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Filing # 128192800 E-Filed 06/07/2021 09:47:39 AM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT IN AND FOR MARION
COUNTY, FLORIDA
CASE NUMBER: 2019-CA-2760
MARSHA SUE PIDHERNEY,
Plaintiff,
VS.
MARION COUNTY, FLORIDA, a political
subdivision of the State of Florida,
Defendant.
PLAINTIFF’S EXPERT WITNESS DISCLOSURE
COMES NOW, the Plaintiff, MARSHA SUE PIDHERNEY, by and through the
undersigned attorneys and pursuant to the Court’s Order Scheduling Pretrial Conference and
Trial dated April 22, 2021, hereby submits her expert witness disclosure as follows:
1. Raymond Dominick, MD
8404 US Hwy 441
Leesburg, FL 34788
Dr. Raymond Dominick is an internal medicine physician that treated the Plaintiff. She
will testify as to the Plaintiff's injuries, treatment, care, damages and causation.
2. Amit Varma, MD
Florida Sports Injury & Orthopedic Institute
1925 Don Wickham Drive
Clermont, FL 34711
Dr. Amit Varma is a board certified orthopedic surgeon that treated the Plaintiff. She
will testify as to the Plaintiff's injuries, treatment, care, damages and causation.
3. Joseph Morreale, DC
32749 Radio Road
Leesburg, FL 34788
Electronically Filed Marion Case # 19CA002760AX 06/07/2021 09:47:39 AM10.
Dr. Joseph Morreale is a chiropractor that treated the Plaintiff. He will testify as to the
Plaintiff's injuries, treatment, care, damages and causation.
Sean M. Mahan, M.D.
EliteRad Radiology Services
5840 Red Bug Lake Road, Suite 185
Winter Springs, FL 32708
Dr. Sean M. Mahan is a board certified radiologist that treated the Plaintiff. He will
testify as to the Plaintiffs injuries, treatment, care, damages and causation.
Joseph J. Kavanagh, M.D.
EliteRad Radiology Services
5840 Red Bug Lake Road, Suite 185
Winter Springs, FL 32708
Dr. Joseph J. Kavanagh is a board certified radiologist that treated the Plaintiff. He will
testify as to the Plaintiff’s injuries, treatment, care, damages and causation
Avery J. Knapp, Jr., M.D.
EliteRad Radiology Services
5840 Red Bug Lake Road, Suite 185
Winter Springs, FL 32708
Dr. Avery J. Knapp, Jr., is a board certified radiologist that treated the Plaintiff. He will
testify as to the Plaintiff's injuries, treatment, care, damages and causation.
Reginald James Davis, MD
BioSpine Institute
4211 W. Boy Scout Blvd., Suite 400
Tampa, FL 33607
Dr. Reginald James Davis is a board certified neurosurgeon that treated the Plaintiff. He
will testify as to the Plaintiff’s injuries, treatment, care, damages and causation.
Any and all records custodians, treating physicians and/or physical therapists who have
examined, treated or rendered therapeutic or medical services to Plaintiff who have not
been named previously
All experts witnesses, who due to the nature of the continuing discovery, may hereafter
be retained in anticipation of giving expert testimony at trial, subject to prompt and
timely disclosure to Defendants.
Any and all treating physicians and/or physical therapists who have examined, treated or
rendered therapeutic or medical services to Plaintiff not previously named.11. Any expert witness listed on other parties’ expert witness disclosure and/or any expert
referred to in any interrogatory, records produced, depositions, requests for admissions,
or any other document produced in this cause.
12. Any and all experts necessary for rebuttal purposes.
13. Plaintiff reserves the right to amend the Expert Witness Disclosure in accordance with
the rules of the Court.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 7, 2021, I electronically filed the foregoing with the
Clerk of the Courts by using the ECF system which will send a notice of electronic filing to the
following: Matthew G. Minter, Esquire (matthew.minter@marioncountyfl.org;
Donnita.martin@marioncountyfl.org).
/s/ D. Graham Anderson
D. Graham Anderson, Esq.
Florida Bar No.: 62443
Bogin, Munns & Munns, P.A.
1390 N. Hancock Road, Suite 201
Clermont, FL 34711
(352)243-8981
Attorney for Plaintiff
ganderson@boginmunns.com
escherr@boginmunns.com
aquintana@boginmunns.com
bmmservice@boginmunns.com
1191363
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Filing # 128192800 E-Filed 06/07/2021 09:47:39 AM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR MARION COUNTY, FLORIDA CASE NUMBER: 2019-CA-2760 MARSHA SUE PIDHERNEY, Plaintiff, VS. MARION COUNTY, FLORIDA, a political subdivision of the State of Florida, Defendant. PLAINTIFF’S EXPERT WITNESS DISCLOSURE COMES NOW, the Plaintiff, MARSHA SUE PIDHERNEY, by and through the undersigned attorneys and pursuant to the Court’s Order Scheduling Pretrial Conference and Trial dated April 22, 2021, hereby submits her expert witness disclosure as follows: 1. Raymond Dominick, MD 8404 US Hwy 441 Leesburg, FL 34788 Dr. Raymond Dominick is an internal medicine physician that treated the Plaintiff. She will testify as to the Plaintiff's injuries, treatment, care, damages and causation. 2. Amit Varma, MD Florida Sports Injury & Orthopedic Institute 1925 Don Wickham Drive Clermont, FL 34711 Dr. Amit Varma is a board certified orthopedic surgeon that treated the Plaintiff. She will testify as to the Plaintiff's injuries, treatment, care, damages and causation. 3. Joseph Morreale, DC 32749 Radio Road Leesburg, FL 34788 Electronically Filed Marion Case # 19CA002760AX 06/07/2021 09:47:39 AM10. Dr. Joseph Morreale is a chiropractor that treated the Plaintiff. He will testify as to the Plaintiff's injuries, treatment, care, damages and causation. Sean M. Mahan, M.D. EliteRad Radiology Services 5840 Red Bug Lake Road, Suite 185 Winter Springs, FL 32708 Dr. Sean M. Mahan is a board certified radiologist that treated the Plaintiff. He will testify as to the Plaintiffs injuries, treatment, care, damages and causation. Joseph J. Kavanagh, M.D. EliteRad Radiology Services 5840 Red Bug Lake Road, Suite 185 Winter Springs, FL 32708 Dr. Joseph J. Kavanagh is a board certified radiologist that treated the Plaintiff. He will testify as to the Plaintiff’s injuries, treatment, care, damages and causation Avery J. Knapp, Jr., M.D. EliteRad Radiology Services 5840 Red Bug Lake Road, Suite 185 Winter Springs, FL 32708 Dr. Avery J. Knapp, Jr., is a board certified radiologist that treated the Plaintiff. He will testify as to the Plaintiff's injuries, treatment, care, damages and causation. Reginald James Davis, MD BioSpine Institute 4211 W. Boy Scout Blvd., Suite 400 Tampa, FL 33607 Dr. Reginald James Davis is a board certified neurosurgeon that treated the Plaintiff. He will testify as to the Plaintiff’s injuries, treatment, care, damages and causation. Any and all records custodians, treating physicians and/or physical therapists who have examined, treated or rendered therapeutic or medical services to Plaintiff who have not been named previously All experts witnesses, who due to the nature of the continuing discovery, may hereafter be retained in anticipation of giving expert testimony at trial, subject to prompt and timely disclosure to Defendants. Any and all treating physicians and/or physical therapists who have examined, treated or rendered therapeutic or medical services to Plaintiff not previously named.11. Any expert witness listed on other parties’ expert witness disclosure and/or any expert referred to in any interrogatory, records produced, depositions, requests for admissions, or any other document produced in this cause. 12. Any and all experts necessary for rebuttal purposes. 13. Plaintiff reserves the right to amend the Expert Witness Disclosure in accordance with the rules of the Court. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 7, 2021, I electronically filed the foregoing with the Clerk of the Courts by using the ECF system which will send a notice of electronic filing to the following: Matthew G. Minter, Esquire (matthew.minter@marioncountyfl.org; Donnita.martin@marioncountyfl.org). /s/ D. Graham Anderson D. Graham Anderson, Esq. Florida Bar No.: 62443 Bogin, Munns & Munns, P.A. 1390 N. Hancock Road, Suite 201 Clermont, FL 34711 (352)243-8981 Attorney for Plaintiff ganderson@boginmunns.com escherr@boginmunns.com aquintana@boginmunns.com bmmservice@boginmunns.com 1191363