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Angela Claiborne IN THE DISTRICT COURT OF
Vv HARRIS COUNTY, TEXAS
APTVC, LLC
190
PLAINTIFF ANGELA CLAIBORNE’ S DESIGNATION OF EXPERTS
TO: Defendant, APTVC, LLC, by and through its attorney of record, Robert G. Gibson, Jr.,
Box 387, Rosenberg, Texas 77471.
TO: Defendant GATESCO, INC., by and through its attorney of record, Kawika Vellalos,
Plaintiff ANGELA CLAIBORNE serves this Designation of Experts in compliance
with the Court’s Docket Control Order. This designation also serves as a supplement to
Plaintiff’ s Response to Disclosure.
General Reservations
Plaintiff submits these responses and objections without intending to waive and
expressly reserves the right to change, modify, supplement, or clarify these responses
and objections at any time before trial.
In providing the information requested by Defendant, Plaintiff does not waive any
objections as to the admissibility of such information in evidence.
The inadvertent production of any privileged information or documents shall not be
deemed to be a waiver of any applicable privilege with respect to such information,
Retained Experts
Dr. Todd Cowen
Texas Physical Medicine & Rehabilitation Institute
2833 Babcock Road, Suite 110
San Antonio, Texas 78229
(210) 692-2000
Dr. Cowen is a medical expert. He possesses expertise and knowledge in his respective
area. Specifically, he may testify about Plaintiff Angela Claiborne’s care, treatment, diagnosis,
prognosis, causation, physical restrictions, reasonable costs for medical care in the past and
future, and the need, if any, for future treatment. Dr. Cowen has charged Plaintiff
approximately $6,500.00 for his time. Exhibit B to this Designation includes (1) Dr. Cowen’s
report dated September 11, 2017, (2) Dr. Cowe
testimony history.
As discovery remains ongoing and Plaintiffs medical treatment continues, Dr. Cowen
will continue to review relevant documents upon receipt. Currently, Dr. Cowen has reviewed
the following documents in preparing his report:
(95 pages)
s Therapy Center Billing
Therapy Center Medical
hysical Therapy_Medical
R000303 - RO00305 A. Claibome_ Republic Pain & Anesthesia
Consultants Medical
R000306 - RO00308 A. Claibome_ Republic Pain & Anesthesia
R000301 - RO00302 A. Claibome_ Memorial Hermann Hospital Memorial
City_Radiology
R000262 - RO00300 A. Claibome_ Memorial Hermann Hospital Memorial
R000222 - RO00261 A. Claibome_ Memorial Hermann Hospital Memorial
RO000075 RO00221 A. Claibome_ Memorial Hermann Hospital Memorial
RO000069 RO00072 A. Claibome_ Memorial Bone & Joint Clinic Billing
R000073 RO000074 A. Claibome_ Memorial Bone & Joint Clinic Radiology
RO000060 RO00068 A. Claibome_ Memorial Bone & Joint Clinic_Medical
Pharmacy Pharmacy
_ Advanced Diagnostics
Diagnostics Healthcare_Billing
(2)
dvanced Diagnostics Hea
Diagnostics Healthcare_Medical
(2)
nced Diagnostics Health
imary Care Physicians SW
R000448 - RO00452 A. Claibome_ Memorial Bone & Joint Clinic Medical
R000436 - RO00444 A. Claiborne Memorial Bone & Joint Clinic_Medical -
Updates
R000445 - R000447 A. Claibome_ Memorial Bone & Joint Clinic_Billing
R000432 - R000435 A. Claiborne Memorial Bone & Joint Clinic_Billing -
Updates
dvanced Diagnostic Hospita
nced Diagnostic Hospital
East_Radiology
_ Advanced Diagnostics
Healthcare_Radiology
nced Diagnostic Hospital
East_Medical
MichaelJ. Welton, CPM, RPA
3279 E. Stanford Avenue
Gilbert, AZ 85234
(480) 699-8289
Mr. Welton will testify about all aspects of liability. Mr. Welton will base his
opinion upon his educational background, traini
Mr. Welton has charged Plaintiff approximately $2,500.00 for his time. Exhibit D to
this Designation includes: (1) Mr. Welton’s report dated October 18, 2017; and (2)
aring his report:
Plaintiff’ s Response to Request for Disclosure
Plaintiffs Response to Interrogatories, Requests for Admission, and Request
for Production
Plaintiff’ s First Supplemental Response to Interrogatories, Admission and
APTVC Answers to Interrogatories
APTVC Response to Request for Production
APTVC Response to Re
APTVC Response to Request for Disclosure
APTVC First Supplemental Response to Request for Production
Plaintiff may call the following non-retained, expert witnesses to give expert testimony.
The following doctors, nurses, therapists, medical technicians, and other healthcare providers
have cared for and provided treatment to Angela Claibome. As such, they possess expertise
and knowledge in their respective areas. This designation is made to permit the Plaintiff the
opportunity to introduce evidence from these individuals which might be deemed in the nature
of opinion or expert testimony. Specifically, these individuals may testify about the care,
treatment, causation, physical restrictions, prognosis, diagnosis, reasonable costs for medical
care.
ACS Primary Care Physicians
Advanced Diagnostic Hospital East
12950 East Freeway, Suite 100
Advanced Diagnostics
Dr. Victoria Do
AHK Neurology
Dr. Ramiro Hernandez
Dream Pharmacy
1140 Business Center Dr., Suite 103
Memorial Bone & Joint
Dr. Zoran Cupic
1140 Business Center Dr., Suite 101
Memorial Hermann Memorial City
Republic Pain & Anesthesia
Select Physical Therapy
17360 Northwest Freeway
South Texas Therapy Center
Other Experts
There may be other individuals who are designated as experts by parties, all of whom
the Plaintiff reserves the right to call as expert witnesses. By making this cross-designation,
Plaintiff does not waive the right to challenge the ability of the other parties’ experts to testify
Plaintiff reserves the right to designate and call rebuttal expert witnesses, the identity
of which cannot reasonably be anticipated at this time. Plaintiff reserves the right to challenge
the testimony and qualifications of any expert designated by Defendants. Plaintiff reserves the
right to supplement this designation.
ARNOLD & ITKIN
/s/ Noah M. Wexler
Texas Bar No. 24032461
Noah M. Wexler
Texas State Bar No. 24060816
Texas State Bar No. 24076086
Rebecca L. Adams
Texas State Bar No. 24098255
6009 Memorial Drive
Facsimile: (713) 222-3850
e-service@ arnolditkin.com
wexler@ arnolditkin.com
radams@ armolditkin.com
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument has been
forwarded to the following counsel
Noah M. Wexler
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Angela Claiborne IN THE DISTRICT COURT OF Vv HARRIS COUNTY, TEXAS APTVC, LLC 190 PLAINTIFF ANGELA CLAIBORNE’ S DESIGNATION OF EXPERTS TO: Defendant, APTVC, LLC, by and through its attorney of record, Robert G. Gibson, Jr., Box 387, Rosenberg, Texas 77471. TO: Defendant GATESCO, INC., by and through its attorney of record, Kawika Vellalos, Plaintiff ANGELA CLAIBORNE serves this Designation of Experts in compliance with the Court’s Docket Control Order. This designation also serves as a supplement to Plaintiff’ s Response to Disclosure. General Reservations Plaintiff submits these responses and objections without intending to waive and expressly reserves the right to change, modify, supplement, or clarify these responses and objections at any time before trial. In providing the information requested by Defendant, Plaintiff does not waive any objections as to the admissibility of such information in evidence. The inadvertent production of any privileged information or documents shall not be deemed to be a waiver of any applicable privilege with respect to such information, Retained Experts Dr. Todd Cowen Texas Physical Medicine & Rehabilitation Institute 2833 Babcock Road, Suite 110 San Antonio, Texas 78229 (210) 692-2000 Dr. Cowen is a medical expert. He possesses expertise and knowledge in his respective area. Specifically, he may testify about Plaintiff Angela Claiborne’s care, treatment, diagnosis, prognosis, causation, physical restrictions, reasonable costs for medical care in the past and future, and the need, if any, for future treatment. Dr. Cowen has charged Plaintiff approximately $6,500.00 for his time. Exhibit B to this Designation includes (1) Dr. Cowen’s report dated September 11, 2017, (2) Dr. Cowe testimony history. As discovery remains ongoing and Plaintiffs medical treatment continues, Dr. Cowen will continue to review relevant documents upon receipt. Currently, Dr. Cowen has reviewed the following documents in preparing his report: (95 pages) s Therapy Center Billing Therapy Center Medical hysical Therapy_Medical R000303 - RO00305 A. Claibome_ Republic Pain & Anesthesia Consultants Medical R000306 - RO00308 A. Claibome_ Republic Pain & Anesthesia R000301 - RO00302 A. Claibome_ Memorial Hermann Hospital Memorial City_Radiology R000262 - RO00300 A. Claibome_ Memorial Hermann Hospital Memorial R000222 - RO00261 A. Claibome_ Memorial Hermann Hospital Memorial RO000075 RO00221 A. Claibome_ Memorial Hermann Hospital Memorial RO000069 RO00072 A. Claibome_ Memorial Bone & Joint Clinic Billing R000073 RO000074 A. Claibome_ Memorial Bone & Joint Clinic Radiology RO000060 RO00068 A. Claibome_ Memorial Bone & Joint Clinic_Medical Pharmacy Pharmacy _ Advanced Diagnostics Diagnostics Healthcare_Billing (2) dvanced Diagnostics Hea Diagnostics Healthcare_Medical (2) nced Diagnostics Health imary Care Physicians SW R000448 - RO00452 A. Claibome_ Memorial Bone & Joint Clinic Medical R000436 - RO00444 A. Claiborne Memorial Bone & Joint Clinic_Medical - Updates R000445 - R000447 A. Claibome_ Memorial Bone & Joint Clinic_Billing R000432 - R000435 A. Claiborne Memorial Bone & Joint Clinic_Billing - Updates dvanced Diagnostic Hospita nced Diagnostic Hospital East_Radiology _ Advanced Diagnostics Healthcare_Radiology nced Diagnostic Hospital East_Medical MichaelJ. Welton, CPM, RPA 3279 E. Stanford Avenue Gilbert, AZ 85234 (480) 699-8289 Mr. Welton will testify about all aspects of liability. Mr. Welton will base his opinion upon his educational background, traini Mr. Welton has charged Plaintiff approximately $2,500.00 for his time. Exhibit D to this Designation includes: (1) Mr. Welton’s report dated October 18, 2017; and (2) aring his report: Plaintiff’ s Response to Request for Disclosure Plaintiffs Response to Interrogatories, Requests for Admission, and Request for Production Plaintiff’ s First Supplemental Response to Interrogatories, Admission and APTVC Answers to Interrogatories APTVC Response to Request for Production APTVC Response to Re APTVC Response to Request for Disclosure APTVC First Supplemental Response to Request for Production Plaintiff may call the following non-retained, expert witnesses to give expert testimony. The following doctors, nurses, therapists, medical technicians, and other healthcare providers have cared for and provided treatment to Angela Claibome. As such, they possess expertise and knowledge in their respective areas. This designation is made to permit the Plaintiff the opportunity to introduce evidence from these individuals which might be deemed in the nature of opinion or expert testimony. Specifically, these individuals may testify about the care, treatment, causation, physical restrictions, prognosis, diagnosis, reasonable costs for medical care. ACS Primary Care Physicians Advanced Diagnostic Hospital East 12950 East Freeway, Suite 100 Advanced Diagnostics Dr. Victoria Do AHK Neurology Dr. Ramiro Hernandez Dream Pharmacy 1140 Business Center Dr., Suite 103 Memorial Bone & Joint Dr. Zoran Cupic 1140 Business Center Dr., Suite 101 Memorial Hermann Memorial City Republic Pain & Anesthesia Select Physical Therapy 17360 Northwest Freeway South Texas Therapy Center Other Experts There may be other individuals who are designated as experts by parties, all of whom the Plaintiff reserves the right to call as expert witnesses. By making this cross-designation, Plaintiff does not waive the right to challenge the ability of the other parties’ experts to testify Plaintiff reserves the right to designate and call rebuttal expert witnesses, the identity of which cannot reasonably be anticipated at this time. Plaintiff reserves the right to challenge the testimony and qualifications of any expert designated by Defendants. Plaintiff reserves the right to supplement this designation. ARNOLD & ITKIN /s/ Noah M. Wexler Texas Bar No. 24032461 Noah M. Wexler Texas State Bar No. 24060816 Texas State Bar No. 24076086 Rebecca L. Adams Texas State Bar No. 24098255 6009 Memorial Drive Facsimile: (713) 222-3850 e-service@ arnolditkin.com wexler@ arnolditkin.com radams@ armolditkin.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been forwarded to the following counsel Noah M. Wexler