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Filing # 161074886 E-Filed 11/11/2022 11:19:08 AM
IN THE CIRCUIT COURT OF THE
5™ JUDICIAL CiRCUIT IN AND FOR
LAKE COUNTY, FLORIDA
THE DIOCESE OF CENTRAL FLORIDA,
Case No. 35-2021-CA-001639
PLAINTIFF,
V.
CERTAIN UNDERWRITERS AT LLOYD’S, LONDON
SUBSCRIBING TO POLIcy No. MSRC-2830-00-00,
DEFENDANTS. |
DEFENDANTS’ EXPERT WITNESS REQUEST FOR PRODUCTION OF DOCUMENTS
Defendants, CERTAIN UNDERWRITERS AT LLOYD’s, LONDON SUBSCRIBING TO POLICY
No. MSRC-2830-00-00, requests that Plaintiff, THE Diocese OF CENTRAL FLORIDA, within
the time provided by Fla. R. Civ. P. 1.350, produce the following documents at the
offices of undersigned counsel.
1 A copy of the Curriculum Vitae of each expert retained by you in this
matter.
2 A copy of each Expert Witness’ engagement letter, contract, and other
written agreement for this matter.
3 Copies of all reports relating to this matter prepared by each expert
retained by you.
4 Copies of all documents, exhibits and/or other documents, including
electronic documents, each expert is expected to potentially use as a demonstrative aid
or to be admitted into evidence at the hearing in this cause.
5. Complete copies of all materials provided to any and all Expert Witnesses,
including but not limited to records, reports, correspondence, notes, memoranda,
research and any and all other materials of whatsoever kind or nature, reviewed or
utilized by said Expert Witnesses in this matter. This includes electronic and physical
materials provided to each Expert Witness.
6 Copy of any notes prepared by the Expert(s) during the course of his
review in this matter, including any calculations or mathematics.
7. All writings and/or conclusions made regarding the issues involved herein
or any other materials used in arriving at said Expert Witnesses’ opinions in the instant
BERK, MERCHANT |&|Srms
2 Alhambra Plaza, Suite 700 ¢ CORAL GABLES, FLORIDA 33134 # PHONE: 786.338.2900 @ FAX: 786.338.2888
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 11/14/2022 02:39:07 PM.
Case No. 2021-CA-001639-AXXX-XX
THE DIOCESE OF CENTRAL FLA. V CERT. Uwrs AT LLoYD’s, LONDON
Page 2 of 2
matter, and all materials prepared by or for said Expert Witnesses with regard to any
issue with respect to the above-captioned matter.
8 Color copies of all photographs, illustrations, drawings, sketches, and
other similar items reviewed by each Expert Witness in the course of his assignment on
this matter.
9 A complete copy, cover to cover, of the file for each testifying expert who
was retained by Plaintiff for the subject litigation, whether kept in paper form, electronic
form or other means.
10. Complete statement of all billings and charges for each Expert Witnesses’
work in this case.
Respectfully submitted,
BERK, MERCHANT & Sims, PLC.
/s/ Patrick E. BETAR
Patrick E. Betar / FBN: 11073
Laura C. Tapia / FBN: 968676
2 Alhambra Plaza, Suite 700
Coral Gables, Florida 33134
Tel: (786) 338-2900 / Fax: (786) 338-2888
Email: pbetar@berklawfirm.com
kmendez@berklawfirm.com
ltapia@berklawfirm.com
norwitch@berklawfirm.com
Counsel for Defendants
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was served via
email on this 11" day of November, 2022 to:
Jeremy T. Schilling / FBN: 0098111
Aaron D. Silvers / FBN: 104811
SCHILLING & SILVERS, PLLC
1700 NW 64" Street, Suite 460
Fort Lauderdale, FL 33301
Tel: (954) 712-8877
E-Mail: jschilling@schillingsilvers.com
dadams@schillingsilvers.com
Counsel for Plaintiff
/s/ PATRICK E. BETAR
BERK, MERCHANT e| Sims
2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 ePHONE: 786.338.2900 ¢ FAX: 786.338.2888
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Filing # 161074886 E-Filed 11/11/2022 11:19:08 AM IN THE CIRCUIT COURT OF THE 5™ JUDICIAL CiRCUIT IN AND FOR LAKE COUNTY, FLORIDA THE DIOCESE OF CENTRAL FLORIDA, Case No. 35-2021-CA-001639 PLAINTIFF, V. CERTAIN UNDERWRITERS AT LLOYD’S, LONDON SUBSCRIBING TO POLIcy No. MSRC-2830-00-00, DEFENDANTS. | DEFENDANTS’ EXPERT WITNESS REQUEST FOR PRODUCTION OF DOCUMENTS Defendants, CERTAIN UNDERWRITERS AT LLOYD’s, LONDON SUBSCRIBING TO POLICY No. MSRC-2830-00-00, requests that Plaintiff, THE Diocese OF CENTRAL FLORIDA, within the time provided by Fla. R. Civ. P. 1.350, produce the following documents at the offices of undersigned counsel. 1 A copy of the Curriculum Vitae of each expert retained by you in this matter. 2 A copy of each Expert Witness’ engagement letter, contract, and other written agreement for this matter. 3 Copies of all reports relating to this matter prepared by each expert retained by you. 4 Copies of all documents, exhibits and/or other documents, including electronic documents, each expert is expected to potentially use as a demonstrative aid or to be admitted into evidence at the hearing in this cause. 5. Complete copies of all materials provided to any and all Expert Witnesses, including but not limited to records, reports, correspondence, notes, memoranda, research and any and all other materials of whatsoever kind or nature, reviewed or utilized by said Expert Witnesses in this matter. This includes electronic and physical materials provided to each Expert Witness. 6 Copy of any notes prepared by the Expert(s) during the course of his review in this matter, including any calculations or mathematics. 7. All writings and/or conclusions made regarding the issues involved herein or any other materials used in arriving at said Expert Witnesses’ opinions in the instant BERK, MERCHANT |&|Srms 2 Alhambra Plaza, Suite 700 ¢ CORAL GABLES, FLORIDA 33134 # PHONE: 786.338.2900 @ FAX: 786.338.2888 FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 11/14/2022 02:39:07 PM. Case No. 2021-CA-001639-AXXX-XX THE DIOCESE OF CENTRAL FLA. V CERT. Uwrs AT LLoYD’s, LONDON Page 2 of 2 matter, and all materials prepared by or for said Expert Witnesses with regard to any issue with respect to the above-captioned matter. 8 Color copies of all photographs, illustrations, drawings, sketches, and other similar items reviewed by each Expert Witness in the course of his assignment on this matter. 9 A complete copy, cover to cover, of the file for each testifying expert who was retained by Plaintiff for the subject litigation, whether kept in paper form, electronic form or other means. 10. Complete statement of all billings and charges for each Expert Witnesses’ work in this case. Respectfully submitted, BERK, MERCHANT & Sims, PLC. /s/ Patrick E. BETAR Patrick E. Betar / FBN: 11073 Laura C. Tapia / FBN: 968676 2 Alhambra Plaza, Suite 700 Coral Gables, Florida 33134 Tel: (786) 338-2900 / Fax: (786) 338-2888 Email: pbetar@berklawfirm.com kmendez@berklawfirm.com ltapia@berklawfirm.com norwitch@berklawfirm.com Counsel for Defendants CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was served via email on this 11" day of November, 2022 to: Jeremy T. Schilling / FBN: 0098111 Aaron D. Silvers / FBN: 104811 SCHILLING & SILVERS, PLLC 1700 NW 64" Street, Suite 460 Fort Lauderdale, FL 33301 Tel: (954) 712-8877 E-Mail: jschilling@schillingsilvers.com dadams@schillingsilvers.com Counsel for Plaintiff /s/ PATRICK E. BETAR BERK, MERCHANT e| Sims 2 ALHAMBRA PLAZA, SUITE 700 ¢ CORAL GABLES, FLORIDA 33134 ePHONE: 786.338.2900 ¢ FAX: 786.338.2888