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  • Carriage Hills Condo Inc Plaintiff vs. Traders & Pacific Ins Co, et al Defendant Contract and Indebtedness document preview
  • Carriage Hills Condo Inc Plaintiff vs. Traders & Pacific Ins Co, et al Defendant Contract and Indebtedness document preview
  • Carriage Hills Condo Inc Plaintiff vs. Traders & Pacific Ins Co, et al Defendant Contract and Indebtedness document preview
  • Carriage Hills Condo Inc Plaintiff vs. Traders & Pacific Ins Co, et al Defendant Contract and Indebtedness document preview
						
                                

Preview

Filing # 13824805 Electronically Filed 05/19/2014 02:48:17 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No.: 08-10460 CACE (19) CARRIAGE HILLS CONDOMINIUM, INC., a Florida Non-Profit Corporation, Plaintiff/Appellant, VS. UNITED STATES FIRE INSURANCE COMPANY, Defendant/Appellee. / DEFENDANT'’S NOTICE OF SERVING UNVERIFIED ANSWERS TO PLAINTIFF’S EXPERT WITNESS INTERROGATORIES TO: Mitchell B. Haller, Esq. Katzman Garfinkel Berger 300 North Maitland Avenue Maitland, FL 32751-4724 MHaller@likeyourlawyer.com Attorneys For: Plaintiff COMES NOW, the Defendant, UNITED STATES FIRE INSURANCE COMPANY, by and through its undersigned counsel, and files this Notice of Serving its Answers to Plaintiff, CARRIAGE HILLS CONDOMINIUM, INC.’s Expert Witness Interrogatories propounded on April 17, 2014, numbered one (1) through seven (7). BUTLEB,PAPPAS WEIHMULLER KATZ CRAIG LLP JOHN J. PAPPAS, ESQ. Florida Bar No.: 0355941 jpappas@butlerpappas.com *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/19/2014 2:48:17 PM.****Secondary: eservice@butlerpappas.com CHRISTOPHER M. RAMEY, ESQ. Florida Bar No.: 0044808 cramey@butlerppas.com Secondary: eservice@butlerpappas.com 777 S. Harbour Island Boulevard, Suite 500 Tampa, Florida 33602 Telephone: (813) 281-1900 Facsimile: (813) 281-0900 Attorneys for Defendant/Appellee UNITED STATES FIRE INSURANCE COMPANY CERTIFICATE OF SERVICE | certify that a copy of this Notice of Filing has been furnished to: Keith J. Lambdin, Esq. Mitchell B. Haller, Esq. Katzman Garfinkel Berger 5297 West Copans Road Margate, FL 33063 Steven M. Katzman, Esq. Katzman, Wasserman, Bennardini & Rubinstein, P.A. 7900 Glades Road, Suite 140 Boca Raton, FL 33434 by ePortal on May 19, 2014. CHRISTOPHER M. RAMEY, ESQ.IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No.: 08-10460 CACE (19) CARRIAGE HILLS CONDOMINIUM, INC., a Florida Non-Profit Corporation, Plaintiff/Appellant, vs. UNITED STATES FIRE INSURANCE COMPANY, Defendant/Appellee. / DEFENDANT’S UNVERIFIED ANSWERS TO PLAINTIFF’S EXPERT WITNESS INTERROGATORIES 1. Please identify each person who you expect to call as an expert witness at any attorney fee hearing scheduled in this matter, providing for each witness his/her name, street address, and telephone number. ANSWER: U.S. Fire has not yet hired an expert but is currently attempting to do so. Once this expert has been hired and renders opinions, U.S. Fire will amend this response accordingly. 2. Please provide a summary of the subject matter on which each expert disclosed in Interrogatory Number 1 is expected to testify. ANSWER: U.S. Fire has not yet hired an expert but is currently attempting to do so. Once this expert has been hired and renders opinions, U.S. Fire will amend this response accordingly.3. Please state the substance of the facts and opinions to which each expert disclosed in Interrogatory Number 1 is expected to testify and a summary of the grounds for each opinion. ANSWER: U.S. Fire has not yet hired an expert but is currently attempting to do so. Once this expert has been hired and renders opinions, U.S. Fire will amend this response accordingly. 4. With regards to each expert disclosed in Interrogatory Number 1, please state the scope of his or her employment in this matter and the compensation for such service. ANSWER: U.S. Fire has not yet hired an expert but is currently attempting to do so. Once this expert has been hired and renders opinions, U.S. Fire will amend this response accordingly. 5. State in detail, the educational background, training and/or experience of each person identified above which qualifies him/her as an expert and identify for each person listed above the field of his or her expertise. (You may attach a current CV in lieu of answering the question). ANSWER: U.S. Fire has not yet hired an expert but is currently attempting to do so. Once this expert has been hired and renders opinions, U.S. Fire will amend this response accordingly. 6. As to any person identified in Interrogatory Number 1 above, state the number of times said expert has testified on behalf of the law firm of Butler Pappas, et al. in the past five (5) years. ANSWER: U.S. Fire has not yet hired an expert but is currently attempting to do so. Once this expert has been hired and renders opinions, U.S. Fire will amend this response accordingly.7. As to any person identified in Interrogatory Number 1 above, please state said expert's opinion he/she is prepared to testify to at an attorney fee hearing as to the following categories: A. B. G. Total number of reasonable hours incurred by all attorneys for Defendant. Specific number of hours deemed reasonable for attorney John J. Pappas. Specific number of hours deemed reasonable for attorney Christopher Ramey. Total number of reasonable hours incurred by all paralegals for Defendant. Specific number of hours deemed reasonably [sic] for paralegal Lisa C. Lieberher. Reasonable hourly rate for each attorney for whom Defendant is seeking compensation. Reasonable hourly rate for each paralegal for whom Defendant is seeking compensation. ANSWER: U.S. Fire has not yet hired an expert but is currently attempting to do so. Once this expert has been hired and renders opinions, U.S. Fire will amend this response accordingly.