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Filing # 119291794 E-Filed 01/08/2021 11:33:04 AM
IN THE CIRCUIT COURT OF THE 14°"
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
CASE NO.: 19004412CA
JAMIE AND JENNIFER CARR,
Plaintiffs,
v.
GULFSTREAM PROPERTY & CASUALTY
INSURANCE COMPANY
Defendant.
ee
PLAINTIFFS’ FINAL DISCLOSURES
COME NOW Plaintiffs, JAMIE AND JENNIFER CARR, by and through their undersigned
attorneys, file their Final Disclosures pursuant to the Trial Order, and state as follows:
1. All parties to this action and their representatives.
2. Jose Puentes
Expert Inspections, LLC d.b.a. iTestenvironmental
14411 Commerce Way, #300-C
Miami Lakes, Florida
Mr. Puentes is expected to testify as to any and all mold issues that have arisen 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.
3. 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 soon to be 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.
4. 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 his soon to be scheduled on-site inspection,
education, traming 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.
5. Any and all witnesses listed in Defendant’s Witness List.
6. Rebuttal and impeachment witnesses as needed.
7. Expert witnesses listed on Defendant’s Expert Witness List.
8. All persons who are identified in any pleadings in this case.
9. All persons or entities named in any depositions and exhibits thereto, answer to
interrogatories, insurance claim reports, or other discovery taken in this case.
10. All persons named in response to request for production of documents by the parties in this
case.
11. All persons who have conducted investigations of the Plaintiffs’ Property.
12. 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 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 8th
day of January, 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 egal.
GED LAWYERS, LLP
Attorneysfor the Plaintiffs
7171 North Federal Highway
Boca Raton, FL 33487
Telephone: (561) 995-1966
Facsimile: (561) 241-0812
Primary Email: pditiaw@gediawyers.com
Secondary Email:bgoetsch@ gedlawyers.com
BY: //Scott M. Rosso
SCOTT M. ROSSO, ESQ.
Florida Bar No.: 505757
DAVID R. SHAHEEN, ESQ.
Florida Bar No.: 0117947
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Filing # 119291794 E-Filed 01/08/2021 11:33:04 AM IN THE CIRCUIT COURT OF THE 14°" JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO.: 19004412CA JAMIE AND JENNIFER CARR, Plaintiffs, v. GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY Defendant. ee PLAINTIFFS’ FINAL DISCLOSURES COME NOW Plaintiffs, JAMIE AND JENNIFER CARR, by and through their undersigned attorneys, file their Final Disclosures pursuant to the Trial Order, and state as follows: 1. All parties to this action and their representatives. 2. Jose Puentes Expert Inspections, LLC d.b.a. iTestenvironmental 14411 Commerce Way, #300-C Miami Lakes, Florida Mr. Puentes is expected to testify as to any and all mold issues that have arisen 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. 3. 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 soon to be 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. 4. 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 his soon to be scheduled on-site inspection, education, traming 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. 5. Any and all witnesses listed in Defendant’s Witness List. 6. Rebuttal and impeachment witnesses as needed. 7. Expert witnesses listed on Defendant’s Expert Witness List. 8. All persons who are identified in any pleadings in this case. 9. All persons or entities named in any depositions and exhibits thereto, answer to interrogatories, insurance claim reports, or other discovery taken in this case. 10. All persons named in response to request for production of documents by the parties in this case. 11. All persons who have conducted investigations of the Plaintiffs’ Property. 12. 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 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 8th day of January, 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 egal. GED LAWYERS, LLP Attorneysfor the Plaintiffs 7171 North Federal Highway Boca Raton, FL 33487 Telephone: (561) 995-1966 Facsimile: (561) 241-0812 Primary Email: pditiaw@gediawyers.com Secondary Email:bgoetsch@ gedlawyers.com BY: //Scott M. Rosso SCOTT M. ROSSO, ESQ. Florida Bar No.: 505757 DAVID R. SHAHEEN, ESQ. Florida Bar No.: 0117947