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Filing # 87537242 E-Filed 04/05/2019 11:55:31 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA.
CASE NO: CACE-18-001242
BRIAN WILLIAM GARLAND,
Plaintiff,
vs.
STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY, a Foreign
Corporation,
Defendant.
/
EXPERT INTERROGATORIES TO PLAINTIFF
AND NOTICE OF FILING EXPERT INTERROGATORIES
Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY,
by and through undersigned counsel propounds Expert Interrogatories attached hereto and
numbered | through 17, and thereby made a part hereof, unto the Plaintiff, BRIAN
GARLAND, to be answered under oath and in writing within the time and manner
prescribed by law and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure.
CERTIFICATE OF SERVICE
I HERAAY CERTIFY that a true copy of the foregding has be¢n sent, via Florida E-
Portal this day of APRIL, 2019 to Jon Zepnick/Esq.. THE $CHILLER, KESSLER
GROUP, PLC, 7501 West Oakland Park Boulevard, Segond Floor, Fi/ Lauderdale, FL 33319.
efil uredinflorida.com.
FLANAGAN & MANIOAIS, P.A.
By:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/5/2019 11:55:31 AM.****N
DEFENDANT’S EXPERT WITNESS INTERROGATORIES
TO PLAINTIFF, BRIAN GARLAND
State the name, address, educational background and profession of each person
whom you expect to call as an expert witness at trial or for any other purposes in
this cause (this would include both medical and non-medical experts), and attach a
copy of each expert’s CV with these answers.
With regard to each listed above, state his/her background and experience which
qualify him/her to testify as an expert in his area of expertise.
Please state the number of times, the style of each case and the Court for which
each of your experts has been retained by your attorney’s office (The Schiller
Kessler Group, PLC) in other litigated cases over the past three (3) years.
Please state the style, the attorneys and the Court of all other cases in which each
of the experts listed above have testified over the last three (3) years, and also state
whether he/she testified for the Plaintiff or Defendant.Please state the date in which each expert listed above was retained by you or your
law firm or the date the expert began treating you.
State the fees charged for services or opinions, if any. by each of those experts in
the subject case.
Please provide the substance of facts to which each expert listed above is expected
to testify at trial.
Please state each and every opinion(s) to which each expert listed above is
expected to testify at trial.
Please provide a summary of the grounds or basis for each opinion stated above.10.
1h.
Give a complete list of all documents, depositions, exhibits, plans, drawings,
ordinances or statutes which each expert has used in basing his opinion.
Did any of the experts listed above submit a report setting forth his/her opinions or
conclusions reached from his/her examination or any tests or investigations he/she
conducted? If so, please state:
A. The date the report was submitted.
B. The substance of each report.
C. Each and every person or entity in possession of said report.
Please provide each expert’s yearly income derived from performing litigation-
related services for your attorneys or any attorney in The Schiller Kessler Group,
PLC, for the last three (3) years (this may include 1099 information provided to
the expert).13.
Has the expert listed above practiced or worked in his field during the past five
years? If so, please state:
A. Whether he/she was self-employed by someone else or associated as a
partner.
B. Each address where he/she practiced or was employed and dates of
employment.
C. The type of duty he/she performed with each employer.
If he/she has not practiced or worked in his field during the last five years, what
was his employment during this time?
If you will do so without a Request to Produce, attach a copy of any reports made
by each expert on the basis of his/her tests, medical procedures performed on the
Plaintiff, and examinations or analyses to your answers to these Interrogatories.17.
Is the expert to be compensated for his/her work and efforts in connection with
this action?
A. Ifso, how much has he/she been paid or;
B. If he/she has not been paid, then give the basis for payment, such as hourly
rate, weekly rate, procedure rate, if the expert is called to testify at trial or at
deposition.
Please state the general litigation of any and all expert witnesses whose names
appear in your answer to Interrogatory 1 above and set forth for each expert
witness named:
A. The percentage of work performed for Plaintiffs and the percentage of work
performed for Defendants.
B. The Expert’s involvement as an expert witness in terms of percentage of
income derived from serving as an expert witness, percentage of hours
spent serving as an expert witness and number of hours spent serving as an
expert witness.
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iBY:
STATE OF FLORIDA )
COUNTY OF PALM BEACH)
The foregoing Answers to Expert Interrogatories was acknowledged before me, an officer
duly authorized in the State and County aforesaid, to take acknowledgments, this day of
+ 2019, by . the individual whose signature appears
above. who:
[] ispersonally known to me; or
{] has produced as identification; and who
{] didor
C) did not, take an oath
and who executed the within document, and who acknowledged the within document to be freely
and voluntarily executed for the purposes therein recited.
NOTARY PUBLIC
(SEAL) PRINT NAME:
My Commission Expires:
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Filing # 87537242 E-Filed 04/05/2019 11:55:31 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: CACE-18-001242 BRIAN WILLIAM GARLAND, Plaintiff, vs. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, a Foreign Corporation, Defendant. / EXPERT INTERROGATORIES TO PLAINTIFF AND NOTICE OF FILING EXPERT INTERROGATORIES Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, by and through undersigned counsel propounds Expert Interrogatories attached hereto and numbered | through 17, and thereby made a part hereof, unto the Plaintiff, BRIAN GARLAND, to be answered under oath and in writing within the time and manner prescribed by law and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure. CERTIFICATE OF SERVICE I HERAAY CERTIFY that a true copy of the foregding has be¢n sent, via Florida E- Portal this day of APRIL, 2019 to Jon Zepnick/Esq.. THE $CHILLER, KESSLER GROUP, PLC, 7501 West Oakland Park Boulevard, Segond Floor, Fi/ Lauderdale, FL 33319. efil uredinflorida.com. FLANAGAN & MANIOAIS, P.A. By: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/5/2019 11:55:31 AM.****N DEFENDANT’S EXPERT WITNESS INTERROGATORIES TO PLAINTIFF, BRIAN GARLAND State the name, address, educational background and profession of each person whom you expect to call as an expert witness at trial or for any other purposes in this cause (this would include both medical and non-medical experts), and attach a copy of each expert’s CV with these answers. With regard to each listed above, state his/her background and experience which qualify him/her to testify as an expert in his area of expertise. Please state the number of times, the style of each case and the Court for which each of your experts has been retained by your attorney’s office (The Schiller Kessler Group, PLC) in other litigated cases over the past three (3) years. Please state the style, the attorneys and the Court of all other cases in which each of the experts listed above have testified over the last three (3) years, and also state whether he/she testified for the Plaintiff or Defendant.Please state the date in which each expert listed above was retained by you or your law firm or the date the expert began treating you. State the fees charged for services or opinions, if any. by each of those experts in the subject case. Please provide the substance of facts to which each expert listed above is expected to testify at trial. Please state each and every opinion(s) to which each expert listed above is expected to testify at trial. Please provide a summary of the grounds or basis for each opinion stated above.10. 1h. Give a complete list of all documents, depositions, exhibits, plans, drawings, ordinances or statutes which each expert has used in basing his opinion. Did any of the experts listed above submit a report setting forth his/her opinions or conclusions reached from his/her examination or any tests or investigations he/she conducted? If so, please state: A. The date the report was submitted. B. The substance of each report. C. Each and every person or entity in possession of said report. Please provide each expert’s yearly income derived from performing litigation- related services for your attorneys or any attorney in The Schiller Kessler Group, PLC, for the last three (3) years (this may include 1099 information provided to the expert).13. Has the expert listed above practiced or worked in his field during the past five years? If so, please state: A. Whether he/she was self-employed by someone else or associated as a partner. B. Each address where he/she practiced or was employed and dates of employment. C. The type of duty he/she performed with each employer. If he/she has not practiced or worked in his field during the last five years, what was his employment during this time? If you will do so without a Request to Produce, attach a copy of any reports made by each expert on the basis of his/her tests, medical procedures performed on the Plaintiff, and examinations or analyses to your answers to these Interrogatories.17. Is the expert to be compensated for his/her work and efforts in connection with this action? A. Ifso, how much has he/she been paid or; B. If he/she has not been paid, then give the basis for payment, such as hourly rate, weekly rate, procedure rate, if the expert is called to testify at trial or at deposition. Please state the general litigation of any and all expert witnesses whose names appear in your answer to Interrogatory 1 above and set forth for each expert witness named: A. The percentage of work performed for Plaintiffs and the percentage of work performed for Defendants. B. The Expert’s involvement as an expert witness in terms of percentage of income derived from serving as an expert witness, percentage of hours spent serving as an expert witness and number of hours spent serving as an expert witness. | | | | iBY: STATE OF FLORIDA ) COUNTY OF PALM BEACH) The foregoing Answers to Expert Interrogatories was acknowledged before me, an officer duly authorized in the State and County aforesaid, to take acknowledgments, this day of + 2019, by . the individual whose signature appears above. who: [] ispersonally known to me; or {] has produced as identification; and who {] didor C) did not, take an oath and who executed the within document, and who acknowledged the within document to be freely and voluntarily executed for the purposes therein recited. NOTARY PUBLIC (SEAL) PRINT NAME: My Commission Expires: