Giovacchini v. The Cincinnati Insurance Company

CourtDistrict Court, N.D. California
DecidedDecember 10, 2024
Docket3:22-cv-07787
StatusUnknown

This text of Giovacchini v. The Cincinnati Insurance Company (Giovacchini v. The Cincinnati Insurance Company) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Giovacchini v. The Cincinnati Insurance Company, (N.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 STEFANO GIOVACCHINI, et al., Case No. 22-cv-07787-LB

12 Plaintiffs, ORDER REGARDING REBUTTAL EXPERT TESTIMONY 13 v. Re: ECF No. 47 14 CINCINNATI INSURANCE COMPANY, 15 Defendant. 16 17 INTRODUCTION 18 This is a dispute about whether the plaintiffs’ rebuttal expert’s opinions are appropriate 19 rebuttal opinions. The plaintiffs sued the defendant under their homeowners’ policy for water 20 damage to the interior and exterior of their home resulting from a storm. The defendant’s expert 21 gave his opinion about the costs to repair the interior damage. He did not assess the costs of 22 exterior repairs, and he did not opine about covered loss under the insurance contract. The 23 plaintiffs designated a rebuttal expert, who is a lawyer, to testify about (1) damages from the water 24 and costs of repair and (2) and the expert’s assumptions that caused him to calculate damages only 25 for interior repairs (and not exterior repairs). They did not disclose a report, the expert’s CV, or 26 other mandatory disclosures under Fed. R. Civ. P. 26(a)(2)(B). The defendant moved to strike the 27 expert and exclude his testimony on the grounds that the plaintiffs did not comply with Rule 1 outside the scope of the initial expert testimony. The plaintiffs did not comply with Rule 2 26(a)(2)(B). but they can cure that error. On this record, the rebuttal opinions either duplicate 3 information that should have been in the plaintiffs’ initial reports or are outside the scope of the 4 defendant’s expert opinions. They thus are not appropriate rebuttal opinions. 5 6 STATEMENT 7 This is an insurance-coverage case involving the plaintiffs’ claim under their homeowners’ 8 policy for interior and exterior water damage from a major storm (characterized as “a massive 9 bomb cyclone and atmospheric river”).1 After the defendant denied coverage, the plaintiff sued for 10 breach of contract and breach of the implied covenant of good faith and fair dealing.2 11 The parties disclosed their experts on August 23, 2024.3 The plaintiffs designated two experts. 12 First, they designated James Range of Range & Associates to testify on the following topics: 13 (1) cause and origin of the subject water damage; (2) scene analysis (3) reconstruction; (4) damage resulting from the water intrusion; (5) construction 14 practices related to waterproofing residential structures; (6) forensic investigation 15 principles related to water intrusion in residential structures; (7) water staining and mold; (8) design and construction of plaintiffs’ residence, including the water 16 drainage system; (9) analysis of any borescope or other imaging; (10) general property damage; (11) scope of repair; (12) cost of repair; and (13) any other 17 subjects or opinions referenced in his report or in subsequent deposition testimony, 18 including reasonable inferences arising therein.4 19 Second, they designated Gabe Moufarrej of GEM Builders as a non-retained expert to testify 20 on the following topics: (1) the water intrusion incident; (2) the cause and origin of the water intrusion; (3) 21 the design of the subject property where the water intrusion occurred; (4) the 22 construction of the subject property where the water intrusion occurred; (5) water proofing; (6) the condition of the deck; (7) maintenance of the subject property, 23 24 25 1 Compl., Ex. A to Notice of Removal – ECF No. 1-1 at 4 (¶¶ 5–6); 5 (¶¶ 9–10). Citations refer to material in the Electronic Case File (ECF); pinpoint citations are to the ECF-generated page numbers 26 at the top of documents. 2 Id. at 5–6 (¶¶ 15–18); 6–9 (¶¶ 20–45) 27 3 Mrowka Decl. – ECF No. 47-1 & Disclosures., Exs. A-B to id. including the deck; (8) scope of repair; (9) cost of repair; and (10) mitigation 1 efforts.5 2 The defendant disclosed two retained experts, Sean Hallet, P.E., to opine on the cause and 3 origin of the claimed damage, and Jeff Jones of Young & Associates to opine on the scope and 4 cost of repairs.6 The disclosure of Mr. Jones’s expert opinion is the relevant disclosure: 5 YOUNG and Associates (YA) was retained . . . for the purpose of: 6 • Review and provide comment on Insured’s Contractor GEM Builders repair scope and costs. 7 • Identifying the necessary scope of repair work to be performed at the 8 property due to water intrusion. 9 • Estimating the repair costs associated with the interior water damage to the property. 10 YA was neither retained to opine as to any aspect of insurance coverage nor to 11 provide any origin and cause determination. 12 The scope of work was limited to resulting water damage only to interior finishes and excludes any repairs to existing structural members which would appear to be 13 long term exposure to moisture, any exterior repairs or exterior work related to the 14 correction of construction deficiencies leading to the cause of the water intrusion to the interior of the residence, and any interior or exterior finishes removed to facilitate 15 repairs related to structural or exterior building envelope repairs.7 16 On September 20, 2024, the plaintiffs designated their rebuttal expert Tim Larsen, who is an 17 attorney and a public adjuster, to opine on the following topics: 18 (1) the scope of services and assumptions underlying the Jeff Jones expert report; (2) insurance coverage under the CIC policy; (3) the scope of repair; (4) damage 19 resulting from the water intrusion; (5) cost of repair; and (6) any other subjects or 20 opinions referenced in his report or in subsequent deposition testimony, including reasonable inferences arising therein. . . . 21 . . . 22 Mr. Larsen will opine that the assumptions underlying the Jeff Jones report regarding the limitation to resulting water damage only to interior finishes and excluding any 23 repairs to existing structural members misstates the coverage obligation CIC has 24 under the subject policy. Accordingly, Mr. Jones’ estimating process and subsequent itemized cost estimate understates the amount of costs to which the plaintiffs are 25 26 5 Id. (p. 2:15–19). 27 6 Def.’s Disclosure, Ex. B to Mrowka Decl. – ECF No. 47-1 at 14–59. entitled. Moreover, the repair costs charged by GEM Builders falls within a 1 reasonable range of repair costs given the damages covered by the subject policy. 2 The disclosure did not include a report, any exhibits, a CV, a list of publications, or other cases 3 where the expert testified.8 See Fed. R. Civ. P. 26(a)(2) (required expert disclosures). 4 The defendants’ experts were deposed on October 16, 2024. No questions were asked about 5 insurance coverage, and neither expert opined on the topic of insurance coverage.9 6 The court held a hearing on December 5, 2024. 7 8 ANALYSIS 9 The defendant moved to strike the plaintiffs’ rebuttal-expert disclosure and exclude the expert 10 on the grounds that the disclosure did not comply with Fed. R. Civ. P. 26(a)(2)(B), and it is not 11 rebuttal testimony. On this record, the opinions are not proper rebuttal testimony.

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Giovacchini v. The Cincinnati Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/giovacchini-v-the-cincinnati-insurance-company-cand-2024.