On November 06, 2017 a
Clerk Notice
was filed
involving a dispute between
Norma Castellon,
Yovani Castellon,
and
Southern Fidelity Insurance Company,
for CONTRACT & DEBT
in the District Court of Palm Beach County.
Preview
Filing # 132988207 E-Filed 08/19/2021 09:34:45 AM
IN THE CIRCUIT COURT OF THE ISTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 502017CA012165XXXXMBAE
YOVANI CASTELLON and NORMA
CASTELLON,
Plaintiffs,
Vv.
SOUTHERN FIDELITY INSURANCE
COMPANY,
Defendant.
NOTICE OF SPECIAL SET HEARING
(Pursuant to Court Order Setting Hearing on All Pre-Trial Motions,
dated July 22, 2021)
(Allotted Time: 3.5 hours)
YOU ARE HEREBY NOTIFIED Defendant will be calling for hearing, the following:
MATTER TO BE HEARD: 1. Defendant’s Daubert Motion to Strike
Plaintiffs’ Expert, Peter Lemus, P.E.
2. Defendant’s Amended Motion to Determine
Burdens of Proof
3. Defendant’s Memorandum of Law re Voire Dire
4. Defendant’s MIL Nos. 1 — 13 (See Exhibit A)
DATE & TIME: September 9, 2021 @ 1:30pm
LOCATION: Honorable Judge Ashley C. Zuckerman
Judge Daniel T. K. Hurley Courthouse
205 N. Dixie Hwy
Courtroom 9C
N. Dixie Hwy, West Palm Beach, FL 33401
'** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 08/19/2021 09:34:45 AM ***Castellon, Yovani and Norma Castellon vs, Southern Fidelity Insurance Company
Case No.: 502017CA012165XXXXMBAE
Movant’s attorney has spoken in person or by telephone with the
attorney(s) for all parties who may be affected by the relief sought in
the motion in a good faith effort to resolve or narrow the issues raised.
Xx Movant’s attorney has attempted to speak in person or by telephone with
the attorney(s) for all parties who may be affected by the relief sought in
the motion.
One or more of the parties who may be affected by the motion are self-
represented.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
electronically this 19™ day of August, 2021, to: Chastity G. Delgado, Esq., and Andrew M.
Brodsky, Esq., The Property Advocates, P.A., 2525 Ponce de Leon Boulevard, Suite 600, Coral
Gables, FL 33134; pleadings@thepropertyadvocates.com; team2@thepropertyadvocates.com;
cdelgado@thepropertyadvocates.com.
VERNIS & BOWLING OF PALM BEACH, P.A.
618 U.S. Highway One, Suite 200
North Palm Beach, Florida 33408
Telephone: (561) 775-9822
Fax: (561) 775-9821
Attorney for Defendant, Southern Fidelity
Insurance Company
By: /s/ Lauren Maione-Walsh
Lauren Maione-Walsh, Esq.
Florida Bar No.: 0072122
LWalsh@florida-law.com
PBFiling@florida-law.comCastellon, Yovani and Norma Castellon vs, Southern Fidelity Insurance Company
Case No.: 502017CA012165XXXXMBAE
EXHIBIT A
Def’s MIL 1 — Defendant’s Motion in Limine
Def’s MIL 2 Exclude Lay Witness Testimony
Def’s MIL 3 Exclude Unreported Roof Damages
Def’s MIL 4 Exclude Testimony, Argument, and Evidence of Coverage,
Determinations on any of Plaintiffs’ Prior or Subsequent Claims
Def’s MIL 5 Exclude Photographs not already Produced During Discovery
Def’s MIL 6 Exclude Argument or Testimony Containing False Sympathy or
Inflammatory Language
Def’s MIL 7 Exclude the Use of the Improper Measure of Damages
Def’s MIL 8 Exclude Weather Data as it was not Sufficiently Close Enough to Insured
Property
Def’s MIL 9 Exclude Payment of Premiums
Def’s MIL 10 Exclude Improper Characterization of Insured Company)
Def’s MIL 11 Strike JD Restoration from Plaintiffs’ Witness List & Exclude all
Documents, Evidence, Testimony, and Argument Related to JD
Restoration
Def’s MIL 12 Exclude All Documents, Evidence, Testimony, and Argument by
Contender
Def’s MIL 13 Exclude Damages which have Assigned Benefits
Document Filed Date
August 19, 2021
Case Filing Date
November 06, 2017
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Filing # 132988207 E-Filed 08/19/2021 09:34:45 AM IN THE CIRCUIT COURT OF THE ISTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502017CA012165XXXXMBAE YOVANI CASTELLON and NORMA CASTELLON, Plaintiffs, Vv. SOUTHERN FIDELITY INSURANCE COMPANY, Defendant. NOTICE OF SPECIAL SET HEARING (Pursuant to Court Order Setting Hearing on All Pre-Trial Motions, dated July 22, 2021) (Allotted Time: 3.5 hours) YOU ARE HEREBY NOTIFIED Defendant will be calling for hearing, the following: MATTER TO BE HEARD: 1. Defendant’s Daubert Motion to Strike Plaintiffs’ Expert, Peter Lemus, P.E. 2. Defendant’s Amended Motion to Determine Burdens of Proof 3. Defendant’s Memorandum of Law re Voire Dire 4. Defendant’s MIL Nos. 1 — 13 (See Exhibit A) DATE & TIME: September 9, 2021 @ 1:30pm LOCATION: Honorable Judge Ashley C. Zuckerman Judge Daniel T. K. Hurley Courthouse 205 N. Dixie Hwy Courtroom 9C N. Dixie Hwy, West Palm Beach, FL 33401 '** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 08/19/2021 09:34:45 AM ***Castellon, Yovani and Norma Castellon vs, Southern Fidelity Insurance Company Case No.: 502017CA012165XXXXMBAE Movant’s attorney has spoken in person or by telephone with the attorney(s) for all parties who may be affected by the relief sought in the motion in a good faith effort to resolve or narrow the issues raised. Xx Movant’s attorney has attempted to speak in person or by telephone with the attorney(s) for all parties who may be affected by the relief sought in the motion. One or more of the parties who may be affected by the motion are self- represented. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished electronically this 19™ day of August, 2021, to: Chastity G. Delgado, Esq., and Andrew M. Brodsky, Esq., The Property Advocates, P.A., 2525 Ponce de Leon Boulevard, Suite 600, Coral Gables, FL 33134; pleadings@thepropertyadvocates.com; team2@thepropertyadvocates.com; cdelgado@thepropertyadvocates.com. VERNIS & BOWLING OF PALM BEACH, P.A. 618 U.S. Highway One, Suite 200 North Palm Beach, Florida 33408 Telephone: (561) 775-9822 Fax: (561) 775-9821 Attorney for Defendant, Southern Fidelity Insurance Company By: /s/ Lauren Maione-Walsh Lauren Maione-Walsh, Esq. Florida Bar No.: 0072122 LWalsh@florida-law.com PBFiling@florida-law.comCastellon, Yovani and Norma Castellon vs, Southern Fidelity Insurance Company Case No.: 502017CA012165XXXXMBAE EXHIBIT A Def’s MIL 1 — Defendant’s Motion in Limine Def’s MIL 2 Exclude Lay Witness Testimony Def’s MIL 3 Exclude Unreported Roof Damages Def’s MIL 4 Exclude Testimony, Argument, and Evidence of Coverage, Determinations on any of Plaintiffs’ Prior or Subsequent Claims Def’s MIL 5 Exclude Photographs not already Produced During Discovery Def’s MIL 6 Exclude Argument or Testimony Containing False Sympathy or Inflammatory Language Def’s MIL 7 Exclude the Use of the Improper Measure of Damages Def’s MIL 8 Exclude Weather Data as it was not Sufficiently Close Enough to Insured Property Def’s MIL 9 Exclude Payment of Premiums Def’s MIL 10 Exclude Improper Characterization of Insured Company) Def’s MIL 11 Strike JD Restoration from Plaintiffs’ Witness List & Exclude all Documents, Evidence, Testimony, and Argument Related to JD Restoration Def’s MIL 12 Exclude All Documents, Evidence, Testimony, and Argument by Contender Def’s MIL 13 Exclude Damages which have Assigned Benefits