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Filing# 174269813 E-Filed 05/31/2023 11:00:24 AM
In The Circuit Court OfThe 17thJudicial Circuit
In And For Broward County, Florida
PETER AND MONICA TREPPEDA,
Case No.: CACE-21-007431
Plaintiff(s),
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
PLAINTIFFS PETER TREPPEDA AND MONICA TREPPEDA'S NOTICE OF
SERVING ANSWERS TO DEFENDANT'S EXPERT INTERROGATORIES
Pursuant to Florida Rules of Civil Procedure, Plaintiff Peter Treppeda and Monica Treppeda
by and through its undersignedcounsel, hereby givesnotice of servingits Answers to Defendant's
Expert Interrogatoriesl.
Respectfully submitted,
Property People FL, PA.
AmmgsM Plaintijf
117 NE 1st Ave, Unit 15-104
Miami, FL 33132
Telephone: 844.776.7364
E-Service: Service@PropertyPeopleLaw.com
By: /s/ Annette M. Vera
Annette M. Vera, Esq.
Florida Bar No. 118474
Email: Annette@PropertyPeopleLaw.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this May 31, 2023, a true and correct copy of the foregoing
has been furnished via electronic mail to Rafael Reyes, Esq.,Attorney for Defendant at
upciceservice01@universalproperty.coin,
vb0221@universalproperty.com,
rr0308@universalproperty.com.
/s/ Annette M. Vera
Annette M. Vera
1
Due to social distancing measures compelled by the COVID-19 pandemic, Plaintiffs' signaturescould not be
notarized. When circumstances safelyallow, a verification page to confirm notarized answers to interrogatories
will
be served.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/31/2023 11:00:23 AM.****
GENERAL OBJECTIONS
1. Plaintiff objectsto each document request,
instruction, definition, and interrogatory to the extent
that it purports to impose greater than or different from those
any requirementor discoveryobligation
under the Federal Rules of Civil Procedure and the applicable
Rules and Orders of the Court.
2. Plaintiff objects to each document request and interrogatory
that is overly broad, unduly
burdensome, or not reasonablycalculated to lead to the discoveryof admissible evidence.
3. Plaintiff objectsto each document request to the extent that it calls for production of a privilege
log for internal documents of Plaintiff. A request for such a log is unreasonable and unduly
burdensome in lightof the work product doctrine, governmental deliberative process privilege,
and
protectingsuch internal documents from discovery.
other privileges
4. Plaintiff objectsto each instruction, definition,document request, and interrogatory to the extent
that it seeks documents protectedfrom disclosure by the attorney-client deliberative process
privilege,
attorney work productdoctrine,or any other applicable
privilege, Should any such disclosure
privilege.
by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege.
5. Plaintiff objectsto each instruction,definition,document request, and interrogatory
as overbroad
and unduly burdensome to the extent it seeks documents or information that are readilyor more
accessible to Defendant from Defendant's own files,
from documents or information in Defendant's
or from documents or information
possession, that Defendant previously
produced to Plaintiff.
6. Defendant's document requests and interrogatory
call for the production of documents and
information that were produced to the Plaintiff by other entities and that may contain confidential,
or trade
proprietary, secret information.
7. To the extent any of Defendant's document requests or its interrogatory
seek documents or answers
that include expert material,includingbut not limited to survey materials,Plaintiff objectsto any such
requests and interrogatory
as premature and expressly
reserves the rightto supplement,clarify,
revise,
or correct any or all responses to such requests, and to assert additional objectionsor privileges,
in
one or more subsequent supplementalresponse(s)in accordance with the time period for exchanging
expert reports set by the Court.
8. Plaintiff incorporatesby reference every generalobjectionset forth above into each specific
response set forth below. A response may repeat
specific a generalobjectionfor emphasis or some
other reason. The failure to include response does not waive any
any generalobjectionin any specific
generalobjectionto that request. Moreover, Plaintiff does not waive its rightto amend its responses.
PLAINTIFFS PETER TREPPEDA AND MONICA TREPPEDA'S ANSWERS TO
DEFENDANT'S EXPERT INTERROGATORIES
1. Please state the name and address of any expert witness you expect to call to testify
at the
trial of the above-captionedmatter.
ANSWER: Green Ace, LLC., Harold R. Charles, PE, CGC, ICC, PMP, LEED AP
13611 South Dixie Highway, Suite 509, Miami, FL 33176, 305-204-8115.
2. of the expert witness and set forth the professional
Please state the field of expertise degrees,
specialprofessional trainingand experienceand/or special knowledge or skill of said expert
witness.
ANSWER: Mr. Charles is a certified General Contractor and a Licensed
Professional Engineer in the state of Florida. Please see CV produced in response to
Defendant's Expert Request for Production.
3. Please state the subjectmatter on which said expert witness is
expectedto testify.
ANSWER: Mr. Charles will be testifying
regardingthe condition of the property,
but not limited to the cause of loss
specifically at issue herein,the scope of the loss
and damage, the amount cost to repairthe property and put the property back
it will
condition, the time that it took for the damage to occur for the above-
in its pre-loss
referenced matter, and the necessity of mitigation that the
efforts. It is anticipated
testimonyof the expert witness will be based upon his education, and
training,
as well as his review
experience, of the pertinent documents, records,photographs,
and/or inspection(s) for the above- referenced matter. He will also testify
as a
rebuttal witness and or expert witness to any of Defendant's witnesses/experts.
4. Please state the substance of the facts and opinionto which the said expert witness if
expectedto testify.
ANSWER: Unknown at this time. Mr. Charles will be testifying
regardingthe
but not limited to the cause of loss at issue
condition of the property, specifically
herein, the scope of the loss and damage, the amount it will cost to repairthe
property and put the property back in its pre-loss
condition,the time that it took for
the damage to occur for the above-referenced matter, and the necessityof mitigation
efforts. It is
anticipated that the testimonyof the expert witness will be based upon
his education,
training, and experience, as well as his review of the pertinent
documents, records, photographs,and/or inspection(s) for the above- referenced
matter. He will also testify
as a rebuttal witness and or expert witness to any of
Defendant's witnesses/experts. Plaintiff reserves the rightto
Additionally, amend its
answer to this Request as discoveryis ongoing.
5. Please state the summary of the grounds for each opinionsaid expert witness is to testify
on.
ANSWER: Unknown at this time. Additionally,
Plaintiff reserves the rightto amend
its answer to this Mr.
Interrogatoryas discoveryis ongoing. Notwithstanding,
Charles will be testifyingregardingthe condition of the property, specifically but not
limited to the cause of loss at issue herein, the scope of the loss and damage, the
amount it will cost to repairthe property and put the property back in its pre-loss
condition, the time that it took for the damage to occur for the above-referenced
matter, and the necessity of mitigation efforts. It is anticipatedthat the testimony of
the expert witness will be based upon his training, education, and experience, as well
as his review of the pertinentdocuments, records, photographs,and/or inspection(s)
for the above- referenced matter. He will also testify
as a rebuttal witness and or
expert witness to any of Defendant's witnesses/experts.
6. Please attach a current resume or curriculum vitae for each identified expert.
ANSWER: Please refer to CV of retained experts produced under separate cover.
7. With regardto each expert whose name is given in response to any of the foregoing
interrogatories and if this information is not included on the CV. or the CV is not attached,
pleaseprovide the followinginformation: a. The formal education of said expert in his field
of expertiseand in preparationfor studyin his/her field of expertise. b. Other trainingof
the said expert in his/her field of expertiseor related fields.
ANSWER: Please see CV produced in response to Defendant's Expert Request for
Production.
8. If any expert named in the submitted any report, memorandum,
precedinginterrogatory
pleasestate the name and address of the person to whom the
note or other such writing,
report or writingwas addressed or directed, and the present location of the original
and all
copiesof such writing.
ANSWER: To date, no written report has been created by Plaintiff's expert, Harold
Charles. If one is created,it will be
produced to Defendant immediatelyupon
receipt. Plaintiff reserves the rightto amend its answer to this Request
Additionally,
as discoveryis ongoing.
9. For each person listed in your answer to questionnumber one (1),pleasestate the date the
expert was hired,if applicable.
ANSWER: Please see documents produced in response to Defendant's Expert
Request for Production.
10. Please state whether any of the above-described expert witness has ever testified on behalf
of the attorneys representingany Plaintiff herein. If so, providethe names of the cases in
which priortestimonywas given and the dates.
ANSWER: Please see documents produced in response to Defendant's Expert
Request for Production.
11. Please state whether the above-described expert has previouslytestified live or depositionin
as an expert witness. If so, specify
any other litigation the date,location and case names.
ANSWER: Please see documents produced in response to Defendant's Expert
Request for Production.
12. Please state whether your expert has been disqualified or preventedby any court to testify
as
an expert witness. of case, court and subjectmatter on
If so, pleasestate the date, style
which said expert witness was prevented or disqualified from testifying.
ANSWER: Mr. Charles has not been disqualified
or preventedby any Court to
at an expert witness.
testify
13. For each expert listed in response to interrogatorynumber one (1)pleaseprovidea list of all
the cases in which the expert(s)has been excluded from testifying at trial,
regardlessofwhen,
the
including state, county, city, court of
style the case, and case number of each such case.
ANSWER: Not applicable.
14. List text book
any publications, articles or other written materials prepared or authorized by
the above-described expert witness.
ANSWER: Please refer to CV of retained experts produced under separate cover.
15. List any articles, of whatever nature referred to by the expert
textbooks or other publications
in the formulation of his opinion.
ANSWER: Please see documents produced in response to Defendant's Expert
Request for Production.
16. List all areas in which this witness professesexpertise.
ANSWER: Please refer to CV of retained experts produced under separate cover.
17. State whether you have retained or have specially employed an expert to assist in the
preparation of this cause who is not expected to testify
at trial. If so, state such expert's
name, specialty, present address and telephone number.
ANSWER: Not applicable.
Plaintiff maintains discoveryis ongoing.
18. For each expert listed in response to interrogatory number one (1)pleasestate: a. The rate of
compensation for services provided by the expert; b. The amount billed to date by the
expert, and paid;C. The amount billed to date which remains unpaid;d. The amount of time
for which the expert has worked, which has not yet been billed. e. His/her fees for
depositiontestimony, whether travel time is included, and whether there is a minimum fee;
and f. His/her fees for trial testimony,whether travel time is included, and whether there is a
minimum fee.
ANSWER: Objection.This Interrogatoryis overbroad in scope with respect to
time
subject, and lacks specificity.
Notwithstanding and without waiving said
Mr.
objections, Charles is paid by the hour for his services at $425.00 for Court or
depositionrelated matters.
Preview
Filing# 174269813 E-Filed 05/31/2023 11:00:24 AM In The Circuit Court OfThe 17thJudicial Circuit In And For Broward County, Florida PETER AND MONICA TREPPEDA, Case No.: CACE-21-007431 Plaintiff(s), VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. PLAINTIFFS PETER TREPPEDA AND MONICA TREPPEDA'S NOTICE OF SERVING ANSWERS TO DEFENDANT'S EXPERT INTERROGATORIES Pursuant to Florida Rules of Civil Procedure, Plaintiff Peter Treppeda and Monica Treppeda by and through its undersignedcounsel, hereby givesnotice of servingits Answers to Defendant's Expert Interrogatoriesl. Respectfully submitted, Property People FL, PA. AmmgsM Plaintijf 117 NE 1st Ave, Unit 15-104 Miami, FL 33132 Telephone: 844.776.7364 E-Service: Service@PropertyPeopleLaw.com By: /s/ Annette M. Vera Annette M. Vera, Esq. Florida Bar No. 118474 Email: Annette@PropertyPeopleLaw.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this May 31, 2023, a true and correct copy of the foregoing has been furnished via electronic mail to Rafael Reyes, Esq.,Attorney for Defendant at upciceservice01@universalproperty.coin, vb0221@universalproperty.com, rr0308@universalproperty.com. /s/ Annette M. Vera Annette M. Vera 1 Due to social distancing measures compelled by the COVID-19 pandemic, Plaintiffs' signaturescould not be notarized. When circumstances safelyallow, a verification page to confirm notarized answers to interrogatories will be served. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/31/2023 11:00:23 AM.**** GENERAL OBJECTIONS 1. Plaintiff objectsto each document request, instruction, definition, and interrogatory to the extent that it purports to impose greater than or different from those any requirementor discoveryobligation under the Federal Rules of Civil Procedure and the applicable Rules and Orders of the Court. 2. Plaintiff objects to each document request and interrogatory that is overly broad, unduly burdensome, or not reasonablycalculated to lead to the discoveryof admissible evidence. 3. Plaintiff objectsto each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. A request for such a log is unreasonable and unduly burdensome in lightof the work product doctrine, governmental deliberative process privilege, and protectingsuch internal documents from discovery. other privileges 4. Plaintiff objectsto each instruction, definition,document request, and interrogatory to the extent that it seeks documents protectedfrom disclosure by the attorney-client deliberative process privilege, attorney work productdoctrine,or any other applicable privilege, Should any such disclosure privilege. by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. 5. Plaintiff objectsto each instruction,definition,document request, and interrogatory as overbroad and unduly burdensome to the extent it seeks documents or information that are readilyor more accessible to Defendant from Defendant's own files, from documents or information in Defendant's or from documents or information possession, that Defendant previously produced to Plaintiff. 6. Defendant's document requests and interrogatory call for the production of documents and information that were produced to the Plaintiff by other entities and that may contain confidential, or trade proprietary, secret information. 7. To the extent any of Defendant's document requests or its interrogatory seek documents or answers that include expert material,includingbut not limited to survey materials,Plaintiff objectsto any such requests and interrogatory as premature and expressly reserves the rightto supplement,clarify, revise, or correct any or all responses to such requests, and to assert additional objectionsor privileges, in one or more subsequent supplementalresponse(s)in accordance with the time period for exchanging expert reports set by the Court. 8. Plaintiff incorporatesby reference every generalobjectionset forth above into each specific response set forth below. A response may repeat specific a generalobjectionfor emphasis or some other reason. The failure to include response does not waive any any generalobjectionin any specific generalobjectionto that request. Moreover, Plaintiff does not waive its rightto amend its responses. PLAINTIFFS PETER TREPPEDA AND MONICA TREPPEDA'S ANSWERS TO DEFENDANT'S EXPERT INTERROGATORIES 1. Please state the name and address of any expert witness you expect to call to testify at the trial of the above-captionedmatter. ANSWER: Green Ace, LLC., Harold R. Charles, PE, CGC, ICC, PMP, LEED AP 13611 South Dixie Highway, Suite 509, Miami, FL 33176, 305-204-8115. 2. of the expert witness and set forth the professional Please state the field of expertise degrees, specialprofessional trainingand experienceand/or special knowledge or skill of said expert witness. ANSWER: Mr. Charles is a certified General Contractor and a Licensed Professional Engineer in the state of Florida. Please see CV produced in response to Defendant's Expert Request for Production. 3. Please state the subjectmatter on which said expert witness is expectedto testify. ANSWER: Mr. Charles will be testifying regardingthe condition of the property, but not limited to the cause of loss specifically at issue herein,the scope of the loss and damage, the amount cost to repairthe property and put the property back it will condition, the time that it took for the damage to occur for the above- in its pre-loss referenced matter, and the necessity of mitigation that the efforts. It is anticipated testimonyof the expert witness will be based upon his education, and training, as well as his review experience, of the pertinent documents, records,photographs, and/or inspection(s) for the above- referenced matter. He will also testify as a rebuttal witness and or expert witness to any of Defendant's witnesses/experts. 4. Please state the substance of the facts and opinionto which the said expert witness if expectedto testify. ANSWER: Unknown at this time. Mr. Charles will be testifying regardingthe but not limited to the cause of loss at issue condition of the property, specifically herein, the scope of the loss and damage, the amount it will cost to repairthe property and put the property back in its pre-loss condition,the time that it took for the damage to occur for the above-referenced matter, and the necessityof mitigation efforts. It is anticipated that the testimonyof the expert witness will be based upon his education, training, and experience, as well as his review of the pertinent documents, records, photographs,and/or inspection(s) for the above- referenced matter. He will also testify as a rebuttal witness and or expert witness to any of Defendant's witnesses/experts. Plaintiff reserves the rightto Additionally, amend its answer to this Request as discoveryis ongoing. 5. Please state the summary of the grounds for each opinionsaid expert witness is to testify on. ANSWER: Unknown at this time. Additionally, Plaintiff reserves the rightto amend its answer to this Mr. Interrogatoryas discoveryis ongoing. Notwithstanding, Charles will be testifyingregardingthe condition of the property, specifically but not limited to the cause of loss at issue herein, the scope of the loss and damage, the amount it will cost to repairthe property and put the property back in its pre-loss condition, the time that it took for the damage to occur for the above-referenced matter, and the necessity of mitigation efforts. It is anticipatedthat the testimony of the expert witness will be based upon his training, education, and experience, as well as his review of the pertinentdocuments, records, photographs,and/or inspection(s) for the above- referenced matter. He will also testify as a rebuttal witness and or expert witness to any of Defendant's witnesses/experts. 6. Please attach a current resume or curriculum vitae for each identified expert. ANSWER: Please refer to CV of retained experts produced under separate cover. 7. With regardto each expert whose name is given in response to any of the foregoing interrogatories and if this information is not included on the CV. or the CV is not attached, pleaseprovide the followinginformation: a. The formal education of said expert in his field of expertiseand in preparationfor studyin his/her field of expertise. b. Other trainingof the said expert in his/her field of expertiseor related fields. ANSWER: Please see CV produced in response to Defendant's Expert Request for Production. 8. If any expert named in the submitted any report, memorandum, precedinginterrogatory pleasestate the name and address of the person to whom the note or other such writing, report or writingwas addressed or directed, and the present location of the original and all copiesof such writing. ANSWER: To date, no written report has been created by Plaintiff's expert, Harold Charles. If one is created,it will be produced to Defendant immediatelyupon receipt. Plaintiff reserves the rightto amend its answer to this Request Additionally, as discoveryis ongoing. 9. For each person listed in your answer to questionnumber one (1),pleasestate the date the expert was hired,if applicable. ANSWER: Please see documents produced in response to Defendant's Expert Request for Production. 10. Please state whether any of the above-described expert witness has ever testified on behalf of the attorneys representingany Plaintiff herein. If so, providethe names of the cases in which priortestimonywas given and the dates. ANSWER: Please see documents produced in response to Defendant's Expert Request for Production. 11. Please state whether the above-described expert has previouslytestified live or depositionin as an expert witness. If so, specify any other litigation the date,location and case names. ANSWER: Please see documents produced in response to Defendant's Expert Request for Production. 12. Please state whether your expert has been disqualified or preventedby any court to testify as an expert witness. of case, court and subjectmatter on If so, pleasestate the date, style which said expert witness was prevented or disqualified from testifying. ANSWER: Mr. Charles has not been disqualified or preventedby any Court to at an expert witness. testify 13. For each expert listed in response to interrogatorynumber one (1)pleaseprovidea list of all the cases in which the expert(s)has been excluded from testifying at trial, regardlessofwhen, the including state, county, city, court of style the case, and case number of each such case. ANSWER: Not applicable. 14. List text book any publications, articles or other written materials prepared or authorized by the above-described expert witness. ANSWER: Please refer to CV of retained experts produced under separate cover. 15. List any articles, of whatever nature referred to by the expert textbooks or other publications in the formulation of his opinion. ANSWER: Please see documents produced in response to Defendant's Expert Request for Production. 16. List all areas in which this witness professesexpertise. ANSWER: Please refer to CV of retained experts produced under separate cover. 17. State whether you have retained or have specially employed an expert to assist in the preparation of this cause who is not expected to testify at trial. If so, state such expert's name, specialty, present address and telephone number. ANSWER: Not applicable. Plaintiff maintains discoveryis ongoing. 18. For each expert listed in response to interrogatory number one (1)pleasestate: a. The rate of compensation for services provided by the expert; b. The amount billed to date by the expert, and paid;C. The amount billed to date which remains unpaid;d. The amount of time for which the expert has worked, which has not yet been billed. e. His/her fees for depositiontestimony, whether travel time is included, and whether there is a minimum fee; and f. His/her fees for trial testimony,whether travel time is included, and whether there is a minimum fee. ANSWER: Objection.This Interrogatoryis overbroad in scope with respect to time subject, and lacks specificity. Notwithstanding and without waiving said Mr. objections, Charles is paid by the hour for his services at $425.00 for Court or depositionrelated matters.