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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
TIBAR, LLC, TERESA CASE NO.: 2008 CA 18070
BASNIGHT and MICHAEL
A. BASNIGHT
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PLAINTIFFS’ TRIAL WITNESS LIST
- Plaintiffs, TIBAR, LLC, TERESA BASNIGHT and MICHAEL A. BASNIGHT by and
through undersigned counsel, hereby files this their Trial Witness List, pursuant to the Court’s Order
Setting Case for Jury Trial, dated July 21, 2011:
All parties to this action.
Michael Basnight
c/o Wayne M. Alder
Seiden, Alder & Matthewman, P.A.
7795 NW Beacon Square Boulevard, Suite 201
Boca Raton, FL 33487
Mr. Basnight’s expected testimony 1s his knowledge with respect to Plaintiffs’ claims and
alleged damages and all other relevant topics.
Teresa Basnight
c/o Wayne M. Alder
Seiden, Alder & Matthewman, P.A.
7795 NW Beacon Square Boulevard, Suite 201
Boca, Raton, FL 33487
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Ms. Basnight’s expected testimony is her knowledge with respect to Plaintiffs’ claims and
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alleged damages and all other relevant topics.
Corporate Representative of Tibar, LLC
c/o Wayne M. Alder
Seiden, Alder & Matthewman, P.A.
7795 NW Beacon Square Boulevard, Suite 201
Boca Raton, FL 33487
The Corporate Representative of Tibar, LLC’s expected testimony is his/her knowledge with
respect to Plaintiffs’ claims and alleged damages and all other relevant topics.
] ohn Moore -
c/o Jessica Kirkwood Alley
Phelps Dunbar, LLP
100: South Ashley Drive, Suite 1900
Tampa, FL 33602-5311
John Moore’s expected testimony is regarding the legal services provided by Defendants to
Plaintiffs.
Terri Costa
c/o Jessica Kirkwood Alley
Phelps Dunbar, LLP
100 South Ashley Drive, Suite 1900
Tampa, FL 33602-5311
Terni Costa’s expected testimony is regarding the legal services provided by Defendants to
Plaintiffs.
Linda Getzen
c/o Jessica Kirkwood Alley
Phelps Dunbar LLP
100 South Ashley Drive, Suit 1900
Tampa, FL 33602
Williams, Parker, Harrison, Dietz & Getzen, P.A. - Corporate Representative
c/o Lawrence P. Ingram and Jessica Kirkwood Alley
Phelps Dunbar LLP
100 South Ashley Drive, Suit 1900
Tampa, FL 33602
Corporate Representative of Williams, Parker, Harrison, Dietz & Getzen, P.A.’s expected
testimony 1s Defendants’ alleged defenses and the legal services provided by Defendants to
Plaintiffs, ethics, and conflicts of interest.
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Bookkeeping Department of Williams, Parker, Harrison, Dietz & Getzen, PA.
c/o Jessica Kirkwood Alley
Phelps Dunbar LLP
100 South. Ashley Drive, Suit 1900
Tampa, FL 33 602
Bookkeeping Department of Williams, Parker, Harrison, Dietz & Getzen, P.A.’s expected
testimony is relating to opening files, billing of files and claims in this matter.
Firm Administrator of Williams, Parker, Harrison, Dietz & Getzen, P.A.
c/o Jessica Kirkwood Alley
Phelps Dunbar LLP
100 South Ashley Drive, Suit 1900
Tampa, FL 33602
Firm Administrator of Williams, Parker, Harrison, Dietz & Getzen, P.A.’s expected
testimony is relating to opening files, billing of files and claims in this matter.
10 Management Committee of Williams, Parker, Harrison, Dietz & Getzen, P.A.
c/o Jessica Kirkwood Alley
Phelps Dunbar LLP
100 South Ashley Drive, Suit 1900
Tampa, FL 33602
Management Committee of Williams, Parker, Harrison, Dietz & Getzen, P.A.’s expected
testimony is relating to opening files, billing of files and claims in this matter.
1] Northern Trust, N.A. - Records Custodian
901 Venetia Bay Boulevard, Suite 100
Venice, FL 34285
Records Custodian of Northern Trust, N.A.’s expected testimony is Plaintiffs’ claims and
damages, documents relevant to the subject medical office building, and all other relevant
topics. Defendants’ alleged defenses.
12 Audrey Gow
6528 Samona Drive
Sarasota, FL
Audrey Gow’s expected testimony is Plaintiffs’ claims and alleged damages, and all other
relevant topics.
13 H. Campbell Reynolds
Tami Conetta, Esq.,
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Northern Trust Bank
901 Venetia Bay Blvd., Ste 100
Venice, FL 34285
H. Campbell Reynold’s expected testimony is Plaintiffs’ claims and alleged damages, and
all other relevant topics.
14 Dr. Susan Bratschi
Miami International Cardiac Consultants
3801 Biscayne Boulevard, Suite 300
Miami, FL 33137
Dr. Susan Bratschi’s expected testimony 1s Plaintiffs’ claims and alleged damages, including
but not limited to physician employment and operations and all other relevant topics.
15 Dr. Chandana Bopitiya
Senior Friendship Health Services
2350 Scenic Drive
Venice, FL 34293
Dr. Chandana Bopitiya’s expected testimony is Plaintiffs’ claims and alleged damages,
including but not limited to physician employment and operations and all other relevant
topics.
16 Dr. Victor Baga
517 Riviera Street, Suite C
Venice, FL 34285
Dr. Victor Baga’s expected testimony is Plaintiffs’ claims and alleged damages, including
but not limited to physician employment and operations and all other relevant topics.
17 Dr. George Abernathy
The Heart Institute of Venice
1370 East Venice Avenue, #102
Venice, FL 34285
Dr. George Abernathy’s expected testimony is Plaintiffs’ claims and alleged damages,
including but not limited to physician employment and operations of The Heart and Vascular
Center of Venice and HVC Ventures, and all other relevant topics.
18 Dr. Barry Weckesser
The Heart Institute of Venice
1370 East Venice Avenue, #102
Venice, FL 34285
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Dr. Barry Weckesser’s expected testimony is operations and employment of HVCV and
Ventures. The Weckesser litigation, and all other relevant topics.
19 Linda Ogilbee
The Heart and Vascular Center of Venice, P.A.
1287 US Highway 41 Bypass South
Venice, FL 34285
Linda Ogilbee’s expected testimony 1s Plaintiffs’ claims and alleged damages, and all other
relevant topics.
20 Robert Stanell
Christopher, Smith, Leonard, Bristow & Stanell, P.A.
1001 3% Avenue West, Suite 700
Bradenton, FL 34205
Robert Stanell’s expected testimony is Plaintiffs’ claims, alleged damages and accounting
regarding HVCV and TiBar, LLC and all other relevant topics.
21 Aubrey Lynch
Christopher, Smith, Leonard, Bristow & Stanell, P.A.
1001 3™ Avenue West, Suite 700
Bradenton, FL 34205
Aubrey Lynch’s expected testimony is Plaintiffs’ claims, alleged damages and accounting
regarding HVCV and TiBar, LLC and all other relevant topics.
22 Patrick Marston
Optimal Outcome, LLC
240 1 Avenue S, #400
St. Petersburg, FL 33701
Patrick Marston’s expected testimony is Plaintiffs’ claims, alleged damages and the
attempted purchase of the subject medical office building and all other relevant topics.
23 Grace Edwards
5134 Station Way
Sarasota, FL 34233
Grace Edwards’ expected testimony is the operation, ownership and attempted sales of the
subject medical office building of TiBar and all other relevant topics.
24 Barry Edwards
Barry D. Edwards and Associates, Inc.
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5134 Station Way
Sarasota, FL 34233
Barry Edwards’ expected testimony is the TiBar, LLC’s operation, management, ownership,
and attempted sales of the subject medical office building and all other relevant topics.
25 Barry D. Edwards and Associates, Inc., Records Custodian
5134 Station Way
Sarasota, FL 34233
Records Custodian of Barry Edwards’ expected testimony is Plaintiffs’ claims, alleged
damages and TiBar, LLC’s operation, ownership, and attempted sales of the subject medical
office building and all other relevant topics.
26 Barry D. Edwards and Associates, inc., Corporate Representatives
5134 Station Way
Sarasota, FL 34233
Corporate Representatives’ expected testimony is TiBar, LLC’s operation, management,
ownership, and attempted sales of the subject medical office building and all other relevant
topics.
27 Linda Emery
5134 Station Way
Sarasota, FL 34233
Linda Emery’s expected testimony is the operation, ownership, and attempted sales of the
subject medical office building and all other relevant topics.
28 Thomas Dart, Esquire
Adams & Reese, P.A.
1515 Ringling Boulevard, Suite 700
Sarasota, FL 34236
Thomas Dart’s expected testimony is HVCV and Venture’s ownership, attempted sales and
completed sale of the subject medical office building. The litigation with Weckesser and all
other relevant topics.
29 Steve Herb, Esq.
Nelson Hesse LLP
2070 Ringling Boulevard
Sarasota, FL 34237
Steve Herb’s expected testimony is TiBar and Weckesser litigation. HVCV and Ventures’
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ownership and sale of the subject medical building and all other relevant topics.
30 Bill Dooley, Esq.
1432 First Street
Sarasota, FL
Bill Dooley’s expected testimony is Plaintiffs’ claims and alleged damages, and all other
relevant topics. Legal services provided by Defendants to Plaintiffs.
31 William Kalish, Esq.
401 E. Jackson Street, Suite 1700
Tampa, FL 33602
William Kalish’s expected testimony is Plaintiffs’ claims and alleged damages, and all other
relevant topics. Legal services provided by Defendants to Plaintiffs.
32 Rhada Bachman, Esq.
(Address unknown at this time)
Rhada Bachman’s expected testimonyis Plaintiffs’ claims and alleged damages, and all other
relevant topics. Legal services provided by Defendants to Plaintiffs.
33 Wayne Ruben
Ruben Holland Development, LLC
1991 Main Street, Suite 208
Sarasota, FL 34236
Wayne Ruben’s expected testimony is Plaintiffs’ claims and alleged damages, the attempted
purchase of the subject medical office building, and all other relevant topics.
34 Teresa Abood-Hoffman
Hoffman & Hoffman, P.A.
848 Brickell Avenue, Suite 501
Miami, FL 33131
Teresa Abood-Hoffman’s expected testimony is related to legal work needed to be done due
to errors and malpractice done in trust and estate work.
35 Scott Russell
Environmental Safety Consultants, Inc:
6400 Manatee Avenue West, Suite C
Bradenton, FL 34209
Scott Russell’s expected testimony is the mold remediation operations and documents as
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related to Plaintiffs’ claims and damages.
36 Maggio & Sons, d/b/a ServePro of Venice and Port Charlotte - Corp. Rep.
355 Sand Pine Blvd.
Venice, FL 34292
Corporate Representative of ServePro’s expected testimony is the mold remediation
operations and documents as related to Plaintiffs’ claims and damages.
37 Ziegler Healthcare Real Estate Funds - Corporate Representative
200 South Wacker Drive, Suite 2000
Chicago, IL 60606
Corporate Representative for Ziegler Healthcare Real Estate Funds’ expected testimony is
Plaintiffs’ claims and damages and the attempted purchase of the subject medical office
building.
38 James Piro
7719 Holiday Drive
Sarasota, Fl 34231
Mr. Piro’s expected testimony is will concern the apprasial he did for Northern Trust, the
value of the building if he was told of the mold, the value if he was told the tenet was
purchaser and as otherwise set forth in his deposition.
39 George V. Famighio, Jr.
1634 Main Street
Sarasota, FL 34236
George Famiglio’s expected testimony is Plaintiffs’ claims, alleged damages and
accounting regarding HVCV and TiBar, LLC and all other relevant topics.
40 Records Custodians for all exhibits listed in the Exhibit List.
41 All individuals listed in any documents provided in response to any Responses to any
Request to Produce, regardless of whom responded.
42 Hugh Middlebrooks
c/o Jessica Kirkwood Alley
Phelps Dunbar, LLP
100 South Ashley Drive, Suite 1900
Tampa, FL 33602-5311
Mr. Middlebrook’s expected testimony is regarding the legal services provided by
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Defendants to Plaintiffs.
43 David Wallace
c/o Jessica Kirkwood Alley
Phelps Dunbar, LLP
100 South Ashley Drive, Suite 1900
Tampa, FL 33602-5311
Mr. Wallace’s expected testimony is regarding the legal services provided by Defendants
to Plaintiffs.
44 All witnesses identified by any of the parties to this action.
45 All deponents in this action.
46 All witnesses disclosed in depositions taken or to be taken in this action.
47 Impeachment and/or rebuttal witnesses.
48 All expert witnesses as separately listed by Plaintiffs.
49 Any and all Paralegals listed on any bills provided by Williams, Parker, Harrison, Dietz &
Getzen, P.A. to the Plaintiffs.
50 The Plaintiffs reserve the right to call any Witnesses listed by Defendants, in either Plaintiffs’
case or otherwise, without waiver of objections.
51 The Plaintiffs reserve the right to amend, supplement, alter, delete and/or revise individuals
from this list as provided by the Florida Rules of Civil Procedure, The Court’s rules, by
stipulation, or as otherwise provided by Florida law, as discovery continues in this matter.
52 By listing a witness or witnesses herein, Plaintiffs are reserving the right to use any such
listed witness. Please does not waive any objections they might otherwise have to such a
witness or witnesses.
53 The Plaintiffs further reserve the right to call any witness listed on their original list as a
rebuttal witness whether or not named on the instant condensed list of witnesses.
54 Plaintiffs reserve their right to add or substitute expert witnesses as additional
information regarding this matter is discovered. Discovery is still ongoing and not all
relevant documents have been produced.
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
Facsimile and U.S. Mail to: Jessica Kirkwood Alley, Phelps Dunbar, LLP. 100 South Ashley Drive,
Suite 1900, Tampa, Florida 33602-5311, on this IS day of August, 2011.
SEIDEN, ALDER & MATTHEWMAN P.A.
7795 N.W. Beacon Square Blvd., Suite #201
Boca Raton, FL 33487
Telephone:(561) 416-017
ee ]
LZpy
an
LE
Alder
orida Bar No. 850616
Andrew Seiden
Florida Bar No. 373672
W:\1219.001\Pleadings\Witness List Supple Trial.02(hc).wpd
Page 10 of 10
Preview
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA TIBAR, LLC, TERESA CASE NO.: 2008 CA 18070 BASNIGHT and MICHAEL A. BASNIGHT Plaintiffs, ey - 2 wm FEY > cod Spe pee ry VS. “Ly Be 2 ay ewe my Son ~39 2 WILLIAMS, PARKER, HARRISON, Et oy Oo co CS oo Cu Defendants. a / PLAINTIFFS’ TRIAL WITNESS LIST - Plaintiffs, TIBAR, LLC, TERESA BASNIGHT and MICHAEL A. BASNIGHT by and through undersigned counsel, hereby files this their Trial Witness List, pursuant to the Court’s Order Setting Case for Jury Trial, dated July 21, 2011: All parties to this action. Michael Basnight c/o Wayne M. Alder Seiden, Alder & Matthewman, P.A. 7795 NW Beacon Square Boulevard, Suite 201 Boca Raton, FL 33487 Mr. Basnight’s expected testimony 1s his knowledge with respect to Plaintiffs’ claims and alleged damages and all other relevant topics. Teresa Basnight c/o Wayne M. Alder Seiden, Alder & Matthewman, P.A. 7795 NW Beacon Square Boulevard, Suite 201 Boca, Raton, FL 33487 1 Ms. Basnight’s expected testimony is her knowledge with respect to Plaintiffs’ claims and r , iim Page 1 of 10 ‘ , Neo —__ — ” alleged damages and all other relevant topics. Corporate Representative of Tibar, LLC c/o Wayne M. Alder Seiden, Alder & Matthewman, P.A. 7795 NW Beacon Square Boulevard, Suite 201 Boca Raton, FL 33487 The Corporate Representative of Tibar, LLC’s expected testimony is his/her knowledge with respect to Plaintiffs’ claims and alleged damages and all other relevant topics. ] ohn Moore - c/o Jessica Kirkwood Alley Phelps Dunbar, LLP 100: South Ashley Drive, Suite 1900 Tampa, FL 33602-5311 John Moore’s expected testimony is regarding the legal services provided by Defendants to Plaintiffs. Terri Costa c/o Jessica Kirkwood Alley Phelps Dunbar, LLP 100 South Ashley Drive, Suite 1900 Tampa, FL 33602-5311 Terni Costa’s expected testimony is regarding the legal services provided by Defendants to Plaintiffs. Linda Getzen c/o Jessica Kirkwood Alley Phelps Dunbar LLP 100 South Ashley Drive, Suit 1900 Tampa, FL 33602 Williams, Parker, Harrison, Dietz & Getzen, P.A. - Corporate Representative c/o Lawrence P. Ingram and Jessica Kirkwood Alley Phelps Dunbar LLP 100 South Ashley Drive, Suit 1900 Tampa, FL 33602 Corporate Representative of Williams, Parker, Harrison, Dietz & Getzen, P.A.’s expected testimony 1s Defendants’ alleged defenses and the legal services provided by Defendants to Plaintiffs, ethics, and conflicts of interest. Page 2 of 10 Bookkeeping Department of Williams, Parker, Harrison, Dietz & Getzen, PA. c/o Jessica Kirkwood Alley Phelps Dunbar LLP 100 South. Ashley Drive, Suit 1900 Tampa, FL 33 602 Bookkeeping Department of Williams, Parker, Harrison, Dietz & Getzen, P.A.’s expected testimony is relating to opening files, billing of files and claims in this matter. Firm Administrator of Williams, Parker, Harrison, Dietz & Getzen, P.A. c/o Jessica Kirkwood Alley Phelps Dunbar LLP 100 South Ashley Drive, Suit 1900 Tampa, FL 33602 Firm Administrator of Williams, Parker, Harrison, Dietz & Getzen, P.A.’s expected testimony is relating to opening files, billing of files and claims in this matter. 10 Management Committee of Williams, Parker, Harrison, Dietz & Getzen, P.A. c/o Jessica Kirkwood Alley Phelps Dunbar LLP 100 South Ashley Drive, Suit 1900 Tampa, FL 33602 Management Committee of Williams, Parker, Harrison, Dietz & Getzen, P.A.’s expected testimony is relating to opening files, billing of files and claims in this matter. 1] Northern Trust, N.A. - Records Custodian 901 Venetia Bay Boulevard, Suite 100 Venice, FL 34285 Records Custodian of Northern Trust, N.A.’s expected testimony is Plaintiffs’ claims and damages, documents relevant to the subject medical office building, and all other relevant topics. Defendants’ alleged defenses. 12 Audrey Gow 6528 Samona Drive Sarasota, FL Audrey Gow’s expected testimony is Plaintiffs’ claims and alleged damages, and all other relevant topics. 13 H. Campbell Reynolds Tami Conetta, Esq., Page 3 of 10 Northern Trust Bank 901 Venetia Bay Blvd., Ste 100 Venice, FL 34285 H. Campbell Reynold’s expected testimony is Plaintiffs’ claims and alleged damages, and all other relevant topics. 14 Dr. Susan Bratschi Miami International Cardiac Consultants 3801 Biscayne Boulevard, Suite 300 Miami, FL 33137 Dr. Susan Bratschi’s expected testimony 1s Plaintiffs’ claims and alleged damages, including but not limited to physician employment and operations and all other relevant topics. 15 Dr. Chandana Bopitiya Senior Friendship Health Services 2350 Scenic Drive Venice, FL 34293 Dr. Chandana Bopitiya’s expected testimony is Plaintiffs’ claims and alleged damages, including but not limited to physician employment and operations and all other relevant topics. 16 Dr. Victor Baga 517 Riviera Street, Suite C Venice, FL 34285 Dr. Victor Baga’s expected testimony is Plaintiffs’ claims and alleged damages, including but not limited to physician employment and operations and all other relevant topics. 17 Dr. George Abernathy The Heart Institute of Venice 1370 East Venice Avenue, #102 Venice, FL 34285 Dr. George Abernathy’s expected testimony is Plaintiffs’ claims and alleged damages, including but not limited to physician employment and operations of The Heart and Vascular Center of Venice and HVC Ventures, and all other relevant topics. 18 Dr. Barry Weckesser The Heart Institute of Venice 1370 East Venice Avenue, #102 Venice, FL 34285 Page 4 of 10 Dr. Barry Weckesser’s expected testimony is operations and employment of HVCV and Ventures. The Weckesser litigation, and all other relevant topics. 19 Linda Ogilbee The Heart and Vascular Center of Venice, P.A. 1287 US Highway 41 Bypass South Venice, FL 34285 Linda Ogilbee’s expected testimony 1s Plaintiffs’ claims and alleged damages, and all other relevant topics. 20 Robert Stanell Christopher, Smith, Leonard, Bristow & Stanell, P.A. 1001 3% Avenue West, Suite 700 Bradenton, FL 34205 Robert Stanell’s expected testimony is Plaintiffs’ claims, alleged damages and accounting regarding HVCV and TiBar, LLC and all other relevant topics. 21 Aubrey Lynch Christopher, Smith, Leonard, Bristow & Stanell, P.A. 1001 3™ Avenue West, Suite 700 Bradenton, FL 34205 Aubrey Lynch’s expected testimony is Plaintiffs’ claims, alleged damages and accounting regarding HVCV and TiBar, LLC and all other relevant topics. 22 Patrick Marston Optimal Outcome, LLC 240 1 Avenue S, #400 St. Petersburg, FL 33701 Patrick Marston’s expected testimony is Plaintiffs’ claims, alleged damages and the attempted purchase of the subject medical office building and all other relevant topics. 23 Grace Edwards 5134 Station Way Sarasota, FL 34233 Grace Edwards’ expected testimony is the operation, ownership and attempted sales of the subject medical office building of TiBar and all other relevant topics. 24 Barry Edwards Barry D. Edwards and Associates, Inc. Page 5 of 10 5134 Station Way Sarasota, FL 34233 Barry Edwards’ expected testimony is the TiBar, LLC’s operation, management, ownership, and attempted sales of the subject medical office building and all other relevant topics. 25 Barry D. Edwards and Associates, Inc., Records Custodian 5134 Station Way Sarasota, FL 34233 Records Custodian of Barry Edwards’ expected testimony is Plaintiffs’ claims, alleged damages and TiBar, LLC’s operation, ownership, and attempted sales of the subject medical office building and all other relevant topics. 26 Barry D. Edwards and Associates, inc., Corporate Representatives 5134 Station Way Sarasota, FL 34233 Corporate Representatives’ expected testimony is TiBar, LLC’s operation, management, ownership, and attempted sales of the subject medical office building and all other relevant topics. 27 Linda Emery 5134 Station Way Sarasota, FL 34233 Linda Emery’s expected testimony is the operation, ownership, and attempted sales of the subject medical office building and all other relevant topics. 28 Thomas Dart, Esquire Adams & Reese, P.A. 1515 Ringling Boulevard, Suite 700 Sarasota, FL 34236 Thomas Dart’s expected testimony is HVCV and Venture’s ownership, attempted sales and completed sale of the subject medical office building. The litigation with Weckesser and all other relevant topics. 29 Steve Herb, Esq. Nelson Hesse LLP 2070 Ringling Boulevard Sarasota, FL 34237 Steve Herb’s expected testimony is TiBar and Weckesser litigation. HVCV and Ventures’ Page 6 of 10 ownership and sale of the subject medical building and all other relevant topics. 30 Bill Dooley, Esq. 1432 First Street Sarasota, FL Bill Dooley’s expected testimony is Plaintiffs’ claims and alleged damages, and all other relevant topics. Legal services provided by Defendants to Plaintiffs. 31 William Kalish, Esq. 401 E. Jackson Street, Suite 1700 Tampa, FL 33602 William Kalish’s expected testimony is Plaintiffs’ claims and alleged damages, and all other relevant topics. Legal services provided by Defendants to Plaintiffs. 32 Rhada Bachman, Esq. (Address unknown at this time) Rhada Bachman’s expected testimonyis Plaintiffs’ claims and alleged damages, and all other relevant topics. Legal services provided by Defendants to Plaintiffs. 33 Wayne Ruben Ruben Holland Development, LLC 1991 Main Street, Suite 208 Sarasota, FL 34236 Wayne Ruben’s expected testimony is Plaintiffs’ claims and alleged damages, the attempted purchase of the subject medical office building, and all other relevant topics. 34 Teresa Abood-Hoffman Hoffman & Hoffman, P.A. 848 Brickell Avenue, Suite 501 Miami, FL 33131 Teresa Abood-Hoffman’s expected testimony is related to legal work needed to be done due to errors and malpractice done in trust and estate work. 35 Scott Russell Environmental Safety Consultants, Inc: 6400 Manatee Avenue West, Suite C Bradenton, FL 34209 Scott Russell’s expected testimony is the mold remediation operations and documents as Page 7 of 10 related to Plaintiffs’ claims and damages. 36 Maggio & Sons, d/b/a ServePro of Venice and Port Charlotte - Corp. Rep. 355 Sand Pine Blvd. Venice, FL 34292 Corporate Representative of ServePro’s expected testimony is the mold remediation operations and documents as related to Plaintiffs’ claims and damages. 37 Ziegler Healthcare Real Estate Funds - Corporate Representative 200 South Wacker Drive, Suite 2000 Chicago, IL 60606 Corporate Representative for Ziegler Healthcare Real Estate Funds’ expected testimony is Plaintiffs’ claims and damages and the attempted purchase of the subject medical office building. 38 James Piro 7719 Holiday Drive Sarasota, Fl 34231 Mr. Piro’s expected testimony is will concern the apprasial he did for Northern Trust, the value of the building if he was told of the mold, the value if he was told the tenet was purchaser and as otherwise set forth in his deposition. 39 George V. Famighio, Jr. 1634 Main Street Sarasota, FL 34236 George Famiglio’s expected testimony is Plaintiffs’ claims, alleged damages and accounting regarding HVCV and TiBar, LLC and all other relevant topics. 40 Records Custodians for all exhibits listed in the Exhibit List. 41 All individuals listed in any documents provided in response to any Responses to any Request to Produce, regardless of whom responded. 42 Hugh Middlebrooks c/o Jessica Kirkwood Alley Phelps Dunbar, LLP 100 South Ashley Drive, Suite 1900 Tampa, FL 33602-5311 Mr. Middlebrook’s expected testimony is regarding the legal services provided by Page 8 of 10 Defendants to Plaintiffs. 43 David Wallace c/o Jessica Kirkwood Alley Phelps Dunbar, LLP 100 South Ashley Drive, Suite 1900 Tampa, FL 33602-5311 Mr. Wallace’s expected testimony is regarding the legal services provided by Defendants to Plaintiffs. 44 All witnesses identified by any of the parties to this action. 45 All deponents in this action. 46 All witnesses disclosed in depositions taken or to be taken in this action. 47 Impeachment and/or rebuttal witnesses. 48 All expert witnesses as separately listed by Plaintiffs. 49 Any and all Paralegals listed on any bills provided by Williams, Parker, Harrison, Dietz & Getzen, P.A. to the Plaintiffs. 50 The Plaintiffs reserve the right to call any Witnesses listed by Defendants, in either Plaintiffs’ case or otherwise, without waiver of objections. 51 The Plaintiffs reserve the right to amend, supplement, alter, delete and/or revise individuals from this list as provided by the Florida Rules of Civil Procedure, The Court’s rules, by stipulation, or as otherwise provided by Florida law, as discovery continues in this matter. 52 By listing a witness or witnesses herein, Plaintiffs are reserving the right to use any such listed witness. Please does not waive any objections they might otherwise have to such a witness or witnesses. 53 The Plaintiffs further reserve the right to call any witness listed on their original list as a rebuttal witness whether or not named on the instant condensed list of witnesses. 54 Plaintiffs reserve their right to add or substitute expert witnesses as additional information regarding this matter is discovered. Discovery is still ongoing and not all relevant documents have been produced. Page 9 of 10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Facsimile and U.S. Mail to: Jessica Kirkwood Alley, Phelps Dunbar, LLP. 100 South Ashley Drive, Suite 1900, Tampa, Florida 33602-5311, on this IS day of August, 2011. SEIDEN, ALDER & MATTHEWMAN P.A. 7795 N.W. Beacon Square Blvd., Suite #201 Boca Raton, FL 33487 Telephone:(561) 416-017 ee ] LZpy an LE Alder orida Bar No. 850616 Andrew Seiden Florida Bar No. 373672 W:\1219.001\Pleadings\Witness List Supple Trial.02(hc).wpd Page 10 of 10