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Filing # 116909364 E-Filed 11/18/2020 04:10:41 PM
IN THE CIRCUIT COURT OF THE 11th
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
LAMAR MITCHELL,
CASE NO.: 2019-008931-CA-01
Plaintiff,
vs.
MIAMI-DADE COUNTY and GINLEY
LAWN SERVICE & LANDSCAPING,
INC., a Florida For Profit Corporation,
Defendants.
NOTICE OF SERVING DEFENDANT, GINLEY LAWN SERVICE &
LANDSCAPING, INC.’S FIRST SET OF EXPERT INTERROGATORIES TO
PLAINTIFF, LAMAR MITCHELL
Defendant, Ginley Lawn Service & Landscaping, Inc., (“Ginley” or
“Defendant”), by and through its undersigned counsel and pursuant to Rule 1.340 of
the Florida Rules of Civil Procedure hereby gives notice of propounding their First
Set of Expert Interrogatories to Plaintiff, Lamar Mitchell, (“Plaintiff”), to be
answered separately and fully in writing under oath with the time period prescribed
by law.
Date: November 18, 2020
Respectfully submitted,
/s/ Niva M. Harney-Hiller
Niva M. Harney-Hiller, Esq.
Florida Bar No. 31058
nharney@hamiltonmillerlaw.com
Reeba Hartley-Belle, Esq.
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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690
CASE NO.: 2019-008931-CA-01
Florida Bar Number: 117036
rhartleybelle@hamiltonmillerlaw.com
HAMILTON, MILLER & BIRTHISEL, LLP
150 Southeast Second Avenue, Suite 1200
Miami, Florida 33131
Telephone: (305) 379-3686
Facsimile: (305) 379-3690
Counsel for Defendant Ginley Lawn Service &
Landscaping, Inc.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 18, 2020 the foregoing document
is being filed with the Clerk of Court using the E-filing Portal and served on all
counsel of record or pro se parties identified on the below Service List either via
transmission of Notices of Electronic Filing generated by the E-filing Portal or in
some other authorized manner for those counsel or parties who are not authorized
to receive electronically via the E-filing Portal.
/s/ Niva M. Harney-Hiller
Niva M. Harney-Hiller, Esq.
SERVICE LIST
Andres Hermida, Esq. Daniel Frastai, Esq.
Florida Bar Number: 1010725 Florida Bar Number: 0666041
MORGAN & MORGAN, P.A. ABIGAIL PRICE-WILLIAMS
703 Waterford Way, Suite 1050 Stephen P. Clark Center
Miami, Florida 33126 111 Northwest First Street,
Telephone: (305) 929-1912 Suite 2810
Facsimile: (305) 929-1930 Miami, Florida 33128-1993
AHermida@forthepeople.com Telephone: (305) 375-5480
JJaime@forthepeople.com Facsimile: (305) 375-5634
Frastai@miamidade.gov
Counsel for Plaintiff Lamar Mitchell jeane.neal@miamidade.gov
Counsel for Defendant Miami-
Dade County
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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690
CASE NO.: 2019-008931-CA-01
Definitions
1. "Document(s)" or "written communication(s)" is used in the broad and liberal
sense and means written, typed, printed, recorded or graphic matter, however
produced or reproduced, of any kind and description, and whether an original,
master, duplicate or copy, including, but not limited to, accounts,
advertisements, agreements, appointment books, bank checks, bills, books,
books of account, bulletins, cablegrams, cancelled checks, cashier's checks,
catalogs, charts, check stubs, communications, computer printouts, contracts,
corporate records, correspondence, desk calendars, diaries, diary entries,
drawings, e-mail, graphic records, guarantees, inter-office communications,
intra-office communications, invoices, ledger books, letters, logs, mailgrams,
magazines, manuals, marginal notes (appearing on any document),
memoranda, minutes (e.g., board of directors, committee), models, motion
pictures, notations, notebooks, notes, offers, pamphlets, papers, photographs,
physical objects, plans, printed matter, projections, prospectuses, publications,
receipts, reports, returns, sketches, sound recordings (including, by way of
example, any type of personal or telephone conversation, meeting or
conference) specifications, statements, statistics, studies, summaries, surveys,
tape recordings, tapes, telegrams, telefaxes, teletypes, transcriptions
(including, by way of example, any type of personal or telephone conversation,
meeting or conference), transcripts, video tapes, vouchers, warranties, working
papers, worksheets; and all amendments, changes, drafts, modifications of any
of the foregoing, of which you have knowledge or which are now or were
formerly in your actual or constructive possession, custody or control. The
responses concerning documents requested shall include information regarding
whether such document is an original, a duplicate, or a copy thereof.
2. "Concern," "concerning," "evidencing," "regarding," "reflecting," "relates," or
"relates to" shall mean relating to, referring to, connected with, commenting
on, responding to, containing, evidencing, showing, memorializing, describing,
analyzing, comprising, or constituting.
3. "You" and "your" shall refer to and include your agents, attorneys, experts,
investigators, representatives and all others, whether past or present, who
have obtained information for or on behalf of you.
4. If a corporation, "you" and "your" shall refer to and include any of your
affiliates and subsidiaries, agents, associates, attorneys, directors, employees,
experts, independent contractors, representatives, servants, and all others,
whether past or present, who have obtained information for or on behalf of the
corporation.
5. The words "and" and "or" shall be construed conjunctively and disjunctively as
necessary to make the request inclusive rather than exclusive.
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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690
CASE NO.: 2019-008931-CA-01
6. "Identify," or "state the identity of":
(a) When used in reference to a natural person means to please state:
(1) His/her full name;
(2) Present or last known business and residence address;
(3) His/her present or last known occupation and position;
(4) His/her present or last known employer or business affiliation;
(5) His/her occupation or position at the time in question specified in the
particular request.
(b) When used in reference to a "document" means to please state:
(1) A description of the type of document (e.g., letter, memorandum,
telegram, etc.);
(2) The identity of the person or persons who authored or prepared it;
(3) In the case of an agreement or contract, the identity of the parties'
signatory;
(4) The identity of the addressee(s), if any, and the recipient(s) of the
original and a copy thereof;
(5) The title thereof, if any, and a description of the general nature of its
subject matter;
(6) The date of the document, or, if none, the approximate date of its
preparation;
(7) The manner of distribution and publication, if any;
(8) The present location or custodian of the original and each copy
thereof;
(9) The identity of any persons who can identify it;
(10) Whether such documents contained, enclosed, were attached to or
accompanied by any other documents, and if so, state the identity
thereof;
(11) If a privilege is claimed, the specific basis therefore.
(c) In lieu of identifying a particular document when such identification is
requested, a copy of such document may, at your option, be attached to the
response to these requests; provided that any specific information
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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690
CASE NO.: 2019-008931-CA-01
required pursuant to the foregoing definition which is not fully set forth
on the face of such copy of a document must be separately provided in
response to these requests.
7. "Person" shall mean any natural person, firm, corporation, partnership, joint
venture or any other form of business entity.
8. Masculine pronouns shall not connote any particular gender but shall be taken
to mean masculine, feminine or neutral gender, as the case may be.
9. "Date" shall mean the exact day, month, and year, if ascertainable, or, if not,
the best approximation thereof (including relationship to other events).
10. “Ginley,” as used herein, shall refer to GINLEY LAWN SERVICE &
LANDSCAPING, INC., its affiliates and subsidiaries, agents, associates,
attorneys, directors, employees, experts, independent contractors,
representatives, servants, and all others, whether past or present, who have
obtained information for or on behalf of the corporation.
11. "Incident," as used herein, shall refer to the incident which you allege to have
occurred, as is more fully set forth in your Amended Complaint.
12. "The subject matter of this lawsuit," as used herein, shall refer to all facts and
issues as set forth in your Amended Complaint.
13. "Medical condition," as used herein, shall refer to any condition, including but
not limited to, that for which you are making a claim, regardless of whether it
is a physical illness, disease or injury, mental illness, disease or injury or
aggravation of a preexisting condition.
14. "Physician," as used herein, shall refer to and include doctors, nurses, other
healthcare providers and practitioners of the healing arts.
15. “Plaintiff” refers to LAMAR MITCHELL.
16. Legal counsel includes Plaintiff’s Counsel, Andres Hermida, Esq. and the
partners, associates, paralegals, secretaries, and other employees of Morgan &
Morgan, P.A.
17. “Miami-Dade” refers to MIAMI-DADE COUNTY.
18. Legal counsel includes Miami-Dade’s Counsel, Daniel Frastai, Esq. and the
partners, associates, paralegals, secretaries, and other employees of Abigail
Price-Williams.
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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690
CASE NO.: 2019-008931-CA-01
DEFENDANT, GINLEY LAWN SERVICE & LANDSCAPING, INC.’S FIRST
SET OF EXPERT INTERROGATORIES TO PLAINTIFF, LAMAR
MITCHELL
1. Please identify each person who will testify as an expert witness during the
trial of this matter and when such person was first retained.
RESPONSE:
2. Please state the following information for each expert witness listed in the
answer to Interrogatory No. 1 above:
a. Profession or occupation and the field of expertise.
b. The name and address of each school attended and a description of each
degree received.
c. The name of any professional or trade associations of which expert is
affiliated.
d. The title, subject matter, publisher, and date of publications of any
books, papers or articles on subjects in the field of expertise.
e. The number of years practiced or worked in the field of expertise.
f. Places of employment for the past ten (10) years.
g. All past and present teaching appointments in the expert’s field of
expertise or related or allied fields.
h. The subject matter, in detail, on which the expert is expected to testify.
i. The scope of employment in the pending case and compensation for
services;
j. The expert’s general litigation experience, including the percentage of
work performed for Plaintiffs and Defendants;
k. The identity of other cases, in the last four years, in which the expert
has testified by deposition or at trial.
l. The portion of the expert’s time spent as an expert witness, identifying
the number of hours, percentage of hours, or percentage of earned
income derived from serving as an expert witness and the number of
cases, percentage of cases, or percentage of income earned from Plaintiffs
and Defendants.
RESPONSE:
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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690
CASE NO.: 2019-008931-CA-01
3. Please state whether any of the experts listed in answer to Interrogatory
No. 1 above have formed any opinion concerning any issues involved in this
case.
RESPONSE:
4. If the answer to Interrogatory No. 3 is “yes,” please state:
a. The name of the expert(s) and each issue(s) about which he/she has an
opinion.
b. A summary of each opinion formed by each expert per issue.
c. The significant facts or grounds relied on by each expert in arriving at
each opinion.
d. For each such expert, please list each document, material, medical
record, medical bill, film, photograph, newspaper, videotape, movie,
academic study, computer data, deposition, legal document, memoranda,
correspondence, report, test or experiment, printout, audio tape or other
document or material which has been furnished to such expert in
connection with this matter and was used by such expert in forming the
basis of him/her opinion.
e. For each such expert, please identify each book, treatise, manual,
guideline, article, films, medical records, medical bills, case study,
sample, person, group, or other documents or material or person(s)
consulted by such expert in formulating his opinion and the
corresponding reasons for such consultations.
RESPONSE:
5. Did any expert in answer to Interrogatory No. 4(a) above submit a report or
reports setting forth any opinion or conclusion? If so, please state:
a. The date of each report and the date each report was submitted and who
submitted it.
b. The name or other means of identification of the person to whom each
report was submitted, and who has present custody of each report.
c. A summary of the contents of each report.
RESPONSE:
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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690
CASE NO.: 2019-008931-CA-01
6. For each expert identified, please give a detailed list of all publications
which each expert identified above has authored, or co-authored and the
name of the publication in which the article has appeared, each and every
article, book, or other publication written by such expert and whether
such expert possesses a copy of the document(s).
RESPONSE:
7. For each expert identified, please answer the following (attach a separate
answer sheet if necessary):
a. List each and every case you have provided deposition or trial testimony
for in the past three (3) years by date, case style, whether retained by the
Plaintiff or Defendants, and area of expertise in which you gave your
opinion.
b. For each case listed in response to Interrogatory No. 8(a), above, identify
whether a report was prepared by such expert, the records custodian of
each such report, and the location of each such expert.
RESPONSE:
8. Please provide the total amounts of monies the attorneys for Plaintiff
submitted to each expert identified in response to Interrogatory No. 1, above
in payment of services provided for review, sworn statement, affidavit,
deposition, and/or trial testimony for the preceding five (5) years.
RESPONSE:
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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690
CASE NO.: 2019-008931-CA-01
ACKNOWLEDGMENT AND VERIFICATION
I swear that the Answers to my interrogatories are true and correct.
By:
LAMAR MITCHELL
STATE OF ______________ }
}ss
COUNTY OF ____________ }
The foregoing instrument was acknowledged before me by means of ☐ physical
presence or ☐ online notarization, this ________ day of _________, 2020, by LAMAR
MITCHELL, who is ☐ personally known to me or ☐ who has produced
____________________, as identification and did/did not take an oath.
Notary Public: ________________________
My Commission Expires: ______________
Commission Number: _________________
Notary Seal
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150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690
Preview
Filing # 116909364 E-Filed 11/18/2020 04:10:41 PM IN THE CIRCUIT COURT OF THE 11th JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA LAMAR MITCHELL, CASE NO.: 2019-008931-CA-01 Plaintiff, vs. MIAMI-DADE COUNTY and GINLEY LAWN SERVICE & LANDSCAPING, INC., a Florida For Profit Corporation, Defendants. NOTICE OF SERVING DEFENDANT, GINLEY LAWN SERVICE & LANDSCAPING, INC.’S FIRST SET OF EXPERT INTERROGATORIES TO PLAINTIFF, LAMAR MITCHELL Defendant, Ginley Lawn Service & Landscaping, Inc., (“Ginley” or “Defendant”), by and through its undersigned counsel and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure hereby gives notice of propounding their First Set of Expert Interrogatories to Plaintiff, Lamar Mitchell, (“Plaintiff”), to be answered separately and fully in writing under oath with the time period prescribed by law. Date: November 18, 2020 Respectfully submitted, /s/ Niva M. Harney-Hiller Niva M. Harney-Hiller, Esq. Florida Bar No. 31058 nharney@hamiltonmillerlaw.com Reeba Hartley-Belle, Esq. 1 150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690 CASE NO.: 2019-008931-CA-01 Florida Bar Number: 117036 rhartleybelle@hamiltonmillerlaw.com HAMILTON, MILLER & BIRTHISEL, LLP 150 Southeast Second Avenue, Suite 1200 Miami, Florida 33131 Telephone: (305) 379-3686 Facsimile: (305) 379-3690 Counsel for Defendant Ginley Lawn Service & Landscaping, Inc. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on November 18, 2020 the foregoing document is being filed with the Clerk of Court using the E-filing Portal and served on all counsel of record or pro se parties identified on the below Service List either via transmission of Notices of Electronic Filing generated by the E-filing Portal or in some other authorized manner for those counsel or parties who are not authorized to receive electronically via the E-filing Portal. /s/ Niva M. Harney-Hiller Niva M. Harney-Hiller, Esq. SERVICE LIST Andres Hermida, Esq. Daniel Frastai, Esq. Florida Bar Number: 1010725 Florida Bar Number: 0666041 MORGAN & MORGAN, P.A. ABIGAIL PRICE-WILLIAMS 703 Waterford Way, Suite 1050 Stephen P. Clark Center Miami, Florida 33126 111 Northwest First Street, Telephone: (305) 929-1912 Suite 2810 Facsimile: (305) 929-1930 Miami, Florida 33128-1993 AHermida@forthepeople.com Telephone: (305) 375-5480 JJaime@forthepeople.com Facsimile: (305) 375-5634 Frastai@miamidade.gov Counsel for Plaintiff Lamar Mitchell jeane.neal@miamidade.gov Counsel for Defendant Miami- Dade County 2 150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690 CASE NO.: 2019-008931-CA-01 Definitions 1. "Document(s)" or "written communication(s)" is used in the broad and liberal sense and means written, typed, printed, recorded or graphic matter, however produced or reproduced, of any kind and description, and whether an original, master, duplicate or copy, including, but not limited to, accounts, advertisements, agreements, appointment books, bank checks, bills, books, books of account, bulletins, cablegrams, cancelled checks, cashier's checks, catalogs, charts, check stubs, communications, computer printouts, contracts, corporate records, correspondence, desk calendars, diaries, diary entries, drawings, e-mail, graphic records, guarantees, inter-office communications, intra-office communications, invoices, ledger books, letters, logs, mailgrams, magazines, manuals, marginal notes (appearing on any document), memoranda, minutes (e.g., board of directors, committee), models, motion pictures, notations, notebooks, notes, offers, pamphlets, papers, photographs, physical objects, plans, printed matter, projections, prospectuses, publications, receipts, reports, returns, sketches, sound recordings (including, by way of example, any type of personal or telephone conversation, meeting or conference) specifications, statements, statistics, studies, summaries, surveys, tape recordings, tapes, telegrams, telefaxes, teletypes, transcriptions (including, by way of example, any type of personal or telephone conversation, meeting or conference), transcripts, video tapes, vouchers, warranties, working papers, worksheets; and all amendments, changes, drafts, modifications of any of the foregoing, of which you have knowledge or which are now or were formerly in your actual or constructive possession, custody or control. The responses concerning documents requested shall include information regarding whether such document is an original, a duplicate, or a copy thereof. 2. "Concern," "concerning," "evidencing," "regarding," "reflecting," "relates," or "relates to" shall mean relating to, referring to, connected with, commenting on, responding to, containing, evidencing, showing, memorializing, describing, analyzing, comprising, or constituting. 3. "You" and "your" shall refer to and include your agents, attorneys, experts, investigators, representatives and all others, whether past or present, who have obtained information for or on behalf of you. 4. If a corporation, "you" and "your" shall refer to and include any of your affiliates and subsidiaries, agents, associates, attorneys, directors, employees, experts, independent contractors, representatives, servants, and all others, whether past or present, who have obtained information for or on behalf of the corporation. 5. The words "and" and "or" shall be construed conjunctively and disjunctively as necessary to make the request inclusive rather than exclusive. 3 150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690 CASE NO.: 2019-008931-CA-01 6. "Identify," or "state the identity of": (a) When used in reference to a natural person means to please state: (1) His/her full name; (2) Present or last known business and residence address; (3) His/her present or last known occupation and position; (4) His/her present or last known employer or business affiliation; (5) His/her occupation or position at the time in question specified in the particular request. (b) When used in reference to a "document" means to please state: (1) A description of the type of document (e.g., letter, memorandum, telegram, etc.); (2) The identity of the person or persons who authored or prepared it; (3) In the case of an agreement or contract, the identity of the parties' signatory; (4) The identity of the addressee(s), if any, and the recipient(s) of the original and a copy thereof; (5) The title thereof, if any, and a description of the general nature of its subject matter; (6) The date of the document, or, if none, the approximate date of its preparation; (7) The manner of distribution and publication, if any; (8) The present location or custodian of the original and each copy thereof; (9) The identity of any persons who can identify it; (10) Whether such documents contained, enclosed, were attached to or accompanied by any other documents, and if so, state the identity thereof; (11) If a privilege is claimed, the specific basis therefore. (c) In lieu of identifying a particular document when such identification is requested, a copy of such document may, at your option, be attached to the response to these requests; provided that any specific information 4 150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690 CASE NO.: 2019-008931-CA-01 required pursuant to the foregoing definition which is not fully set forth on the face of such copy of a document must be separately provided in response to these requests. 7. "Person" shall mean any natural person, firm, corporation, partnership, joint venture or any other form of business entity. 8. Masculine pronouns shall not connote any particular gender but shall be taken to mean masculine, feminine or neutral gender, as the case may be. 9. "Date" shall mean the exact day, month, and year, if ascertainable, or, if not, the best approximation thereof (including relationship to other events). 10. “Ginley,” as used herein, shall refer to GINLEY LAWN SERVICE & LANDSCAPING, INC., its affiliates and subsidiaries, agents, associates, attorneys, directors, employees, experts, independent contractors, representatives, servants, and all others, whether past or present, who have obtained information for or on behalf of the corporation. 11. "Incident," as used herein, shall refer to the incident which you allege to have occurred, as is more fully set forth in your Amended Complaint. 12. "The subject matter of this lawsuit," as used herein, shall refer to all facts and issues as set forth in your Amended Complaint. 13. "Medical condition," as used herein, shall refer to any condition, including but not limited to, that for which you are making a claim, regardless of whether it is a physical illness, disease or injury, mental illness, disease or injury or aggravation of a preexisting condition. 14. "Physician," as used herein, shall refer to and include doctors, nurses, other healthcare providers and practitioners of the healing arts. 15. “Plaintiff” refers to LAMAR MITCHELL. 16. Legal counsel includes Plaintiff’s Counsel, Andres Hermida, Esq. and the partners, associates, paralegals, secretaries, and other employees of Morgan & Morgan, P.A. 17. “Miami-Dade” refers to MIAMI-DADE COUNTY. 18. Legal counsel includes Miami-Dade’s Counsel, Daniel Frastai, Esq. and the partners, associates, paralegals, secretaries, and other employees of Abigail Price-Williams. 5 150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690 CASE NO.: 2019-008931-CA-01 DEFENDANT, GINLEY LAWN SERVICE & LANDSCAPING, INC.’S FIRST SET OF EXPERT INTERROGATORIES TO PLAINTIFF, LAMAR MITCHELL 1. Please identify each person who will testify as an expert witness during the trial of this matter and when such person was first retained. RESPONSE: 2. Please state the following information for each expert witness listed in the answer to Interrogatory No. 1 above: a. Profession or occupation and the field of expertise. b. The name and address of each school attended and a description of each degree received. c. The name of any professional or trade associations of which expert is affiliated. d. The title, subject matter, publisher, and date of publications of any books, papers or articles on subjects in the field of expertise. e. The number of years practiced or worked in the field of expertise. f. Places of employment for the past ten (10) years. g. All past and present teaching appointments in the expert’s field of expertise or related or allied fields. h. The subject matter, in detail, on which the expert is expected to testify. i. The scope of employment in the pending case and compensation for services; j. The expert’s general litigation experience, including the percentage of work performed for Plaintiffs and Defendants; k. The identity of other cases, in the last four years, in which the expert has testified by deposition or at trial. l. The portion of the expert’s time spent as an expert witness, identifying the number of hours, percentage of hours, or percentage of earned income derived from serving as an expert witness and the number of cases, percentage of cases, or percentage of income earned from Plaintiffs and Defendants. RESPONSE: 6 150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690 CASE NO.: 2019-008931-CA-01 3. Please state whether any of the experts listed in answer to Interrogatory No. 1 above have formed any opinion concerning any issues involved in this case. RESPONSE: 4. If the answer to Interrogatory No. 3 is “yes,” please state: a. The name of the expert(s) and each issue(s) about which he/she has an opinion. b. A summary of each opinion formed by each expert per issue. c. The significant facts or grounds relied on by each expert in arriving at each opinion. d. For each such expert, please list each document, material, medical record, medical bill, film, photograph, newspaper, videotape, movie, academic study, computer data, deposition, legal document, memoranda, correspondence, report, test or experiment, printout, audio tape or other document or material which has been furnished to such expert in connection with this matter and was used by such expert in forming the basis of him/her opinion. e. For each such expert, please identify each book, treatise, manual, guideline, article, films, medical records, medical bills, case study, sample, person, group, or other documents or material or person(s) consulted by such expert in formulating his opinion and the corresponding reasons for such consultations. RESPONSE: 5. Did any expert in answer to Interrogatory No. 4(a) above submit a report or reports setting forth any opinion or conclusion? If so, please state: a. The date of each report and the date each report was submitted and who submitted it. b. The name or other means of identification of the person to whom each report was submitted, and who has present custody of each report. c. A summary of the contents of each report. RESPONSE: 7 150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690 CASE NO.: 2019-008931-CA-01 6. For each expert identified, please give a detailed list of all publications which each expert identified above has authored, or co-authored and the name of the publication in which the article has appeared, each and every article, book, or other publication written by such expert and whether such expert possesses a copy of the document(s). RESPONSE: 7. For each expert identified, please answer the following (attach a separate answer sheet if necessary): a. List each and every case you have provided deposition or trial testimony for in the past three (3) years by date, case style, whether retained by the Plaintiff or Defendants, and area of expertise in which you gave your opinion. b. For each case listed in response to Interrogatory No. 8(a), above, identify whether a report was prepared by such expert, the records custodian of each such report, and the location of each such expert. RESPONSE: 8. Please provide the total amounts of monies the attorneys for Plaintiff submitted to each expert identified in response to Interrogatory No. 1, above in payment of services provided for review, sworn statement, affidavit, deposition, and/or trial testimony for the preceding five (5) years. RESPONSE: 8 150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690 CASE NO.: 2019-008931-CA-01 ACKNOWLEDGMENT AND VERIFICATION I swear that the Answers to my interrogatories are true and correct. By: LAMAR MITCHELL STATE OF ______________ } }ss COUNTY OF ____________ } The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this ________ day of _________, 2020, by LAMAR MITCHELL, who is ☐ personally known to me or ☐ who has produced ____________________, as identification and did/did not take an oath. Notary Public: ________________________ My Commission Expires: ______________ Commission Number: _________________ Notary Seal 9 150 SOUTHEAST SECOND AVENUE, SUITE 1200 · MIAMI, FLORIDA 33131 · TELEPHONE: 305-379-3686 · FACSIMILE: 305-379-3690