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Filing # 12639714 Electronically Filed 04/17/2014 02:57:19 PM.
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.: CACE 08010460 11
CARRIAGE HILLS CONDOMINIUM,
INC.,
Plaintiff,
VS.
UNITED STATES FIRE INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S EXPERT REQUEST FOR PRODUCTION TO DEFENDANT
Plaintiff, CARRIAGE HILLS CONDOMINIUM, INC., by and through its undersigned
counsel and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests the Defendant,
UNITED STATES FIRE INSURANCE COMPANY, to produce the following within thirty (30)
days.
1. Curriculum Vitae for each expert you intend to call at the fee hearing in this
matter.
2. Reports, correspondence, invoices, bills, statements, documents and materials
relative to this lawsuit received by Defendant’s counsel from each expert you intend to call at the
fee hearing in this matter.
3. Reports, correspondence, documents and materials relative to this lawsuit sent or
transmitted to each expert either 1) listed in your answers to Plaintiff’s expert interrogatories, or
2) that you intend to call at the fee hearing of this matter.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/17/2014 2:57:17 PM.****4. A complete copy of the file(s) maintained by each expert either 1) listed in your
answers to Plaintiffs expert interrogatories, or 2) that you intend to call at the fee hearing in this
matter, relative to the subject lawsuit, including all documents and materials created by each
expert, received by or transmitted to each expert, and upon which each expert relies for his or her
respective opinions.
5. Copies of any and all notes, calculations or other data prepared by each expert
either 1) listed in your answers to Plaintiff's expert interrogatories, or 2) that you intend to call at
a fee hearing in this matter, in formulating his opinions in connection with this case.
6. Any and all records of payment to all retained experts, retainer agreements, and
other agreements between Defendant and all experts either 1) listed in your answers to Plaintiff's
expert interrogatories, or 2) that you intend to call at the fee hearing in this matter, governing the
compensation of said experts.
7, All documents each expert either 1) listed in your answers to Plaintiff's expert
interrogatories, or 2) that you intend to call at the fee hearing in this matter, viewed, referred to
or relied upon in arriving at any of his or her opinions or conclusions concerning the reasonable
value of Defendant’s attorney’s fees and litigation costs, including but not limited to all case law,
publications, codes, standards and other literature.
8. All drafts and non final versions of reports, estimates, affidavits, and any other
documents produced by the expert(s).CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Electronic Mail only on this 17" day of April, 2014 to John J. Pappas, Esq., via
JPappas@butlerpappas.com and cramey(@butlerpappas.com
Respectfully submitted,
4s/ Mitchell B. Haller
Mitchell B. Haller, Esq.
Florida Bar No.: 511961
MHaller@likeyourlawyer.com
Katzman Garfinkel
5297 W. Copans Road
Margate, FL 33063
Phone: (954) 486-7774
Telefax: (954) 486-7782
Preview
Filing # 12639714 Electronically Filed 04/17/2014 02:57:19 PM. IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 08010460 11 CARRIAGE HILLS CONDOMINIUM, INC., Plaintiff, VS. UNITED STATES FIRE INSURANCE COMPANY, Defendant. / PLAINTIFF’S EXPERT REQUEST FOR PRODUCTION TO DEFENDANT Plaintiff, CARRIAGE HILLS CONDOMINIUM, INC., by and through its undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests the Defendant, UNITED STATES FIRE INSURANCE COMPANY, to produce the following within thirty (30) days. 1. Curriculum Vitae for each expert you intend to call at the fee hearing in this matter. 2. Reports, correspondence, invoices, bills, statements, documents and materials relative to this lawsuit received by Defendant’s counsel from each expert you intend to call at the fee hearing in this matter. 3. Reports, correspondence, documents and materials relative to this lawsuit sent or transmitted to each expert either 1) listed in your answers to Plaintiff’s expert interrogatories, or 2) that you intend to call at the fee hearing of this matter. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/17/2014 2:57:17 PM.****4. A complete copy of the file(s) maintained by each expert either 1) listed in your answers to Plaintiffs expert interrogatories, or 2) that you intend to call at the fee hearing in this matter, relative to the subject lawsuit, including all documents and materials created by each expert, received by or transmitted to each expert, and upon which each expert relies for his or her respective opinions. 5. Copies of any and all notes, calculations or other data prepared by each expert either 1) listed in your answers to Plaintiff's expert interrogatories, or 2) that you intend to call at a fee hearing in this matter, in formulating his opinions in connection with this case. 6. Any and all records of payment to all retained experts, retainer agreements, and other agreements between Defendant and all experts either 1) listed in your answers to Plaintiff's expert interrogatories, or 2) that you intend to call at the fee hearing in this matter, governing the compensation of said experts. 7, All documents each expert either 1) listed in your answers to Plaintiff's expert interrogatories, or 2) that you intend to call at the fee hearing in this matter, viewed, referred to or relied upon in arriving at any of his or her opinions or conclusions concerning the reasonable value of Defendant’s attorney’s fees and litigation costs, including but not limited to all case law, publications, codes, standards and other literature. 8. All drafts and non final versions of reports, estimates, affidavits, and any other documents produced by the expert(s).CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic Mail only on this 17" day of April, 2014 to John J. Pappas, Esq., via JPappas@butlerpappas.com and cramey(@butlerpappas.com Respectfully submitted, 4s/ Mitchell B. Haller Mitchell B. Haller, Esq. Florida Bar No.: 511961 MHaller@likeyourlawyer.com Katzman Garfinkel 5297 W. Copans Road Margate, FL 33063 Phone: (954) 486-7774 Telefax: (954) 486-7782