Preview
Filing # 146297267 E-Filed 03/23/2022 04:32:05 PM
IN THE CIRCUIT COURT OF THE
EIGHTEENTH JUDICIAL CIRCUIT IN
AND FOR BREVARD COUNTY, FL
CASE NO. 052020CA024628XXXXXX
ANTHONY DAVIS JR.,
Plaintiff,
Vv.
SECURITY FIRST INSURANCE COMPANY DBA SECURITY FIRST FLORIDA,
Defendant.
/
PLAINTIFF'S DISCLOSURE OF EXPERT AND LAY WITNESSES
COMES NOW the Plaintiff, ANTHONY DAVIS JR., by and through the undersigned
attorney, and pursuant to this Court's Order Setting Cut-Off Dates, Mediation, and Trial Date
dated June 22, 2021, Plaintiff hereby disclose the following expert witnesses:
1. Expert Witnesses
A. Edward “Joe” Jaremko (“Jaremko”)
Arko Plumbing Corp.
8306 Mills Drive, #569
Miami, FL 33183
(i) The subject matter about which the expert is expected to testify: Mr.
Jaremko is expected to testify that the cast iron pipe plumbing system
at Plaintiffs’ home has failed, has caused the damage complained of at
Plaintiffs’ home, caused damage to the structural backfill under the
home, and the entire system needs to be dug out and replaced. He will
also testify about the method of tearing out and replacing the cast iron
pipe system. He will also testify that other potential causes of loss at
the home are not plausible, and are not the cause of the loss at
Plaintiffs’ home. He will testify that alternative methods of repair of the
cast iron pipe system are not appropriate.
Mr. Jaremko’s opinion is supported and further explained by the
moisture meter readings, hydrostatic test, camera inspection and the
photos/videos of Arko Plumbing Corp and photos of Triad Restoration
Filing 146297267 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XXFiling 146297267
Services, as well as the reports of Triad Restoration Services.
(ii) The substance of the facts and opinions about which the expert is
expected to testify: See (i) above.
(iii) | Asummary of the grounds for each opinion: See (i) above.
(iv) | Acopy of any written reports issued by the expert regarding this case:
Plaintiffs will produce under separate cover.
(v) | A-copy of the expert’s curriculum vitae: Plaintiffs will produce under
separate cover.
(vi) | Proposed deposition dates: 4/5/2022 at 1:00 PM, 4/8/2022 at 11:00
AM, 4/20/2022 at 1:00 PM
Dennis James
Triad Restoration Services (“Triad”)
2801 Alt 19
Dunedin, FL 34698
(i) The subject matter about which the expert is expected to testify: Mr.
James is a General Contractor and will testify as to the repair costs and
what the estimate is intended to repair/replace, and how he arrived at
those figures. He is also expected to testify that the cast iron pipe
plumbing system at Plaintiffs’ home has failed, has caused the damage
complained of at Plaintiffs’ home, caused damage to the structural
backfill under the home and the entire system needs to be dug out and
replaced. He will also testify about the costs and the repairs
necessitated by tearing out and replacing the cast iron pipe system. He
will testify that other potential causes of loss at the home are not
plausible, and are not the cause of the loss at Plaintiffs’ home. He will
testify that alternative methods of repair of the home are not
appropriate.
Mr. James will testify that the cost to perform the work described above
is $102,516.36 (RCV) and $96,574.08 (ACV), what the estimates are
intended to repair/replace, and how he arrived at those figures. Mr.
James will also testify that the cost to perform the work described
above is $93,938.70 (RCV) and $88,799.12 (ACV), if matching costs
are excluded from the estimate. Mr. James’ opinion is supported and
further explained by the moisture meter readings, and the
photos/videos of Arko Plumbing Corp and photos of Triad Restoration
Services, as well as the reports of Arko Plumbing Corp.
(ii) The substance of the facts and opinions about which the expert is
ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XXFiling 146297267
expected to testify: See (i) above.
(iii) | A summary of the grounds for each opinion: See (i) above.
(iv) |Acopy of any written reports issued by the expert regarding this case:
Plaintiffs will produce under separate cover.
(v) A copy of the expert’s curriculum vitae: Plaintiffs will produce under
separate cover.
(vi) | Proposed deposition dates: 4/5/2022 at 1:00 PM, 4/8/2022 at 11:00
AM, 4/20/2022 at 1:00 PM
Qut of an abundance of caution, Plaintiff also discloses the following who
performed testing at Plaintiff's home and/or took photographs and/or videos at
Plaintiff's home. The following are not expected to give expert opinions, but
may be called to authenticate videos/photos and, if applicable, to describe the
testing performed:
A. Brent Caporusso
Triad Restoration Services
2801 Alt 19
Dunedin, FL 34698
Will authenticate photographs of Plaintiff's home taken on November 5, 2020.
B. Alejandro Naranjo
Arko Plumbing Corp.
8306 Is Drive, #569
Miami, FL 33183
Will authenticate video inspections, moisture readings, photos and hydrostatic
test at Plaintiff's home on September 11, 2020.
C. Mason Chickonski
C/O Gina Kimmel, Esquire
Morgan & Morgan
20 N. Orange Avenue Suite 1600
Orlando, FL 32801
Will authenticate video inspections and photographs of Plaintiffs home taken
on January 10, 2020 and January 13, 2020.
D. Marion Williams, Former APT Employee
3700 S Atlantic Avenue Apt 401
ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XXNew Smyrna, FL 32169
Took photographs at Plaintiff's home on January 10, 200.
. William Pratt, Former APT Employee
4175 S Atlantic Avenue Apt 315
New Smyrna, FL 32169
Took videos at Plaintiff's home on January 13, 2020.
All exhibits herein have been previously provided to Defendant through OneDrive, a
file sharing site on March 10, 2022.
3.
Filing 146297267
Lay Witnesses
F.
Anthony Davis
c/o Gina Kimmel
Morgan & Morgan
20 N. Orange Avenue Suite 1600
Orlando, FL 32801
. Corporate Representative Designee at trial
c/o Defendant
. Bob Walters, Field Claims Adjuster
c/o Defendant
Ken
First Response Disaster Team
2322 Hibiscus Drive
Edgewater, FL 32141
. Andrew Ratliff
HydroScout
PO Box 519
Freeport, FL 32439
Reinaldo Perez, Mitigation Manager
Royal Plus
1150 Belle Avenue Suite 1000
Winter Springs, FL 32702
ANTHONY DAVIS J VS SECURITY
05-2020-CA-024628-XXXX-XXL. Markham Services Mold Inspection
7380 Sylvan Drive
Sanford, FL 32771
4. Any witnesses listed or called by the Defendant for any purpose so listed.
5. Any witnesses necessary for impeachment and/or rebuttal.
6. Any Records Custodian(s) as necessary.
7. All witnesses identified in discovery, now or in the future, including Answers to
Interrogatories, Responses to Request to Produce and depositions.
8. Discovery is ongoing and Plaintiff reserves the right to amend this witness list.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by electronic mail to Ashley Ward-Singleton, Esquire; Jennifer L. Velazco,
Esquire; [iniv.ashley.wardsingleton@qpwblaw.com; jvelazco@qpwblaw.com;
cynthia.mejias@qpwblaw.com] Quintairos, Prieto, Wood & Boyer, P.A., 1410 North
Westshore Boulevard Suite 200, Tampa, FL 33607, this 23" day of March 2022.
/s/_ Gina Kimmel
GINA KIMMEL, ESQ., Esquire
Florida Bar No. 0121929
Morgan & Morgan, P.A.
20 N. Orange Avenue, 4" Floor
Post Office Box 4979
Orlando, Florida 32802-4979
Telephone: (407) 420-1414
Facsimile: (407) 245-3414
Primary email: GKimmel@forthepeople.com
Secondary email:SFloresrivera@forthepeople.com
LRolon@forthepeople.com
Attorneys for Plaintiff
GK/sfr
Filing 146297267 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX
Preview
Filing # 146297267 E-Filed 03/23/2022 04:32:05 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FL CASE NO. 052020CA024628XXXXXX ANTHONY DAVIS JR., Plaintiff, Vv. SECURITY FIRST INSURANCE COMPANY DBA SECURITY FIRST FLORIDA, Defendant. / PLAINTIFF'S DISCLOSURE OF EXPERT AND LAY WITNESSES COMES NOW the Plaintiff, ANTHONY DAVIS JR., by and through the undersigned attorney, and pursuant to this Court's Order Setting Cut-Off Dates, Mediation, and Trial Date dated June 22, 2021, Plaintiff hereby disclose the following expert witnesses: 1. Expert Witnesses A. Edward “Joe” Jaremko (“Jaremko”) Arko Plumbing Corp. 8306 Mills Drive, #569 Miami, FL 33183 (i) The subject matter about which the expert is expected to testify: Mr. Jaremko is expected to testify that the cast iron pipe plumbing system at Plaintiffs’ home has failed, has caused the damage complained of at Plaintiffs’ home, caused damage to the structural backfill under the home, and the entire system needs to be dug out and replaced. He will also testify about the method of tearing out and replacing the cast iron pipe system. He will also testify that other potential causes of loss at the home are not plausible, and are not the cause of the loss at Plaintiffs’ home. He will testify that alternative methods of repair of the cast iron pipe system are not appropriate. Mr. Jaremko’s opinion is supported and further explained by the moisture meter readings, hydrostatic test, camera inspection and the photos/videos of Arko Plumbing Corp and photos of Triad Restoration Filing 146297267 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XXFiling 146297267 Services, as well as the reports of Triad Restoration Services. (ii) The substance of the facts and opinions about which the expert is expected to testify: See (i) above. (iii) | Asummary of the grounds for each opinion: See (i) above. (iv) | Acopy of any written reports issued by the expert regarding this case: Plaintiffs will produce under separate cover. (v) | A-copy of the expert’s curriculum vitae: Plaintiffs will produce under separate cover. (vi) | Proposed deposition dates: 4/5/2022 at 1:00 PM, 4/8/2022 at 11:00 AM, 4/20/2022 at 1:00 PM Dennis James Triad Restoration Services (“Triad”) 2801 Alt 19 Dunedin, FL 34698 (i) The subject matter about which the expert is expected to testify: Mr. James is a General Contractor and will testify as to the repair costs and what the estimate is intended to repair/replace, and how he arrived at those figures. He is also expected to testify that the cast iron pipe plumbing system at Plaintiffs’ home has failed, has caused the damage complained of at Plaintiffs’ home, caused damage to the structural backfill under the home and the entire system needs to be dug out and replaced. He will also testify about the costs and the repairs necessitated by tearing out and replacing the cast iron pipe system. He will testify that other potential causes of loss at the home are not plausible, and are not the cause of the loss at Plaintiffs’ home. He will testify that alternative methods of repair of the home are not appropriate. Mr. James will testify that the cost to perform the work described above is $102,516.36 (RCV) and $96,574.08 (ACV), what the estimates are intended to repair/replace, and how he arrived at those figures. Mr. James will also testify that the cost to perform the work described above is $93,938.70 (RCV) and $88,799.12 (ACV), if matching costs are excluded from the estimate. Mr. James’ opinion is supported and further explained by the moisture meter readings, and the photos/videos of Arko Plumbing Corp and photos of Triad Restoration Services, as well as the reports of Arko Plumbing Corp. (ii) The substance of the facts and opinions about which the expert is ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XXFiling 146297267 expected to testify: See (i) above. (iii) | A summary of the grounds for each opinion: See (i) above. (iv) |Acopy of any written reports issued by the expert regarding this case: Plaintiffs will produce under separate cover. (v) A copy of the expert’s curriculum vitae: Plaintiffs will produce under separate cover. (vi) | Proposed deposition dates: 4/5/2022 at 1:00 PM, 4/8/2022 at 11:00 AM, 4/20/2022 at 1:00 PM Qut of an abundance of caution, Plaintiff also discloses the following who performed testing at Plaintiff's home and/or took photographs and/or videos at Plaintiff's home. The following are not expected to give expert opinions, but may be called to authenticate videos/photos and, if applicable, to describe the testing performed: A. Brent Caporusso Triad Restoration Services 2801 Alt 19 Dunedin, FL 34698 Will authenticate photographs of Plaintiff's home taken on November 5, 2020. B. Alejandro Naranjo Arko Plumbing Corp. 8306 Is Drive, #569 Miami, FL 33183 Will authenticate video inspections, moisture readings, photos and hydrostatic test at Plaintiff's home on September 11, 2020. C. Mason Chickonski C/O Gina Kimmel, Esquire Morgan & Morgan 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 Will authenticate video inspections and photographs of Plaintiffs home taken on January 10, 2020 and January 13, 2020. D. Marion Williams, Former APT Employee 3700 S Atlantic Avenue Apt 401 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XXNew Smyrna, FL 32169 Took photographs at Plaintiff's home on January 10, 200. . William Pratt, Former APT Employee 4175 S Atlantic Avenue Apt 315 New Smyrna, FL 32169 Took videos at Plaintiff's home on January 13, 2020. All exhibits herein have been previously provided to Defendant through OneDrive, a file sharing site on March 10, 2022. 3. Filing 146297267 Lay Witnesses F. Anthony Davis c/o Gina Kimmel Morgan & Morgan 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 . Corporate Representative Designee at trial c/o Defendant . Bob Walters, Field Claims Adjuster c/o Defendant Ken First Response Disaster Team 2322 Hibiscus Drive Edgewater, FL 32141 . Andrew Ratliff HydroScout PO Box 519 Freeport, FL 32439 Reinaldo Perez, Mitigation Manager Royal Plus 1150 Belle Avenue Suite 1000 Winter Springs, FL 32702 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XXL. Markham Services Mold Inspection 7380 Sylvan Drive Sanford, FL 32771 4. Any witnesses listed or called by the Defendant for any purpose so listed. 5. Any witnesses necessary for impeachment and/or rebuttal. 6. Any Records Custodian(s) as necessary. 7. All witnesses identified in discovery, now or in the future, including Answers to Interrogatories, Responses to Request to Produce and depositions. 8. Discovery is ongoing and Plaintiff reserves the right to amend this witness list. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic mail to Ashley Ward-Singleton, Esquire; Jennifer L. Velazco, Esquire; [iniv.ashley.wardsingleton@qpwblaw.com; jvelazco@qpwblaw.com; cynthia.mejias@qpwblaw.com] Quintairos, Prieto, Wood & Boyer, P.A., 1410 North Westshore Boulevard Suite 200, Tampa, FL 33607, this 23" day of March 2022. /s/_ Gina Kimmel GINA KIMMEL, ESQ., Esquire Florida Bar No. 0121929 Morgan & Morgan, P.A. 20 N. Orange Avenue, 4" Floor Post Office Box 4979 Orlando, Florida 32802-4979 Telephone: (407) 420-1414 Facsimile: (407) 245-3414 Primary email: GKimmel@forthepeople.com Secondary email:SFloresrivera@forthepeople.com LRolon@forthepeople.com Attorneys for Plaintiff GK/sfr Filing 146297267 ANTHONY DAVIS J VS SECURITY 05-2020-CA-024628-XXXX-XX