publishedthe article,and enough information about the publication
to enable the to obtain a copy of it.
Plaintiff(s)
4. Please state the state county, cityand court styleofthe case, and case number of every case
that each ofthe experts listed above has been identified either by answers to expert interrogatories
or by the fact that they have presentedthemselves and given a depositionand/or trial in the three
(3)years precedingthe date ofthese interrogatories.
5. Has the expert served as an expert witness in case in the past three (3)
any other litigated
years? If so, pleasestate:
a. The styleof the case, the court in which it was filed,and the names and addresses
of the attorneys involved.
b. Whether the expert testified for the plaintiff
or defense whether depositionor trial.
C The area or field in which he held himself out to be an expert.
6. State the experienceincludingthe percentage of work performed
expert'slitigation for
and
plaintiffs defendants.
7. State with as much specificity
as possiblethe portionof the
expert'sinvolvement as an
expert witness. This should include approximationsof (1)the number ofmonthly hours dedicated
to work as an expert witness, (2)the percentage annuallyoftotal professional/worktime dedicated
towork as an expert witness, and (3)the percentage annuallyof income derived from servingas
an expert witness.
8 Please state with specificity
the compensation paid to each expert in this case. State the
date and amount of all payments to date as well as the basis for all sums outstandingnot yet paid
with the hourly rates.
9- With respect to the opinions/findings
of each expert identified,
pleasefumish:
(a) A complete statement of all opinions to be expressed and the basis and reasons
therefore.
(b) Thedate or other information considered by the witness in forming the opinions.
(c) Any exhibits to be used as a summary of or support for any ofthe opinions.
10. Did the expert submit a report settingforth his opinions or conclusions reached from his
examination or any tests he conducted? If so, please state:
(a) The date the report was submitted.
(b) The name or other means of identification of the person to whom this report was
submitted.
(c) The name and address of the person who has present custody of the report.
11. Please attach a copy of any reports made by each expert on the basis of his tests,
examination or analysisto your answer to these interrogatories.
12. Is each expert listed above to be compensated for their work and efforts in connection with
this action? If so, pleasestate:
(a) How much is he to be paid?
(b) Ifhe has not been paid,then give the basis for payment, such as hourly rate, weekly
rate, etc.
(c) How much money, if any, is not yet paid to each expert.
13. Please state the hourly rate each of your expert requests for:
(a) Deposition?
(b) What is the minimum fee requiredfor deposition?
(c) Videotape Deposition?
(d) Trial?
(e) What is the minimum fee requiredfor Trial?
(f) Review of records/ photographs,etc
(g) Conference with attorney
(h) Answering Interrogatories
(I) Preparing for Deposition/Trial
14. Ifthe expert is a physician,what is the charge for:
(a) Compulsory Medical Examination (formerly known as Independent Medical
Examination)
(b) Review of X-rays
(c) Review of MRI
(d) Review of Medical Records
15. To the extent you have a medical expert, state:
(a) State the number of CME's (CPE's) that each ofyour expert witnesses performs in
one year.
(b) State the number of CME's (CPE's) that each ofyour expert witnesses performs in
one month.
(c) State the number of CME's (CPE's) that each of your expert witnesses performed
in the last three (3)years.
16. As identifythose whose testimony is expected to be
to each such expert listed above,
and those whose testimony is expectedto be offered in person at trial.
offered by deposition
17. Please identifyevery case in which Defendants' retained experts and members of said
expert's organizationhave testified at depositionduring the last three years for Defendants,
Defendants' law firm or by Defendants' insurance carrier. See Springerv. West, 769 So. 2d 1068,
Morgan Colling& Gilbert v. Pope, 798 So. 2d 1 (Fla.2d DCA 2001).
18. Please identifyevery case in which Defendants' retained experts and members of said
have testified as a retained expert witness by depositionduringthe last three
expert'sorganization
yearsby Defendants, Defendants' law firm or by Defendants' insurance carrier. See Springerv.
West, 769 So. 2d 1068, Morgan Colling & Gilbert v. Pope, 798 So. 2d 1 (Fla.2d DCA 2001).
19. Please identifythe amounts paid to Defendants' retained experts and members of said
expert'sorganizationfor services as an expert witness during the last three years by Defendants,
Defendants' law firm or by Defendants' insurance carrier. See Springerv. West, 769 So. 2d 1068,
Morgan Colling & Gilbert v. Pope, 798 So. 2d 1 (Fla.2d DCA 2001).
20. Please identifythenumber of litigation cases where Defendants' retained experts and
members of said expert's organizationhave performed an analysis,examination or rendered
opinions as a retained expert witness during the last three years by Defendants, Defendants' law
firm or by Defendants' insurance carrier. See Springerv. West, 769 So. 2d 1068, Morgan Colling
& Gilbert v. Pope, 798 So. 2d 1 (Fla.2d DCA 2001).
21. Please identifyevery case where Defendants' retained experts and members of said
expert'sorganizationhave testified at trial as a retained expert witness during the last three years
for Defendants, Defendants' law firm or by Defendants' insurance carrier. See Springerv. West,
769 So. 2d 1068 (Fla-5th DCA 2000),Morgan Colling & Gilbert v. Pope, 798 So. 2d 1 (Fla.2d
DCA 2001).
22. State the date that each Defense expert was first retained by Defense counsel in connection
with the instant lawsuit.
AFFIANT
STATE OF FLORIDA
)SS
COUNTY OF
BEFORE ME the undersignedauthority,
personallyappeared ,on
the day of , 201-, who has produced as
identification and who did/did not take an oath,deposes and says that he/she has read the foregoing
Answers to Interrogatories
and that the statements and facts therein contained are true and correct
to the best of his/her knowledge and that he/she is the person in and who executed the same.
SWORN AND SUBSCRIBED TO BEFORE ME this dayor , 20 .
NOTARY PUBLIC, State of Florida
(Signature)
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Filing# 149536770 E-Filed 05/13/2022 10:56:35 AM IN THE CIRCUIT COURT OF THE 17 IH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ADRIANA HINCAPIE and NICOLAS HINCAPIE, CIVIL DIVISION Plaintiffs, CASE NO.: CACE-21-016648 V JOSEPH BERNARD WEZKIEWICZ, Defendant. i PLAINTIFFS' NOTICE OF SERVING EXPERT WITNESS INTERROGATORIES TO DEFENDANT, JOSEPH BERNARD WEZKIEWICZ, III ADRIANA The Plaintiffs, HINCAPIE and NICOLAS HINCAPIE, by and through the undersigned counsel and pursuant to Fla. R. Civ. P. § 1.280(b)(4),hereby give notice of propounding Expert Witness Interrogatories upon the Defendant, JOSEPH BERNARD WEZKIEWICZ, III. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically submitted on this 13th day ofMay, 2022, to: Sheri L. Critelli, Esq.,Nicholas J. Ryan & Associates, 110 SE 6th Street, Suite 2100, Fort Lauderdale, FL 33301; flor.law- shericritelli.2980 19@statefarm.com. RUBENSTEIN LAW, P.A. Attorneys for Plaintiffs 261 N. UniversityDrive, Suite 700 Plantation,FL 33324 Phone: (305) 661-6000 Fax: (305) 670-7555 Email: mfagrait@rubensteinlaw.corn lbanciella@rubensteinlaw.com com eservice(*rubensteinlaw. By-. /sl Miriam Fresco Agrait MIRIAM FRESCO AGRAIT Florida Bar No.. 91428 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/13/2022 10:56:35 AM.**** PLAINTIFFS' EXPERT WITNESS INTERROGATORIES TO DEFENDANT, JOSEPH BERNARD WEZKIEWICZ, III 1. Please identifyeach person whom you expect to call as an expert witness at the trial, providing his/her name, street address and telephone number and (a) state the subjectmatter on which each expert identified is expected to testify, (b) the substance of the facts and opinionsto which each expert is expected to testify and a summary of the grounds for each opinion. a. The subjectmatter to which each expert will testify. b. The substance of the facts and opinions to which each expert will testify C A summary of the grounds for each opinion. 2. State in detail,the educational background, training,and/or experience,of each person identifiedabove which qualifies him/her as an expert and identifyfor each person listed above the field oftheir professionand occupation. (You expertise, may attach a Curriculum Vitae in lieu of answering the question). 3 Please give a detailed list of all publicationsin which each expert identified above has authored, or co-authored and the name of the publicationin which the article has appeared,or the name ofthe publisherwho has publishedthe article,and enough information about the publication to enable the to obtain a copy of it. Plaintiff(s) 4. Please state the state county, cityand court styleofthe case, and case number of every case that each ofthe experts listed above has been identified either by answers to expert interrogatories or by the fact that they have presentedthemselves and given a depositionand/or trial in the three (3)years precedingthe date ofthese interrogatories. 5. Has the expert served as an expert witness in case in the past three (3) any other litigated years? If so, pleasestate: a. The styleof the case, the court in which it was filed,and the names and addresses of the attorneys involved. b. Whether the expert testified for the plaintiff or defense whether depositionor trial. C The area or field in which he held himself out to be an expert. 6. State the experienceincludingthe percentage of work performed expert'slitigation for and plaintiffs defendants. 7. State with as much specificity as possiblethe portionof the expert'sinvolvement as an expert witness. This should include approximationsof (1)the number ofmonthly hours dedicated to work as an expert witness, (2)the percentage annuallyoftotal professional/worktime dedicated towork as an expert witness, and (3)the percentage annuallyof income derived from servingas an expert witness. 8 Please state with specificity the compensation paid to each expert in this case. State the date and amount of all payments to date as well as the basis for all sums outstandingnot yet paid with the hourly rates. 9- With respect to the opinions/findings of each expert identified, pleasefumish: (a) A complete statement of all opinions to be expressed and the basis and reasons therefore. (b) Thedate or other information considered by the witness in forming the opinions. (c) Any exhibits to be used as a summary of or support for any ofthe opinions. 10. Did the expert submit a report settingforth his opinions or conclusions reached from his examination or any tests he conducted? If so, please state: (a) The date the report was submitted. (b) The name or other means of identification of the person to whom this report was submitted. (c) The name and address of the person who has present custody of the report. 11. Please attach a copy of any reports made by each expert on the basis of his tests, examination or analysisto your answer to these interrogatories. 12. Is each expert listed above to be compensated for their work and efforts in connection with this action? If so, pleasestate: (a) How much is he to be paid? (b) Ifhe has not been paid,then give the basis for payment, such as hourly rate, weekly rate, etc. (c) How much money, if any, is not yet paid to each expert. 13. Please state the hourly rate each of your expert requests for: (a) Deposition? (b) What is the minimum fee requiredfor deposition? (c) Videotape Deposition? (d) Trial? (e) What is the minimum fee requiredfor Trial? (f) Review of records/ photographs,etc (g) Conference with attorney (h) Answering Interrogatories (I) Preparing for Deposition/Trial 14. Ifthe expert is a physician,what is the charge for: (a) Compulsory Medical Examination (formerly known as Independent Medical Examination) (b) Review of X-rays (c) Review of MRI (d) Review of Medical Records 15. To the extent you have a medical expert, state: (a) State the number of CME's (CPE's) that each ofyour expert witnesses performs in one year. (b) State the number of CME's (CPE's) that each ofyour expert witnesses performs in one month. (c) State the number of CME's (CPE's) that each of your expert witnesses performed in the last three (3)years. 16. As identifythose whose testimony is expected to be to each such expert listed above, and those whose testimony is expectedto be offered in person at trial. offered by deposition 17. Please identifyevery case in which Defendants' retained experts and members of said expert's organizationhave testified at depositionduring the last three years for Defendants, Defendants' law firm or by Defendants' insurance carrier. See Springerv. West, 769 So. 2d 1068, Morgan Colling& Gilbert v. Pope, 798 So. 2d 1 (Fla.2d DCA 2001). 18. Please identifyevery case in which Defendants' retained experts and members of said have testified as a retained expert witness by depositionduringthe last three expert'sorganization yearsby Defendants, Defendants' law firm or by Defendants' insurance carrier. See Springerv. West, 769 So. 2d 1068, Morgan Colling & Gilbert v. Pope, 798 So. 2d 1 (Fla.2d DCA 2001). 19. Please identifythe amounts paid to Defendants' retained experts and members of said expert'sorganizationfor services as an expert witness during the last three years by Defendants, Defendants' law firm or by Defendants' insurance carrier. See Springerv. West, 769 So. 2d 1068, Morgan Colling & Gilbert v. Pope, 798 So. 2d 1 (Fla.2d DCA 2001). 20. Please identifythenumber of litigation cases where Defendants' retained experts and members of said expert's organizationhave performed an analysis,examination or rendered opinions as a retained expert witness during the last three years by Defendants, Defendants' law firm or by Defendants' insurance carrier. See Springerv. West, 769 So. 2d 1068, Morgan Colling & Gilbert v. Pope, 798 So. 2d 1 (Fla.2d DCA 2001). 21. Please identifyevery case where Defendants' retained experts and members of said expert'sorganizationhave testified at trial as a retained expert witness during the last three years for Defendants, Defendants' law firm or by Defendants' insurance carrier. See Springerv. West, 769 So. 2d 1068 (Fla-5th DCA 2000),Morgan Colling & Gilbert v. Pope, 798 So. 2d 1 (Fla.2d DCA 2001). 22. State the date that each Defense expert was first retained by Defense counsel in connection with the instant lawsuit. AFFIANT STATE OF FLORIDA )SS COUNTY OF BEFORE ME the undersignedauthority, personallyappeared ,on the day of , 201-, who has produced as identification and who did/did not take an oath,deposes and says that he/she has read the foregoing Answers to Interrogatories and that the statements and facts therein contained are true and correct to the best of his/her knowledge and that he/she is the person in and who executed the same. SWORN AND SUBSCRIBED TO BEFORE ME this dayor , 20 . NOTARY PUBLIC, State of Florida (Signature) (Print)