DEPOSITION OUTLINE

DEPOSITION OUTLINE
VICTOR HADDON
Senior Vice President of Claims, Ironclad Indemnity Corporation
ATTORNEY WORK PRODUCT — PRIVILEGED AND CONFIDENTIAL
This document constitutes attorney work product prepared in anticipation of litigation and is protected by the work-product doctrine and the attorney-client privilege. This document is not to be disclosed to any person or entity outside of Calderwood & Harkness LLP and authorized representatives of Verimark Hospitality Group Inc. without prior written authorization from the responsible partner.
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I. DEPOSITION OBJECTIVES
The deposition of Victor Haddon, Senior Vice President of Claims at Ironclad Indemnity Corporation ("Ironclad"), is a critical component of our discovery plan in Verimark Hospitality Group Inc. v. Ironclad Indemnity Corp. et al. The primary objectives of this deposition are as follows:
1.  Establish Haddon's Personal Involvement. We must comprehensively establish the scope and depth of Haddon's personal involvement in the claims-handling process for Verimark Hospitality Group's ("VHG") Hurricane Callista claim, beginning with initial notice of loss on September 22, 2022 and continuing through the issuance of the formal denial letter on February 3, 2023. Haddon's direct role in every material decision—assignment, investigation, reservation of rights, and ultimate denial—must be documented under oath.
2.  Windstorm Sub-Limit Admissions. We must obtain admissions from Haddon regarding the absence of a finalized endorsement reflecting the $15 million named-windstorm sub-limit in the 2022 renewal policy (Policy No. IIC-PRP-2022-07541). This is the single most important coverage issue in the case, and Haddon's admissions—or evasions—regarding whether the sub-limit was properly included in the renewal policy will be dispositive of the partial summary judgment motion we intend to file on November 1, 2023.
3.  Internal Contradictions in the Claims Evaluation. We must explore Ironclad's internal claims evaluation, including any internal memoranda, reserve analyses, coverage opinions, or correspondence that contradict or undermine the bases stated in the formal denial. If Ironclad's own personnel, adjusters, or internal counsel questioned the viability of any of the four denial grounds, those contradictions must be elicited during this deposition.
4.  Probe Each Denial Ground in Detail. The February 3, 2023 denial letter rests on four separate grounds: (1) the named-windstorm sub-limit; (2) the period of restoration; (3) the concurrent causation / flood exclusion; and (4) failure to mitigate. Haddon must be questioned in granular detail regarding the factual and legal basis for each ground, the evidence upon which Ironclad relied, and whether reasonable claims-handling practices supported each asserted ground.
5.  Arbor Claims Relationship and Directives. We must examine Haddon's communications with and directives to Arbor Claims Services LLC, particularly Denise Whitford, the independent adjuster retained by Ironclad to investigate the claim. Any evidence that Haddon steered, influenced, or overrode Arbor Claims' independent findings will be central to our bad-faith theory.
6.  Excess Carrier Coordination. We must identify all communications between Ironclad and the three excess carriers—Pinnacle Surplus Lines Inc. (excess layer, $25M–$40M), Montclair Assurance Company ($40M–$50M), and Sovereign Re Ltd. ($50M–$60M)—regarding the VHG claim. Coordination of denial strategy among the carriers would strengthen our claim that the denial was the product of a concerted strategy rather than an independent good-faith claims evaluation.
7.  Investigation of the Sub-Limit Deletion. We must determine whether Ironclad conducted any independent investigation of the windstorm sub-limit deletion during the claims process—specifically, whether Haddon or anyone in claims consulted with Ironclad's underwriting department—or whether Ironclad simply relied on the policy form as issued, without verifying that the form accurately reflected the agreed-upon terms.
8.  Foundation for Bad-Faith Claims. We must lay the evidentiary foundation for VHG's bad-faith claims under Florida Statutes § 624.155 by establishing that Ironclad lacked a reasonable basis for the denial, failed to properly investigate the claim, and disregarded evidence favorable to coverage. Haddon is the key fact witness for this purpose, as the senior claims officer with ultimate authority over the denial decision.
9.  Loss Quantum Acknowledgments. We must pin down Haddon's understanding of VHG's loss quantum and determine whether Ironclad internally acknowledged that the losses exceeded the total tower of $60 million. If Ironclad's internal analyses recognized that the claimed losses were legitimate and substantial, the decision to deny coverage in its entirety becomes significantly more difficult to defend as reasonable.
II. BACKGROUND AND QUALIFICATIONS OF WITNESS
A. Professional Background
The initial portion of the deposition should establish Haddon's qualifications and professional history to demonstrate that he is a highly experienced insurance claims professional who cannot claim ignorance of industry standards or Florida-specific claims-handling obligations.
Examination points:
•  State your full legal name for the record.
•  What is your current title and position at Ironclad Indemnity Corporation?
•  Confirm that his current title is Senior Vice President of Claims.
•  What is your business address? Confirm: 55 Constitution Boulevard, Hartford, CT 06103.
•  How long have you been employed by Ironclad Indemnity Corporation? Identify the date of initial hire and all positions held within the company during his tenure.
•  Prior to your current role as Senior Vice President of Claims, what positions did you hold at Ironclad? Obtain dates for each position and the nature of the responsibilities associated with each role.
•  Before joining Ironclad, did you work at any other insurance companies, managing general agencies, reinsurance companies, or claims-handling organizations? Obtain a complete employment history in the insurance industry, with dates and positions.
•  Describe your educational background, including undergraduate and graduate degrees, fields of study, and institutions attended.
•  Do you hold any professional designations? Specifically inquire regarding the following designations: Chartered Property Casualty Underwriter (CPCU), Associate in Claims (AIC), Certified Insurance Counselor (CIC), or any other professional credentials.
•  How many total years of experience do you have in the property and casualty insurance industry?
•  How many total years of experience do you have specifically in claims handling and claims management?
B. Scope of Responsibilities
This subsection establishes Haddon's authority and day-to-day responsibilities, which are essential to demonstrating that his actions and decisions on the VHG claim were within the ordinary scope of his duties and fully authorized by Ironclad.
Examination points:
•  Describe your current duties and responsibilities as Senior Vice President of Claims at Ironclad Indemnity Corporation.
•  How many claims professionals report to you, either directly or indirectly? Obtain the organizational structure of the claims department, including the number of direct reports and the total headcount of the claims operation.
•  What types of claims do you personally oversee? Do you personally oversee large and complex property claims? Catastrophe claims? Claims exceeding a certain dollar threshold?
•  What is your authority level with respect to claims decisions? Is there a dollar threshold at which you personally review and approve claim decisions, as distinguished from decisions that can be made by subordinate claims examiners?
•  Do you have the authority to approve or deny claims with a claimed value exceeding $10 million?
•  Do you have the authority to approve or deny claims with a claimed value exceeding $25 million?
•  If your authority is limited, who must approve claims decisions above your threshold? Is there a claims committee, a senior officer, or a board-level approval process for large claims?
•  Describe your reporting structure. Who do you report to? Does that person hold the title of Chief Executive Officer, Chief Operating Officer, General Counsel, or another title?
•  Do you report to or interact with Ironclad's underwriting committee or board of directors in connection with large claims?
•  Are you involved in setting claims reserves? Describe your role in the reserving process for claims within your purview.
C. Experience with Hurricane / Catastrophe Claims
This subsection is designed to establish that Haddon has extensive experience with hurricane-related claims and is fully familiar with the unique challenges and legal requirements associated with catastrophe claims in Florida.
Examination points:
•  Over the course of your career, approximately how many hurricane-related property and business-interruption claims have you personally handled or supervised?
•  Have you previously handled or supervised claims arising from Category 4 or Category 5 hurricanes? If so, identify the storms and the approximate number of claims involved.
•  Are you familiar with the legal and regulatory framework governing property insurance claims handling in the State of Florida?
•  Have you received any training—formal or informal—on the Florida bad-faith statutes, including Florida Statutes § 624.155?
•  Have you received any training on the obligations of insurers under Florida law with respect to the timely investigation and resolution of first-party property insurance claims?
•  Has Ironclad ever been the subject of a bad-faith action under Florida law in connection with a hurricane-related claim? If so, describe the circumstances and outcome.
III. VHG CLAIM — INITIAL INVOLVEMENT AND NOTICE OF LOSS
A. First Knowledge of the Claim
This section establishes the timeline of Haddon's personal involvement from the earliest stages of the claim, which is critical to our argument that Ironclad's claims-handling decisions were made with Haddon's direct knowledge and approval throughout the process.
Examination points:
•  When did you first become aware of the VHG Hurricane Callista claim? Establish the specific date and the manner in which Haddon learned of the claim (e.g., internal notification, email, telephone call, meeting).
•  VHG submitted its initial notice of loss to Ironclad on September 22, 2022, four days after Hurricane Callista made landfall. Did you personally receive or review that initial notice of loss?
•  If you did not receive the initial notice directly, who at Ironclad received it? Through what channel—email, facsimile, telephone, online portal, or broker communication?
•  Was the VHG claim flagged as a large-loss claim or a catastrophe claim within Ironclad's internal claims-management system? At what dollar threshold does a claim receive such a designation?
•  What is Ironclad's standard protocol for large-loss or catastrophe claims upon receipt of initial notice? Walk through the steps.
•  When were you personally assigned to or involved with the VHG claim? Was your involvement immediate, or did a period of time elapse between initial notice and your assignment?
•  Who assigned you to the claim, or did you assume responsibility based on the magnitude of the loss and your role as SVP of Claims?
B. Initial Assessment
Examination points:
•  What steps did Ironclad take upon receiving VHG's notice of loss on September 22, 2022?
•  Was a claim file opened? What is the claim file number? Confirm that the claim is associated with Policy No. IIC-PRP-2022-07541.
•  Were initial reserves set for the VHG claim? If so, what amount? On what date were the initial reserves established?
•  Were reserves subsequently adjusted during the claims process? If so, on what dates, to what amounts, and based on what information or analysis?
•  Was the VHG claim reported to Ironclad's reinsurers? If so, when and to which reinsurers?
•  At the time of initial notice, did you personally review the Ironclad primary policy, Policy No. IIC-PRP-2022-07541? If so, what coverage provisions did you identify as potentially applicable to the VHG claim?
•  At the time of initial notice, did you identify any potential coverage defenses, exclusions, or sub-limits that might apply? If so, which ones? What prompted you to identify those defenses at that early stage?
•  Did you review the policy declarations page? The named-peril or all-risk coverage grant? The business-interruption coverage section? The endorsements?
C. Retention of Arbor Claims Services LLC
This subsection is critical because it establishes the framework for our later examination of Ironclad's relationship with Arbor Claims and whether the adjustment was truly independent.
Examination points:
•  When was Arbor Claims Services LLC retained to serve as the independent adjuster on the VHG Hurricane Callista claim? Establish the specific date and the terms of the engagement.
•  Who at Ironclad made the decision to retain Arbor Claims Services LLC? Was that decision made by you, or by someone else?
•  Were you involved in the selection of Arbor Claims Services LLC and/or the specific adjuster, Denise Whitford, to handle this claim?
•  Had Ironclad previously used Arbor Claims Services LLC on other claims? If so, approximately how many times and over what period?
•  What instructions were given to Arbor Claims Services LLC regarding the scope of their investigation? Were they instructed to investigate the nature and cause of damage, the extent of business interruption, or both?
•  Were there written engagement instructions provided to Arbor Claims? If so, identify those documents and obtain copies.
•  Were there any limitations or parameters placed on Arbor Claims' investigation? For example, were they told to focus on any particular coverage issues or exclusions?
•  Arbor Claims' initial inspection of the three VHG properties—Grand Key Resort in Marathon, FL; Harborview Hotel & Marina in Fort Myers, FL; and Sunset Shores Resort in Clearwater, FL—occurred on or about October 5, 2022. Were you aware of the date of the initial inspection?
•  Did you receive Arbor Claims' initial inspection reports? When were those reports delivered to Ironclad?
•  What did the initial inspection reports conclude regarding the nature and extent of damage at each of the three VHG properties? Walk through each property individually.
•  Did the initial inspection reports identify the causes of damage at each property—i.e., wind, storm surge, flooding, or a combination?
•  Did the initial inspection reports provide preliminary damage estimates?
IV. RESERVATION OF RIGHTS LETTER — OCTOBER 12, 2022
A. Drafting and Issuance
The reservation of rights letter is the first formal written communication from Ironclad to VHG identifying potential coverage defenses. Its contents, the process by which it was drafted, and the involvement of outside counsel are all significant.
Examination points:
•  I am going to direct your attention to what has been marked as Exhibit 2, Ironclad's reservation of rights letter dated October 12, 2022. Do you recognize this document?
•  Who drafted this reservation of rights letter? Was it drafted by Ironclad's in-house claims personnel, in-house counsel, or outside counsel?
•  Did you personally review and approve this letter before it was sent to VHG?
•  Were any revisions made to the letter between the initial draft and the final version that was sent? If so, describe the nature of those revisions and who requested them.
•  Was outside counsel—specifically, Fendowell Rourke & Stanton LLP and/or Gregory Stanton—involved in drafting, reviewing, or approving the reservation of rights letter?
•  When was outside counsel first engaged on the VHG claim? Establish the specific date. Was the engagement of outside counsel before or after the reservation of rights letter was issued?
•  What prompted the decision to engage outside counsel? Was it the dollar value of the claim, the complexity of the coverage issues, or some other factor?
B. Bases for Reservation
Examination points:
•  What specific coverage issues were identified in the reservation of rights letter? Walk through each issue identified.
•  The letter references a named-windstorm sub-limit of $15 million applicable to business-interruption coverage. What was the basis for asserting that this sub-limit existed in the 2022 renewal policy?
•  Before issuing the reservation of rights letter, did you personally review the policy endorsements from the July 2022 renewal to confirm that the windstorm sub-limit was in fact reflected in the policy as issued?
•  Before issuing the reservation of rights letter, did you contact Ironclad's underwriting department to determine whether the windstorm sub-limit had been deleted as part of the July 2022 renewal negotiations?
•  At the time the reservation of rights letter was issued, were you aware of any negotiations between Ironclad's underwriters and VHG's broker, Tidewater Risk Advisors LLC, through Franklin Orde, regarding deletion of the named-windstorm sub-limit?
•  Did the reservation of rights letter also reference the flood exclusion? The concurrent causation clause?
•  Did it reference any issues regarding the period of restoration or VHG's alleged failure to mitigate at that early stage, approximately three weeks after the hurricane?
•  If the letter did not reference period of restoration or failure to mitigate at that early stage, when did those issues first arise in Ironclad's claims evaluation?
C. Response from VHG
Examination points:
•  I am going to direct your attention to what has been marked as Exhibit 3, a letter from Calderwood & Harkness LLP dated October 25, 2022, authored by Elaine Forsythe, responding to Ironclad's reservation of rights. Did you receive this letter?
•  Did you personally review this letter?
•  The October 25 letter argued, among other things, that the named-windstorm sub-limit had been deleted as part of the July 2022 renewal and that VHG paid additional premium for that deletion. What was your reaction to that argument?
•  Did any of the arguments raised in the October 25 letter cause you or anyone at Ironclad to reconsider any of the reservations stated in the October 12 letter?
•  Did you take any investigative steps in response to the October 25 letter—for example, reviewing the underwriting file, contacting the underwriting department, or contacting Tidewater Risk Advisors?
•  If you did not take any such steps, why not?
V. THE WINDSTORM SUB-LIMIT ISSUE — DEEP DIVE
NOTE TO EXAMINING ATTORNEY: This is the highest-priority topic. Allocate 90 minutes. Press for specifics and do not accept vague or evasive answers. Pin down exactly what Haddon knew, when he knew it, and what he did or failed to do to investigate the sub-limit issue.
A. Policy Language and Endorsements
Examination points:
•  I am going to direct your attention to what has been marked as Exhibit 1, the Ironclad primary policy, Policy No. IIC-PRP-2022-07541. Please identify the specific policy provision or endorsement that Ironclad contends establishes the $15 million named-windstorm sub-limit applicable to business-interruption coverage.
•  Is this sub-limit set forth in the base policy form, or is it contained in a separate endorsement?
•  If it is in a separate endorsement, what is the endorsement number and what is the effective date of that endorsement?
•  Was this named-windstorm sub-limit present in the prior policy year—i.e., the policy period running from July 2021 to July 2022?
•  Was the sub-limit amount in the prior policy year the same $15 million, or was it a different amount?
•  If the sub-limit was present in the prior year, is the same endorsement form and language used in the 2022 renewal policy?
•  Is there any language in the 2022 renewal policy declarations page or schedule of coverages that references the named-windstorm sub-limit? Or does the declarations page reflect the full policy limit of $25 million without any windstorm sub-limit?
B. July 2022 Renewal Negotiations
This subsection is designed to establish what Haddon knew or should have known about the underwriting negotiations that led to the 2022 renewal, and specifically whether the windstorm sub-limit was agreed to be deleted.
Examination points:
•  Were you involved in or aware of the July 2022 renewal negotiations for VHG's property and business-interruption policy?
•  In your role as SVP of Claims, do you typically have involvement in or visibility into policy renewals and underwriting negotiations?
•  Do you know whether Ironclad's underwriting department received a request from Tidewater Risk Advisors LLC, through Franklin Orde, to delete the named-windstorm sub-limit as part of the July 2022 renewal?
•  Do you know whether Ironclad's underwriters agreed to delete the named-windstorm sub-limit in exchange for additional premium?
•  What was the total annual premium for the primary layer under the 2022 renewal policy? Confirm that the total annual premium was $980,000.
•  Do you know whether the premium for the 2022 renewal increased from the prior policy year? If so, by how much?
•  Was any portion of the premium increase attributable to the deletion of the named-windstorm sub-limit?
•  At any time during the claims-handling process—from initial notice through formal denial—did you personally review any underwriting correspondence, emails, file notes, or other documents regarding the deletion of the windstorm sub-limit?
•  If you did not review the underwriting files, was that a deliberate decision? Was there a reason you chose not to consult the underwriting department or review the underwriting file when evaluating the VHG claim?
•  Did anyone at Ironclad instruct you not to review the underwriting file or contact the underwriting department in connection with the VHG claim?
C. The Binder vs. the Issued Policy
Examination points:
•  Was a policy binder issued in connection with the July 2022 renewal before the formal policy was delivered to VHG or Tidewater Risk Advisors?
•  Did the policy binder contain the named-windstorm sub-limit, or was the binder silent on the issue of a windstorm sub-limit?
•  When was the formal policy—the complete policy form with all endorsements—delivered to VHG and/or Tidewater Risk Advisors?
•  Is there a discrepancy between the terms reflected in the binder and the terms reflected in the issued policy with respect to the named-windstorm sub-limit?
•  If there is such a discrepancy, which document controls under Ironclad's standard practices—the binder or the issued policy?
•  Under Florida law, are you aware that a binder may constitute a temporary contract of insurance, and that the terms of the binder may control where there is a conflict with the subsequently issued policy?
•  Has Ironclad taken a position on whether the binder or the issued policy controls in this case?
D. Impact on Claim
Examination points:
•  If the named-windstorm sub-limit of $15 million applies, what is Ironclad's position on the maximum business-interruption recovery available to VHG under the primary layer?
•  Specifically, is it Ironclad's position that the BI recovery would be capped at $15 million rather than the full $25 million primary layer limit?
•  Does Ironclad acknowledge that VHG's total claimed business-interruption loss of $60 million exceeds $15 million?
•  Does Ironclad acknowledge that all three VHG properties—Grand Key Resort, Harborview Hotel & Marina, and Sunset Shores Resort—suffered damage as a result of Hurricane Callista, which was a named windstorm?
•  If the sub-limit does not apply—if, in fact, it was deleted at renewal—does Ironclad acknowledge that the full $25 million primary layer limit would be available for the BI claim?
•  Does Ironclad acknowledge that the application or non-application of the windstorm sub-limit directly affects the excess carriers' exposure, because if the sub-limit caps the primary layer at $15 million, the primary layer would not be exhausted and the excess layers would not be reached?
VI. FORMAL COVERAGE DENIAL — FEBRUARY 3, 2023
A. Decision-Making Process
Examination points:
•  I am going to direct your attention to what has been marked as Exhibit 5, Ironclad's formal denial letter dated February 3, 2023. Do you recognize this document?
•  Who made the decision to issue the formal denial of VHG's Hurricane Callista claim?
•  Was the decision made by you alone, or did it require approval from a supervisor, a claims committee, a member of senior management, or the board of directors?
•  If the decision required approval from others, identify each person who approved or authorized the denial.
•  Was outside counsel—specifically, Gregory Stanton of Fendowell Rourke & Stanton LLP—involved in drafting the denial letter?
•  Did Fendowell Rourke & Stanton LLP provide a formal coverage opinion in connection with the VHG claim? If so, when was that opinion delivered? What did it conclude?
•  Were there any internal memoranda or coverage analyses prepared by Ironclad's in-house coverage counsel regarding the VHG claim? If so, identify those documents by date and author.
•  Were there any internal discussions within Ironclad in which any person—whether in claims, underwriting, legal, or management—disagreed with the decision to deny the VHG claim? Were there any dissenting views expressed by anyone?
•  Were alternative approaches to the claim considered prior to the issuance of the formal denial? Specifically, was partial payment considered? Was payment under a reservation of rights considered? Was a compromise or settlement considered?
•  If alternative approaches were considered, why were they rejected?
B. Four Bases for Denial — Detailed Examination
1. Named Windstorm Sub-Limit ($15M)
•  This issue was covered extensively in Section V above. Cross-reference that testimony here.
•  At the time of the denial on February 3, 2023, had you reviewed the underwriting file for the July 2022 renewal?
•  At the time of the denial, had you spoken with anyone in Ironclad's underwriting department about whether the named-windstorm sub-limit was deleted as part of the renewal?
•  If you had not consulted the underwriting department or reviewed the underwriting file by the time of the denial, how could you have had a reasonable basis for relying on the windstorm sub-limit as a ground for denial?
2. Period of Restoration
Examination points:
•  What is Ironclad's position on the appropriate period of restoration for each of the three VHG properties?
•  Let's take each property in turn.
•  Grand Key Resort (Marathon, FL): VHG contends that the Grand Key Resort was fully closed from September 18, 2022 through March 15, 2023, a period of 178 days. Does Ironclad dispute this timeline?
•  What does Ironclad contend the period of restoration should have been for Grand Key Resort? On what basis?
•  Harborview Hotel & Marina (Fort Myers, FL): VHG contends that the Harborview was fully closed from September 18, 2022 through January 31, 2023, a period of 135 days. Does Ironclad dispute this timeline?
•  What does Ironclad contend the period of restoration should have been for Harborview? On what basis?
•  Sunset Shores Resort (Clearwater, FL): VHG contends that Sunset Shores had 73 days of full closure and experienced partial closure through February 2023. Does Ironclad dispute these timelines?
•  What evidence did Ironclad rely on to support its assertion that VHG unreasonably delayed the restoration of its properties?
•  Did Ironclad or Arbor Claims Services obtain any independent estimates of repair timelines from contractors, engineers, or construction consultants?
•  Were you aware that following Hurricane Callista, there were severe contractor shortages, labor shortages, and supply-chain delays affecting the Florida Keys and the Gulf Coast of Florida?
•  Did Ironclad consider the impact of those shortages and delays on VHG's ability to complete repairs and reopen its properties?
•  Were you aware that mandatory evacuation orders were issued for Monroe County on September 16, 2022 and for Lee County on September 17, 2022?
•  Did Ironclad consider the impact of those mandatory evacuation orders and the subsequent restricted access periods on the period of restoration?
•  Did Ironclad consider that VHG could not begin restoration work until evacuation orders were lifted and physical access to the properties was restored?
3. Concurrent Causation / Flood Exclusion
Examination points:
•  Which specific VHG property or properties does Ironclad contend sustained flood or storm-surge damage that triggers the flood exclusion? Anticipated answer: Grand Key Resort in Marathon, FL.
•  I am going to direct you to the flood exclusion provision in the policy. Please read the relevant language into the record. What does the flood exclusion provide?
•  Does the policy contain an anti-concurrent causation clause? If so, please read the relevant language into the record. What does the anti-concurrent causation clause provide?
•  What percentage of the damage at Grand Key Resort does Ironclad attribute to storm surge or flood, as opposed to wind?
•  On what basis did Ironclad arrive at that allocation? Was there an engineering analysis, an expert evaluation, or some other methodology?
•  Did Ironclad retain any forensic engineer or cause-of-loss expert to differentiate between wind damage and flood damage at Grand Key Resort or at any other VHG property?
•  If Ironclad did not retain an independent expert, on what basis did Ironclad determine that the flood exclusion applied?
•  Did Arbor Claims Services, through Denise Whitford, provide an opinion on the cause of loss at Grand Key Resort? Did that opinion differentiate between wind and flood damage?
•  Storm surge in Monroe County during Hurricane Callista was reported at 8 to 14 feet. Do you acknowledge this?
•  Does Ironclad's position apply the flood exclusion to bar all business-interruption recovery at Grand Key Resort, or does Ironclad's position only exclude the portion of the BI loss attributable to flood damage?
•  If Ironclad's position is that the anti-concurrent causation clause bars all coverage whenever flood damage is a concurrent cause—even if wind damage was the predominant cause—are you aware that this position is inconsistent with the efficient proximate cause doctrine as applied under Florida law?
•  Have you consulted with counsel regarding the enforceability of anti-concurrent causation clauses under Florida law?
4. Failure to Mitigate
Examination points:
•  The denial letter cites VHG's alleged failure to mitigate its losses as a fourth ground for denial. What specific mitigation steps does Ironclad contend VHG failed to take?
•  During the claims-handling process, between September 22, 2022 and February 3, 2023, did Ironclad communicate to VHG what specific mitigation steps Ironclad expected VHG to take?
•  If Ironclad did not communicate specific mitigation expectations to VHG, how can Ironclad now contend that VHG failed to mitigate?
•  Did Ironclad offer to advance funds to VHG for emergency repairs or to facilitate temporary operations at any of the three properties?
•  Were you aware that VHG incurred substantial extra expenses to mitigate its losses, including emergency generator costs, temporary relocation of staff, and expedited contractor engagements?
•  Does Ironclad acknowledge that VHG evacuated all three properties in compliance with mandatory evacuation orders—Monroe County on September 16, 2022 and Lee County on September 17, 2022—before Hurricane Callista made landfall on September 18, 2022?
•  Does Ironclad acknowledge that VHG's compliance with mandatory evacuation orders necessarily resulted in the closure of its properties and the cessation of revenue-generating operations?
•  Is it Ironclad's position that VHG should have taken actions inconsistent with mandatory evacuation orders to mitigate its losses?
C. Timing of Denial
Examination points:
•  VHG submitted its sworn statement in proof of loss on November 15, 2022. The formal denial was issued on February 3, 2023, approximately 80 days later. During that 80-day period, what investigation did Ironclad conduct?
•  Did Ironclad request any additional information or documentation from VHG during that period? If so, what was requested, and was it provided?
•  Did VHG fully cooperate with Ironclad's investigation and respond to all requests for information?
•  Was the timing of the denial influenced by any strategic considerations? For example, was the denial timed to coincide with any reinsurance reporting deadline, any excess carrier coordination, or any internal Ironclad budgetary or reserving cycle?
•  Under Florida law, are you aware of any statutory or regulatory timeframe within which an insurer must accept or deny a property insurance claim after receiving a proof of loss?
VII. IRONCLAD'S RELATIONSHIP WITH ARBOR CLAIMS SERVICES LLC
A. Scope of Engagement
Examination points:
•  What was the scope of Arbor Claims Services LLC's engagement on the VHG claim? Please describe in detail what Arbor Claims was retained to do.
•  Was Arbor Claims asked to opine on coverage issues—such as the applicability of the windstorm sub-limit, the flood exclusion, or the period of restoration—or was their engagement limited to the factual investigation of damages?
•  How many inspections did Arbor Claims conduct at VHG's three properties?
•  We have discussed the initial inspection on October 5, 2022. Were there subsequent inspections? If so, when did they occur and what was their purpose?
•  Were Arbor Claims' reports shared with VHG? If so, when were they shared? Were they shared in their entirety, or were portions withheld?
B. Arbor Claims' Findings and Recommendations
Examination points:
•  What did Denise Whitford of Arbor Claims conclude regarding the nature and extent of damage at each of the three VHG properties? Walk through each property.
•  Did Arbor Claims provide a recommended business-interruption loss figure? If so, what was the recommended figure for each property and in the aggregate?
•  Did Arbor Claims' assessment of the BI losses differ from Ironclad's ultimate position? If so, in what respects?
•  Did Arbor Claims recommend payment of any portion of the VHG claim?
•  If Arbor Claims recommended payment of the claim, in whole or in part, why did Ironclad not follow that recommendation?
•  Who at Ironclad made the decision to depart from Arbor Claims' recommendation?
•  Was the decision to overrule Arbor Claims' recommendation documented in writing?
C. Communications and Directives
Examination points:
•  How frequently did you communicate with Denise Whitford during the course of the adjustment of the VHG claim?
•  What was the mode of communication—telephone, email, videoconference, in-person meetings, or some combination?
•  Were there any communications—whether oral or written—in which you directed, instructed, or suggested to Arbor Claims or Denise Whitford that they should reach a particular conclusion regarding the nature, extent, or cause of damage?
•  Were there any communications in which you directed Arbor Claims to focus on specific exclusions, sub-limits, or coverage defenses?
•  Did you instruct Arbor Claims to investigate the windstorm sub-limit issue? Did you instruct them to investigate the flood exclusion or the concurrent causation issue?
•  Were any communications between Ironclad and Arbor Claims in writing—whether by email, letter, memorandum, or any other written format?
•  Regardless of form, we will require production of all such communications. Have all written communications between Ironclad and Arbor Claims been produced in discovery?
VIII. COMMUNICATIONS WITH EXCESS CARRIERS
A. Notice to Excess Carriers
Examination points:
•  When did Ironclad notify the excess carriers of the VHG Hurricane Callista claim? Specifically, when did Ironclad notify Pinnacle Surplus Lines Inc., Montclair Assurance Company, and Sovereign Re Ltd.?
•  What information was shared with the excess carriers at the time of initial notification?
•  Did Ironclad share its reservation of rights letter dated October 12, 2022 with the excess carriers?
•  Did Ironclad share its formal denial letter dated February 3, 2023 with the excess carriers?
•  Did Ironclad share Arbor Claims' inspection reports or any other investigative materials with the excess carriers?
B. Coordination of Coverage Positions
Examination points:
•  Did Ironclad coordinate its coverage position or denial strategy with any of the three excess carriers before issuing the formal denial on February 3, 2023?
•  Pinnacle Surplus Lines Inc. issued a follow-form denial on February 10, 2023—just one week after Ironclad's denial. Was this timing coordinated between Ironclad and Pinnacle?
•  Did you personally communicate with anyone at Pinnacle Surplus Lines Inc. regarding the VHG claim or the denial?
•  Did you personally communicate with anyone at Montclair Assurance Company regarding the VHG claim?
•  Did you personally communicate with anyone at Sovereign Re Ltd. regarding the VHG claim?
•  Were there any joint defense agreements, common interest agreements, or claims-handling agreements among the carriers with respect to the VHG claim?
•  Did any of the three excess carriers express a different view of coverage than Ironclad? Did any carrier question the viability of Ironclad's denial grounds?
•  Were there any conference calls, meetings, or joint communications among two or more of the carriers regarding the VHG claim?
C. Impact of Windstorm Sub-Limit on Excess Layers
Examination points:
•  If the $15 million named-windstorm sub-limit applies, what is the impact on the excess carriers' exposure? Specifically, if the primary layer limit is effectively capped at $15 million for windstorm BI losses, would the primary layer be exhausted?
•  Does Ironclad acknowledge that if the windstorm sub-limit applies and caps the primary layer at $15 million, the excess layers would not be reached? The primary policy limit is $25 million, Pinnacle attaches at $25 million, Montclair attaches at $40 million, and Sovereign Re attaches at $50 million.
•  Are you aware that Montclair Assurance Company and Sovereign Re Ltd. reserved their rights but did not issue formal denials? Is that your understanding of their positions?
•  Do you understand that Montclair's excess layer attaches at $40 million and Sovereign Re's layer attaches at $50 million?
•  Did the impact of the windstorm sub-limit on the excess layers factor into Ironclad's decision to assert the sub-limit as a ground for denial?
IX. VHG'S SWORN STATEMENT IN PROOF OF LOSS
A. Receipt and Review
Examination points:
•  I am going to direct your attention to what has been marked as Exhibit 4, VHG's sworn statement in proof of loss dated November 15, 2022. Do you recognize this document?
•  Did you personally receive and review VHG's sworn statement in proof of loss?
•  The proof of loss claims total business-interruption losses of $60 million across VHG's three properties. At the time you reviewed the proof of loss, did you consider this amount to be reasonable, excessive, insufficient, or did you not form an opinion?
•  The proof of loss breaks down the claimed losses by property: Grand Key Resort at $31.4 million, Harborview Hotel & Marina at $18.7 million, and Sunset Shores Resort at $9.9 million. Did Ironclad evaluate each property's claimed loss individually?
•  Did Ironclad request any supporting documentation from VHG to substantiate the claimed loss amounts? If so, what was requested, and was it provided?
•  Did Ironclad identify any specific deficiencies or inaccuracies in the proof of loss?
B. Ironclad's Loss Quantification
Examination points:
•  Did Ironclad perform its own independent business-interruption loss quantification for the VHG claim?
•  If so, what figure did Ironclad arrive at, in the aggregate and by property?
•  Who performed that analysis? Was it done internally or by an outside expert?
•  Did Ironclad retain any outside expert, other than Arbor Claims Services, to evaluate the business-interruption losses during the claims-handling process?
•  Was Graystone Consulting Group LLC, specifically Dr. Warren Birk, retained during the claims-handling process, or was Graystone retained only after litigation was filed?
•  If Ironclad did not perform its own loss quantification before denying the claim, how did Ironclad evaluate whether VHG's claimed losses were reasonable?
•  At any point during the claims-handling process, did anyone at Ironclad internally acknowledge or conclude that VHG's losses were substantial and likely exceeded the total insurance tower of $60 million?
X. BAD FAITH AND CLAIMS HANDLING
A. Florida Claims-Handling Standards
Examination points:
•  Are you familiar with Florida Statutes § 624.155, which provides a civil remedy for bad-faith insurance claims handling?
•  Describe your understanding of the obligations imposed on insurers by Florida Statutes § 624.155.
•  Are you familiar with the duty of good faith and fair dealing that an insurer owes to its insured under Florida law?
•  Does Ironclad Indemnity Corporation maintain internal claims-handling guidelines, best practices manuals, or standard operating procedures for the handling of property and business-interruption claims?
•  If so, produce those documents. Were those guidelines and procedures followed in the handling of VHG's Hurricane Callista claim?
•  If those guidelines were not followed in any respect, identify each departure and the reason for the departure.
•  Do Ironclad's claims-handling guidelines require a claims professional to investigate all relevant facts, including facts favorable to coverage, before making a coverage determination?
•  Do Ironclad's guidelines require consultation with the underwriting department when a coverage question depends on the terms negotiated at renewal?
B. Reasonableness of Denial
Examination points:
•  At the time you authorized or participated in the decision to deny VHG's claim on February 3, 2023, did you personally believe that there was a reasonable basis for each of the four grounds cited in the denial letter?
•  Walk through each ground individually. For each ground, explain the factual and evidentiary basis that you believed supported the denial at the time it was issued.
•  Did you consider whether partial payment could be made for undisputed portions of the VHG claim? For example, if there was a dispute about the windstorm sub-limit but no dispute that VHG suffered at least some covered BI losses, did you consider paying the undisputed amount while continuing to investigate the disputed portions?
•  VHG is a major hospitality company. Its three affected properties collectively generate substantial annual revenue. VHG's company-wide revenue for fiscal year 2021 was approximately $412 million. Did you appreciate the magnitude of the business interruption that VHG was experiencing as a result of Hurricane Callista?
•  Did you understand that by denying the claim in its entirety, VHG would be deprived of all insurance proceeds to fund its restoration and recovery efforts?
•  Were there any internal discussions at Ironclad about the risk of a bad-faith finding if the denial was subsequently overturned? If so, describe those discussions, including who participated, when they occurred, and what was concluded.
C. Post-Denial Conduct
Examination points:
•  After issuing the formal denial on February 3, 2023, did Ironclad take any further steps to investigate the VHG claim?
•  Did Ironclad receive Calderwood & Harkness's letter dated February 15, 2023, which addressed the bad-faith implications of the denial? I am going to direct your attention to what has been marked as Exhibit 6. Do you recognize this letter?
•  What was Ironclad's response to that letter?
•  Did the February 15 letter cause Ironclad or you personally to reconsider the denial?
•  Did Ironclad conduct any additional investigation after receiving the February 15 letter? For example, did anyone at Ironclad finally review the underwriting file or contact the underwriting department after receiving this letter?
•  Has Ironclad's position on any of the four denial grounds changed since the denial was issued on February 3, 2023?
XI. DOCUMENT REQUESTS AND PRESERVATION
A. Documents to Request at Deposition
The following documents should be requested on the record during the deposition to the extent they have not already been produced in response to formal discovery. Even if previously requested, placing the request on the deposition record creates an additional basis for a motion to compel if the documents are withheld.
1.  The complete claim file for the VHG Hurricane Callista claim, including all electronic and hard-copy documents contained therein.
2.  All internal memoranda, emails, instant messages, text messages, and handwritten or typed notes regarding the VHG claim, from any Ironclad employee, officer, or director.
3.  All coverage opinions—whether prepared by in-house counsel, in-house claims personnel, or outside counsel—prepared in connection with the VHG claim.
4.  All communications between Haddon and any member of Ironclad's underwriting department regarding the named-windstorm sub-limit in VHG's 2022 renewal policy.
5.  All communications between Haddon (or any Ironclad claims personnel) and Arbor Claims Services LLC and/or Denise Whitford, including engagement letters, instructions, reports, correspondence, emails, and notes of telephone conversations.
6.  All communications between Haddon (or any Ironclad personnel) and any representative of the excess carriers—Pinnacle Surplus Lines Inc., Montclair Assurance Company, and Sovereign Re Ltd.—regarding the VHG claim.
7.  All communications between Haddon (or any Ironclad personnel) and outside counsel at Fendowell Rourke & Stanton LLP regarding the VHG claim. (Note: Privilege will likely be asserted; see Section XI.B below.)
8.  The complete reserve history for the VHG claim, including all reserve entries, adjustments, and the dates and reasons for each adjustment.
9.  Ironclad's claims-handling guidelines, best practices manuals, standard operating procedures, and any training materials related to property and BI claims handling, catastrophe claims, or Florida-specific claims obligations.
10.  Any presentations, reports, memoranda, or communications to Ironclad's board of directors, executive management team, or claims committee regarding the VHG claim.
B. Privilege Issues
The following privilege issues should be anticipated and addressed during the deposition:
•  Defense counsel will almost certainly assert attorney-client privilege and work-product protection for communications between Ironclad and its outside counsel, Fendowell Rourke & Stanton LLP. This assertion is expected and, for post-litigation communications, likely valid.
•  However, the examining attorney should probe whether coverage opinions or coverage analyses were prepared by in-house claims personnel rather than by in-house counsel. Documents prepared by claims personnel in the ordinary course of claims handling are generally not protected by the attorney-client privilege, even if they address coverage issues, unless they were prepared at the direction of counsel for the purpose of providing legal advice.
•  The examining attorney should also explore whether any privileged communications were shared with the excess carriers—Pinnacle, Montclair, or Sovereign Re. If privileged materials were shared with third parties outside the scope of a valid common-interest or joint-defense agreement, the privilege may have been waived.
•  If defense counsel instructs the witness not to answer on privilege grounds, note the instruction on the record, preserve the objection, and move on. The issue can be raised with the court by motion to compel if necessary.
XII. KEY EXHIBITS TO USE DURING DEPOSITION
The following exhibits should be pre-marked and organized in a binder for use during the deposition. Each exhibit should be provided to the court reporter for formal marking at the time it is introduced during the examination.
NOTE: Additional exhibits may be identified based on documents produced in discovery between the date of this outline (July 7, 2023) and the date of the deposition (July 10, 2023). Check with litigation support for any supplemental productions received.
XIII. ANTICIPATED DEFENSE OBJECTIONS AND STRATEGIES
A. Expected Objections
Based on the subject matter of this deposition and the involvement of defense counsel from Fendowell Rourke & Stanton LLP, we anticipate the following objections and obstructive tactics:
1.  Attorney-Client Privilege. Defense counsel will assert attorney-client privilege for all communications between Haddon (or any Ironclad representative) and Fendowell Rourke & Stanton LLP. This objection will likely be asserted for any question touching on legal advice received from outside counsel, the substance of coverage opinions prepared by outside counsel, and the drafting of the reservation of rights and denial letters to the extent counsel was involved.
2.  Work-Product Doctrine. Defense counsel will invoke the work-product doctrine for any analyses, memoranda, or documents prepared in anticipation of litigation. This objection may be asserted broadly for any document created after Ironclad retained outside counsel or after VHG filed suit.
3.  Instructions Not to Answer. Defense counsel may instruct the witness not to answer questions that call for disclosure of Ironclad's litigation strategy, mental impressions of counsel, or the substance of attorney-client communications. Under Florida's rules of civil procedure, instructions not to answer are generally limited to assertions of privilege or to prevent annoyance, embarrassment, or oppression.
4.  Reserve Information. Defense counsel may object to questions about reserve amounts, asserting that reserve information is irrelevant, prejudicial, or protected under the work-product doctrine. The discoverability of reserve information in Florida is a contested issue that may require briefing. Florida courts have generally permitted discovery of reserve information in bad-faith actions, but the issue is not settled beyond dispute.
B. Strategies to Overcome
1.  Pre-Litigation vs. Post-Litigation Distinction. The examining attorney should carefully distinguish between pre-litigation claims handling (which is generally not protected by the attorney-client privilege or work-product doctrine) and post-litigation strategy. Claims-handling decisions made before the filing of suit—including the decision to deny the claim—are ordinarily subject to full discovery, even if counsel was consulted. The fact that outside counsel was involved in drafting the denial letter does not, standing alone, shield the underlying factual bases for the denial from discovery.
2.  Crime-Fraud Exception. If Ironclad's denial was made in bad faith—as VHG contends—the crime-fraud exception to the attorney-client privilege may apply. While we are unlikely to invoke this exception during the deposition itself, it should be noted in our post-deposition motion practice if defense counsel's privilege assertions prove overly broad.
3.  Factual vs. Legal Questions. The examining attorney should frame questions to elicit factual information—what did Haddon do, what did he know, when did he know it, who did he communicate with, what documents did he review—rather than asking for legal conclusions or legal advice received. This approach minimizes the number of valid privilege objections and forces the witness to provide factual testimony that is not privileged.
4.  Use of Documents Already in Evidence. Where the witness claims inability to recall or defense counsel asserts privilege, the examining attorney should use documents already produced in discovery to refresh the witness's recollection or to compel answers. If a document has already been produced without a privilege designation, it cannot subsequently be shielded from questioning at deposition.
5.  Proffer and Preserve. For any question where defense counsel instructs the witness not to answer, the examining attorney should make a clear proffer on the record explaining the relevance of the question and why the assertion of privilege is improper. This preserves the issue for the court and creates a record supporting a motion to compel if needed.
XIV. CROSS-REFERENCE NOTES
The testimony obtained from Victor Haddon at his July 10, 2023 deposition must be carefully compared and cross-referenced with the testimony of other witnesses to identify inconsistencies, admissions, and areas for further development. The following cross-references should be noted:
1.  Denise Whitford (Arbor Claims Services LLC) — Deposition scheduled July 24, 2023. Whitford's testimony regarding her inspection findings, her recommended loss amounts, and her communications with Haddon and Ironclad should be compared directly with Haddon's testimony. Any inconsistencies between Haddon's characterization of Arbor Claims' findings and Whitford's own account of her findings and recommendations will be significant, particularly if Haddon understates or mischaracterizes Arbor Claims' recommended loss figures.
2.  Franklin Orde (Tidewater Risk Advisors LLC) — Deposition scheduled August 28, 2023. Orde will testify from the broker's perspective regarding the July 2022 renewal negotiations and the deletion of the named-windstorm sub-limit. Haddon's testimony regarding his knowledge of (or failure to investigate) the underwriting negotiations should be compared with Orde's account of the discussions between Tidewater and Ironclad's underwriting department. If Orde testifies that the sub-limit deletion was clearly agreed upon and reflected in the binder, Haddon's failure to investigate this issue before denying the claim will be damning.
3.  Sandra Pellegrini (VHG Vice President of Risk Management) — Deposition scheduled August 14, 2023. Pellegrini will address VHG's understanding of the sub-limit deletion and the premium negotiations. Her testimony should be coordinated with Haddon's to ensure a consistent narrative from the policyholder's perspective.
4.  Expert Reports — Due September 15, 2023. Dr. Helen Vasquez of Meridian Forensic Economics (retained by VHG at $625/hour) will opine on VHG's business-interruption losses. Dr. Warren Birk of Graystone Consulting Group LLC (retained by Ironclad) will provide the defense's loss quantification. Haddon's testimony regarding Ironclad's internal loss quantification—or lack thereof—will directly inform the preparation of Dr. Vasquez's report and the cross-examination of Dr. Birk.
XV. TIME ALLOCATION AND EXAMINATION ORDER
The deposition of Victor Haddon is expected to consume a full day, with an estimated total examination time of six to seven hours. The following time allocation reflects the relative importance of each topic area and ensures that the most critical topics—particularly the windstorm sub-limit issue—receive adequate attention.
NOTE: The time estimates above are guidelines. The examining attorney should exercise judgment and adjust the allocation as warranted based on the witness's responsiveness, the productivity of each line of questioning, and any unexpected admissions or revelations. Section V (Windstorm Sub-Limit) is the highest-priority topic and should not be curtailed in favor of lower-priority sections. If time becomes constrained, Sections VIII and IX may be abbreviated, with the remaining questions addressed through interrogatories or a subsequent deposition session if necessary.
XVI. POST-DEPOSITION ACTION ITEMS
The following action items should be completed following the conclusion of the Haddon deposition:
1.  Post-Deposition Summary and Key Admissions Memorandum. Tiffany Rosenthal to prepare a comprehensive summary of the Haddon deposition testimony, highlighting all key admissions, evasions, and areas of vulnerability. Target completion date: within two weeks of the deposition (by July 24, 2023).
2.  Inconsistency Analysis. Flag any testimony that is inconsistent with documents produced in discovery. Inconsistencies should be catalogued for potential use in the partial summary judgment motion on the windstorm sub-limit issue and for impeachment at trial.
3.  Supplemental Document Requests. Identify any new document requests prompted by the deposition testimony. If Haddon references documents that have not been produced—such as internal memoranda, reserve analyses, or communications with underwriting—serve supplemental requests for production promptly.
4.  Whitford Deposition Preparation. Coordinate with Tiffany Rosenthal and Andrew Fitzpatrick on the preparation for the Denise Whitford (Arbor Claims Services) deposition, scheduled for July 24, 2023. Haddon's testimony regarding his communications with Whitford and his characterization of Arbor Claims' findings should directly inform the Whitford deposition outline.
5.  Case Strategy Update. Update the master case strategy memorandum with the findings from the Haddon deposition. Circulate the updated memorandum to the full litigation team, including Elaine Forsythe, Andrew Fitzpatrick, and any other team members.
6.  Summary Judgment Assessment. Assess whether Haddon's testimony strengthens or weakens VHG's position on the partial summary judgment motion on the windstorm sub-limit issue. The motion is currently scheduled to be filed on November 1, 2023. If Haddon admitted that he did not review the underwriting file, did not consult with underwriting, and relied solely on the policy as issued without investigating whether the sub-limit was properly included, these admissions will be powerful evidence in support of summary judgment.
7.  Bad-Faith Evaluation. Evaluate whether Haddon's testimony supports a viable bad-faith claim under Florida Statutes § 624.155. Key considerations include: (a) whether Ironclad conducted a reasonable investigation before denying the claim; (b) whether Ironclad had a reasonable basis for each denial ground; (c) whether Ironclad considered partial payment of undisputed amounts; (d) whether Ironclad overrode Arbor Claims' recommendations; and (e) whether Ironclad coordinated its denial with the excess carriers. If the deposition testimony establishes that Ironclad failed to meet its statutory and common-law obligations, the bad-faith claim should be pursued aggressively.
— END OF DEPOSITION OUTLINE —
PREPARED BY:
Tiffany Rosenthal Associate Calderwood & Harkness LLP
Date: July 7, 2023
REVIEWED AND APPROVED BY:
Elaine Forsythe Partner Calderwood & Harkness LLP
Date: July 7, 2023
CONFIDENTIAL — ATTORNEY WORK PRODUCT — NOT FOR DISTRIBUTION
Matter: | Verimark Hospitality Group Inc. v. Ironclad Indemnity Corp. et al., Case No. 2022-CA-031547, Eleventh Judicial Circuit of Florida, Miami-Dade County
Engagement Number: | 1021-00003
Prepared By: | Tiffany Rosenthal, Associate, Calderwood & Harkness LLP
Reviewed By: | Elaine Forsythe, Partner, Calderwood & Harkness LLP
Date Prepared: | July 7, 2023
Deposition Date: | July 10, 2023
Deponent: | Victor Haddon, Senior Vice President of Claims, Ironclad Indemnity Corporation
Court Reporter: | To be confirmed
Location: | Anticipated at the offices of Fendowell Rourke & Stanton LLP, 101 E. Kennedy Boulevard, Suite 3900, Tampa, FL 33602 (or as designated by defense counsel)
Defense Counsel Present: | Gregory Stanton (Partner), Meredith Liang (Senior Associate), Fendowell Rourke & Stanton LLP
Calderwood & Harkn