Julia Young (Partner-Orlando, FL) defended an insurance company client in a case involving a named-perils policy, which, under Florida substantive law, means the plaintiff’s initial burden in the case is to prove that damage was sustained to her property as the result of windstorm (a named peril under the policy). The property insurer investigated the claim and determined that repair of covered damages did not exceed the applicable policy deductible. The insured then filed suit for breach of contract, and sought damages in excess of $75,000. The matter was removed to the U.S. District Court for the Middle District of Florida. The plaintiff’s counsel failed to disclose any expert by the deadline, and one extension of time was provided to the plaintiff, who again failed to meet the deadline. Julia did not consent to a second extension of time, and contested the plaintiff’s motion seeking one; the court ultimately denied the plaintiff’s motion. Julia argued that, lacking expert evidence, the plaintiff could not meet her initial burden, and, therefore, the client was entitled to summary judgment. Judge Badalamenti handed down his order granting our motion, noting that, without expert evidence, the plaintiff could not demonstrate the necessary element of causation, and could not rebut testimony of our experts regarding whether damage arose due to windstorm or to age-related deterioration. Judge Badalamenti concluded his Order with: “This is a prime example of a complex issue outside the scope of a layperson’s knowledge that requires testimony from an expert witness.”