Memorandum of Law

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                          Filing # 109751167 E-Filed 07/02/2020 03:42:43 PM

IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA

CASE NO. CACE 16-008743
HEARING DATE MONDAY JULY 6, 2020 AT 2:30 P.M.
ERIC LIPNACK,
Plaintiff,

NATIONAL UNION FIRE INSURANCE COMPANY
OF PITTSBURGH, PA,

Intervening Plaintiff,
v.
TOP NOTCH MARINE OF POMPANO, INC.,
a Florida Corporation, COBALT BOAT
COMPANY, a foreign corporation, and
BRUNSWICK PRODUCT PROTECTION
CORPORATION, a foreign corporation,

Defendants.
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INTERVENING PLAINTIFF’S MEMORANDUM OF LAW ON THE ISSUE OF DAMAGES
At the summary judgment hearing of Thursday, July 2, 2020, the
Court requested information on the issue of damages. Intervening

Plaintiff, National Union Fire Insurance Company of Pittsburgh, PA

(“National Union”), as subrogee of Plaintiff, Erick Lipnack (“Lipnack”
states:
I. Lipnack’s Deposition testimony does not bind him to JAS Marine’s

estimate of June 3, 2016.
Lipnack testified as follows:
Q. You have the JAS estimate…