Filing # 182059900 E-Filed 09/18/2023 04:02:07 PM
`
`KIM JEROME,
`
`Plaintiff,
`
`IN THE CIRCUIT COURT FOR THE
`15TH JUDICIAL CIRCUIT, IN AND FOR
`PALM BEACH COUNTY, FLORIDA
`
`CASE NO.: 2022-CA-007793
`
`vs.
`
`MICHELLE RODRIGUEZ, OSCAR RODRIGUEZ,
`FLORAL LAKES COMMUNITY ASSOCIATION,
`INC., A Florida Not for Profit Corporation, and
`CAMPBELL PROPERTY MANAGEMENT AND
`REAL ESTATE, INC., a Florida Profit Corporation,
`
`Defendants.
`___________________________________/
`
`PLAINTIFF¶S EX-PARTE MOTION TO COMPEL ANSWERS TO PLAINTIFF¶S
`EXPERT DISCOVERY
`Plaintiff, KIM JEROME, by and through the undersigned counsel, pursuant to Florida
`
`Rule of Civil Procedure 1.380, hereby files her Ex-Parte Motion to Compel Defendants, FLORAL
`
`LAKES COMMUNITY ASSOCIATION and Defendant, CAMPBELL PROPERTY
`
`MANAGEMENT AND REAL ESTATE, INC. propounded March 9, 2023, and in support thereof,
`
`states as follows:
`
`NOT A CERTIFIED COPY
`
`1.
`
`This case arises out of a dog attack that occurred on Defendant, FLORAL LAKES
`
`COMMUNITY ASSOCIATION and Defendant, CAMPBELL PROPERTY MANAGEMENT
`
`AND REAL ESTATE, INC (³Defendants´), premises on July 25, 2021, where Plaintiff suffered
`
`serious injury.
`
`2.
`
`On March 9, 2023, Plaintiff served Defendant with Expert Interrogatories and
`
`Expert Request for Production due on or about April 9, 2023. See Ex. ³A´.
`
`3.
`
`As of the date and time of this Motion, Defendants, have failed to respond to
`
`Plaintiff¶s discovery request.
`
`*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 09/18/2023 04:02:07 PM ***
`
`

`

`4.
`
`5.
`
`More than thirty (30) days have elapsed and no objections were filed thereto and
`no request for extension has been made.
`Local Rule 10(A), entered on June 29, 2021, states in relevant part:
`When a motion to compel alleges a complete failure to respond or object to
`discovery, and there has been no request for extension, an ex parte order may be
`entered requiring compliance with the original discovery demand within ten (10)
`days of the signing of the order. Movant shall submit the proposed order.
`
`WHEREFORE, Plaintiff, KIM JEROME respectfully request this Honorable Court to
`enter an order Granting her Ex-Parte Motion to Compel Responses to Plaintiffs Expert
`Discovery and compelling Defendant’s responses within ten (10) days of the Order
`in
`compliance with Local Rule 10A and for any and all relief this Court deems just and proper.
`CERTIFICATE OF SERVICE
`I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
`to: SIOLI ALEXANDER PINO, Esquire of SIOLI
`via the Florida Courts E-Filing Portal
`ALEXANDER PINO, Attorneys for Floral Lakes Community Association Inc. & Campbell
`and
`Real
`JPino@SioliLaw.com;
`at
`Estate,
`Inc.,
`Property Management
`SAPMail@SioliLaw.com;
`SRodriguez@SioliLaw.com;
`LHernandez@siolilaw.com; and Defendants, Oscar Rodriguez Torres and Michelle Rodriguez,
`at oscar@ayicargo.com; smichellerod@outlook.com on this 18th day of September 2023.
`KANNER & PINTALUGA, P.A.
`Attorneys for Plaintiff
`925 S Federal Highway, Sixth Floor
`Boca Raton, Florida 33432
`Phone (561) 892-9810/Fax (844) 818-5452
`Pleadings9@KPAttorney.com (service email)
`Alettman@KPAttorney.com
`
`NOT A CERTIFIED COPY
`
`/s/AlyssaLettman_
`
`ALYSSA LETTMAN, ESQ.
`FBN:
`1030947
`
`By:
`
`

`

`
`
`
`
`
`
`
`
`EXHIBIT “A”
`
`
`NOT A CERTIFIED COPY
`
`
`
`

`

`Filing # 168376729 E-Filed 03/09/2023 11:33:10 AM
`
`IN THE CIRCUIT COURT FOR THE
`15TH JUDICIAL CIRCUIT, IN AND FOR
`PALM BEACH COUNTY, FLORIDA
`
`
`
` CASE NO.: 2022-CA-007793
`
`
`
`
`
`
`
`
`
`
`
`
`
`KIM JEROME,
`
`
`
`
`Plaintiff,
`vs.
`
`MICHELLE RODRIGUEZ, OSCAR
`RODRIGUEZ, FLORAL LAKES
`COMMUNITY
`ASSOCIATION,
`INC., A Florida Not for Profit
`Corporation,
`and CAMPBELL
`PROPERTY MANAGEMENT AND
`REAL ESTATE, INC., a Florida
`Profit Corporation,
`
`Defendants.
`
`____________________________/
`
`
`REAL ESTATE, INC.
`
`
`
`
`
`
`
`
`
`
`
`
`(Certificate of Service on the Following Page)
`
`1
`
`NOT A CERTIFIED COPY
`
`PLAINTIFF’S NOTICE OF SERVING EXPERT INTERROGATORIES TO
`DEFENDANTS, FLORAL LAKES COMMUNITY ASSOCAITION, INC., and
`CAMPBELL PROPERTY MANAGEMENT and REAL ESTATE, INC.
`
`COMES NOW, Plaintiff, KIM JEROME, by and through undersigned counsel, and
`
`pursuant to the Florida Rules of Civil Procedure, and applicable case law, including Allstate
`
`Insurance Co. v. Boecher, 733 So. 2d 993 (Fla. 1999) and Springer v West, 769 So. 2d 1068 (Fla.
`
`5th DCA 2000), files this Notice of Serving Expert Interrogatories to FLORAL LAKES
`
`COMMUNITY ASSOCAITION, INC., and CAMPBELL PROPERTY MANAGEMENT and
`
`

`

`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
`to: SIOLI ALEXANDER PINO, Esquire of SIOLI
`the Florida Courts E-Filing Portal
`ALEXANDER PINO, Attorneys for Floral Lakes Community Association Inc. & Campbell
`and
`Real
`at
`Estate,
`Inc.,
`Property Management
`JPino@SioliLaw.com;
`SAPMail@SioliLaw.com;
`SRodriguez@SioliLaw.com;
`LHernandez@siolilaw.com; SSuarez@siolilaw.com; and Tameka C. Franko, Esquire and Olga
`Butkevich, Esquire of Cole, Scott, and Kissane, PA, Attorneys for Oscar Rodriguez Torres and
`Michelle Rodriguez,
`and
`at Olga.Butkevich@csklegal.com;
`tameka.franco@csklegal.com;
`loren.ryan@csklegal.com, on this 9th day of March, 2023.
`
`KANNER & PINTALUGA, P.A.
`Attorneys for Plaintiff
`925 S Federal Highway, Sixth Floor
`Boca Raton, Florida 33432
`Phone (561) 892-9810/Fax (844) 818-5452
`Pleadings9@KPAttorney.com (service email)
`Alettman@KPAttorney.com
`
`NOT A CERTIFIED COPY
`
`By:
`
`/s/AlyssaLettman_
`
`ALYSSA LETTMAN, ESQ.
`FBN:
`1030947
`
`2
`
`

`

`
`
`PLAINTIFF’S EXPERT INTERROGATORIES TO DEFENDANTS, FLORAL LAKES
`COMMUNITY ASSOCAITION, INC., and CAMPBELL PROPERTY MANAGEMENT
`and REAL ESTATE, INC.
`
`Please identify each Expert that Defendants has retained who will give opinions at
`1.
`trial. With regard to each Expert, give full name and business address; the field of expertise; and
`the subject matter on which the expert is expected to testify.
`
`
`
`
`
`
`
`
`
`
`
`
`
`For each retained Expert listed in #1, above, please state the substance of the facts
`2.
`and each and every opinion which the expert is expected to testify, including a summary of the
`grounds for each opinion. Simply giving generic boilerplate response that the expert is expected
`to testify in their respective specialty, or conclusion(s) without the grounds specific to this case, is
`not sufficient. If the expert rendered a report containing all of the above, production of the report
`is a sufficient response to this interrogatory.
`
`
`
`
`
`
`
`
`
`
`
`For your retained Experts, please give the amount of compensation each has been
`3.
`paid for this case to date, as well as a fee schedule for future charges including appearance for trial,
`video deposition for use at trial, and discovery deposition.
`
`
`
`
`
`
`NOT A CERTIFIED COPY
`
`
`
`3
`
`

`

`
`
`For each retained Expert, please identify each court case in which they have
`4.
`actually testified, whether by deposition or at trial, during the last 3 years and state whether they
`were testifying in the capacity for plaintiff or defendants. (Elkins v. Sykens, 672 So. 2d 517 (Fla.
`1996); Orthopedic Care Center v. Parks, 155 So. 3d 377 (Fla. 3d DCA 2014). A current proper
`Elkins List (consistent with Elkins and Parks) will suffice as a response to this Interrogatory and
`should include which party retained the Expert.
`
`
`
`
`
`
`
`
`
`
`
`
`Please identify the number of cases in the last 3 years in which the Defendants’
`5.
`representatives (the insurance companies, or any of its subsidiaries), has retained and/or employed
`each of the Experts listed in #1 to perform compulsory medical evaluations (CME/IME), medical
`records review, medical billing review, biomechanical analysis, engineering opinions, human
`factors opinions, or accident reconstruction.
`
`
`
`
`
`
`
`
`
`
`
`Please state the total amount of money paid to each of the retained Experts/Medical
`6.
`Practices by the Defendants’ representatives (the insurance companies or any of its subsidiaries)
`in the 3 years before these Interrogatories. Please note that this interrogatory also encompasses the
`total amount paid to the Expert’s company or medical practice.
`
`
`
`
`
`
`
`NOT A CERTIFIED COPY
`
`
`
`4
`
`

`

`Please state the total amount of money paid to each of the retained Experts/Medical
`7.
`Practices by the Defendants’ attorney and/or law firm, Joanna N. Pino, Esq. and SIOLI
`ALEXANDER PINO in the 3 years before these Interrogatories. Please note that this interrogatory
`also encompasses the total amount paid to the Expert’s company or medical practice.
`
`
`
`
`
`
`
`
`
`
`
`
`Please provide a good-faith approximation of the number of times, over the last 3
`8.
`years the experts listed in Interrogatory 1, above, have performed CME/IMEs, medical records
`reviews, Radiology Reviews, medical billing reviews, biomechanical analysis, engineering
`opinions, human factors opinions, or accident reconstruction. See Elkins v. Syken.
`
`
`
`
`
`
`
`
`
`
`
`
`Please identify the number of cases in the last 3 years in which the Defendants’
`9.
`attorney and/or law office retained each of the Experts listed in #1 to perform compulsory medical
`evaluations (CME/IME), medical records review, medical billing review, biomechanical analysis,
`engineering opinions, human factors opinions, or accident reconstruction.
`
`
`
`
`
`
`
`
`
`
`NOT A CERTIFIED COPY
`
`
`
`5
`
`

`

`Please describe the expert(s)’s listed in #1 general litigation experience, including
`10.
`the percentage of work performed for Plaintiffs and Defendants.
`
`
`
`
`
`
`
`
`
`Please approximate the portion of the expert(s)’s listed in #1 involvement as an
`11.
`expert witness. This approximation may be based on the number of hours, percentage of hours, or
`percentage of earning income derived from retentions as an expert witness.
`
`
`
`
`
`
`
`
`
`
`Please list all litigation cases that each retained expert has performed an analysis
`12.
`and/or rendered opinions for any attorney, on behalf of a Defendants, over the past three (3) years.
`
`
`
`
`
`
`
`
`
`
`Please list all litigation cases that each retained expert has performed an analysis
`13.
`and/or rendered opinions for any insurance company, over the past three (3) years.
`
`
`NOT A CERTIFIED COPY
`
`
`
`
`
`
`
`
`
`
`
`6
`
`

`

`
`
`
`
`STATE OF FLORIDA
`
`)
`)
`COUNTY OF ___________ )
`
`
`
`THE FOREGOING INSTRUMENT was acknowledged before me this ____ day of
`_________________, 2023, by _________________________________, who is personally
`known to me or who has produced _________________________________ as identification and
`who did/did not take an oath.
`
`
`_____________________________________
`Floral Lakes Community Association, Inc.
`
`
`
`
`
`
`SS:
`
`_____________________________________
`NOTARY PUBLIC
`State of Florida at Large
`
`
`_____________________________________
`Name of Notary Public - typed, printed or
`stamped
`
`(Seal)
`
`NOT A CERTIFIED COPY
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`7
`
`

`

`_____________________________________
`Campbell Property Management and Real
`Estate, Inc.
`
`
`
`
`
`
`SS:
`
`STATE OF FLORIDA
`
`)
`)
`COUNTY OF ___________ )
`
`
`
`THE FOREGOING INSTRUMENT was acknowledged before me this ____ day of
`_________________, 2023, by _________________________________, who is personally
`known to me or who has produced _________________________________ as identification and
`who did/did not take an oath.
`
`
`NOT A CERTIFIED COPY
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`_____________________________________
`NOTARY PUBLIC
`State of Florida at Large
`
`
`_____________________________________
`Name of Notary Public - typed, printed or
`stamped
`
`(Seal)
`
`8
`
`

`

`Filing # 168376729 E-Filed 03/09/2023 11:33:10 AM
`
`IN THE CIRCUIT COURT FOR THE
`15TH JUDICIAL CIRCUIT, IN AND FOR
`PALM BEACH COUNTY, FLORIDA
`
`
`
` CASE NO.: 2022-CA-007793
`
`
`
`
`
`
`
`
`
`
`
`
`
`KIM JEROME,
`
`
`
`
`Plaintiff,
`vs.
`
`MICHELLE RODRIGUEZ, OSCAR
`RODRIGUEZ, FLORAL LAKES
`COMMUNITY
`ASSOCIATION,
`INC., A Florida Not for Profit
`Corporation,
`and CAMPBELL
`PROPERTY MANAGEMENT AND
`REAL ESTATE, INC., a Florida
`Profit Corporation,
`
`Defendants.
`
`____________________________/
`
`
`PLAINTIFF’S EXPERT REQUEST FOR PRODUCTION TO DEFENDANTS, FLORAL
`LAKES COMMUNITY ASSOCAITION, INC., and CAMPBELL PROPERTY
`MANAGEMENT and REAL ESTATE, INC.
`
`COMES NOW, Plaintiff, KIM JEROME, by and through undersigned counsel, and
`
`pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby requests that Defendants,
`
`FLORAL LAKES COMMUNITY ASSOCAITION, INC., and CAMPBELL PROPERTY
`
`MANAGEMENT and REAL ESTATE, INC., produce and permit said Plaintiff to inspect and to
`
`copy each of the following documents:
`
`NOT A CERTIFIED COPY
`
`DEFINITIONS AND INSTRUCTIONS
`
`
`
`As used herein, the terms “you” or “your,” shall mean the party to whom these
`1.
`requests are directed and includes anyone acting for or on behalf of the party to whom these requests
`are directed, including but not limited to the party’s principals, officers, directors, employees,
`partners, corporate parent, subsidiaries, affiliates, representatives or agents.
`
`The term "person" means, in the plural as well as the singular, any natural person,
`2.
`individual, proprietorship, partnership, corporation, business, firm, association, unincorporated
`association, organization, joint venture, other business enterprise, legal, governmental body, group of
`natural persons, or other entity. The masculine, feminine and neuter shall include each of the genders.
`
`
`
`1
`
`

`

`
`The term “document” means (a) the original and/or any non-identical original or copy
`3.
`including those with any marginal note or comment or showing additions, deletions, or substitutions;
`(b) drafts; (c) attachment to or enclosure with any document; and (d) every document referred to in
`any other documents, and requires production of all electronically stored information stored in any
`medium from which information can be obtained either directly or, if necessary, after translation by
`the responding party into a reasonable usable form, and includes metadata.
`
`The term "document" includes any information electronically stored, printed, written,
`4.
`typed, recorded, transcribed, taped, photographic, graphic or aural records or representations of any
`kind (including without limitation, photographs, microfiche, microfilm, videotape, flash drives, CD,
`DVD, records and motion pictures) and electronic, mechanical or electronic records or representations
`of any kind (including without limitation, CDs, DVDs, tapes, cassettes, discs and records), however
`produced or reproduced, including but not limited to: any e-mail, text message, SMS message, MMS
`message, metadata, letter, correspondence, facsimile or communication of any sort; film, print or
`negative of photograph; sound recording, video recording; note, notebook, books, diary, calendar,
`minutes, memorandum, inter-office and intra-office, contract, agreement or any amendment thereto;
`telex, teletype, telegram, cable, bulletin; studies, summaries, report or record of telephone
`conversation, personal conversation, discussion, interview, meeting, conference, investigation,
`negotiation, act or activity; projection, worksheet, work paper or draft; computer output or input, data
`processing card; opinion or report of consultant; request, order, invoice or bill of lading; analysis,
`diagram, map, index, sketch, drawing, plan, chart, manual, brochure, pamphlet, advertising circular,
`newspaper or magazine clipping, press release, transcripts; receipt, journal, ledger, schedule, bill or
`voucher; financial statements, prospectuses, schedules, affidavits, statement of account, bank
`statement, checkbook, stubs or register, cancelled check, deposit slip, charge slip, tax return (income
`or other), requisition; file, study, graph, tabulation, and any and all other writings and recordings of
`whatever nature, whether signed or unsigned or transcribed and any other data compilation from
`which information can be obtained, translated, if necessary, by the respondent through detection
`devices into reasonably usable form.
`
`The term "all documents" means every document or group of documents as above
`5.
`defined that are known to you or that can be located or discovered by reasonably diligent efforts.
`
`The term “communication” shall mean every manner of means of transmittal of
`6.
`information whether in person, by telephone, mobile device, facsimile, mail, electronic mail, text
`message, SMS message, MMS message, personal delivery or otherwise (in the form of facts,
`opinions, ideas, inquiries or otherwise) and includes, without limitation, the following: conversations,
`telephone conversations, statements, discussions, debates, arguments, disclosures, interviews,
`consultation and every other manner or oral utterance.
`
`The terms “Plaintiffs,” “Plaintiff,” “Defendants,” and “Defendant,” as well as party’s
`7.
`full or abbreviated name or a pronoun referring to a party means the party, its principals, officers,
`directors, employees, partners, corporate parent, subsidiaries, affiliates, representatives, or agents.
`
`"Relating to" means containing, constituting, showing, mentioning, reflecting, or
`8.
`pertaining or referring to in any way, directly or indirectly, and, with regard to documents, is meant
`
`NOT A CERTIFIED COPY
`
`
`
`2
`
`

`

`to include, among other documents, those underlying, supporting, or previously attached or appended
`to, or used in the preparation of any document requested
`
`“Information” means anything known to you, either personally or from other sources,
`9.
`including such found within documents or oral communication, relating to the subject matter being
`requested.
`
`As used herein, “concerns, refers or relates to” shall mean about, related to, referring
`10.
`to, describing, offering evidence of, or constituting.
`
`The words "and" and "or" shall be construed either conjunctively or disjunctively to
`11.
`bring within the scope of these requests any documents which might otherwise be construed to be
`outside their scope.
`
`12. When producing the documents, please keep all documents segregated by the file in
`which the documents are contained and indicate the name of the file in which the documents are
`contained and the name of the documents being produced.
`
`13. When producing the required documents, please produce all other documents that are
`clipped, stapled or otherwise attached to any requested document.
`
`In the event such file(s) or document(s) has (have) been removed, either for the
`14.
`purpose of this action or for some other purpose, please state the name and address of the person who
`removed the file, the title of the file and each subfile, if any, maintained within the file, and the present
`location of the file.
`
`If you choose to withhold from production for inspection and copying on the ground
`15.
`of privilege or the like, it is requested that you provide the following information: date, type of
`document, author, addressee or recipient, present location, present custodian and all past custodians,
`number of pages, general description, privilege claimed, and any other pertinent information
`concerning the claim of privilege or work product doctrine as will permit the adjudication of the
`propriety of the claim.
`
`If any document to be produced has been destroyed or is otherwise incapable of
`16.
`production, state: (a) the date, place and means of destruction; (b) the name and address of each person
`deciding upon, participating in and having knowledge of the destruction; (c) the reason for the
`destruction; and (d) if not destroyed, the reason why the document is incapable of production.
`
`Your attention is called to the duty to supplement your responses to these requests
`17.
`with respect to information hereinafter acquired.
`
`
`
`NOT A CERTIFIED COPY
`
`
`
`
`
`3
`
`

`

`
`
`DOCUMENTS REQUESTED
`
`1.
`
`All written reports (in any format without limitation) from every expert expected
`
`to testify for Defendants at trial.
`
`2.
`
`All correspondence (in any format without limitation) between Defendants,
`
`Defendants’ counsel, and Defendants’ insurer and every expert (and the entity the expert works
`
`for) expected to testify for Defendants at trial.
`
`3.
`
`All materials (reports, photographs, tangible items, etc. of any type without
`
`limitation) provided to every expert expected to testify for Defendants at trial.
`
`4.
`
`All materials (reports, photographs, tangible items, etc. of any type without
`
`limitation) used by every expert expected to testify for Defendants at trial.
`
`5.
`
`All report(s) created by every expert expected to testify for Defendants at trial.
`
`6.
`
`7.
`
`The CV for each expert expected to testify for Defendants at trial.
`
`All invoices, records, memoranda, checks, check stubs, receipts, and 1099s evincing
`
`compensation for the last three years by defense counsel to every expert (and the entity the expert
`
`works for) expected to testify for Defendants at trial pursuant to Morgan, Colling & Gilbert, P.A.
`
`NOT A CERTIFIED COPY
`
`v. Pope, 798 So. 2d 1 (Fla. 2d DCA 2001).
`
`8.
`
`All invoices, records, memoranda, checks, check stubs, receipts, and 1099s evincing
`
`compensation for the last three years by Defendants or Defendants’ liability carrier to every expert
`
`(and the entity the expert works for) expected to testify for Defendant at trial pursuant to Allstate
`
`Ins. Co. v. Hodges, 855 So. 2d 636 (Fla. 2d DCA 2003) and Allstate Ins. Co. v. Boecher, 733 So.
`
`2d 993 (Fla. 1999).
`
`
`
`4
`
`

`

`9.
`
`10.
`
`Testimony lists for the last three years for every expert expected to testify for
`Defendants at trial pursuant to Florida Rule of Civil Procedure
`Allstate Ins. Co.
`v. Boecher, 733 So. 2d 993 (Fla. 1999), and£7^s v. Syken, 672 So. 2d 517 (Fla. 1996).
`All bills sent by every expert expected to testify for Defendants at trial pursuant to
`Florida Rule of Civil Procedure
`
`11.
`
`Evidence of all payments made to every expert in this case expected to testify for
`Defendants at trial pursuant to Florida Rule of Civil Procedure
`All orders, memoranda decisions, magistrate opinions, and transcripts in which any
`expert expected to testify for Defendants at trial was ever partially or completely disqualified.
`
`12.
`
`NOT A CERTIFIED COPY
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
`to: SIOLI ALEXANDER PINO, Esquire of SIOLI
`the Florida Courts E-Filing Portal
`ALEXANDER PINO, Attorneys for Floral Lakes Community Association Inc. & Campbell
`and
`Real
`at
`Estate,
`Inc.,
`Property Management
`JPino@SioliLaw.com;
`SAPMail@SioliLaw.com;
`SRodriguez@SioliLaw.com;
`LHernandez@siolilaw.com; SSuarez@siolilaw.com; and Tameka C. Franko, Esquire and Olga
`Butkevich, Esquire of Cole, Scott, and Kissane, PA, Attorneys for Oscar Rodriguez Torres and
`Michelle Rodriguez,
`and
`at Olga.Butkevich@csklegal.com;
`tameka.franco@csklegal.com;
`loren.ryan@csklegal.com, on this 9th day of March, 2023.
`
`13.
`
`All orders, memoranda decisions, magistrate opinions, and transcripts in which the
`opinion(s) of any expert expected to testify for Defendants at trial was/were limited in any way.
`CERTIFICATE OF SERVICE
`
`KANNER & PINTALUGA, P.A.
`Attorneys for Plaintiff
`925 S Federal Highway, Sixth Floor
`Boca Raton, Florida 33432
`Phone (561) 892-9810/Fax (844) 818-5452
`Pleadings9@KPAttorney.com (service email)
`Alettman@KPAttorney.com
`
`By:
`
`/s/Alyssa Lettman_
`ALYSSA LETTMAN, ESQ.
`FBN:
`1030947
`
`5
`
`