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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.
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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.