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Filing# 160948033 E-Filed 11/09/2022 12:21:14 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
PETER TREPPEDA AND MONICA
TREPPEDA, Case No.: CACE-21-007431
Plaintiff(s),
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
NOTICE OF SERVING EXPERT WITNESS INTERROGATORIES TO DEFENDANT
COMES NOW Plaintiff(s),
PETER TREPPEDA AND MONICA TREPPEDA, by and
through the undersignedattorneys, hereby propounds to Defendant and pursuant to Flo,ida Rules of
CivilProcedure 1.340, the attached answers to which
Expert Witness Interrogatories, will be due
within thirty(30)days from the date of service hereof.
I HEREBY CERTIFY that a true and correct copy of this and
Notice, along with original
were served with the Summons and Complaint.
copy of the Interrogatories
submitted,
Respectfully
The Property People FL, P.A.
forPlaintifs
Attornegs
117 NE 1st Ave, Unit 15-104
Miami, FL 33132
Telephone: 844.776.7364
E-Service: Service@PropertyPeopleLaw.com
By: /s/ Daniel M. Ilani
Daniel M. Ilani,Esq.
Florida Bar No. 116189
Email: Danny@PropertyPeopleLaw.com
Nicole S. Houtnan, Esq.
Florida Bar No. 1013527
Email: Nicole@PropertyPeopleLaw.com
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/09/2022 12:21:14 PM.****
Definitions
A. When used herein "you" or "your" shall mean UNIVERSAL PROPERTY &
CASUALTY INSURANCE COMPANY "Defendant' '),its partners, agents, servants,
(hereinafter
employees,attorneys, expert witnesses, accountants, auditors and all persons over whom it has control
or who have been hired, retained or einployedfor any purpose by it,whether directly
by it or through
any other person or entity.
B. As used herein the term "document" or "documents" mean any and all information in
form and
tangible shall include,without limiting of the foregoing,
the generality all letters,
telegrams,
telexes,teletypes, contracts, drafts,agreetnents, notes to file,
correspondence, reports, memoranda,
of such recordings,
mechanical or electronic recordingsor transcripts flow sheets,calendar
blueprints,
or diaryentries,memoranda or telephoneor personalconversations, memoranda of meetings or
conferences, studies, reports, inter-office and intra-office communications, quotations,offers,
inquiries,bulletins,circulars,statetnents, manuals, sutntnaries, newsletters, compilations,
maps, etc.
C. As used herein "communication means the transmission, sharingor exchange of
information or knowledge in any form, by one with another.
D. As used herein the term "person"means any individual,corporation,
partnership,
joint
venture, group, association, government agency, unit or other organization.
body politic,
E. To "identify
a document" shall mean to state with respect thereto:
i. of the person who prepared it;
The identity
ii. of the person who signedit or in whose name
The identity it was issued;
iii. The identity
of each person to whom it was addressed or distributed;
iv. The nature or substance of the document with sufficient to enable
particularity
it to be identified;
V. Its date,and if it bears no date,the date when it was prepared;and
vi. The physical
location of the document and the custodian or custodian thereof.
F. To "identify
a person"with reference to a natural person means to givehis name, his
last known address and if einployed,
the name and address of his einployer
and his job title or position.
To identifya person who is not an individual,means to state the name and principal
office of such
person.
EXPERT WITNESS INTERROGATORIES
1. each person
Please identify whom you expect to call as a witness at trial,providingfor
each witness his/her name, street address, and telephonenumber and a brief summary of the facts to
which they are expectedto testify. which of the
Please identify listed witnesses are expectedto give
opiniontestimonyand for each expert witness, provide the substance of the facts and opinionsto
which he or she is and
expected to testify a summary of the grounds for each opinion.
2. State in detail,the educational and/or experienceof each person
background,training
identified above which qualifies
him/her as an expert and identify
for each person listed above the
field of their expertise.
(You may attach a current CV in lieu of answeringthe question).
3. For each expert listed,pleasestate the expert'sgenerallitigation
experience,
including
the percentage of work performed for Plaintiffs and Defendants.
4. For each expert listed,pleasestate the identity
of other cases, within the last three (3)
years, in which the expert has testified by depositionor at trial.
5. For each expert listed,pleasegive an approximation of the portion of the expert's
involvement as an expert witness, which may be based on the number of hours, percentage of hours,
or percentage of earned income derived from servingas an expert witness.
6. pleasestate the number of times
For each expert listed, that each expert's
deposition
was taken in the preceding calendar year, and indicate whether the expert testified on behalf of the
Plaintiff or Defendant:
7. pleasestate the number of times each expert appearedin Court
For each expert listed,
to within the
testify last calendar year. Please include times, and where the expert was called to testify
in more than one courtroom on date, counting each time as a separate Court appearance.
a particular
8. No. 7 above, pleasestate the number
For each Court appearance listed in Interrogatory
of times the expert was called to testify:
a.
By Plaintiffs' attorney;
b. By Defendants' attorney as a defense examiner;
9. Give the name or title of each paper which each expert has authored in the area of
his/her expertise.
10. State the name, volume and page number of the publication
in which each article or
paper listed above can be found.
11. State the substance of the facts to which each expert listed above is expectedto testify.
12. State opinionto which each expert listed above is expectedto testify.
13. Please givea summary of the grounds or basis for each opinionstated above.
14. With respect to each expert witness you expect to testify pleasestate
at trial, as follows:
a. In the past three years, how many times has the Defendant retained each such
pe@
exr
b. In the past three years, what is the amount of fees or money that the Defendant paid
each expert testifying
at trial?
c.
Identifyeach lawsuit/case in which each expert that will at
testify trial has been
retained by the Defendant.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this November 9,2022, I electronically
filed the foregoing
document with the Florida Courts E-Filing Portal via transmission of Notices of Electronic Filing
generatedby Florida Courts E-FilingPortal (eservice@myflcourtaccess.coin).
/s/ Daniel M. Ilani
Daniel M. Ilani
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Filing# 160948033 E-Filed 11/09/2022 12:21:14 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA PETER TREPPEDA AND MONICA TREPPEDA, Case No.: CACE-21-007431 Plaintiff(s), VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. NOTICE OF SERVING EXPERT WITNESS INTERROGATORIES TO DEFENDANT COMES NOW Plaintiff(s), PETER TREPPEDA AND MONICA TREPPEDA, by and through the undersignedattorneys, hereby propounds to Defendant and pursuant to Flo,ida Rules of CivilProcedure 1.340, the attached answers to which Expert Witness Interrogatories, will be due within thirty(30)days from the date of service hereof. I HEREBY CERTIFY that a true and correct copy of this and Notice, along with original were served with the Summons and Complaint. copy of the Interrogatories submitted, Respectfully The Property People FL, P.A. forPlaintifs Attornegs 117 NE 1st Ave, Unit 15-104 Miami, FL 33132 Telephone: 844.776.7364 E-Service: Service@PropertyPeopleLaw.com By: /s/ Daniel M. Ilani Daniel M. Ilani,Esq. Florida Bar No. 116189 Email: Danny@PropertyPeopleLaw.com Nicole S. Houtnan, Esq. Florida Bar No. 1013527 Email: Nicole@PropertyPeopleLaw.com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/09/2022 12:21:14 PM.**** Definitions A. When used herein "you" or "your" shall mean UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY "Defendant' '),its partners, agents, servants, (hereinafter employees,attorneys, expert witnesses, accountants, auditors and all persons over whom it has control or who have been hired, retained or einployedfor any purpose by it,whether directly by it or through any other person or entity. B. As used herein the term "document" or "documents" mean any and all information in form and tangible shall include,without limiting of the foregoing, the generality all letters, telegrams, telexes,teletypes, contracts, drafts,agreetnents, notes to file, correspondence, reports, memoranda, of such recordings, mechanical or electronic recordingsor transcripts flow sheets,calendar blueprints, or diaryentries,memoranda or telephoneor personalconversations, memoranda of meetings or conferences, studies, reports, inter-office and intra-office communications, quotations,offers, inquiries,bulletins,circulars,statetnents, manuals, sutntnaries, newsletters, compilations, maps, etc. C. As used herein "communication means the transmission, sharingor exchange of information or knowledge in any form, by one with another. D. As used herein the term "person"means any individual,corporation, partnership, joint venture, group, association, government agency, unit or other organization. body politic, E. To "identify a document" shall mean to state with respect thereto: i. of the person who prepared it; The identity ii. of the person who signedit or in whose name The identity it was issued; iii. The identity of each person to whom it was addressed or distributed; iv. The nature or substance of the document with sufficient to enable particularity it to be identified; V. Its date,and if it bears no date,the date when it was prepared;and vi. The physical location of the document and the custodian or custodian thereof. F. To "identify a person"with reference to a natural person means to givehis name, his last known address and if einployed, the name and address of his einployer and his job title or position. To identifya person who is not an individual,means to state the name and principal office of such person. EXPERT WITNESS INTERROGATORIES 1. each person Please identify whom you expect to call as a witness at trial,providingfor each witness his/her name, street address, and telephonenumber and a brief summary of the facts to which they are expectedto testify. which of the Please identify listed witnesses are expectedto give opiniontestimonyand for each expert witness, provide the substance of the facts and opinionsto which he or she is and expected to testify a summary of the grounds for each opinion. 2. State in detail,the educational and/or experienceof each person background,training identified above which qualifies him/her as an expert and identify for each person listed above the field of their expertise. (You may attach a current CV in lieu of answeringthe question). 3. For each expert listed,pleasestate the expert'sgenerallitigation experience, including the percentage of work performed for Plaintiffs and Defendants. 4. For each expert listed,pleasestate the identity of other cases, within the last three (3) years, in which the expert has testified by depositionor at trial. 5. For each expert listed,pleasegive an approximation of the portion of the expert's involvement as an expert witness, which may be based on the number of hours, percentage of hours, or percentage of earned income derived from servingas an expert witness. 6. pleasestate the number of times For each expert listed, that each expert's deposition was taken in the preceding calendar year, and indicate whether the expert testified on behalf of the Plaintiff or Defendant: 7. pleasestate the number of times each expert appearedin Court For each expert listed, to within the testify last calendar year. Please include times, and where the expert was called to testify in more than one courtroom on date, counting each time as a separate Court appearance. a particular 8. No. 7 above, pleasestate the number For each Court appearance listed in Interrogatory of times the expert was called to testify: a. By Plaintiffs' attorney; b. By Defendants' attorney as a defense examiner; 9. Give the name or title of each paper which each expert has authored in the area of his/her expertise. 10. State the name, volume and page number of the publication in which each article or paper listed above can be found. 11. State the substance of the facts to which each expert listed above is expectedto testify. 12. State opinionto which each expert listed above is expectedto testify. 13. Please givea summary of the grounds or basis for each opinionstated above. 14. With respect to each expert witness you expect to testify pleasestate at trial, as follows: a. In the past three years, how many times has the Defendant retained each such pe@ exr b. In the past three years, what is the amount of fees or money that the Defendant paid each expert testifying at trial? c. Identifyeach lawsuit/case in which each expert that will at testify trial has been retained by the Defendant. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this November 9,2022, I electronically filed the foregoing document with the Florida Courts E-Filing Portal via transmission of Notices of Electronic Filing generatedby Florida Courts E-FilingPortal (eservice@myflcourtaccess.coin). /s/ Daniel M. Ilani Daniel M. Ilani