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Filing # 136674948 E-Filed 10/15/2021 04:29:12 PM
IN THE CIRCUIT COURT OF THE 97! JUDICIAL
CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA
CASE NO.: 2020-CA-002942-ON
VILLAS AT EMERALD LAKE HOMEONWERS
ASSOCIATION, INC., a Florida not for profit corporation,
Plaintiff,
Vv.
ROYAL OAK HOMES, LLC, a Florida limited
liability company; ADVANCED WRAPPING
AND CONCRETE SOLUTIONS OF CENTRAL
FLORIDA, INC., a Florida corporation; DON
KING’S CONCRETE, INC., a Florida corporation;
HUGH MACDONALD CONSTRUCTION, INC.,
a Florida corporation; IMPERIAL BUILDING
CORPORATION, a Florida corporation;
PREMIER PLASTERING OF CENTRAL
FLORIDA, INC. n/k/a TGK STUCCO, INC., a
Florida corporation, WEATHERMASTER
BUILDING PRODUCTS, INC., a Florida
corporation; WEINTRAUB INSPECTIONS &
FORENSICS, INC. n/k/a WEINTRAUB
ENGINEERING AND INSPECTIONS, INC, a
Florida corporation; THE DIMILLO GROUP,
LLC, a Florida limited liability company; WOLF’S
IRRIGATION & LANDSCAPING, INC., A
Florida corporation; SUMMERPARK HOMES,
INC., a Florida corporation; BROWN +
COMPANY ARCHITECTURE, INC., a Florida
corporation;
Defendant.
/
ROYAL OAK HOMES, LLC, a Florida limited
liability company;
Crossclaim Plaintiff,
Vv.
ADVANCED WRAPPING AND CONCRETE
SOLUTION OF CENTRAL FLORIDA, INC., a
Florida corporation; DON KING’S CONCRETE,
INC., a Florida corporation; HUGH MACDONALD
CONSTRUCTION, INC., a Florida corporation;
IMPERIAL BUILDING CORPORATION, a Florida
corporation; PREMIER PLASTERING OF
CENTRAL FLORIDA, INC. n/k/a TGK STUCCO,
INC., a Florida corporation; WEATHERMASTER
BUILDING PRODUCTS, INC., a Florida
corporation; WEINTRAUB INSPECTIONS &
FORENSICS, INC. n/k/a WEINTRAUB
ENGINEERING AND INSPECTIONS, INC., a
Florida corporation; WOLF'S IRRIGATION &
LANDSCAPING, INC., a Florida corporation;
BROWN+ COMPANY ARCHITECTURE, INC., a
Florida corporation;
Crossclaim Defendants
/
DEFENDANT BROWN + COMPANY ARCHITECTURE, INC.’S INITIAL EXPERT
DISCLOSURE
Pursuant to Court Order, Defendant BROWN + COMPANY ARCHITECTURE, INC.
(“BROWN”) disclose and reserve the right to call the following expert witness to testify at trial on
behalf of BROWN in this matter:
(1) Steven H. Kahn, AIA, NCARB
President, Forensic Building Experts, Inc. (*FBE”)
19235 South Creekshore Court, Boca Raton, FL 33498
Nature of Expertise: Mr. Kahn has more than 30 years of experience in the building design
and construction industry. He specializes in forensic architecture and has extensive experience in
building codes, design theory, general construction practices, roofing assemblies and project
management. His building envelope experience includes water intrusion at building foundations,
walls and roofing, and elevated vehicular building structures. He is an expert in building design
defects, building construction defects, and building code compliance cases on behalf of attorneys,
owners, developers, insurance companies and others. Steven’s portfolio also includes design for new
buildings, renovations and remodels for commercial and residential structures, healthcare facilities
and industrial buildings.
Subject Matter and Summary of Opinions: Mr. Kahn is expected to testify and offer
opinions as to the work and services provided by BROWN and the claims made against BROWN.
Mr. Kahn is also expected to offer opinions and testimony that BROWN provided services in
conformance with the BROWN’s contract(s) and agreement(s) for the Project; and that BROWN
provided its professional design services in conformance with the standard of care applicable
to a professional architect in similar circumstances in the locality at issue. Such opinion
testimony is anticipated to address topics including but not limited to BROWN’s scope of
services, as well as BROWN’s professional design services rendered for the Project’s initial
construction. Mr. Kahn is also anticipated to testify and render opinions as to the means and
methods of construction, causation as to alleged defects and deficiencies, as well as the actions of
the owner/developer, general contractor, subcontractors, other design professionals, consultants,
local building authorities and inspectors relative to BROWN’s scope of services. Mr. Kahn is also
expected to testify and offer opinions concerning alleged damages asserted by the Association.
Mr. Kahn is further expected to offer opinions and testimony as to the relative roles and
duties of the owner/developer, general contractor, subcontractors, other design professionals,
consultants local building authorities and inspectors. Additionally, Mr. Kahn is expected to offer
opinions and testimony in rebuttal to the testimony and opinions of the other Parties’ experts.
Lastly, Mr. Kahn’s opinions are more fully set forth within his initial expert report which
will be disclosed to the Parties via electronic link concurrent with this disclosure. BROWN
reserves the right to supplement this disclose in accordance with the procedures set forth in the
applicable Florida Rules of Civil Procedure and Court Orders.
Grounds for Opinion: Mr. Kahn’s site visit of the property, review of expert reports
disclosed by the Parties, review of construction documents, drawings, construction specifications,
change orders, meeting minutes, project correspondence, shop drawings, submittals, project
manuals, Requests for Information, building code reference materials, the Florida Building
Code, Osceola County ordinances and codes, documents disclosed by the Parties in discovery,
documents disclosed by non-parties in discovery, deposition testimony, architectural industry
standard reference materials, contracts between the various parties, construction schedules, photos
by others, applications for payment and related supporting documents, permit applications,
maintenance and operations manuals, designs and specifications produced or provided by others
for remedial, renovation, and expansion projects relative to the Project. Mr. Kahn will also rely on
his experience, training, education, research, and continuing education; and the exhibits and
evidence referenced and set forth in Mr. Kahn’s report(s). Mr. Kahn is anticipated to disclose an
initial and/or expert rebuttal report to the Parties via electronic link in accordance with Court
Orders regarding expert discovery and disclosure. BROWN reserves the right to supplement this
report in response to rebuttal reports or opinions disclosed by any other Party after the date of this
disclosure.
Deposition: Mr. Kahn will be made available for deposition within the expert discovery
period established by the Court.
Curriculum Vitae: Mr. Kahn’s CV is attached hereto as Exhibit A.
CERTIFICATE OF SERVICE ON THE FOLLOWING PAGE
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and accurate copy of the above has been furnished by
Electronic Mail, by filing through the Florida Courts E-Filing E-portal system to the following
parties on the attached service list on this 15th day of October 2021.
MILBER MAKRIS PLOUSADIS & SEIDEN LLP
Attorneys for Defendant BROWN + COMPANY
ARCHITECTURE, INC.
1900 NW Corporate Blvd., East Tower, Suite 440
Boca Raton,Florida 33431
bealderon@milbermakris.com
dhill milbermakris.com
creech@milbermakris.com
Telephone: 561-994-7310
Facsimile: 561-994-7313
By: /s\2 Giegen SUL Gh
Bruce R. Calderon
Florida Bar No.50448
D. Bryan Hill, Jr.
Florida Bar
No.0113687
Audra R. Creech
Florida Bar No. 122373
SERVICE LIST
Phillip E. Joseph, Esq.
Alana Smith, Esq.
Evan J. Small, Esq.
Jeffrey A. Widelitz Esq.
BALL JANIK, LLP
201 East Pine Street — Suite 600
Orlando, FL 32801
pjoseph@ballijanik.com
esmal|@balljanik.com
jwidelitz@balljanik.com
asmith@ballianik.com
ypalmer@balljanik.corr
nwise@balljanik.com
orlandodocket@balljanik.com
Counsel for Plaintiff, Villas at Emerald
Lake Homeowners Association, Inc.
Thamir A. R. Kaddouri, Jr., Esq.
Beth A. Tobey, Esq.
LAW OFFICE OF THAMIR A.R.
KADDOURI, JR., P.A.
3220 West Cypress Street
Tampa, FL 33607
thamir.kaddouri@tampalaw.org
beth.tobey@tampalaw.org
Counsel for Defendant, Imperial Building Corporation
Peter J. Kapsales, Esq.
Margaret M. Efta, Esq.
MILNE LAW GROUP, P.A.
301 East Pine Street — Suite 525
Orlando, FL 32801
pkapsales@milnelawgroup.com
mefta@milnelawgroup.com
eservice@milnelawgroup.com
Counsel for Defendant, Weathermaster Building Products, Inc.
Joseph L. Zollner, Esq.
LAW OFFICE OF J. CHRISTOPHER NORRIS
P.O. Box 7217
London, KY 40742
joseph.zollner@libertymutual.com
FloridaCDLegalMail@LibertyMutual.com
Counsel for Lois Concrete Corp.
Robin H. Leavengood, Esq.
Lannie D. Hough, Jr., Esq.
CARLTON FIELDS, P.A.
4221 W. Boy Scout Boulevard
Tampa, FL 33607-5780
rleavengood@carltonfields.com
brosa@carltonfields.com
though@earltonfields.com
nbonilla@carltonfields.com
vwilliams@carltonfields.com
iiamsiacamronnmercs cont
Counsel for Defendant, Royal Oak Homes, LLC
Ashley Mattingly, Esq.
BUTLER WEIHMULLER KATZ CRAIG
400 North Ashley Drive — Suite 2300
Tampa, FL 33602
mattingly@butler.legal
Counsel for Defendant, Hugh MacDonald Construction, Inc. (HMC)
Denise M. Anderson, Esq.
David Mercer, Esq.
BUTLER WEIHMULLER KATZ CRAIG LLP
400 North Ashley Drive — Suite 2300
Tampa, FL 33602
danderson@butler.legal
dmercer@butler.legal
ws
jacobs@pbutler.legal
mumilligan@butler.legal
Counsel for Defendant, Don King’s Concrete, Inc.
Jayne Ann Pittman, Esq.
Natalie Fischer, Esq.
CONROY SIMBERG
Two South Orange Avenue — Suite 300
Orlando, FL 32801
eserviceorl@conroysimberg.com
jpittman@conroysimberg.com
nfischer(@conroysimberg.com
mmaitland@conroysimberg.com
Counsel for Defendant, Advanced Wrapping and Concrete Solutions
Of Central Florida, Inc.
William M. Woods, Esq.
LAW OFFICE OF WILLIAM WOODS
100 S. Missouri Avenue — Suite 201
Clearwater, FL 33756
wwoods@willwoodslaw.com
annelm@willwoodslaw.com
pleadins@willwoodslaw.con
Counsel for All Glass Installation Corp.
Jennifer L. Shippole, Esq.
LAW OFFICE OF JENNIFER L. SHIPPOLE
14050 NW 14th Street, Suite 180
Sunrise, Florida 33323
ishippole@fednat.com
ckassem@fednat.com
Counsel for Atlantic Concrete Systems, Inc.
Richard L. Russo, Esq.
LAW OFFICE OF RICHARD L. RUSSO
505 Maitland Ave., Suite 1000
Altamonte Springs, FL 32701
rrusso@wfmblaw.com
Counsel for Well Hung Windows & Doors, LLC
Chelsey “Chet” G. Moody, Jr., Esq.
Mai M. Le, Esq.
MOODY & GRAF, P.A.
1101 N. Lake Destiny Rd., Suite 200
Maitland, FL 32751
moody@moodygraf.com
mle@moodygraf.com
Counsel for Premier Plastering of Central Florida, Inc. and Wolf’s Irrigation & Landscaping, Inc.
Andrew E. Hollway, Esq.
Time Ford, Esq.
HILL WARD HENDERSON
101 E. Kennedy Blvd., Suite 3700
Tampa, FL 33602
andrew.holway@hwhlaw.com
tim. ford@hwhlaw.com
kathy.wernsing@hwlaw.com
tracy.coale@hwlaw.com
derrick.calandra@hwlaw.com
Counsel for Weintraub Inspections & Forensics, Inc. n/k/a Weintraub Engineering and Inspections,
Inc.
Michael D. Ruel, Esq.
GALLOWAY JOHNSON TOMPKINS BURR & SMITH
400 N. Ashley Drive, Suite 1000
Tampa, FL 33602
mruel@gallowaylawfirm.com
beollins@gallowaylawfirm.com
tampaservice@gallowaylawfirm.com
Counsel for Casey Hawkins Glass, Inc.
Andrew T. Marshall, Esq.
HAMILTON PRICE
2400 Manatee Ave. West,
Bradenton, FL 34205
andrew@hamiltonpricelaw.com.
nancy@hamiitonpricelaw.com
kelsey@hamiltonpricelaw.com
Counsel for T&M Construction of Sanford, Inc
Scott Ross, Esq.
GROELLE & SALMON, P.A.
1715 N. Westshore Blvd., #320
Tampa, FL 33607
stoss@gspalaw.com
johnson@gspalaw.com
gscourtdocs@gspalaw.com
Counsel for Helberg Enterprises, LLC
EXHIBIT A
FORENSIC BUILDING EXPERTS, INC.
AR15730
Steven H. Kahn, AIA, NCARB
FBE
Steven H. Kahn, AIA, NCARB
— President
Steven Kahn has more than 30 years of experience in the building
design and construction industry. He specializes in forensic
architecture and has extensive experience in building codes, design
theory, general construction practices, roofing assemblies and project
management. His building envelope experience includes water
intrusion at building foundations, walls and roofing, and elevated
vehicular building structures. He is an expert in building design defects,
building construction defects, and building code compliance cases on
behalf of attorneys, owners, developers, insurance companies and
others. Steven's portfolio also includes design for new buildings,
renovations and remodels for commercial and residential structures,
healthcare facilities and industrial buildings.
EDUCATION
1990 BArch, University of Miami School of Architecture
1985 AA, Miami Dade Community College
EXPERIENCE
Litigation Support ~ Expert Witness
’ Dumke v Napoli, Ft. Lauderdale (Las Olas), Florida. Provided litigation support for a three-story single-
family residence where seller's property disclosures were inaccurate, incomplete, and not to the seller's
best knowledge for the current condition of the residence at the time of the real estate transaction. The
residence has an active water intrusion condition at the building envelope causing damage to the built
environment.
te Feria v Sedano's Supermarket, Miami, Florida. Provided litigation support regarding a commercial
property where a grocery chain store was in operation and a patron was on the premises and allegedly
sustained an injury on its public circulation pathway.
ts William Hamilton Arthur Architect, Inc. v John Bell Construction, Inc., Pinecrest, Florida. Provided litigation
support for a single family residence where the building contractor did not prepare the site grading and
set the foundation form boards in accordance with local municipality flood elevation ordinance
requirements causing a stop work order to the project.
& Schneider v William Hamilton Arthur Architect, Inc. et.al., Pinecrest, Florida. Provided litigation support
for a single family residence alleging the architect of record failed to exercise a reasonable degree of skill
and care providing professional services and caused local municipality to issue a stop work order to the
project.
& Holmquist v Metal Shield Industries, Inc., Boynton Beach, Florida. Provided litigation support regarding a
low-rise ground up residential development under construction where a construction worker performing
construction activities at a second story balcony fell off the balcony edge where a railing barrier was not
secured to the building, landing on finish grade and survived.
% Chateau Beach COA v Chateau Beach, LLC et. al. (Kobi Karp Architecture and Interior Design, Inc.),
Sunny Isles, Florida. Provided litigation support for a high-rise mixed-use residential development alleging
June 2021 Page 1 of 14
19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com
FORENSIC BUILDING EXPERTS, INC.
AR15730
Steven H. Kahn, AIA, NCARB
FBE
the architect of record failed to exercise a reasonable degree of skill and care providing professional
services.
” Richitelli v United States Postal Service, Pembroke Pines, Florida. Provided litigation support regarding a
patron operating a USPS Collection Station blue drop box was electrocuted and survived.
° Abraham v WestGate Hotels, Orlando, Florida. Provided litigation support regarding a hotel patron
operating a salon accessory device in the hotel room was electrocuted and survived.
% Genos Derwin “D.J.” Williams, Jr. v Universal Insurance Company of North America, South Miami, Florida.
Provided litigation support for a two-story single-family residence alleging a windstorm event occurred
causing the building envelope roofing assembly to fail and water intrusion at the roofing assembly
damaged the built environment.
” Palau Sunset Harbor COA v Palau Sunset Harbor, LLC et. al. (Kobi Karp Architecture and Interior Design,
Inc.), Miami Beach, Florida. Provided litigation support for a low-rise residential condominium building
structure, with commercial tenants at ground level alleging the architect of record failed to exercise a
reasonable degree of skill and care providing professional services.
Harrigan v People’s Trust Insurance Company et. al. (Rapid Response Team, LLC.), Tamarac, Florida.
Provided litigation support for a one-story single-family residence re-roof alleging the roofing assembly
was installed in a defective manner causing the building envelope to receive water intrusion damaging
the built environment.
es* Woods of Ortega COA v DR HORTON et. al. (North Florida Framing), Jacksonville, Florida. Provided
litigation support for a residential condominium association community consisting of ten building structures
(2-story); alleging the construction of the roof & wall framing and associated sheathing was defectively
installed including its framing members and fasteners causing water intrusion at the applied stucco
assembly.
Quach v Coastal Innovations, Islamorada, Florida. Provided litigation support for a three-story single-
family residence constructed as a ground-up structure which did not receive a certificate of occupancy or
certificate of completion due to construction defects. The building envelope is experiencing water intrusion
at all floor levels causing interior water intrusion damage.
+ One Ocean Condominium Association, Inc. v TRG — Block One, LTD et. al. (Norten Architecture, PC, Inc.
d/b/a Ten Arquitectos), Miami Beach, Florida. Provided litigation support for a mid-rise residential
condominium building structure, alleging the design architect of record provided architectural services,
drawings, plans and specifications for the construction of the building structure, the design architect of
record failed to exercise a reasonable degree of skill and care providing professional services.
es Down Under Construction Services, Inc. v Moshe Kedan, Clearwater Beach, Florida. Provided litigation
support for a mid-rise residential condominium unit owner failed to make final payment for contracted
renovation construction services due to construction defects. Construction defects including architectural
finishes, sliding glass door assemblies, drywall and drywall framing ceiling / walls, plumbing piping &
fixtures, and electrical work in accordance the applicable building code, and permitted construction plans.
S Peter and John Trombadore v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva —
Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence
“Denali” model home, alleging defective design of floor trusses the over the garage causing excessive
truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior
doors to misalign.
oe Kevin and Kathleen Reichard v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva —
Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence
June 2021 Page 2 of 14
a SEO EES EE LE EEL EOE SO SETI OE DELETE OEE
19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com
FORENSIC BUILDING EXPERTS, INC.
AR15730
Steven H. Kahn, AIA, NCARB
FBE
“Denali” model home, alleging defective design of floor trusses the over the garage causing excessive
truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior
doors to misalign.
Jennifer and Roberto Perez v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva —
Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence
“Denali” model home, alleging defective design of floor trusses the over the garage causing excessive
truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior
doors to misalign.
oe Adam and Amy Lucks v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect
of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali”
model home, alleging defective design of floor trusses the over the garage causing excessive truss
deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to
misalign.
* Brad and Cristina Lipson v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva —
Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence
“Denali” model home, alleging defective design of floor trusses the over the garage causing excessive
truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior
doors to misalign.
” Karl and Suzanne Liin v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect
of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali”
model home, alleging defective design of floor trusses the over the garage causing excessive truss
deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to
misalign.
&“ David and Tuyet Johnson v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva —
Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence
“Denali” model home, alleging defective design of floor trusses the over the garage causing excessive
truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior
doors to misalign.
%* Stephanie and Terrace Freeman v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva
— Architect of Record), Parkland, Florida. Provided litigation support
for a two-story single-family residence
“Denali” model home, alleging defective design of floor trusses the over the garage causing excessive
truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior
doors to misalign.
% Kashhif Aqeel and Munazza Fatma v Parkland Reserve, et al. (Architectural Planning Design, Edward
Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family
residence “Denali” model home, alleging defective design of floor trusses the over the garage causing
excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing
interior doors to misalign.
Ss Grosso v Pelican Isles Yacht Club, Naples, Florida. Provided litigation support for a marina clubhouse
free-standing building regarding alleged improper design, construction, and maintenance of its
architectural flooring, where an invitee had fallen sustaining injury at the premises along the common
element interior pathway adjacent to the bar, and dining room.
Speedy Foods v LADS Rental, Ft. Lauderdale, Florida. Provided litigation support for a commercial
property (restaurant) regarding alleged damages that a roofing contractor did not repair the roof in
compliance with appliable building codes.
June 2021 Page 3 of 14
19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com
FORENSIC BUILDING EXPERTS, INC.
AR15730
Steven H. Kahn, AIA, NCARB
FBE
oS Tsyganov v Universal Insurance Company of North America, Ft. Lauderdale, Florida. Provided litigation
support regarding alleged damages of a single-family two-story residence caused by Hurricane IRMA
(2017), damaging building interior building materials and finishes.
Canaveral Port Authority v SKANSKA et.al (KENPAT USA, LLC), Cape Canaveral, Florida. Provided
litigation architectural consulting support for a seven-story structure (Exploration Tower) building envelope
sail-shaped profile with a metal cladding and curtainwall assembly facade. The building envelope is
experiencing water intrusion, allegedly failure due to improper design and installation of the metal cladding
assembly, and air & water barrier system for a non-vertical application.
oe Merrick View Office Condominium Association, Inc. v MK Contractors, Inc. et.al., Coral Gables, Florida.
Supplemental 558 Notice from Merrick View to (Decktight Roofing). Provided litigation support for an
eight-story office condominium building, alleging defective roofing installation for a (Thermoplastic
Polyolefin — TPO Roofing Assembly) having elevated moisture beneath the roof membrane and bonding
deficiencies.
* David Techmanski v ABC Roofing Corp., Wilton Manors, Florida. Provided litigation support for a three-
story quadplex residential townhome(s) alleging defective roofing installation for the penthouse roof a
(Built-Up Roofing Assembly) and residential unit terrace(s) a (Fluid applied waterproofing assembly)
causing interior water intrusion damages.
2 D&D Constantakos, Inc. v Altec Roofing, Inc., Hobe Sound, Florida. Provided litigation support for a one-
story single-family residence receiving a new roofing assembly alleging defective roofing installation,
roofing tiles detachment from roof membrane slipping out of seated position.
* Cristina Garcia v People's Trust Insurance Company et. al. (Rapid Response Team, LLC.), Miami, Florida.
Provided litigation support for a one-story single-family residence receiving a new roofing assembly
alleging defective roofing installation.
Provincial South, Inc. v Leisure Mar Association, Inc., et.al (Duhon Roof Consulting, LLC.), Lauderdale-
by-the-Sea, Florida. Provided litigation support regarding a low slope roofing assembly for a 15-story high-
rise condominium residence caused by Hurricane IRMA (2017). Allegation of defects; bonding of roofing
membrane (heat-weld), delamination of ply sheets, base insulation adhesion failure, roof drain and
scupper deficiency, and improper drainage allowing ponding water.
es Regan v Carillion Condominium Association, Atlantis, Florida. Provided litigation support regarding the
allegation that the condominium association failed to maintain the common roof and exterior walls,
specifically stucco cracks which caused water intrusion damaging unit interiors. Counter-claim; actions
undertaken by the Plaintiff to tarp the common roof by mechanical attachment through the concrete roof
tile assembly caused damage to the roofing assembly requiring roof repairs by the condominium
association.
ts Armando Diaz v HTG Veranda Senior, LTD, Homestead, Florida. Provided litigation support regarding
alleged design deficiency for an elevator at a three-story residential building for senior citizens and
disabled individuals having a singular elevator, whereupon the elevator was inoperable for a period of
time causing a disabled resident residing on an elevated floor to become injured traveling up and down
flights of stairs several times a day.
o Madeleyn Abuin v Macy's Florida Stores, LLC, et.al (IDX Corporation), Miami, Florida. Provided litigation
support regarding the alleged design defects and construction for a raised semi-platform wooded flooring
unique to Denim & Supply by RALPH LAUREN shops within a Macy’s store at Dadeland Mall which failed
causing injury to a business invitee.
June 2021 Page 4 of 14
19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com
FORENSIC BUILDING EXPERTS, INC.
AR15730
Steven H. Kahn, AIA, NCARB
FBE
oS Grace Manning v Gator Miami Lakes, LLC, Miami Lakes, Florida. Provided litigation support regarding
alleged design and construction failing to have adequate or visible ramps for impaired persons in violation
of Florida building codes and ADA standards at an office building where a person fell on the property and
was injured.
* Willie Robinson Cone v The Center for Independent Living, Pompano Beach, Florida. Provided litigation
support regarding a residential apartment interior closet bi-fold door assembly detached from its fixed
connection striking the occupant causing injury.
Saint Raphael Roofing v Norris Home Furnishings, Ft. Myers, Florida. Provided litigation support
regarding the design, and installation methodology of building materials installed at the building
envelope post Hurricane (IRMA) activity for preventing water intrusion into the property, a metal building
structure serving as a designer showroom and offices for a home furnishings retailer.
* Secured Holdings v K.N. Edwards Sales, et al., Boynton Beach, Florida. Provided litigation support
regarding alleged design and construction defects at a low-rise apartment building structure for handrail
related labor and services and/or materials.
2700 North Ocean Condominium Association v Catalfumo Construction, et al (Architecture Metals, LTD
Co.), Riviera Beach, Florida. Provided litigation support regarding alleged design and construction
defects at a high-rise condominium building (The Ritz-Carlton Residences) structure for handrail related
labor and services and/or materials.
te Rodriguez-Gonzalez v The Polish American Club of Miami, Miami, Florida. Provided litigation support
regarding an individual operating drilling equipment into the earth to provide a well-point water source
supply for the property within the vicinity of overhead utility electrical and communication transmission
lines was fatally electrocuted and another individual was injured and survived.
Phillips v Key West Harbour, (Stock Island) Key West, Florida. Provided litigation support regarding
alleged improper design, construction, and maintenance for Key West Harbour architectural floor finish,
where an invitee had a slip and fall injury on exterior covered walkway.
t Cappola v AE Management, Coral Springs, Florida. Provided litigation support regarding improper design
and construction for Angelo Elias’ restaurant, where a customer had a trip and fall injury in the restroom
stall.
” Two City Plaza v Kolter (et al) BC Architects, West Palm Beach, Florida. Provided litigation support
regarding design and construction defects in a high-rise condominium residence building structure
resulting in defective installation of building materials causing building envelope water intrusion, interior
water damage to building materials and underlying finishes and ADA compliance issues.
es Gayer v Basketball Properties, Miami, Florida. Provided litigation support regarding improper design and
construction of the American Airlines Arena where a business invitee attending a conference had a trip
and fall injury on an unlevel surface.
a Magner v Chen Moore and Associates, et al., Miami Beach, Florida. Provided litigation support regarding
alleged improper design and construction of a handicap ramp having improper measurements for cross
slope and running slope surfaces at a public sidewalk / right-of-way at the SW intersection of 19" street
and James Avenue corner fronting Sherita Apartments along 19" street, where a pedestrian had a slip
and fall injury.
& Drummond v Universal Insurance Company of North America, Hollywood (Miramar), Florida. Provided
litigation support regarding alleged damages of a multifamily two-story residence caused by Hurricane
IRMA (2017), damaging building interior building materials and finishes.
June 2021 Page 5 of 14
19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com
FORENSIC BUILDING EXPERTS, INC.
AR15730
Steven H. Kahn, AIA, NCARB
FBE
oS Morejon v North Miami Beach Rehabilitation Center, North Miami Beach, Florida. Provided litigation
support regarding city controlled and maintained parking spaces fronting the business having alleged
parking layout deficiencies including ADA and a passenger loading zone causing a transportation vehicle
driver to become injured during passenger loading / unloading activities struck by another vehicle.
* Nieves v Universal Insurance Company of North America, Miami (Kendall), Florida. Provided litigation
support regarding alleged damages of a single-family residence caused by Hurricane IRMA (2017),
damaging building interior building materials and finishes.
Edge v Trans Coastal Construction (4'" Party Defendant), West Palm Beach, Florida. Provided litigation
support regarding a building envelope water intrusion of the low slope roofing assembly at The Edge
Condominium, a 15-story high-rise residential condominium structure, allegedly caused water damage.
© Geraldine Cerami v Quadomain Condominium II Association, Inc., Hollywood, Florida. Provided litigation
support regarding a building envelope water intrusion event at Catania Tower; a 27-story high-rise
residential condominium structure, allegedly caused interior water damage to Unit #203.
% Jorge Paula v The Home Depot, Miami Lakes, Florida. Provided litigation support for a two-story single-
family residence receiving a new roofing assembly resulting in defective roofing installation, building
envelope water intrusion, and interior water damage to building materials and underlying finishes.
ee Negron v Universal Insurance Company of North America, Miami (Hialeah), Florida. Provided litigation
support regarding alleged damages of a single-family residence caused by Hurricane IRMA (2017),
damaging building interior building materials and finishes.
t Diaz / Rodriguez v Universal Insurance Company of North America, Miami, Florida. Provided litigation
support regarding alleged damages of a single-family residence caused by Hurricane IRMA (2017),
damaging building interior building materials and finishes.
se Greystone v Crawford Williams Engineering, Miami (Kendall), Florida. Provided litigation support for a
ground-up one-story skilled nursing facility. AHCA 80% inspection failure notice regarding the installation
of mechanical fire dampers at ceilings requiring ceiling radiation dampers assemblies.
& City of Port St. Lucie Notice of Claim Pursuant to Chapter 558 of Florida Statute, to Suffolk Construction,
Port St. Lucie, Florida. Civic Center 6-level covered precast parking garage; construction defects resulting
in improper precast assembly of the building structure, concrete spalls, concrete cracks, improper
placement of precast tee embed plates, improper placement of sealants and backer rod, water intrusion
into the main electrical room, deterioration of vehicular cable barrier fasteners, EIFS exterior wall
extrusions adhesive failure, exposed rebar having improper concrete coverage deteriorating concrete
reinforcing rebars and promoting concrete spalls.
es Maria |. Diaz Garcia v Publix Super Markets, Inc. et al. (Advanced Roofing, Inc.), Miami (Kendall), Florida.
Provided litigation support regarding alleged defective roof repairs for a Publix grocery store having a low
slope roofing system, allowed water to enter the building envelope roofing assembly and puddle water on
the floor surface at a shopping aisle where a customer had a slip and fall injury.
& Raquel M. Donofrio v Pompano Atlantis Condominium Association, Pompano Beach, Florida. Provided
litigation support regarding a mid-rise condominium penthouse residence water infiltration through the
building envelope exterior wall.
o Wachter v Tuscan Harvey Estate Homes (3 Party Plaintiff) v Garcia Stromberg f/k/a Garcia Brenner &
Stromberg, et al., Palm Beach Gardens, Florida. Provided litigation support for a single family residence
regarding alleged architectural design defects resulting in improper constructed roof and building
structure, improper designed windows, water intrusion from a roof leak, windows leaks, improper
supported Korbel supports, dryer vent exceeding code length, improper stucco application, improper
June 2021 Page 6 of 14
19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com
FORENSIC BUILDING EXPERTS, INC.
AR15730
Steven H. Kahn, AIA, NCARB
FBE
installed swimming pool and spa, improper framing, improper installed stair riser heights, and improper
flashing at balcony resulting in water intrusion.
” Mark A. Bobrowsky v Ramblewood East Condominium Association, Inc., Coral Springs, Florida. Provided
litigation support regarding alleged condominium association failed to maintain operation and
maintenance of common and limited common elements including but not necessarily limited to; the roof,
roofing system, windows, exterior of the building, external sprinkler systems, drains, plumbing,
connections, all plumbing and water lines, intakes and the like outside the condominium units.
101 Condominium Association, Inc. Notice of Claim Pursuant to Chapter 558 of Florida Statute, to Gabriel
Lopez Architect, PA (architect of record), Key Biscayne, Florida. Alleged design / construction defects and
deficiencies, including tile slip coefficient of friction at the Roof — Pool Area. Provided litigation support
regarding alleged design / construction defects for a 5-story building, residential condominium association
community having a swimming pool located at rooftop with floor surfacing material surround at the
swimming pool area and decking to be porcelain tile. Safety and Slip Hazard allegation to be significantly
below standard.
a Woodland Terrace at Timber Springs Homeowner's Association, Inc. v Toll Orlando Limited Partnership,
et al. (Don Schmidt Contracting & Roofing, Inc.), Orlando, Florida. Provided litigation support regarding
alleged construction defects for multiple buildings within a homeowner's association residential
community having a laminated shingle roofing assembly and water infiltration into the building envelope.
” Hartzell Construction, Inc. v Ramblewood East Condominium Association, Inc. (Counter-Claim), Coral
Springs, Florida. Provided litigation support regarding construction defects for multiple buildings within a
condominium association residential community; low slope roofing assembly, steep slope asphalt
shingle roofing assembly, including improper installation of stucco veneer application, associated
cladding accessories and water infiltration into the building envelope.
&“ Palmetto Hospitality of Tamarac |, LLC v Kast, (El Faro Construction, Inc. & Realistic Group, Inc. - Fourth
Party Defendants), Tamarac, Florida. Provided litigation support regarding alleged construction defects
at a 5-Story Hampton Inn & Suites Hotel, including improper installation of stucco veneer application and
associated cladding accessories and water infiltration into the building envelope.
& Centimark Construction v United States Development, LTD, Miami, Florida. Provided litigation support
regarding construction defects at a AMC 18 Cineplex Theater for Thermoplastic Polyolefin (TPO) single-
ply reflective roofing membrane recover system applied over an existing low slope roofing assembly and
water infiltration into the building envelope.
oe Ronin Development LLC v Michael H Paycher, Parkland, Florida. Provided litigation support regarding
construction defects for a custom single-family residence.
& The Barclay at Hamptons West Condominium Association, Inc. v Polo International, Inc., N. Lauderdale,
Florida. Provided litigation support regarding alleged construction defects in a low-rise condominium
residence for a roof coating system applied over an existing low slope roofing assembly and water
infiltration into the building envelope.
& Mangrove Bay Housing LLC v Lacerte Builders, et al (Third Party Defendant), Jupiter, Florida. Provided
litigation support regarding alleged construction roofing defects in a multi-residential apartment
buildings (low-rise) community.
oe Fireman's Fund Insurance Co. a/s/o/ Richard Sarner v Michael K Walsh Roofing, Jupiter, Florida.
Provided litigation support regarding alleged construction roofing defects for a custom single-family
residence having a steep slope (concrete tile), and BUR roofing assembly. Water infiltration into the
building envelope.
June 2021 Page 7 of 14
19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com
FORENSIC BUILDING EXPERTS, INC.
AR15730
Steven H. Kahn, AIA, NCARB
FBE
oS BRE v Decktight, Boca Raton, Florida. Provided litigation support regarding alleged construction defects
in a low-rise condominium residence for a steep slope mansard roofing assembly and water infiltration
into the building envelope (fascia).
Soares Da Costa CS LLC v Panterra Dev. et al, TCT Corp d/b/a Tamiami Carpet Tile (Third Party
Defendant), Miami, Florida. Provided litigation support regarding alleged construction defects shower
tile installation in a high-rise condominium residence.
* Vista Trace v Rollan Plumbing, Miami, Florida. Provided litigation support regarding alleged design and
construction plumbing defects in a multi-residential buildings and community center condominium
association.
e Towers of Channelside Condominium Association v Curts Gaines Hall Jones Architects, et al, Tampa,
Florida. Provided litigation support regarding alleged design defects in a high-rise condominium
residence podium building structure (covered parking garage).
Veranda Park Interim Association v PCL Construction, Orlando, Florida. Provided litigation support
regarding alleged construction defects in a low-rise mixed-use residence. Water infiltration at open air
courtyards over parking garage.
” Osher v Sutter Roofing Company, Sarasota, Florida. Provided litigation support regarding construction
defects in a low-rise condominium residence for a modified bituminous roof replacement and water
infiltration into the building envelope.
es Oceanside Plaza v Foam King Industries, Miami Beach, Florida. Provided litigation support regarding
construction defects in a mid-rise condominium residence for an SPF roof replacement, including improper
placement of the new roof, blistering of the roof coating and water infiltration into the building envelope.
“ Mangrove Cay v Commercial Plastering, St. Petersburg, Florida. Provided litigation support regarding
alleged construction defects in a mid-rise condominium residence, including improper installation of
cladding accessories, and stucco veneer application.
& Goren v Welsh, Naples, Florida. Provided litigation support regarding alleged construction defects in a
single-family luxury cust
Preview
Filing # 136674948 E-Filed 10/15/2021 04:29:12 PM IN THE CIRCUIT COURT OF THE 97! JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2020-CA-002942-ON VILLAS AT EMERALD LAKE HOMEONWERS ASSOCIATION, INC., a Florida not for profit corporation, Plaintiff, Vv. ROYAL OAK HOMES, LLC, a Florida limited liability company; ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC., a Florida corporation; DON KING’S CONCRETE, INC., a Florida corporation; HUGH MACDONALD CONSTRUCTION, INC., a Florida corporation; IMPERIAL BUILDING CORPORATION, a Florida corporation; PREMIER PLASTERING OF CENTRAL FLORIDA, INC. n/k/a TGK STUCCO, INC., a Florida corporation, WEATHERMASTER BUILDING PRODUCTS, INC., a Florida corporation; WEINTRAUB INSPECTIONS & FORENSICS, INC. n/k/a WEINTRAUB ENGINEERING AND INSPECTIONS, INC, a Florida corporation; THE DIMILLO GROUP, LLC, a Florida limited liability company; WOLF’S IRRIGATION & LANDSCAPING, INC., A Florida corporation; SUMMERPARK HOMES, INC., a Florida corporation; BROWN + COMPANY ARCHITECTURE, INC., a Florida corporation; Defendant. / ROYAL OAK HOMES, LLC, a Florida limited liability company; Crossclaim Plaintiff, Vv. ADVANCED WRAPPING AND CONCRETE SOLUTION OF CENTRAL FLORIDA, INC., a Florida corporation; DON KING’S CONCRETE, INC., a Florida corporation; HUGH MACDONALD CONSTRUCTION, INC., a Florida corporation; IMPERIAL BUILDING CORPORATION, a Florida corporation; PREMIER PLASTERING OF CENTRAL FLORIDA, INC. n/k/a TGK STUCCO, INC., a Florida corporation; WEATHERMASTER BUILDING PRODUCTS, INC., a Florida corporation; WEINTRAUB INSPECTIONS & FORENSICS, INC. n/k/a WEINTRAUB ENGINEERING AND INSPECTIONS, INC., a Florida corporation; WOLF'S IRRIGATION & LANDSCAPING, INC., a Florida corporation; BROWN+ COMPANY ARCHITECTURE, INC., a Florida corporation; Crossclaim Defendants / DEFENDANT BROWN + COMPANY ARCHITECTURE, INC.’S INITIAL EXPERT DISCLOSURE Pursuant to Court Order, Defendant BROWN + COMPANY ARCHITECTURE, INC. (“BROWN”) disclose and reserve the right to call the following expert witness to testify at trial on behalf of BROWN in this matter: (1) Steven H. Kahn, AIA, NCARB President, Forensic Building Experts, Inc. (*FBE”) 19235 South Creekshore Court, Boca Raton, FL 33498 Nature of Expertise: Mr. Kahn has more than 30 years of experience in the building design and construction industry. He specializes in forensic architecture and has extensive experience in building codes, design theory, general construction practices, roofing assemblies and project management. His building envelope experience includes water intrusion at building foundations, walls and roofing, and elevated vehicular building structures. He is an expert in building design defects, building construction defects, and building code compliance cases on behalf of attorneys, owners, developers, insurance companies and others. Steven’s portfolio also includes design for new buildings, renovations and remodels for commercial and residential structures, healthcare facilities and industrial buildings. Subject Matter and Summary of Opinions: Mr. Kahn is expected to testify and offer opinions as to the work and services provided by BROWN and the claims made against BROWN. Mr. Kahn is also expected to offer opinions and testimony that BROWN provided services in conformance with the BROWN’s contract(s) and agreement(s) for the Project; and that BROWN provided its professional design services in conformance with the standard of care applicable to a professional architect in similar circumstances in the locality at issue. Such opinion testimony is anticipated to address topics including but not limited to BROWN’s scope of services, as well as BROWN’s professional design services rendered for the Project’s initial construction. Mr. Kahn is also anticipated to testify and render opinions as to the means and methods of construction, causation as to alleged defects and deficiencies, as well as the actions of the owner/developer, general contractor, subcontractors, other design professionals, consultants, local building authorities and inspectors relative to BROWN’s scope of services. Mr. Kahn is also expected to testify and offer opinions concerning alleged damages asserted by the Association. Mr. Kahn is further expected to offer opinions and testimony as to the relative roles and duties of the owner/developer, general contractor, subcontractors, other design professionals, consultants local building authorities and inspectors. Additionally, Mr. Kahn is expected to offer opinions and testimony in rebuttal to the testimony and opinions of the other Parties’ experts. Lastly, Mr. Kahn’s opinions are more fully set forth within his initial expert report which will be disclosed to the Parties via electronic link concurrent with this disclosure. BROWN reserves the right to supplement this disclose in accordance with the procedures set forth in the applicable Florida Rules of Civil Procedure and Court Orders. Grounds for Opinion: Mr. Kahn’s site visit of the property, review of expert reports disclosed by the Parties, review of construction documents, drawings, construction specifications, change orders, meeting minutes, project correspondence, shop drawings, submittals, project manuals, Requests for Information, building code reference materials, the Florida Building Code, Osceola County ordinances and codes, documents disclosed by the Parties in discovery, documents disclosed by non-parties in discovery, deposition testimony, architectural industry standard reference materials, contracts between the various parties, construction schedules, photos by others, applications for payment and related supporting documents, permit applications, maintenance and operations manuals, designs and specifications produced or provided by others for remedial, renovation, and expansion projects relative to the Project. Mr. Kahn will also rely on his experience, training, education, research, and continuing education; and the exhibits and evidence referenced and set forth in Mr. Kahn’s report(s). Mr. Kahn is anticipated to disclose an initial and/or expert rebuttal report to the Parties via electronic link in accordance with Court Orders regarding expert discovery and disclosure. BROWN reserves the right to supplement this report in response to rebuttal reports or opinions disclosed by any other Party after the date of this disclosure. Deposition: Mr. Kahn will be made available for deposition within the expert discovery period established by the Court. Curriculum Vitae: Mr. Kahn’s CV is attached hereto as Exhibit A. CERTIFICATE OF SERVICE ON THE FOLLOWING PAGE CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and accurate copy of the above has been furnished by Electronic Mail, by filing through the Florida Courts E-Filing E-portal system to the following parties on the attached service list on this 15th day of October 2021. MILBER MAKRIS PLOUSADIS & SEIDEN LLP Attorneys for Defendant BROWN + COMPANY ARCHITECTURE, INC. 1900 NW Corporate Blvd., East Tower, Suite 440 Boca Raton,Florida 33431 bealderon@milbermakris.com dhill milbermakris.com creech@milbermakris.com Telephone: 561-994-7310 Facsimile: 561-994-7313 By: /s\2 Giegen SUL Gh Bruce R. Calderon Florida Bar No.50448 D. Bryan Hill, Jr. Florida Bar No.0113687 Audra R. Creech Florida Bar No. 122373 SERVICE LIST Phillip E. Joseph, Esq. Alana Smith, Esq. Evan J. Small, Esq. Jeffrey A. Widelitz Esq. BALL JANIK, LLP 201 East Pine Street — Suite 600 Orlando, FL 32801 pjoseph@ballijanik.com esmal|@balljanik.com jwidelitz@balljanik.com asmith@ballianik.com ypalmer@balljanik.corr nwise@balljanik.com orlandodocket@balljanik.com Counsel for Plaintiff, Villas at Emerald Lake Homeowners Association, Inc. Thamir A. R. Kaddouri, Jr., Esq. Beth A. Tobey, Esq. LAW OFFICE OF THAMIR A.R. KADDOURI, JR., P.A. 3220 West Cypress Street Tampa, FL 33607 thamir.kaddouri@tampalaw.org beth.tobey@tampalaw.org Counsel for Defendant, Imperial Building Corporation Peter J. Kapsales, Esq. Margaret M. Efta, Esq. MILNE LAW GROUP, P.A. 301 East Pine Street — Suite 525 Orlando, FL 32801 pkapsales@milnelawgroup.com mefta@milnelawgroup.com eservice@milnelawgroup.com Counsel for Defendant, Weathermaster Building Products, Inc. Joseph L. Zollner, Esq. LAW OFFICE OF J. CHRISTOPHER NORRIS P.O. Box 7217 London, KY 40742 joseph.zollner@libertymutual.com FloridaCDLegalMail@LibertyMutual.com Counsel for Lois Concrete Corp. Robin H. Leavengood, Esq. Lannie D. Hough, Jr., Esq. CARLTON FIELDS, P.A. 4221 W. Boy Scout Boulevard Tampa, FL 33607-5780 rleavengood@carltonfields.com brosa@carltonfields.com though@earltonfields.com nbonilla@carltonfields.com vwilliams@carltonfields.com iiamsiacamronnmercs cont Counsel for Defendant, Royal Oak Homes, LLC Ashley Mattingly, Esq. BUTLER WEIHMULLER KATZ CRAIG 400 North Ashley Drive — Suite 2300 Tampa, FL 33602 mattingly@butler.legal Counsel for Defendant, Hugh MacDonald Construction, Inc. (HMC) Denise M. Anderson, Esq. David Mercer, Esq. BUTLER WEIHMULLER KATZ CRAIG LLP 400 North Ashley Drive — Suite 2300 Tampa, FL 33602 danderson@butler.legal dmercer@butler.legal ws jacobs@pbutler.legal mumilligan@butler.legal Counsel for Defendant, Don King’s Concrete, Inc. Jayne Ann Pittman, Esq. Natalie Fischer, Esq. CONROY SIMBERG Two South Orange Avenue — Suite 300 Orlando, FL 32801 eserviceorl@conroysimberg.com jpittman@conroysimberg.com nfischer(@conroysimberg.com mmaitland@conroysimberg.com Counsel for Defendant, Advanced Wrapping and Concrete Solutions Of Central Florida, Inc. William M. Woods, Esq. LAW OFFICE OF WILLIAM WOODS 100 S. Missouri Avenue — Suite 201 Clearwater, FL 33756 wwoods@willwoodslaw.com annelm@willwoodslaw.com pleadins@willwoodslaw.con Counsel for All Glass Installation Corp. Jennifer L. Shippole, Esq. LAW OFFICE OF JENNIFER L. SHIPPOLE 14050 NW 14th Street, Suite 180 Sunrise, Florida 33323 ishippole@fednat.com ckassem@fednat.com Counsel for Atlantic Concrete Systems, Inc. Richard L. Russo, Esq. LAW OFFICE OF RICHARD L. RUSSO 505 Maitland Ave., Suite 1000 Altamonte Springs, FL 32701 rrusso@wfmblaw.com Counsel for Well Hung Windows & Doors, LLC Chelsey “Chet” G. Moody, Jr., Esq. Mai M. Le, Esq. MOODY & GRAF, P.A. 1101 N. Lake Destiny Rd., Suite 200 Maitland, FL 32751 moody@moodygraf.com mle@moodygraf.com Counsel for Premier Plastering of Central Florida, Inc. and Wolf’s Irrigation & Landscaping, Inc. Andrew E. Hollway, Esq. Time Ford, Esq. HILL WARD HENDERSON 101 E. Kennedy Blvd., Suite 3700 Tampa, FL 33602 andrew.holway@hwhlaw.com tim. ford@hwhlaw.com kathy.wernsing@hwlaw.com tracy.coale@hwlaw.com derrick.calandra@hwlaw.com Counsel for Weintraub Inspections & Forensics, Inc. n/k/a Weintraub Engineering and Inspections, Inc. Michael D. Ruel, Esq. GALLOWAY JOHNSON TOMPKINS BURR & SMITH 400 N. Ashley Drive, Suite 1000 Tampa, FL 33602 mruel@gallowaylawfirm.com beollins@gallowaylawfirm.com tampaservice@gallowaylawfirm.com Counsel for Casey Hawkins Glass, Inc. Andrew T. Marshall, Esq. HAMILTON PRICE 2400 Manatee Ave. West, Bradenton, FL 34205 andrew@hamiltonpricelaw.com. nancy@hamiitonpricelaw.com kelsey@hamiltonpricelaw.com Counsel for T&M Construction of Sanford, Inc Scott Ross, Esq. GROELLE & SALMON, P.A. 1715 N. Westshore Blvd., #320 Tampa, FL 33607 stoss@gspalaw.com johnson@gspalaw.com gscourtdocs@gspalaw.com Counsel for Helberg Enterprises, LLC EXHIBIT A FORENSIC BUILDING EXPERTS, INC. AR15730 Steven H. Kahn, AIA, NCARB FBE Steven H. Kahn, AIA, NCARB — President Steven Kahn has more than 30 years of experience in the building design and construction industry. He specializes in forensic architecture and has extensive experience in building codes, design theory, general construction practices, roofing assemblies and project management. His building envelope experience includes water intrusion at building foundations, walls and roofing, and elevated vehicular building structures. He is an expert in building design defects, building construction defects, and building code compliance cases on behalf of attorneys, owners, developers, insurance companies and others. Steven's portfolio also includes design for new buildings, renovations and remodels for commercial and residential structures, healthcare facilities and industrial buildings. EDUCATION 1990 BArch, University of Miami School of Architecture 1985 AA, Miami Dade Community College EXPERIENCE Litigation Support ~ Expert Witness ’ Dumke v Napoli, Ft. Lauderdale (Las Olas), Florida. Provided litigation support for a three-story single- family residence where seller's property disclosures were inaccurate, incomplete, and not to the seller's best knowledge for the current condition of the residence at the time of the real estate transaction. The residence has an active water intrusion condition at the building envelope causing damage to the built environment. te Feria v Sedano's Supermarket, Miami, Florida. Provided litigation support regarding a commercial property where a grocery chain store was in operation and a patron was on the premises and allegedly sustained an injury on its public circulation pathway. ts William Hamilton Arthur Architect, Inc. v John Bell Construction, Inc., Pinecrest, Florida. Provided litigation support for a single family residence where the building contractor did not prepare the site grading and set the foundation form boards in accordance with local municipality flood elevation ordinance requirements causing a stop work order to the project. & Schneider v William Hamilton Arthur Architect, Inc. et.al., Pinecrest, Florida. Provided litigation support for a single family residence alleging the architect of record failed to exercise a reasonable degree of skill and care providing professional services and caused local municipality to issue a stop work order to the project. & Holmquist v Metal Shield Industries, Inc., Boynton Beach, Florida. Provided litigation support regarding a low-rise ground up residential development under construction where a construction worker performing construction activities at a second story balcony fell off the balcony edge where a railing barrier was not secured to the building, landing on finish grade and survived. % Chateau Beach COA v Chateau Beach, LLC et. al. (Kobi Karp Architecture and Interior Design, Inc.), Sunny Isles, Florida. Provided litigation support for a high-rise mixed-use residential development alleging June 2021 Page 1 of 14 19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com FORENSIC BUILDING EXPERTS, INC. AR15730 Steven H. Kahn, AIA, NCARB FBE the architect of record failed to exercise a reasonable degree of skill and care providing professional services. ” Richitelli v United States Postal Service, Pembroke Pines, Florida. Provided litigation support regarding a patron operating a USPS Collection Station blue drop box was electrocuted and survived. ° Abraham v WestGate Hotels, Orlando, Florida. Provided litigation support regarding a hotel patron operating a salon accessory device in the hotel room was electrocuted and survived. % Genos Derwin “D.J.” Williams, Jr. v Universal Insurance Company of North America, South Miami, Florida. Provided litigation support for a two-story single-family residence alleging a windstorm event occurred causing the building envelope roofing assembly to fail and water intrusion at the roofing assembly damaged the built environment. ” Palau Sunset Harbor COA v Palau Sunset Harbor, LLC et. al. (Kobi Karp Architecture and Interior Design, Inc.), Miami Beach, Florida. Provided litigation support for a low-rise residential condominium building structure, with commercial tenants at ground level alleging the architect of record failed to exercise a reasonable degree of skill and care providing professional services. Harrigan v People’s Trust Insurance Company et. al. (Rapid Response Team, LLC.), Tamarac, Florida. Provided litigation support for a one-story single-family residence re-roof alleging the roofing assembly was installed in a defective manner causing the building envelope to receive water intrusion damaging the built environment. es* Woods of Ortega COA v DR HORTON et. al. (North Florida Framing), Jacksonville, Florida. Provided litigation support for a residential condominium association community consisting of ten building structures (2-story); alleging the construction of the roof & wall framing and associated sheathing was defectively installed including its framing members and fasteners causing water intrusion at the applied stucco assembly. Quach v Coastal Innovations, Islamorada, Florida. Provided litigation support for a three-story single- family residence constructed as a ground-up structure which did not receive a certificate of occupancy or certificate of completion due to construction defects. The building envelope is experiencing water intrusion at all floor levels causing interior water intrusion damage. + One Ocean Condominium Association, Inc. v TRG — Block One, LTD et. al. (Norten Architecture, PC, Inc. d/b/a Ten Arquitectos), Miami Beach, Florida. Provided litigation support for a mid-rise residential condominium building structure, alleging the design architect of record provided architectural services, drawings, plans and specifications for the construction of the building structure, the design architect of record failed to exercise a reasonable degree of skill and care providing professional services. es Down Under Construction Services, Inc. v Moshe Kedan, Clearwater Beach, Florida. Provided litigation support for a mid-rise residential condominium unit owner failed to make final payment for contracted renovation construction services due to construction defects. Construction defects including architectural finishes, sliding glass door assemblies, drywall and drywall framing ceiling / walls, plumbing piping & fixtures, and electrical work in accordance the applicable building code, and permitted construction plans. S Peter and John Trombadore v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali” model home, alleging defective design of floor trusses the over the garage causing excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to misalign. oe Kevin and Kathleen Reichard v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence June 2021 Page 2 of 14 a SEO EES EE LE EEL EOE SO SETI OE DELETE OEE 19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com FORENSIC BUILDING EXPERTS, INC. AR15730 Steven H. Kahn, AIA, NCARB FBE “Denali” model home, alleging defective design of floor trusses the over the garage causing excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to misalign. Jennifer and Roberto Perez v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali” model home, alleging defective design of floor trusses the over the garage causing excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to misalign. oe Adam and Amy Lucks v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali” model home, alleging defective design of floor trusses the over the garage causing excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to misalign. * Brad and Cristina Lipson v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali” model home, alleging defective design of floor trusses the over the garage causing excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to misalign. ” Karl and Suzanne Liin v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali” model home, alleging defective design of floor trusses the over the garage causing excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to misalign. &“ David and Tuyet Johnson v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali” model home, alleging defective design of floor trusses the over the garage causing excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to misalign. %* Stephanie and Terrace Freeman v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali” model home, alleging defective design of floor trusses the over the garage causing excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to misalign. % Kashhif Aqeel and Munazza Fatma v Parkland Reserve, et al. (Architectural Planning Design, Edward Silva — Architect of Record), Parkland, Florida. Provided litigation support for a two-story single-family residence “Denali” model home, alleging defective design of floor trusses the over the garage causing excessive truss deflection / creep between bearing exterior walls damaging interior finishes and causing interior doors to misalign. Ss Grosso v Pelican Isles Yacht Club, Naples, Florida. Provided litigation support for a marina clubhouse free-standing building regarding alleged improper design, construction, and maintenance of its architectural flooring, where an invitee had fallen sustaining injury at the premises along the common element interior pathway adjacent to the bar, and dining room. Speedy Foods v LADS Rental, Ft. Lauderdale, Florida. Provided litigation support for a commercial property (restaurant) regarding alleged damages that a roofing contractor did not repair the roof in compliance with appliable building codes. June 2021 Page 3 of 14 19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com FORENSIC BUILDING EXPERTS, INC. AR15730 Steven H. Kahn, AIA, NCARB FBE oS Tsyganov v Universal Insurance Company of North America, Ft. Lauderdale, Florida. Provided litigation support regarding alleged damages of a single-family two-story residence caused by Hurricane IRMA (2017), damaging building interior building materials and finishes. Canaveral Port Authority v SKANSKA et.al (KENPAT USA, LLC), Cape Canaveral, Florida. Provided litigation architectural consulting support for a seven-story structure (Exploration Tower) building envelope sail-shaped profile with a metal cladding and curtainwall assembly facade. The building envelope is experiencing water intrusion, allegedly failure due to improper design and installation of the metal cladding assembly, and air & water barrier system for a non-vertical application. oe Merrick View Office Condominium Association, Inc. v MK Contractors, Inc. et.al., Coral Gables, Florida. Supplemental 558 Notice from Merrick View to (Decktight Roofing). Provided litigation support for an eight-story office condominium building, alleging defective roofing installation for a (Thermoplastic Polyolefin — TPO Roofing Assembly) having elevated moisture beneath the roof membrane and bonding deficiencies. * David Techmanski v ABC Roofing Corp., Wilton Manors, Florida. Provided litigation support for a three- story quadplex residential townhome(s) alleging defective roofing installation for the penthouse roof a (Built-Up Roofing Assembly) and residential unit terrace(s) a (Fluid applied waterproofing assembly) causing interior water intrusion damages. 2 D&D Constantakos, Inc. v Altec Roofing, Inc., Hobe Sound, Florida. Provided litigation support for a one- story single-family residence receiving a new roofing assembly alleging defective roofing installation, roofing tiles detachment from roof membrane slipping out of seated position. * Cristina Garcia v People's Trust Insurance Company et. al. (Rapid Response Team, LLC.), Miami, Florida. Provided litigation support for a one-story single-family residence receiving a new roofing assembly alleging defective roofing installation. Provincial South, Inc. v Leisure Mar Association, Inc., et.al (Duhon Roof Consulting, LLC.), Lauderdale- by-the-Sea, Florida. Provided litigation support regarding a low slope roofing assembly for a 15-story high- rise condominium residence caused by Hurricane IRMA (2017). Allegation of defects; bonding of roofing membrane (heat-weld), delamination of ply sheets, base insulation adhesion failure, roof drain and scupper deficiency, and improper drainage allowing ponding water. es Regan v Carillion Condominium Association, Atlantis, Florida. Provided litigation support regarding the allegation that the condominium association failed to maintain the common roof and exterior walls, specifically stucco cracks which caused water intrusion damaging unit interiors. Counter-claim; actions undertaken by the Plaintiff to tarp the common roof by mechanical attachment through the concrete roof tile assembly caused damage to the roofing assembly requiring roof repairs by the condominium association. ts Armando Diaz v HTG Veranda Senior, LTD, Homestead, Florida. Provided litigation support regarding alleged design deficiency for an elevator at a three-story residential building for senior citizens and disabled individuals having a singular elevator, whereupon the elevator was inoperable for a period of time causing a disabled resident residing on an elevated floor to become injured traveling up and down flights of stairs several times a day. o Madeleyn Abuin v Macy's Florida Stores, LLC, et.al (IDX Corporation), Miami, Florida. Provided litigation support regarding the alleged design defects and construction for a raised semi-platform wooded flooring unique to Denim & Supply by RALPH LAUREN shops within a Macy’s store at Dadeland Mall which failed causing injury to a business invitee. June 2021 Page 4 of 14 19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com FORENSIC BUILDING EXPERTS, INC. AR15730 Steven H. Kahn, AIA, NCARB FBE oS Grace Manning v Gator Miami Lakes, LLC, Miami Lakes, Florida. Provided litigation support regarding alleged design and construction failing to have adequate or visible ramps for impaired persons in violation of Florida building codes and ADA standards at an office building where a person fell on the property and was injured. * Willie Robinson Cone v The Center for Independent Living, Pompano Beach, Florida. Provided litigation support regarding a residential apartment interior closet bi-fold door assembly detached from its fixed connection striking the occupant causing injury. Saint Raphael Roofing v Norris Home Furnishings, Ft. Myers, Florida. Provided litigation support regarding the design, and installation methodology of building materials installed at the building envelope post Hurricane (IRMA) activity for preventing water intrusion into the property, a metal building structure serving as a designer showroom and offices for a home furnishings retailer. * Secured Holdings v K.N. Edwards Sales, et al., Boynton Beach, Florida. Provided litigation support regarding alleged design and construction defects at a low-rise apartment building structure for handrail related labor and services and/or materials. 2700 North Ocean Condominium Association v Catalfumo Construction, et al (Architecture Metals, LTD Co.), Riviera Beach, Florida. Provided litigation support regarding alleged design and construction defects at a high-rise condominium building (The Ritz-Carlton Residences) structure for handrail related labor and services and/or materials. te Rodriguez-Gonzalez v The Polish American Club of Miami, Miami, Florida. Provided litigation support regarding an individual operating drilling equipment into the earth to provide a well-point water source supply for the property within the vicinity of overhead utility electrical and communication transmission lines was fatally electrocuted and another individual was injured and survived. Phillips v Key West Harbour, (Stock Island) Key West, Florida. Provided litigation support regarding alleged improper design, construction, and maintenance for Key West Harbour architectural floor finish, where an invitee had a slip and fall injury on exterior covered walkway. t Cappola v AE Management, Coral Springs, Florida. Provided litigation support regarding improper design and construction for Angelo Elias’ restaurant, where a customer had a trip and fall injury in the restroom stall. ” Two City Plaza v Kolter (et al) BC Architects, West Palm Beach, Florida. Provided litigation support regarding design and construction defects in a high-rise condominium residence building structure resulting in defective installation of building materials causing building envelope water intrusion, interior water damage to building materials and underlying finishes and ADA compliance issues. es Gayer v Basketball Properties, Miami, Florida. Provided litigation support regarding improper design and construction of the American Airlines Arena where a business invitee attending a conference had a trip and fall injury on an unlevel surface. a Magner v Chen Moore and Associates, et al., Miami Beach, Florida. Provided litigation support regarding alleged improper design and construction of a handicap ramp having improper measurements for cross slope and running slope surfaces at a public sidewalk / right-of-way at the SW intersection of 19" street and James Avenue corner fronting Sherita Apartments along 19" street, where a pedestrian had a slip and fall injury. & Drummond v Universal Insurance Company of North America, Hollywood (Miramar), Florida. Provided litigation support regarding alleged damages of a multifamily two-story residence caused by Hurricane IRMA (2017), damaging building interior building materials and finishes. June 2021 Page 5 of 14 19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com FORENSIC BUILDING EXPERTS, INC. AR15730 Steven H. Kahn, AIA, NCARB FBE oS Morejon v North Miami Beach Rehabilitation Center, North Miami Beach, Florida. Provided litigation support regarding city controlled and maintained parking spaces fronting the business having alleged parking layout deficiencies including ADA and a passenger loading zone causing a transportation vehicle driver to become injured during passenger loading / unloading activities struck by another vehicle. * Nieves v Universal Insurance Company of North America, Miami (Kendall), Florida. Provided litigation support regarding alleged damages of a single-family residence caused by Hurricane IRMA (2017), damaging building interior building materials and finishes. Edge v Trans Coastal Construction (4'" Party Defendant), West Palm Beach, Florida. Provided litigation support regarding a building envelope water intrusion of the low slope roofing assembly at The Edge Condominium, a 15-story high-rise residential condominium structure, allegedly caused water damage. © Geraldine Cerami v Quadomain Condominium II Association, Inc., Hollywood, Florida. Provided litigation support regarding a building envelope water intrusion event at Catania Tower; a 27-story high-rise residential condominium structure, allegedly caused interior water damage to Unit #203. % Jorge Paula v The Home Depot, Miami Lakes, Florida. Provided litigation support for a two-story single- family residence receiving a new roofing assembly resulting in defective roofing installation, building envelope water intrusion, and interior water damage to building materials and underlying finishes. ee Negron v Universal Insurance Company of North America, Miami (Hialeah), Florida. Provided litigation support regarding alleged damages of a single-family residence caused by Hurricane IRMA (2017), damaging building interior building materials and finishes. t Diaz / Rodriguez v Universal Insurance Company of North America, Miami, Florida. Provided litigation support regarding alleged damages of a single-family residence caused by Hurricane IRMA (2017), damaging building interior building materials and finishes. se Greystone v Crawford Williams Engineering, Miami (Kendall), Florida. Provided litigation support for a ground-up one-story skilled nursing facility. AHCA 80% inspection failure notice regarding the installation of mechanical fire dampers at ceilings requiring ceiling radiation dampers assemblies. & City of Port St. Lucie Notice of Claim Pursuant to Chapter 558 of Florida Statute, to Suffolk Construction, Port St. Lucie, Florida. Civic Center 6-level covered precast parking garage; construction defects resulting in improper precast assembly of the building structure, concrete spalls, concrete cracks, improper placement of precast tee embed plates, improper placement of sealants and backer rod, water intrusion into the main electrical room, deterioration of vehicular cable barrier fasteners, EIFS exterior wall extrusions adhesive failure, exposed rebar having improper concrete coverage deteriorating concrete reinforcing rebars and promoting concrete spalls. es Maria |. Diaz Garcia v Publix Super Markets, Inc. et al. (Advanced Roofing, Inc.), Miami (Kendall), Florida. Provided litigation support regarding alleged defective roof repairs for a Publix grocery store having a low slope roofing system, allowed water to enter the building envelope roofing assembly and puddle water on the floor surface at a shopping aisle where a customer had a slip and fall injury. & Raquel M. Donofrio v Pompano Atlantis Condominium Association, Pompano Beach, Florida. Provided litigation support regarding a mid-rise condominium penthouse residence water infiltration through the building envelope exterior wall. o Wachter v Tuscan Harvey Estate Homes (3 Party Plaintiff) v Garcia Stromberg f/k/a Garcia Brenner & Stromberg, et al., Palm Beach Gardens, Florida. Provided litigation support for a single family residence regarding alleged architectural design defects resulting in improper constructed roof and building structure, improper designed windows, water intrusion from a roof leak, windows leaks, improper supported Korbel supports, dryer vent exceeding code length, improper stucco application, improper June 2021 Page 6 of 14 19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com FORENSIC BUILDING EXPERTS, INC. AR15730 Steven H. Kahn, AIA, NCARB FBE installed swimming pool and spa, improper framing, improper installed stair riser heights, and improper flashing at balcony resulting in water intrusion. ” Mark A. Bobrowsky v Ramblewood East Condominium Association, Inc., Coral Springs, Florida. Provided litigation support regarding alleged condominium association failed to maintain operation and maintenance of common and limited common elements including but not necessarily limited to; the roof, roofing system, windows, exterior of the building, external sprinkler systems, drains, plumbing, connections, all plumbing and water lines, intakes and the like outside the condominium units. 101 Condominium Association, Inc. Notice of Claim Pursuant to Chapter 558 of Florida Statute, to Gabriel Lopez Architect, PA (architect of record), Key Biscayne, Florida. Alleged design / construction defects and deficiencies, including tile slip coefficient of friction at the Roof — Pool Area. Provided litigation support regarding alleged design / construction defects for a 5-story building, residential condominium association community having a swimming pool located at rooftop with floor surfacing material surround at the swimming pool area and decking to be porcelain tile. Safety and Slip Hazard allegation to be significantly below standard. a Woodland Terrace at Timber Springs Homeowner's Association, Inc. v Toll Orlando Limited Partnership, et al. (Don Schmidt Contracting & Roofing, Inc.), Orlando, Florida. Provided litigation support regarding alleged construction defects for multiple buildings within a homeowner's association residential community having a laminated shingle roofing assembly and water infiltration into the building envelope. ” Hartzell Construction, Inc. v Ramblewood East Condominium Association, Inc. (Counter-Claim), Coral Springs, Florida. Provided litigation support regarding construction defects for multiple buildings within a condominium association residential community; low slope roofing assembly, steep slope asphalt shingle roofing assembly, including improper installation of stucco veneer application, associated cladding accessories and water infiltration into the building envelope. &“ Palmetto Hospitality of Tamarac |, LLC v Kast, (El Faro Construction, Inc. & Realistic Group, Inc. - Fourth Party Defendants), Tamarac, Florida. Provided litigation support regarding alleged construction defects at a 5-Story Hampton Inn & Suites Hotel, including improper installation of stucco veneer application and associated cladding accessories and water infiltration into the building envelope. & Centimark Construction v United States Development, LTD, Miami, Florida. Provided litigation support regarding construction defects at a AMC 18 Cineplex Theater for Thermoplastic Polyolefin (TPO) single- ply reflective roofing membrane recover system applied over an existing low slope roofing assembly and water infiltration into the building envelope. oe Ronin Development LLC v Michael H Paycher, Parkland, Florida. Provided litigation support regarding construction defects for a custom single-family residence. & The Barclay at Hamptons West Condominium Association, Inc. v Polo International, Inc., N. Lauderdale, Florida. Provided litigation support regarding alleged construction defects in a low-rise condominium residence for a roof coating system applied over an existing low slope roofing assembly and water infiltration into the building envelope. & Mangrove Bay Housing LLC v Lacerte Builders, et al (Third Party Defendant), Jupiter, Florida. Provided litigation support regarding alleged construction roofing defects in a multi-residential apartment buildings (low-rise) community. oe Fireman's Fund Insurance Co. a/s/o/ Richard Sarner v Michael K Walsh Roofing, Jupiter, Florida. Provided litigation support regarding alleged construction roofing defects for a custom single-family residence having a steep slope (concrete tile), and BUR roofing assembly. Water infiltration into the building envelope. June 2021 Page 7 of 14 19235 South Creekshore Court, Boca Raton, FL 33498 m O-954.418.0172 m F-954.418.0171 = www.fbeusa.com FORENSIC BUILDING EXPERTS, INC. AR15730 Steven H. Kahn, AIA, NCARB FBE oS BRE v Decktight, Boca Raton, Florida. Provided litigation support regarding alleged construction defects in a low-rise condominium residence for a steep slope mansard roofing assembly and water infiltration into the building envelope (fascia). Soares Da Costa CS LLC v Panterra Dev. et al, TCT Corp d/b/a Tamiami Carpet Tile (Third Party Defendant), Miami, Florida. Provided litigation support regarding alleged construction defects shower tile installation in a high-rise condominium residence. * Vista Trace v Rollan Plumbing, Miami, Florida. Provided litigation support regarding alleged design and construction plumbing defects in a multi-residential buildings and community center condominium association. e Towers of Channelside Condominium Association v Curts Gaines Hall Jones Architects, et al, Tampa, Florida. Provided litigation support regarding alleged design defects in a high-rise condominium residence podium building structure (covered parking garage). Veranda Park Interim Association v PCL Construction, Orlando, Florida. Provided litigation support regarding alleged construction defects in a low-rise mixed-use residence. Water infiltration at open air courtyards over parking garage. ” Osher v Sutter Roofing Company, Sarasota, Florida. Provided litigation support regarding construction defects in a low-rise condominium residence for a modified bituminous roof replacement and water infiltration into the building envelope. es Oceanside Plaza v Foam King Industries, Miami Beach, Florida. Provided litigation support regarding construction defects in a mid-rise condominium residence for an SPF roof replacement, including improper placement of the new roof, blistering of the roof coating and water infiltration into the building envelope. “ Mangrove Cay v Commercial Plastering, St. Petersburg, Florida. Provided litigation support regarding alleged construction defects in a mid-rise condominium residence, including improper installation of cladding accessories, and stucco veneer application. & Goren v Welsh, Naples, Florida. Provided litigation support regarding alleged construction defects in a single-family luxury cust