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Filing # 128672414 E-Filed 06/14/2021 11:30:09 AM
IN THE CIRCUIT COURT OF THE 14”
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
CASE NO.: 19004412CA
JAMIE AND JENNIFER CARR,
Plaintiffs,
Vv.
GULFSTREAM PROPERTY & CASUALTY
INSURANCE COMPANY
Defendant.
eee
PLAINTIFFS’? AMENDED FACT AND EXPERT WITNESS LIST
COME NOW Plaintiffs, JAMIE AND JENNIFER CARR, by and through their
undersigned attorneys, file their Amended Fact and Expert Witness List pursuant to the Trial
Order, and state as follows:
AMDENDED FACT AND EXPERT WITNESS LIST
1. All parties to this action and their representatives.
2. Kevin Downing
DLM Contractors, Inc.
2114 Joan Ave.
Panama City Beach, FL 32408
Mr. Downing is expected to testify as to any and all issues that have arisen in relation
to the claim at issue. While testifying, he will rely upon scheduled on-site
inspection/s, education, training and experience, and all additional relevant physical
evidence of record, including discovery materials and facts presently existing and
which may develop as discovery continues. He is also expected to testify regarding
the respective costs of the work to be performed. DLM Contractors, Inc. replaced the
roof of the subject property.
3. Jose Puentes
Expert Inspections, LLC d.b.a. iTest environmental
14411 Commerce Way, #300-C
Miami Lakes, Florida
Mr. Puentes is expected to testify as to any and all mitigation and mold issues that
have arisen or necessary in relation to the claim at issue. While testifying, he will
rely upon his site inspection/s, education, training and experience, and all additional
relevant physical evidence of record, including discovery materials and facts
presently existing and which may develop as discovery continues. He is also
expected to testify regarding the respective costs of the work performed and/or to be
performed.
4. Jack Husband, P.E.
Southeastern Consulting Engineers, Inc.
P.O. Box 141
Wewahitchka, FL 32465
Mr. Husband is expected to testify as to any and all issues that have arisen in relation
to the claim at issue. While testifying, he will rely upon his scheduled on-site
inspection, education, training and experience, and all additional relevant physical
evidence of record, including discovery materials and facts presently existing and
which may develop as discovery continues.
5. Marshall Austin
Total Claim Source, LLC
PO Box 1054
Crystal Springs, FL 33524
Mr. Austin is expected to testify as to any and all issues that have arisen in relation to
the claim at issue. While testifying, he will rely upon on-site inspection/s, education,
training and experience, and all additional relevant physical evidence of record,
including discovery materials and facts presently existing and which may develop as
discovery continues. He is also expected to testify regarding the respective costs of
the work to be performed.
6. Any and all witnesses listed in Defendant’s Witness List.
7. Rebuttal and impeachment witnesses as needed.
8. Expert witnesses listed on Defendant’s Expert Witness List.
9. All persons who are identified in any pleadings in this case.
10. All persons or entities named in any depositions and exhibits thereto, answer to
interrogatories, insurance claim reports, or other discovery taken in this case.
11. All persons named in response to request for production of documents by the parties
in this case.
12. All persons who have conducted investigations of the Plaintiffs’ Property.
13. All persons named in any documents produced in response to notices of production
from non-parties propounded in this case.
Plaintiffs reserve their right to amend or supplement this witness list as discovery is
currently ongoing.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on
this 14" day of June, 2021, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler
Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602,
kmaus@butler legal.
GED LAWYERS, LLP
Attorneys for the Plaintiffs
7171 North Federal Highway
Boca Raton, FL 33487
Telephone: (561) 995-1966
Facsimile: (561) 241-0812
Primary Email: pdlitlaw@gedlawyers.com
Secondary Email:bgoetsch@gedlawyers.com
BY: /s/Scott M. Rosso
SCOTT M. ROSSO, ESQ.
Florida Bar No.: 505757
DAVID R. SHAHEEN, ESQ.
Florida Bar No.: 0117947
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Filing # 128672414 E-Filed 06/14/2021 11:30:09 AM IN THE CIRCUIT COURT OF THE 14” JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO.: 19004412CA JAMIE AND JENNIFER CARR, Plaintiffs, Vv. GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY Defendant. eee PLAINTIFFS’? AMENDED FACT AND EXPERT WITNESS LIST COME NOW Plaintiffs, JAMIE AND JENNIFER CARR, by and through their undersigned attorneys, file their Amended Fact and Expert Witness List pursuant to the Trial Order, and state as follows: AMDENDED FACT AND EXPERT WITNESS LIST 1. All parties to this action and their representatives. 2. Kevin Downing DLM Contractors, Inc. 2114 Joan Ave. Panama City Beach, FL 32408 Mr. Downing is expected to testify as to any and all issues that have arisen in relation to the claim at issue. While testifying, he will rely upon scheduled on-site inspection/s, education, training and experience, and all additional relevant physical evidence of record, including discovery materials and facts presently existing and which may develop as discovery continues. He is also expected to testify regarding the respective costs of the work to be performed. DLM Contractors, Inc. replaced the roof of the subject property. 3. Jose Puentes Expert Inspections, LLC d.b.a. iTest environmental 14411 Commerce Way, #300-C Miami Lakes, Florida Mr. Puentes is expected to testify as to any and all mitigation and mold issues that have arisen or necessary in relation to the claim at issue. While testifying, he will rely upon his site inspection/s, education, training and experience, and all additional relevant physical evidence of record, including discovery materials and facts presently existing and which may develop as discovery continues. He is also expected to testify regarding the respective costs of the work performed and/or to be performed. 4. Jack Husband, P.E. Southeastern Consulting Engineers, Inc. P.O. Box 141 Wewahitchka, FL 32465 Mr. Husband is expected to testify as to any and all issues that have arisen in relation to the claim at issue. While testifying, he will rely upon his scheduled on-site inspection, education, training and experience, and all additional relevant physical evidence of record, including discovery materials and facts presently existing and which may develop as discovery continues. 5. Marshall Austin Total Claim Source, LLC PO Box 1054 Crystal Springs, FL 33524 Mr. Austin is expected to testify as to any and all issues that have arisen in relation to the claim at issue. While testifying, he will rely upon on-site inspection/s, education, training and experience, and all additional relevant physical evidence of record, including discovery materials and facts presently existing and which may develop as discovery continues. He is also expected to testify regarding the respective costs of the work to be performed. 6. Any and all witnesses listed in Defendant’s Witness List. 7. Rebuttal and impeachment witnesses as needed. 8. Expert witnesses listed on Defendant’s Expert Witness List. 9. All persons who are identified in any pleadings in this case. 10. All persons or entities named in any depositions and exhibits thereto, answer to interrogatories, insurance claim reports, or other discovery taken in this case. 11. All persons named in response to request for production of documents by the parties in this case. 12. All persons who have conducted investigations of the Plaintiffs’ Property. 13. All persons named in any documents produced in response to notices of production from non-parties propounded in this case. Plaintiffs reserve their right to amend or supplement this witness list as discovery is currently ongoing. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on this 14" day of June, 2021, via the Florida E-Filing Portal to: Kathy J. Maus, Esq., Butler Weihmuller Katz Craig LLP, 400 North Ashley Drive, Suite 2300, Tampa, FL 33602, kmaus@butler legal. GED LAWYERS, LLP Attorneys for the Plaintiffs 7171 North Federal Highway Boca Raton, FL 33487 Telephone: (561) 995-1966 Facsimile: (561) 241-0812 Primary Email: pdlitlaw@gedlawyers.com Secondary Email:bgoetsch@gedlawyers.com BY: /s/Scott M. Rosso SCOTT M. ROSSO, ESQ. Florida Bar No.: 505757 DAVID R. SHAHEEN, ESQ. Florida Bar No.: 0117947