FORCON INTERNATIONAL

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1 CURTIS E. FALANY, P.E. EDUCATION Florida State University - B.S. Engineering Science Florida State University - Graduate Studies, Engineering Science University of South Florida - Graduate Studies, Engineering Science , 1974 University of South Florida - Graduate Studies, Chemical Engineering LICENSES AND CERTIFICATIONS Registered Professional Engineer, Florida - since 1974 Registered Professional Engineer, Alabama, since 2012 Certified Building Contractor, Florida - since 1975 Certified Electrical Contractor, Florida - since 1972 CAREER HISTORY J. B. Shepherd & Associates, Inc. - Bushnell, FL - Senior Electrical Engineer - Forensic Electrical Engineer and Expert Witness. Curtis E. Falany, LLC - Plant City, FL - Managing Member - Forensic Consulting - Electrical, Electronic, and Computer to present Florida Electrical Contractors Licensing Board - Tallahassee, FL - Board Member through Qwik.Net Systems, Inc. - Plant City, FL - Founder, Officer, Director - An Internet technology and hosting company specializing in innovative solutions for law, medical, and insurance professionals to the present. Forcon International Corp. - Brandon, Florida - Associate - Consulting in complex electrical and electronic systems, including computer systems, communication systems, networks, office automation, electrical power and control systems. Forensic investigator and expert witness in CURTIS E. FALANY, P.E. - Page 1 of 9 Last Update - September 19, 2014

2 matters involving injury or loss of life from electrical contact in addition to a wide variety of failures and losses, including fires and injuries, from known or unknown causes such as lightning and electrical surges, equipment malfunction, and human resource failure through the present. ComputerMAX, Inc. - Plant City, FL - Founder, Officer, Director - Consulting in electrical systems, control systems, and computer systems hardware, software, design and programming. Forensic investigator and expert witness in computer systems and their operation, maintenance and installation through Energy Control Contractors, Inc. - Plant City, Florida - Founder, Officer, Director - sold and serviced process control computer systems and equipment worldwide for manufacturing, energy production and distribution, data communications, telecommunications and space/defense. Specialized in MODCOMP based computer control systems. Successfully developed and marketed to MODCOMP users several aftermarket memory and 'ramdisk' products. The company was sold in 1987 to a group of investors in, and moved to, Ocala, Florida. Southern Memory Devices - Plant City, Florida - Founder, Officer, Director - A worldwide dealer in rotating memory devices for realtime and process control applications. Merged into Energy Control Contractors, Inc. EGS Systems, Inc. - Plant City, Florida - Founder, Officer, Director - started as a computer software development and consulting firm, the company became involved in industrial control design and electrical engineering. The company was formed in 1975 and merged into Energy Control Contractors, Inc. Self Employed, then as Verandah Properties, then as Curtis E. Falany, LLC - Plant City, Florida - Engineer and Contractor - owned and operated a contracting firm that later grew into an electrical design-build company with a residential and light commercial general construction component. This company was often the construction and/or installation support for other business ventures. Presently involved in real estate to the present. James Linick and Associates, Consulting Engineers - Tampa, Florida - Chief Electrical Engineer - electrical lighting and power distribution design, data acquisition and control, process control system design and turn key construction. Purchased computer systems capabilities from James Linick and Associates and formed EGS Systems, Inc - early 1970s to School of Engineering, University of South Florida - Tampa, Florida - Adjunct Research Facility - nuclear magnetic resonance research and development, computer aided process control and signal recovery from noise - early 1970s. Advanced Development Laboratory, Honeywell Information Systems - Tampa, Florida - R&D Engineer - data communications research and development William J. Kessler and Associates, Consulting Engineers - Gainesville, Florida - Engineer - CURTIS E. FALANY, P.E. - Page 2 of 9 Last Update - September 19, 2014

3 telecommunications research and development PUBLICATIONS - LAST TEN YEARS Fall 2001 Damage to Utility Communications Infrastructure The Consultants Perspective, A Sugar Publication September 2003 Surety Technology and Intellectual Property Northeast Surety and Fidelity Claims Conference April 2004 March 2007 Summer 2007 Bond Claims in Cyberspace Southern Surety and Fidelity Claims Conference Portable Generators and Surge Protectors Can Make a Fiery Combination The Consultants Perspective, A Sugar Publication Determining Fault in Electrical Contact Injuries The Consultants Perspective, A Sugar Publication September 2007 The Case of the Knockoff Motor EC&M, Penton Media Inc., Overland Park, KS April 2011 A Heads Up' on Knock-offs, Copies, Counterfeits, And Chinese Copies Southern Surety and Fidelity Claims Conference REPRESENTATIVE CASES - SURETY Variable message signs and control systems for the Depressed Artery Big Dig Project in Boston, Massachusetts. Hospital fire alarm system for the Naval Hospital, Camp Lejeune, North Carolina. Sewage treatment plant control system including SCADA, employee dispatch, and capital equipment tracking, Camden, NJ. Computer aided dispatch system, all emergency services, Clearwater, FL. Secure communications infrastructure, Ft. Belvoir, VA. CURTIS E. FALANY, P.E. - Page 3 of 9 Last Update - September 19, 2014

4 REPRESENTATIVE CASES - PROPERTY AND CASUALTY Electrical Contact Death of workers moving scaffolding - contact with utility company power lines, Jennings, Florida. Injury of worker on roof directing crane - contact with utility company power lines, Miami, Florida. Death of welder s helper - electrical contact not related to utility company power lines, Houma, Louisiana. Death of swimmers - electrical contact not related to utility company power lines, Sarasota, Florida. Electrical Fires Fire of electrical cause and origin in mall electric service entrance, Queens, New York. Fire of electrical cause and origin in engine room of ocean going barge, Florida. Fire of electrical cause and origin in residence where drywall screw penetrated electric cable, Orlando, Florida. Facilities Damage Damage to underground communication infrastructure where contractor drilling for pilings hit copper and fiber cable, Pensacola, Florida. Damage to underground communication infrastructure where contractor installing new service hit existing copper and fiber cable, Atlanta, Georgia. Damage to overhead communication infrastructure where automobile fire damaged fiber optic cable, Tampa, Florida. Lightning or Surge Damage Electrical, electronic, and computer systems, multiple locations, Florida. CURTIS E. FALANY, P.E. - Page 4 of 9 Last Update - September 19, 2014

5 EXPERT TESTIMONY AT TRIAL OR DEPOSITION September 5, Deposition Estate of Stephen W. Dohoney Et Al vs International Paper Company In the United States District Court, Western District of Kentucky at Owensboro Civil Action No. 4:10-CV-030-JHM-HBB Retained by Plaintiff August 18, Deposition Nephron Pharmaceuticals Corporation... vs Schaefer Systems International, Inc.... In the Circuit Court of the Ninth Judicial Circuit in and for Orange County, Florida Case no CA Retained by Plaintiff June 25, Deposition Certain Underwriters at Lloyds Insurance Company... vs Florida Power and Light Company In the Circuit Court of the 11th Judicial Circuit in and for Miami-Dade County, Florida Case # CA 24 Retained by FPL October 17, 2013 Deposition Orlando Martinez and Emma Martinez, his wife vs. Florida Power and Light Company, Comcast of South Florida I, Inc., and Bellsouth Telecommunications, Inc., d/b/a AT&T Florida and Miami-Dade County. In the Circuit Court of the 11th Judicial Circuit in and for Dade County, Florida, General Jurisdiction Division. Case # CA 08 Retained by FPL CURTIS E. FALANY, P.E. - Page 5 of 9 Last Update - September 19, 2014

6 August 6, 2013 Deposition Taylor Woodrow... vs. Buckeye Plumbing and Traylor Electric American Arbitration Association, Construction Industry Arbitration Rules Case # Retained by Sivyer, Barlow, & Watson, PA July 25, 2013 Deposition Mendoza vs. Heller Bros Packing Corp. In The Circuit Court Of The 20th Judicial Circuit In And For Collier County, Florida Case No.: 12-CA-4209 Retained by FCCI Insurance Group April 21, Deposition Joshua Cortez v. Florida Power and Light Company In The Circuit Court of the Seventeenth Judicial Circuit, In and For Broward County, Florida Circuit Civil Division Case No CACE 12 December 4, 2012 Deposition Shirley Jean Garey, as Personal Representative of the estate of Margaret Kerce, Deceased v. Westwind Development 41, LLC and Contemporary Management Concepts, LLP. Circuit Court of the 8th Judicial Circuit in and for Alachua County, Florida. Case # 2011-CA-2910 CURTIS E. FALANY, P.E. - Page 6 of 9 Last Update - September 19, 2014

7 October 5, Deposition Kelly A. Alvarez - Individually and as Administratrix of the Estate of Angel L. Alvarez, Jr. v. CSX Corporation, Inc. Transportation, Inc. As the Principal operating company thereof, Transflo Terminal Services, Inc. As wholly owned subsidiary of CSX Corp. And CSX Intermodal Terminals, Inc. As a legal entity CSX Intermodal, Inc. and Savage Services Corporation. United States District Court Northern District of Indiana Hammond Division-Indianapolis, Indiana Case # 2:10-cv PRC February 2, Deposition Fire Insurance Exchange a/s/o Christine Kelly v. Presley and Sons Electric Service, Inc. Circuit Court of Mobile County, Alabama Case # CV November 28, Deposition Chase Peysen vs Alliance PJRT Limited Partnership et al Ninth Judicial Circuit Orange County, FL Case # 2008-CA ) March 2, Deposition Jeffrey Van Wormer vs REA Technologies, Inc. 3rd Judicial Circuit Columbia County, FL Case # CA CURTIS E. FALANY, P.E. - Page 7 of 9 Last Update - September 19, 2014

8 September 3, Deposition Jeffrey Van Wormer vs REA Technologies, Inc. 3rd Judicial Circuit Columbia County, FL Case # CA March 2, Trial Estate of Villeda vs Asplundh & Florida Power & Light Company 11th Judicial Circuit - Case # CA 27 Miami-Dade County, FL March 12, Deposition Estate of Villeda vs Asplundh & Florida Power & Light Company 11th Judicial Circuit Miami-Dade County, FL Case # CA 27 May 2, Deposition Francisco Velasco-Reyes vs Flint & Doyle, Inc. 20th Judicial Circuit Lee County, FL Case # 05-CA-2580 June 13, Deposition Centex Construction, LLC vs Acstar Insurance Company & Accutronics Datacom, Inc. U. S. District Court for the Eastern District of Virginia Alexandria Division - Tidewater, VA Civil No. 1:06cv54 JCC/LO CURTIS E. FALANY, P.E. - Page 8 of 9 Last Update - September 19, 2014

9 May 4, Deposition Kopinetz vs NCS Electric, Inc. 12th Judicial Circuit Manatee County, FL May 14, Deposition Fisher vs Florida Power & Light 11th Judicial Circuit Miami-Dade County, FL February 11, Trial Art Lowe vs Saks Fifth Avenue, Inc 15th Judicial Circuit Palm Beach County, FL January 22, Deposition Art Lowe vs Saks Fifth Avenue, Inc. 15th Judicial Circuit Palm Beach County, FL CURTIS E. FALANY, P.E. - Page 9 of 9 Last Update - September 19, 2014