On April 13, 2021 a
Party Discovery
was filed
involving a dispute between
Treppeda, Monica,
Treppeda, Peter,
and
United Property & Casualty Insurance Company, Inc.,
Universal Property & Casualty Insurance Company,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing# 168346586 E-Filed 03/09/2023 01:32:21 AM
IN THE CIRCUITCOURT OF THE 17
,TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
PETER AND MONICA TREPPEDA, CASE NO: CACE-21-007431
Plaintiffs,
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
DEFENDANT UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY'S
REQUEST FOR PRODUCTION OF PLAINTIFF'S EXPERT
COMES NOW, the Defendant, UNIVERSAL PROPERTY AND CASUALTY
INSURANCE COMPANY, by and through undersigned counsel, and requests the Plaintiffs,
PETER AND MONICA TREPPEDA, to produce the within thirty(30) days, the following:
1. Any and all documents which evidences Plaintiff' s identified including
experts'expertise
but not limited to a current CV for each expert, as well as a copy of any photo identification
a Florida Driver's license).
(preferable
RESPONSE:
2. Any and all documents which support or tends to support the opinions reached by each
expert listed.
RESPONSE:
3. A complete copy of any and all correspondenceexchanged with each of the Plaintiff' s
expert witness(es)(liability, causation and damage) listed in your Expert Witness
Disclosure and/or which you intend to call at trial which relate to the instant lawsuit.
RESPONSE:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/09/2023 01:32:20 AM.****
Peter andMonica Treppeda v. UPCIC
Case No.: CACE-21-007431
Page 2 of 5
4. A complete copy of any and all correspondence to and from counsel and expert witness(es)
causation and damage)
(liability, listed in your Expert Witness Disclosure and/or which
you intend to call at trial which relate to the instant lawsuit.
RESPONSE:
5. A complete copy of any and all other documents in your possessionrelative to this matter,
includingbut not limited to memorandums, notes, reports and research that you produced
causation and damage) listed in your Expert
to each of your expert witness(es)(liability,
Witness Disclosure and/or which you intend to call at trial which relate to the instant
lawsuit.
RESPONSE:
6. A copy of each retainer agreement with each expert, and all billingsrelated thereto.
RESPONSE:
7. A complete copy of any and all checks that were given to each of your expert witness(es)
causation and damage)
(liability, listed in your Expert Witness Disclosure and/or which
you intend to call at trial which relate to the instant lawsuit.
RESPONSE:
8. A complete copy of any invoices received from your expert witness(es)(liability,
causation
and damage) listed in your Expert Witness Disclosure and/or which you intend to call trial
which relate to the instant lawsuit.
RESPONSE:
9. A copy of any Form 1099 from Plaintiff,
Plaintiff's agents or attorney, to each expert in
each of the last five (5) years.
Peter andMonica Treppeda v. UPCIC
Case No.: CACE-21-007431
Page 3 of 5
RESPONSE:
10. All documents which show or tends to show any contractor skills possessed by any expert
listed by defendant for each expert.
RESPONSE:
11. All documents which show or tends to show any construction skills possessed by any
expert listed by defendant for each expert.
RESPONSE:
12. All documents which shows or tends to support any skills possessedfor each expert related
to the expertisefor which the expert has been hired.
RESPONSE:
13. A copy of each expert'slicenses(s).
RESPONSE:
14. proceeding in which each expert has been involved regarding
Copies of any disciplinary
any license in the expert'sname in the last 15 years.
RESPONSE:
15. A complete copy of the file(s) maintained by each expert listed on your witness list(s),
relative to the subjectlawsuit, including all documents and materials created by each
expert, received by or transmitted to each expert, upon which each expert relies for his/her
respectiveopinions.
Peter andMonica Treppeda v. UPCIC
Case No.: CACE-21-007431
Page 4 of 5
RESPONSE:
16. All photographs and videotapes viewed and/or taken by or for each expert in connection
with this case.
RESPONSE:
17. Any plans,drawings,graphs or illustrations prepared by each expert in connection with
this case.
RESPONSE:
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
Peter andMonica Treppeda v. UPCIC
Case No.: CACE-21-007431
Page 5 of 5
DEFENDANT, UNIVERSAL PROPER CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-Service to:
Daniel M. Ilani, Esq., the Property People FL, PA. (Service(h).PropertyPeopleLaw.com
and
Danny@PropertyPeopleLaw.com), Counsel on the
for Plaintiffs, 21day of March, 2023.
Attorneyfor Defendant
Universal Property &
Casualty Ins. Co.
P.O. Box 9388
Fort Lauderdale, FL 33309
ParalegalTelephone: (954)- 488-2816
Receptionist Telephone: (954)- 958-3319
Toll-Free: 1-833-685-8594 Judges Only)
Facsimile: 954-958-1262
By. /s/Joseph P. Henn
Joseph P. Henn, Esq.
Florida Bar No. 91143
For Service of Court Documents onlv:
Primary:upciceserviceO1(*universalproperty.com
Secondary: Vb0221@universalproperty.com
Tertiary:Jh0518@universalproperty.com
For Scheduling Matters:
Vb0221(*universalproperty.com
:Please do not send any inquiriesor scheduling matters to unciceservice@universalnropertv.com
or upciceservice01@universalpropertv.com
Document Filed Date
March 09, 2023
Case Filing Date
April 13, 2021
Category
Contract and Indebtedness
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Filing# 168346586 E-Filed 03/09/2023 01:32:21 AM IN THE CIRCUITCOURT OF THE 17 ,TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA PETER AND MONICA TREPPEDA, CASE NO: CACE-21-007431 Plaintiffs, VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i DEFENDANT UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY'S REQUEST FOR PRODUCTION OF PLAINTIFF'S EXPERT COMES NOW, the Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, by and through undersigned counsel, and requests the Plaintiffs, PETER AND MONICA TREPPEDA, to produce the within thirty(30) days, the following: 1. Any and all documents which evidences Plaintiff' s identified including experts'expertise but not limited to a current CV for each expert, as well as a copy of any photo identification a Florida Driver's license). (preferable RESPONSE: 2. Any and all documents which support or tends to support the opinions reached by each expert listed. RESPONSE: 3. A complete copy of any and all correspondenceexchanged with each of the Plaintiff' s expert witness(es)(liability, causation and damage) listed in your Expert Witness Disclosure and/or which you intend to call at trial which relate to the instant lawsuit. RESPONSE: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/09/2023 01:32:20 AM.**** Peter andMonica Treppeda v. UPCIC Case No.: CACE-21-007431 Page 2 of 5 4. A complete copy of any and all correspondence to and from counsel and expert witness(es) causation and damage) (liability, listed in your Expert Witness Disclosure and/or which you intend to call at trial which relate to the instant lawsuit. RESPONSE: 5. A complete copy of any and all other documents in your possessionrelative to this matter, includingbut not limited to memorandums, notes, reports and research that you produced causation and damage) listed in your Expert to each of your expert witness(es)(liability, Witness Disclosure and/or which you intend to call at trial which relate to the instant lawsuit. RESPONSE: 6. A copy of each retainer agreement with each expert, and all billingsrelated thereto. RESPONSE: 7. A complete copy of any and all checks that were given to each of your expert witness(es) causation and damage) (liability, listed in your Expert Witness Disclosure and/or which you intend to call at trial which relate to the instant lawsuit. RESPONSE: 8. A complete copy of any invoices received from your expert witness(es)(liability, causation and damage) listed in your Expert Witness Disclosure and/or which you intend to call trial which relate to the instant lawsuit. RESPONSE: 9. A copy of any Form 1099 from Plaintiff, Plaintiff's agents or attorney, to each expert in each of the last five (5) years. Peter andMonica Treppeda v. UPCIC Case No.: CACE-21-007431 Page 3 of 5 RESPONSE: 10. All documents which show or tends to show any contractor skills possessed by any expert listed by defendant for each expert. RESPONSE: 11. All documents which show or tends to show any construction skills possessed by any expert listed by defendant for each expert. RESPONSE: 12. All documents which shows or tends to support any skills possessedfor each expert related to the expertisefor which the expert has been hired. RESPONSE: 13. A copy of each expert'slicenses(s). RESPONSE: 14. proceeding in which each expert has been involved regarding Copies of any disciplinary any license in the expert'sname in the last 15 years. RESPONSE: 15. A complete copy of the file(s) maintained by each expert listed on your witness list(s), relative to the subjectlawsuit, including all documents and materials created by each expert, received by or transmitted to each expert, upon which each expert relies for his/her respectiveopinions. Peter andMonica Treppeda v. UPCIC Case No.: CACE-21-007431 Page 4 of 5 RESPONSE: 16. All photographs and videotapes viewed and/or taken by or for each expert in connection with this case. RESPONSE: 17. Any plans,drawings,graphs or illustrations prepared by each expert in connection with this case. RESPONSE: [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Peter andMonica Treppeda v. UPCIC Case No.: CACE-21-007431 Page 5 of 5 DEFENDANT, UNIVERSAL PROPER CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-Service to: Daniel M. Ilani, Esq., the Property People FL, PA. (Service(h).PropertyPeopleLaw.com and Danny@PropertyPeopleLaw.com), Counsel on the for Plaintiffs, 21day of March, 2023. Attorneyfor Defendant Universal Property & Casualty Ins. Co. P.O. Box 9388 Fort Lauderdale, FL 33309 ParalegalTelephone: (954)- 488-2816 Receptionist Telephone: (954)- 958-3319 Toll-Free: 1-833-685-8594 Judges Only) Facsimile: 954-958-1262 By. /s/Joseph P. Henn Joseph P. Henn, Esq. Florida Bar No. 91143 For Service of Court Documents onlv: Primary:upciceserviceO1(*universalproperty.com Secondary: Vb0221@universalproperty.com Tertiary:Jh0518@universalproperty.com For Scheduling Matters: Vb0221(*universalproperty.com :Please do not send any inquiriesor scheduling matters to unciceservice@universalnropertv.com or upciceservice01@universalpropertv.com