Preview
Filing# 144355466 E-Filed 02/22/2022 11:36:49 AM
IN THE CIRCUIT COURT OF THE ,th
17'
DISTRICT IN AND FOR BROWARD
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO:
CACE-20-017319
LUIS MORENO and MARY BEATRICE
RAMOS, a married couple,
Plaintiffs,
VS.
BANTA PROPERTIES, INC., a Florida Profit
Corporation,and COLONIAL PARK
APARTMENTS, LLC, a Florida Limited Liability
Company,
Defendants.
i
PLAINTIFF'S AMENDED EXPERT WITNESS LIST
The Plaintiff by and through his undersigned counsel, files this Amended Expert Witness
List in accordance with the Court's Trial Order as follows:
I.
EXPERT WITNESSES:
1.
Ronald F. Zollo, Ph.D, P.E.
EngineeringAnalytics,Inc.
2455 NW 27th Avenue, Suite 230
Miami, Florida 33145
Professor Zollo is a Professional Engineer and an expert in the area of Civil
Architectural and Environmental Engineering who is expected to testifyconcerningthe
mechanics of the underlyingaccident,the negligenceof the defendant and all of his
opinions related thereto. As grounds for his opinions Professor Zollo will relyupon his
education trainingand experience,his review of all documents, photographs, video,
depositions,records, his inspectionof the premises and materials produced in this
litigation.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/22/2022 11:36:49 AM.****
2.
Dr. Steven Hamburg
Affiliated Healthcare Center
9091 Pembroke Road
Pembroke Pines,FL 33025
Dr. Hamburg is a chiropractor.He is expected to testifyas to his care and treatment
ofthe Plaintiffas well as all ofhis opinionsrelated to Plaintiff's complaintsand their causal
relationshipto the subjectincident.
This expert is also expected to testifyas to the
permanency of any allegedinjuriesand the reasonableness and necessityofpast and future
medical services and bills generatedby all health care providers.As grounds for these
opinions,this expert will relyin whole or in part upon his examinations and treatment of
the Plaintiff,review of medical records and diagnostictesting,his medical trainingand
experience,and authoritative medical treatises,
if applicable.He is expected to testifyas
to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of
Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the
reasonableness of the medical treatment Plaintiff received to treat such damages, the
reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs
ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff
to treat such damages, and the reasonableness of the costs associated with the future
medical needs of Plaintiffto treat such damages.
3
Dr. Thomas Riley
Affiliated Healthcare Center
8000 SW 67thAve.
Miami, FL 33043
Dr. Rileyis a board-certified orthopedicsurgeon. He is expectedto testify
as to his
care and treatment of the Plaintiff as well as all of his opinions related to Plaintiff's
complaintsand their causal relationship
to the subjectincident. This expert is also expected
to testifyas to the permanency of any allegedinjuriesand the reasonableness and necessity
of past and future medical services and bills generated by all health care providers.As
grounds for these opinions,this expert will relyin whole or in part upon his examinations
and treatment ofthe Plaintiff,
review ofmedical records and diagnostictesting,
his medical
trainingand experience,and authoritative medical treatises,
if applicable.He is expected
to testifyas to the Plaintiff's damages, the causation ofPlaintiff's damages, the permanency
of Plaintiff' s damages, the medical treatment Plaintiff received to treat such damages, the
reasonableness of the medical treatment Plaintiff received to treat such damages, the
reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs
ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff
to treat such damages, and the reasonableness of the costs associated with the future
medical needs of Plaintiffto treat such damages
4.
Aimee Minguez, A.R.N.P.
Affiliated Healthcare Center
8000 SW 67thAve.
Miami, FL 33143
2
Nurse Minguez is a nurse practitioner.
She is expectedto testifyas to her care and
treatment of the Plaintiff as well as all of her opinionsrelated to Plaintiff's complaintsand
their causal relationship
to the subjectincident. This expert is also expectedto testifyas to
the permanency of any allegedinjuriesand the reasonableness and necessityof past and
future medical services and bills generated by all health care providers.As grounds for
these opinions,this expert will relyin whole or in part upon her examinations and treatment
of the Plaintiff,
review of medical records and diagnostictesting,
her medical trainingand
experience,and authoritative medical treatises,
if applicable.She is expectedto testifyas
to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of
Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the
reasonableness of the medical treatment Plaintiff received to treat such damages, the
reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs
ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff
to treat such damages, and the reasonableness of the costs associated with the future
medical needs of Plaintiffto treat such damages.
5.
Dr. Jose Marquez
Affiliated Healthcare Center
8000 SW 67th Ave.
Miami, FL 33143
Dr. Marquez is a neurologist.
He is expectedto testifyas to his care and treatment
ofthe Plaintiffas well as all ofhis opinionsrelated to Plaintiff's complaintsand their causal
relationshipto the subjectincident.
This expert is also expected to testifyas to the
permanency of any allegedinjuriesand the reasonableness and necessityofpast and future
medical services and bills generated by all health care providers.As grounds for these
opinions,this expert will relyin whole or in part upon his examinations and treatment of
the Plaintiff,
review of medical records and diagnostictesting,
his medical trainingand
experience,and authoritative medical treatises,
if applicable.He is expectedto testifyas
to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of
Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the
reasonableness of the medical treatment Plaintiff received to treat such damages, the
reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs
ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff
to treat such damages, and the reasonableness of the costs associated with the future
medical needs of Plaintiffto treat such damages.
6.
Sean N. Mahan, M.D.
AHC Diagnostic& Imaging Services
8000 SW 67thAve.
Miami, FL 33143
Dr. Mahan is a radiologist.
He is expectedto testifyas to his care and treatment of
the Plaintiff and review of her diagnosticstudies as well as all of his opinionsrelated to
Plaintiff's complaintsand their causal relationship
to the subjectincident. This expert is
also expectedto testifyas to the permanency of any allegedinjuries
and the reasonableness
and necessityof past and future medical services and bills generated by all health care
3
providers.As grounds for these opinions,this expert will relyin whole or in part upon his
examinations and treatment of the Plaintiff,review of medical records and diagnostic
testing,his medical training and experience, and authoritative medical treatises,if
applicable. He is expected to testifyas to the Plaintiff's damages, the causation of
Plaintiff's damages, the permanency ofPlaintiff's damages, the medical treatment Plaintiff
received to treat such damages, the reasonableness of the medical treatment Plaintiff
received to treat such damages, the reasonableness for the bills incurred by Plaintiff for
such treatment, future medical needs of Plaintiff for such damages, the costs associated
with the future medical needs of Plaintiffto treat such damages, and the reasonableness of
the costs associated with the future medical needs of Plaintiff to treat such damages.
7.
Ronald Roskin, M.D.
AHC Diagnostic& Imaging Services
8000 SW 67th Ave.
Miami, FL 33143
Dr. Roskin is a radiologist.
He is expectedto testifyas to his care and treatment of
the Plaintiff and review of her diagnosticstudies as well as all of his opinionsrelated to
Plaintiff's complaints and their causal relationshipto the subjectincident. This expert is
also expectedto testifyas to the permanency of any allegedinjuries
and the reasonableness
and necessityof past and future medical services and bills generatedby all health care
providers.As grounds for these opinions,this expert will relyin whole or in part upon his
examinations and treatment of the Plaintiff,review of medical records and diagnostic
testing,his medical trainingand experience,and authoritative medical treatises,if
applicable. He is expected to testifyas to the Plaintiff's damages, the causation of
Plaintiff's damages, the permanency ofPlaintiff's damages, the medical treatment Plaintiff
received to treat such damages, the reasonableness of the medical treatment Plaintiff
received to treat such damages, the reasonableness for the bills incurred by Plaintiff for
such treatment, future medical needs of Plaintiff for such damages, the costs associated
with the future medical needs of Plaintiffto treat such damages, and the reasonableness of
the costs associated with the future medical needs of Plaintiff to treat such damages.
8.
BrittanyChong, D.C.
Path Medical
8138 W. Broward Blvd.
Plantation,FL 33324
Dr. Chong is a chiropractor.
She is expectedto testifyas to her care and treatment
ofthe Plaintiffas well as all ofher opinionsrelated to Plaintiff's complaintsand their causal
relationshipto the subjectincident.
This expert is also expected to testifyas to the
permanency of any allegedinjuries
and the reasonableness and necessityofpastand future
medical services and bills generated by all health care providers.As grounds for these
opinions,this expert will relyin whole or in part upon her examinations and treatment of
the Plaintiff,
review of medical records and diagnostictesting,
her medical trainingand
experience,and authoritative medical treatises,
if applicable.She is expected to testifyas
to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of
Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the
reasonableness of the medical treatment Plaintiff received to treat such damages, the
4
reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs
ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff
to treat such damages, and the reasonableness of the costs associated with the future
medical needs of Plaintiffto treat such damages.
9-
Kieron Parchment, D.C.
Path Medical
8138 W. Broward Blvd.
Plantation,FL 33324
Dr. Parchment is a chiropractor.She is expected to testifyas to her care and
treatment ofthe Plaintiff as well as all ofher opinionsrelated to Plaintiff's complaintsand
their causal relationshipto the subjectincident. This expert is also expected to testifyas to
the permanency of any allegedinjuriesand the reasonableness and necessityof past and
future medical services and bills generatedby all health care providers.As grounds for
these opinions,this expert will relyin whole or in part upon her examinations and treatment
of the Plaintiff,
review of medical records and diagnostictesting,
her medical trainingand
experience,and authoritative medical treatises,
if applicable.She is expectedto testifyas
to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of
Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the
reasonableness of the medical treatment Plaintiff received to treat such damages, the
reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs
ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff
to treat such damages, and the reasonableness of the costs associated with the future
medical needs of Plaintiffto treat such damages.
10.
Tie Qian, M.D.
Path Medical
8138 W. Broward Blvd.
Plantation,FL 33324
Dr. Qian is board certified in PhysicalMedicine & Rehabilitation. He is expected
to testifyas to his care and treatment ofthe Plaintiff as well as all ofhis opinionsrelated to
Plaintiff's complaintsand their causal relationship
to the subjectincident. This expert is
also expectedto testifyas to the permanency of any allegedinjuriesand the reasonableness
and necessityof past and future medical services and bills generated by all health care
providers.As grounds for these opinions,this expert will relyin whole or in part upon his
examinations and treatment of the Plaintiff,review of medical records and diagnostic
testing,his medical trainingand experience,and authoritative medical treatises,if
applicable. He is expected to testifyas to the Plaintiff's damages, the causation of
Plaintiff's damages, the permanency ofPlaintiff's damages, the medical treatment Plaintiff
received to treat such damages, the reasonableness of the medical treatment Plaintiff
received to treat such damages, the reasonableness for the bills incurred by Plaintiff for
such treatment, future medical needs of Plaintiff for such damages, the costs associated
with the future medical needs of Plaintiffto treat such damages, and the reasonableness of
the costs associated with the future medical needs of Plaintiffto treat such damages.
5
11.
Dr. Roger Ramos
Path Medical- Tamarac MRI
4255 W. Commercial Blvd.
Tamarac, FL 33119
Dr. Ramos is a radiologist.
He is expectedto testifyas to his care and treatment of
the Plaintiff and review of her diagnosticstudies as well as all of his opinions related to
Plaintiff's complaintsand their causal relationship
to the subjectincident. This expert is
also expectedto testifyas to the permanency of any allegedinjuriesand the reasonableness
and necessityof past and future medical services and bills generated by all health care
providers.As grounds for these opinions,this expert will relyin whole or in part upon his
examinations and treatment of the Plaintiff,review of medical records and diagnostic
testing,his medical training and experience, and authoritative medical treatises,if
applicable. He is expected to testifyas to the Plaintiff's damages, the causation of
Plaintiff's damages, the permanency ofPlaintiff's damages, the medical treatment Plaintiff
received to treat such damages, the reasonableness of the medical treatment Plaintiff
received to treat such damages, the reasonableness for the bills incurred by Plaintiff for
such treatment, future medical needs of Plaintiff for such damages, the costs associated
with the future medical needs of Plaintiffto treat such damages, and the reasonableness of
the costs associated with the future medical needs of Plaintiffto treat such damages.
12.
Brandon Faza, M.D.
Holy Cross Hospital
4725 N. Federal Highway
Ft. Lauderdale, FL 33308
Dr. Faza is plaintiff'
s emergency treatingphysician.He is expected to testifyas to
his care and treatment of the Plaintiff and review of her diagnosticstudies as well as all of
his opinionsrelated to Plaintiff's complaints and their causal relationshipto the subject
incident. This expert is also expectedto testify
as to the permanency of any allegedinjuries
and the reasonableness and necessityofpastand future medical services and bills generated
by all health care providers.As grounds for these opinions,this expert will relyin whole
or in part upon his examinations and treatment of the Plaintiff,
review of medical records
and diagnostictesting,his medical trainingand experience,and authoritative medical
treatises,
if applicable.He is expectedto testify
as to the Plaintiff's damages, the causation
of Plaintiff' s damages, the permanency of Plaintiff's damages, the medical treatment
Plaintiff received to treat such damages, the reasonableness of the medical treatment
Plaintiff received to treat such damages, the reasonableness for the bills incurred by
Plaintiff for such treatment, future medical needs of Plaintiff for such damages, the costs
associated with the future medical needs of Plaintiff to treat such damages, and the
reasonableness of the costs associated with the future medical needs of Plaintiff to treat
such damages
13.
Dr. Robert Ludwig
9260 Sunset Drive
Suite 201
Miami, FL 33173
6
Dr. Ludwig is a treatingpsychologist.He is expectedto testifyas to his care and
treatment of the Plaintiff includingbut not limited to Plaintiff's psychologicalcare,
neuropsychologicaltesting,future treatment needs, treatment, as well his opinionsrelated
to the Plaintiff's complaints and their causal relationshipto the subjectincident. This
expert is also expected to testifyas to the permanency of any allegeddamages and the
reasonableness and necessityof past and future medical services generatedby the health
care provider.As grounds for these opinions,this expert will relyin whole or in part upon
his review of medical records of Plaintiff,
diagnostictesting,
treatment of the Plaintiff and
his medical trainingand experience,and authoritative treatises,
if applicable.
14.
The plaintiff
may call as an expert witness, any and all persons who have been deposed
or noticed for deposition.
15.
The plaintiffmay call any and all expert witnesses listed on any expert witness list,
witness list and/or Pre-trial Catalogs filed in this matter, and any and all addenda and
supplementsthereto.
16.
The plaintifffurther advises counsel of record that he reserves the rightto call any and
all treatingphysiciansas expert witnesses at the time of trial.
17.
All witnesses listed on expert witness lists submitted by any other party.
18.
Plaintiff reserves the rightto amend or supplement this expert witness list as necessary
due to continuingdiscovery.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true copy ofthe above and foregoingwas E-Filed and E-
Mailed this 22nd day of February 2022 to: Genevieve P. Rupelli,Esq. Cole, Scott & Kissane, P.A.
(Genevieve.rupelli@csklegal.com;
Annette.habersham@csklegal.com).
7
Respectfullysubmitted,
THE LAW FIRM OF STUART H. SHARE, P.A.
Attorneys for Plaintiff
1000 Brickell Avenue
Suite 600
Miami, Florida 33131
Telephone:
(305) 371-8700
Facsimile:
(305) 749-8573
E-Mail:
Stuart@sharelawpa.com
Josh@sharelawpa.com
Amanda@sharelawpa.com
BY /SI Bae.+04.&hu
STUART H. SHARE
Fla. Bar No.. 511579
8
Preview
Filing# 144355466 E-Filed 02/22/2022 11:36:49 AM IN THE CIRCUIT COURT OF THE ,th 17' DISTRICT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO: CACE-20-017319 LUIS MORENO and MARY BEATRICE RAMOS, a married couple, Plaintiffs, VS. BANTA PROPERTIES, INC., a Florida Profit Corporation,and COLONIAL PARK APARTMENTS, LLC, a Florida Limited Liability Company, Defendants. i PLAINTIFF'S AMENDED EXPERT WITNESS LIST The Plaintiff by and through his undersigned counsel, files this Amended Expert Witness List in accordance with the Court's Trial Order as follows: I. EXPERT WITNESSES: 1. Ronald F. Zollo, Ph.D, P.E. EngineeringAnalytics,Inc. 2455 NW 27th Avenue, Suite 230 Miami, Florida 33145 Professor Zollo is a Professional Engineer and an expert in the area of Civil Architectural and Environmental Engineering who is expected to testifyconcerningthe mechanics of the underlyingaccident,the negligenceof the defendant and all of his opinions related thereto. As grounds for his opinions Professor Zollo will relyupon his education trainingand experience,his review of all documents, photographs, video, depositions,records, his inspectionof the premises and materials produced in this litigation. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/22/2022 11:36:49 AM.**** 2. Dr. Steven Hamburg Affiliated Healthcare Center 9091 Pembroke Road Pembroke Pines,FL 33025 Dr. Hamburg is a chiropractor.He is expected to testifyas to his care and treatment ofthe Plaintiffas well as all ofhis opinionsrelated to Plaintiff's complaintsand their causal relationshipto the subjectincident. This expert is also expected to testifyas to the permanency of any allegedinjuriesand the reasonableness and necessityofpast and future medical services and bills generatedby all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon his examinations and treatment of the Plaintiff,review of medical records and diagnostictesting,his medical trainingand experience,and authoritative medical treatises, if applicable.He is expected to testifyas to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff to treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiffto treat such damages. 3 Dr. Thomas Riley Affiliated Healthcare Center 8000 SW 67thAve. Miami, FL 33043 Dr. Rileyis a board-certified orthopedicsurgeon. He is expectedto testify as to his care and treatment of the Plaintiff as well as all of his opinions related to Plaintiff's complaintsand their causal relationship to the subjectincident. This expert is also expected to testifyas to the permanency of any allegedinjuriesand the reasonableness and necessity of past and future medical services and bills generated by all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon his examinations and treatment ofthe Plaintiff, review ofmedical records and diagnostictesting, his medical trainingand experience,and authoritative medical treatises, if applicable.He is expected to testifyas to the Plaintiff's damages, the causation ofPlaintiff's damages, the permanency of Plaintiff' s damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff to treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiffto treat such damages 4. Aimee Minguez, A.R.N.P. Affiliated Healthcare Center 8000 SW 67thAve. Miami, FL 33143 2 Nurse Minguez is a nurse practitioner. She is expectedto testifyas to her care and treatment of the Plaintiff as well as all of her opinionsrelated to Plaintiff's complaintsand their causal relationship to the subjectincident. This expert is also expectedto testifyas to the permanency of any allegedinjuriesand the reasonableness and necessityof past and future medical services and bills generated by all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon her examinations and treatment of the Plaintiff, review of medical records and diagnostictesting, her medical trainingand experience,and authoritative medical treatises, if applicable.She is expectedto testifyas to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff to treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiffto treat such damages. 5. Dr. Jose Marquez Affiliated Healthcare Center 8000 SW 67th Ave. Miami, FL 33143 Dr. Marquez is a neurologist. He is expectedto testifyas to his care and treatment ofthe Plaintiffas well as all ofhis opinionsrelated to Plaintiff's complaintsand their causal relationshipto the subjectincident. This expert is also expected to testifyas to the permanency of any allegedinjuriesand the reasonableness and necessityofpast and future medical services and bills generated by all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon his examinations and treatment of the Plaintiff, review of medical records and diagnostictesting, his medical trainingand experience,and authoritative medical treatises, if applicable.He is expectedto testifyas to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff to treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiffto treat such damages. 6. Sean N. Mahan, M.D. AHC Diagnostic& Imaging Services 8000 SW 67thAve. Miami, FL 33143 Dr. Mahan is a radiologist. He is expectedto testifyas to his care and treatment of the Plaintiff and review of her diagnosticstudies as well as all of his opinionsrelated to Plaintiff's complaintsand their causal relationship to the subjectincident. This expert is also expectedto testifyas to the permanency of any allegedinjuries and the reasonableness and necessityof past and future medical services and bills generated by all health care 3 providers.As grounds for these opinions,this expert will relyin whole or in part upon his examinations and treatment of the Plaintiff,review of medical records and diagnostic testing,his medical training and experience, and authoritative medical treatises,if applicable. He is expected to testifyas to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency ofPlaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs of Plaintiff for such damages, the costs associated with the future medical needs of Plaintiffto treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiff to treat such damages. 7. Ronald Roskin, M.D. AHC Diagnostic& Imaging Services 8000 SW 67th Ave. Miami, FL 33143 Dr. Roskin is a radiologist. He is expectedto testifyas to his care and treatment of the Plaintiff and review of her diagnosticstudies as well as all of his opinionsrelated to Plaintiff's complaints and their causal relationshipto the subjectincident. This expert is also expectedto testifyas to the permanency of any allegedinjuries and the reasonableness and necessityof past and future medical services and bills generatedby all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon his examinations and treatment of the Plaintiff,review of medical records and diagnostic testing,his medical trainingand experience,and authoritative medical treatises,if applicable. He is expected to testifyas to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency ofPlaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs of Plaintiff for such damages, the costs associated with the future medical needs of Plaintiffto treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiff to treat such damages. 8. BrittanyChong, D.C. Path Medical 8138 W. Broward Blvd. Plantation,FL 33324 Dr. Chong is a chiropractor. She is expectedto testifyas to her care and treatment ofthe Plaintiffas well as all ofher opinionsrelated to Plaintiff's complaintsand their causal relationshipto the subjectincident. This expert is also expected to testifyas to the permanency of any allegedinjuries and the reasonableness and necessityofpastand future medical services and bills generated by all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon her examinations and treatment of the Plaintiff, review of medical records and diagnostictesting, her medical trainingand experience,and authoritative medical treatises, if applicable.She is expected to testifyas to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the 4 reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff to treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiffto treat such damages. 9- Kieron Parchment, D.C. Path Medical 8138 W. Broward Blvd. Plantation,FL 33324 Dr. Parchment is a chiropractor.She is expected to testifyas to her care and treatment ofthe Plaintiff as well as all ofher opinionsrelated to Plaintiff's complaintsand their causal relationshipto the subjectincident. This expert is also expected to testifyas to the permanency of any allegedinjuriesand the reasonableness and necessityof past and future medical services and bills generatedby all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon her examinations and treatment of the Plaintiff, review of medical records and diagnostictesting, her medical trainingand experience,and authoritative medical treatises, if applicable.She is expectedto testifyas to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency of Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs ofPlaintiff for such damages, the costs associated with the future medical needs ofPlaintiff to treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiffto treat such damages. 10. Tie Qian, M.D. Path Medical 8138 W. Broward Blvd. Plantation,FL 33324 Dr. Qian is board certified in PhysicalMedicine & Rehabilitation. He is expected to testifyas to his care and treatment ofthe Plaintiff as well as all ofhis opinionsrelated to Plaintiff's complaintsand their causal relationship to the subjectincident. This expert is also expectedto testifyas to the permanency of any allegedinjuriesand the reasonableness and necessityof past and future medical services and bills generated by all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon his examinations and treatment of the Plaintiff,review of medical records and diagnostic testing,his medical trainingand experience,and authoritative medical treatises,if applicable. He is expected to testifyas to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency ofPlaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs of Plaintiff for such damages, the costs associated with the future medical needs of Plaintiffto treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiffto treat such damages. 5 11. Dr. Roger Ramos Path Medical- Tamarac MRI 4255 W. Commercial Blvd. Tamarac, FL 33119 Dr. Ramos is a radiologist. He is expectedto testifyas to his care and treatment of the Plaintiff and review of her diagnosticstudies as well as all of his opinions related to Plaintiff's complaintsand their causal relationship to the subjectincident. This expert is also expectedto testifyas to the permanency of any allegedinjuriesand the reasonableness and necessityof past and future medical services and bills generated by all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon his examinations and treatment of the Plaintiff,review of medical records and diagnostic testing,his medical training and experience, and authoritative medical treatises,if applicable. He is expected to testifyas to the Plaintiff's damages, the causation of Plaintiff's damages, the permanency ofPlaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs of Plaintiff for such damages, the costs associated with the future medical needs of Plaintiffto treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiffto treat such damages. 12. Brandon Faza, M.D. Holy Cross Hospital 4725 N. Federal Highway Ft. Lauderdale, FL 33308 Dr. Faza is plaintiff' s emergency treatingphysician.He is expected to testifyas to his care and treatment of the Plaintiff and review of her diagnosticstudies as well as all of his opinionsrelated to Plaintiff's complaints and their causal relationshipto the subject incident. This expert is also expectedto testify as to the permanency of any allegedinjuries and the reasonableness and necessityofpastand future medical services and bills generated by all health care providers.As grounds for these opinions,this expert will relyin whole or in part upon his examinations and treatment of the Plaintiff, review of medical records and diagnostictesting,his medical trainingand experience,and authoritative medical treatises, if applicable.He is expectedto testify as to the Plaintiff's damages, the causation of Plaintiff' s damages, the permanency of Plaintiff's damages, the medical treatment Plaintiff received to treat such damages, the reasonableness of the medical treatment Plaintiff received to treat such damages, the reasonableness for the bills incurred by Plaintiff for such treatment, future medical needs of Plaintiff for such damages, the costs associated with the future medical needs of Plaintiff to treat such damages, and the reasonableness of the costs associated with the future medical needs of Plaintiff to treat such damages 13. Dr. Robert Ludwig 9260 Sunset Drive Suite 201 Miami, FL 33173 6 Dr. Ludwig is a treatingpsychologist.He is expectedto testifyas to his care and treatment of the Plaintiff includingbut not limited to Plaintiff's psychologicalcare, neuropsychologicaltesting,future treatment needs, treatment, as well his opinionsrelated to the Plaintiff's complaints and their causal relationshipto the subjectincident. This expert is also expected to testifyas to the permanency of any allegeddamages and the reasonableness and necessityof past and future medical services generatedby the health care provider.As grounds for these opinions,this expert will relyin whole or in part upon his review of medical records of Plaintiff, diagnostictesting, treatment of the Plaintiff and his medical trainingand experience,and authoritative treatises, if applicable. 14. The plaintiff may call as an expert witness, any and all persons who have been deposed or noticed for deposition. 15. The plaintiffmay call any and all expert witnesses listed on any expert witness list, witness list and/or Pre-trial Catalogs filed in this matter, and any and all addenda and supplementsthereto. 16. The plaintifffurther advises counsel of record that he reserves the rightto call any and all treatingphysiciansas expert witnesses at the time of trial. 17. All witnesses listed on expert witness lists submitted by any other party. 18. Plaintiff reserves the rightto amend or supplement this expert witness list as necessary due to continuingdiscovery. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true copy ofthe above and foregoingwas E-Filed and E- Mailed this 22nd day of February 2022 to: Genevieve P. Rupelli,Esq. Cole, Scott & Kissane, P.A. (Genevieve.rupelli@csklegal.com; Annette.habersham@csklegal.com). 7 Respectfullysubmitted, THE LAW FIRM OF STUART H. SHARE, P.A. Attorneys for Plaintiff 1000 Brickell Avenue Suite 600 Miami, Florida 33131 Telephone: (305) 371-8700 Facsimile: (305) 749-8573 E-Mail: Stuart@sharelawpa.com Josh@sharelawpa.com Amanda@sharelawpa.com BY /SI Bae.+04.&hu STUART H. SHARE Fla. Bar No.. 511579 8