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Filing # 154186451 E-Filed 07/27/2022 03:49:57 PM
IN THE CIRCUIT COURT FOR THE TWENTIETH
JUDICIAL CIRCUIT IN AND FOR CHARLOTTE
COUNTY, STATE OF FLORIDA - CIVIL DIVISION
VENISSA DRIGGERS, as Personal
Representative of the Estate
of DAVID B. FLICK, Deceased,
Plaintiff,
vs. Case No 21-CA-000410
MARK BARCIA, HOOTERS OF PORT CHARLOTTE,
INC., BWR NORTH PORT, LLC d/b/a BUFFALO
WINGS AND RINGS, ATLANTA RESTURANT
PARTNERS, LLC d/b/a TGI FRIDAYS, and
JACKMONT HOSPITALITY, INC. d/b/a TGI FRIDAYS,
Defendants.
/
DEFENDANT, MARK BARCIA’S, FACT WITNESS LIST
COMES NOW, the Defendant, MARK BARCIA, by and through his undersigned counsel,
hereby files Defendant’s Fact Witness List, pursuant to the Amended Agreed Case Management
Plan and Order dated January 20, 2022, as follows:
1 Venissa Sherie Driggers a/k/a Venissa Sherie Flick, Survivor and Personal
Representative of the Estate of DAVID B. FLICK, Deceased
119 Earnest St.
Port Charlotte FL 33954
David Anthony Flick, Survivor
20267 Tralee Drive
Port Charlotte FL 33952
Jesse Lee Driggers, Decedent resided with Mr. Driggers
20289 Kinderkemac Ave.
Port Charlotte FL 33952
Mark Barcia, Defendant driver
1166 Cragmont Ave.
North Port FL 34288
00567334.DOCX
Michael P. Lauff, right front passenger in Barcia’s vehicle and with Barcia at TGI
Fridays, Hooters and BWR
21027 Glendale Ave.
Port Charlotte FL 33954
Mary E. Moulton, Lauff’s spouse; had verbal disturbance with Michael Lauff about
his intoxication and drinking with Barcia
21139 Glendale Ave.
Port Charlotte FL 33954
Michelle Moulton, witness to verbal disturbance between Mary Moulton and
Michael Lauff
21139 Glendale Ave.
Port Charlotte FL 33954
Taylor R. Green, driving actions of Barcia prior to crash, stopped at red traffic
signal beside Barcia, first on scene
2645 W. Marion Ave. #611
Punta Gorda FL 33950
Savannah D. Dawson, driving actions of Barcia prior to crash, stopped at red traffic
signal beside Barcia, first on scene
5038 Pinson Dr.
North Port FL 34288
10 Patricia A. Snider, driving actions of Barcia vehicle prior to crash, on her rear patio
and heard/saw vehicle
2709 Royal Palm Dr.
North Port FL 34288
11 Bradley A. Jarvis, driving actions of Barcia vehicle prior to crash, on his rear patio
and heard/saw vehicle
2725 Royal Palm Dr.
North Port FL 34288
12 Joseph S. Majorino, second vehicle to arrive on scene post-crash, witness observed
occupants exit truck
2747 Rebel Ln.
North Port FL 34286
13 Michelle Majorino, in second vehicle to arrive on scene post-crash
2747 Rebel Ln.
North Port FL 34286
00567334.DOCX
14 Pierre R. Louis, Uber driver and owner of Vehicle 2
701 Bayard St.
Port Charlotte FL 33948
15 Nicole F, Cimmino, left rear passenger in Vehicle 2
2027 Wheeling Ave.
North Port FL 34288
16 Ofc. Aaron R. Nick, Traffic Homicide Investigating Officer and arresting officer
17 Ofc. Alexander Fisher, went to Wings and Rings bar to investigate, spoke to
Bourlier and retrieved video surveillance from Bourlier for BWR; went to hospital
and spoke to Lauff; spoke to Mary Moulton; photographed Barcia and Lauff
injuries; assisted with marking scene.
18 Ofc. Guzman, search warrant for blood sample; marking scene.
19 Sgt. Tony Donohew, notified next of kin and medical examiner regarding David B.
Flick
20. Ofc. Greg Pierce, photographed 2008 Ford pick-up truck owned/driven by Barcia
and captured EDR of 2018 Toyota Camry owned/driven by Louis.
21 CSI Cortnie Stender, photographed 2018 Toyota Camry owned/driven by Louis
22 Ofc. McMenamin, retrieved blood kit from Ofc. A. Fisher at Sarasota Memorial
Hospital and delivered to NPPD.
23 Ofe. Francisco Aleman, on scene, collected statements from Dawson and Green
24. Ofc. Anderson
25 Ofe Burns
26. Ofc Coker
27. Ofe. Harvey
28 Ofe St. Jean
29 Ofte. Lagarce
30. Ofc. Mandel
31 Ofc Sineath
32. Ofe. Debra Hill, chain of custody regarding Barcia blood draw
33 Makayla Casey, chain of custody regarding Barcia blood draw
North Port Police Dept.
4980 City Hall Blvd.
North Port FL 34286
34 Dep. Millo
Charlotte County Sheriff's Office
992 Tamiami Trail
Port Charlotte FL 33953
35 Ashley Patrick, 911 operator
36 Daniel Wild, 911 operator
00567334.DOCX
37. Michelle Tutterow, ER nurse who withdrew blood samples from subjects at
hospital
2345 Bobcat Village Center
North Port FL 34288
38 Jeffrey Reich, Ambitrans and/or Sarasota Memorial Hospital North Port ER,
withdrew blood samples from Lauff
2345 Bobcat Village Center
Nort Port FL 34288
a
3 9 Kristie A. Shaw, FDLE Laboratory Analyst, analyzed Barcia blood draw sample
FDLE
500 W. Robinson St.
Orlando FL 32801
40. Sgt. Mark Stone
Sarasota County Jail
2020 Main Street
Sarasota FL 34237
41 North Port Fire Rescue EMS, Gerardo Rodriguez, expert EMT paramedic who
pronounced David B. Flick; Joshua Clements, expert EMT paramedic; James Byrd,
expert EMT; Nick Dezzi; Shawn Krajic; Stephen Kerr; Jorden McPherson; Mark
Postel; Michael Roman
PO Box 917320
Orlando FL 32891
42 Wilson A. Broussard, Jr., MD, expert medical examiner
43 Abby Andrus, Investigator
44 M. Helman, Autopsy Technician
District Twelve Medical Examiner
2001 Siesta Dr., Ste. 302
Sarasota FL 34239
45, University of Florida, Bruce A. Goldberger, Ph.D., F-ABFT, toxicologist for
medical examiner
Dept. of Pathology and Laboratory Medicine
4800 SW 35" Dr.
Gainesville FL 32608
46, SaraPath Diagnostics, Records Custodian, tissue samples for medical examiner
2001 Webber St.
Sarasota FL 34239
00567334. DOCX
47 Brasota Mortuary Transfer, Inc., Records Custodian, transferred Decedent’s body
to ME
509 15™ Ave. W.
Palmetto FL 34221
48 HOOTERS OF PORT CHARLOTTE, INC., Defendant, manager, and employees
on duty
2035 Colonial Blvd.
Fort Myers FL 33907
OR
13600 Tamiami Trail
Port Charlotte FL 33948
49 Byron Holley, Manager of Hooters who provided security video, names of staff,
and bar receipts, and identified Barcia on video.
50. Veronica Santiago, worked 12/31/19 10:30am, served alcoholic beverages to
Barcia
51 Leanelis Garcia, worked 12/31/19 10:30am and 4:15pm
52 Lindsey Hunt, worked 12/31/19 10:30am and 4:15pm
53 Samantha Monnier, worked 12/31/19 10:30am, “Obar”
54 Becca Anastasi, worked 12/31/19 10:30am, inside bar
55 Brittany Livingston, worked 12/31/19 10:30am
56. Katie Hinds, worked 12/31/19 10:30am
57. Thomas Hughes, Opening Mgr., DEF produced “Fly Notes” that he posted on D/A
58 Timothy Burgess, possibly a manager, DEF produced “Fly Notes” that he posted
regarding service on D/A
59. Adriana Locus, worked 12/31/19 4:15pm, outside bar
60. Wendy Otero, worked 12/31/19 4:15pm “Obar”
61 Daniela Applegate, worked 12/31/19 4:15pm
62 Emily Watson, worked 12/31/19 4:15pm
63 Lauren Poliachik, worked 12/31/19 4:15pm
64 Marissa Eubanks, worked 12/31/19 4:15pm
65 Larissa Calligirui, worked 12/31/19 1pm - 7pm, To Go
66. All parties to the lawsuit.
67. All persons listed in interrogatories or mentioned in the depositions taken herein.
68 All witnesses listed by any other party.
69. All witnesses necessary for impeachment or rebuttal purposes.
70 All witnesses listed by all parties.
71 All fact witnesses listed by Plaintiffs, without waiving objections thereto.
72. All persons named in the traffic accident report.
00567334.DOCX
73 All records custodians for all documents listed on Defendant’s exhibit list (and all
other witnesses needed to authenticate such documents.
74 Representatives from Plaintiff's PIP carrier.
75 Kolins Security Group, Russell Kolins, CCDI, BSSM, ICACP
National Security Experts & Consultants
1528 Walnut St., Ste. 600
Philadelphia PA 19102
Plaintiff's expert on topics of liquor liability, Dram Shop, premises
security/liability/safety, service and monitoring of alcohol use, alcohol policies and
procedures, alcohol related death, premises liability, crime prevention
716 Sherry Williams, translated and wrote Louis’ written statement
Address Unknown
77 Kiewet Corporation, Decedent’s employer
5100 W. Kennedy Blvd.
Tampa FL 33609
78 Corporate Representative of BWR NORTH PORT, LLC, d/b/a BUFFALO WINGS
AND RINGS.
79 Corporate Representative of HOOTERS OF PORT CHARLOTTE, INC.
80. Corporate Representative of ATLANTA RESTAURANT PARTNERS, LLC d/b/a
TGI FRIDAYS.
81 Corporate Representative of JACKMONT HOSPITALITY, INC. d/b/a TGI
FRIDAYS.
82. Any and all BWR employees as identified in Plaintiff's Amended Witness List filed
herein on July 12, 2022.
83 Any and all ATLANTA RESTAURANT PARTNERS, LLC d/b/a TGI FRIDAYS’
employees as identified in Plaintiff's Amended Witness List filed herein on July
12, 2022.
84 Any and all JACKMONT HOSPITALITY, INC. d/b/a TGI FRIDAYS’ employees
as identified in Plaintiff's Amended Witness List filed herein on July 12, 2022.
85 Any and all Records Custodians as identified in Plaintiff's Amended Witness List
filed herein on July 12, 2022.
86. All witnesses listed by any Defendant together with any amendments thereto.
00567334.DOCX
87. Plaintiff, VENISSA DRIGGERS, as Personal Representative of the Estate of
DAVID B. FLICK, Deceased.
88 Defendants, MARK BARCIA, HOOTERS OF PORT CHARLOTTE, INC., BWR
NORTH PORT, LLC d/b/a BUFFALO WINGS AND RINGS, ATLANTA
RESTAURANT PARTNERS, LLC d/b/a TGI FRIDAYS, and JACKMONT
HOSPITALITY, INC. d/b/a TGI FRIDAYS.
89. Any and all radiologists, pathologists, and/or physical therapists who have treated
Decedent, performed diagnostic testing or interpreted test results pertaining to the
Plaintiff's medical condition.
90. Any and all medical doctors and/or technicians who have treated Decedent,
performed diagnostic testing or interpreted test results pertaining to the Decedent’s
medical condition including rehab personnel.
o1 Any and all custodians of records for any and all medical or other health care
providers who treated Decedent.
92. Any videographer, photographer, of any surgery, medical procedure, and any other
medical treatment, or accident scene, Decedent’s injuries, Decedent’s lifestyle.
93 Any and all custodians of records for any and all vehicle repair establishments who
repaired and/or prepared estimates for repairs to all vehicles involved in the
accident.
94 Any and all officers who examined the scene of the accident and reported on the
accident.
95 Any and all individuals who took photographs or videos of the accident and the
surrounding area.
The Defendant reserves the right to list additional witnesses with immediate notice
to all other parties to this lawsuit.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent via
email to Randall L. Spivey, Esquire (randall@spiveylaw.com), SPIVEY LAW FIRM, 13400
Parker Commons Boulevard, Fort Myers, Florida 33912; Cristobal A. Casal, Esquire
00567334.DOCX
(eserviceftm@conroysimberg.com), CONROY SIMBERG, 12730 New Brittany Blvd., Suite 300,
Fort Myers FL 33907; Mitchel Chusid, Esquire mchusid@ritterchusid.com), RITTER CHUSID
LLP, 5850 Coral Ridge Drive, Suite 201, Coral Springs FL 33076; and Howard W. Holden,
Esquire (LUKSFTM-Pleadings@Is-law.com), LUKS, SANTANIELLO, PETRILLO & COHEN,
LZ,Joe
1422 Hendry Street, Third Floor, Fort Myers FL 33901, on this 7 day of July 2022.
T.R. UNIC
vo
Florida B mb 58169
UNI JENSEN, P.A.
SoythSt Ban uilding, Second Floor
1$1 le Road
rinity, > Florida 34655
hone (727)723 -3772
ax (727)723-1421
Attorney for Defendant
Primary Email: service@unicesalzman.com
Secondary Emails: jjensen@unicesalzman.com
asiller@unicesalzman.com
dcantwell@unicesalzman.com
00567334.DOCX
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Filing # 154186451 E-Filed 07/27/2022 03:49:57 PM IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, STATE OF FLORIDA - CIVIL DIVISION VENISSA DRIGGERS, as Personal Representative of the Estate of DAVID B. FLICK, Deceased, Plaintiff, vs. Case No 21-CA-000410 MARK BARCIA, HOOTERS OF PORT CHARLOTTE, INC., BWR NORTH PORT, LLC d/b/a BUFFALO WINGS AND RINGS, ATLANTA RESTURANT PARTNERS, LLC d/b/a TGI FRIDAYS, and JACKMONT HOSPITALITY, INC. d/b/a TGI FRIDAYS, Defendants. / DEFENDANT, MARK BARCIA’S, FACT WITNESS LIST COMES NOW, the Defendant, MARK BARCIA, by and through his undersigned counsel, hereby files Defendant’s Fact Witness List, pursuant to the Amended Agreed Case Management Plan and Order dated January 20, 2022, as follows: 1 Venissa Sherie Driggers a/k/a Venissa Sherie Flick, Survivor and Personal Representative of the Estate of DAVID B. FLICK, Deceased 119 Earnest St. Port Charlotte FL 33954 David Anthony Flick, Survivor 20267 Tralee Drive Port Charlotte FL 33952 Jesse Lee Driggers, Decedent resided with Mr. Driggers 20289 Kinderkemac Ave. Port Charlotte FL 33952 Mark Barcia, Defendant driver 1166 Cragmont Ave. North Port FL 34288 00567334.DOCX Michael P. Lauff, right front passenger in Barcia’s vehicle and with Barcia at TGI Fridays, Hooters and BWR 21027 Glendale Ave. Port Charlotte FL 33954 Mary E. Moulton, Lauff’s spouse; had verbal disturbance with Michael Lauff about his intoxication and drinking with Barcia 21139 Glendale Ave. Port Charlotte FL 33954 Michelle Moulton, witness to verbal disturbance between Mary Moulton and Michael Lauff 21139 Glendale Ave. Port Charlotte FL 33954 Taylor R. Green, driving actions of Barcia prior to crash, stopped at red traffic signal beside Barcia, first on scene 2645 W. Marion Ave. #611 Punta Gorda FL 33950 Savannah D. Dawson, driving actions of Barcia prior to crash, stopped at red traffic signal beside Barcia, first on scene 5038 Pinson Dr. North Port FL 34288 10 Patricia A. Snider, driving actions of Barcia vehicle prior to crash, on her rear patio and heard/saw vehicle 2709 Royal Palm Dr. North Port FL 34288 11 Bradley A. Jarvis, driving actions of Barcia vehicle prior to crash, on his rear patio and heard/saw vehicle 2725 Royal Palm Dr. North Port FL 34288 12 Joseph S. Majorino, second vehicle to arrive on scene post-crash, witness observed occupants exit truck 2747 Rebel Ln. North Port FL 34286 13 Michelle Majorino, in second vehicle to arrive on scene post-crash 2747 Rebel Ln. North Port FL 34286 00567334.DOCX 14 Pierre R. Louis, Uber driver and owner of Vehicle 2 701 Bayard St. Port Charlotte FL 33948 15 Nicole F, Cimmino, left rear passenger in Vehicle 2 2027 Wheeling Ave. North Port FL 34288 16 Ofc. Aaron R. Nick, Traffic Homicide Investigating Officer and arresting officer 17 Ofc. Alexander Fisher, went to Wings and Rings bar to investigate, spoke to Bourlier and retrieved video surveillance from Bourlier for BWR; went to hospital and spoke to Lauff; spoke to Mary Moulton; photographed Barcia and Lauff injuries; assisted with marking scene. 18 Ofc. Guzman, search warrant for blood sample; marking scene. 19 Sgt. Tony Donohew, notified next of kin and medical examiner regarding David B. Flick 20. Ofc. Greg Pierce, photographed 2008 Ford pick-up truck owned/driven by Barcia and captured EDR of 2018 Toyota Camry owned/driven by Louis. 21 CSI Cortnie Stender, photographed 2018 Toyota Camry owned/driven by Louis 22 Ofc. McMenamin, retrieved blood kit from Ofc. A. Fisher at Sarasota Memorial Hospital and delivered to NPPD. 23 Ofe. Francisco Aleman, on scene, collected statements from Dawson and Green 24. Ofc. Anderson 25 Ofe Burns 26. Ofc Coker 27. Ofe. Harvey 28 Ofe St. Jean 29 Ofte. Lagarce 30. Ofc. Mandel 31 Ofc Sineath 32. Ofe. Debra Hill, chain of custody regarding Barcia blood draw 33 Makayla Casey, chain of custody regarding Barcia blood draw North Port Police Dept. 4980 City Hall Blvd. North Port FL 34286 34 Dep. Millo Charlotte County Sheriff's Office 992 Tamiami Trail Port Charlotte FL 33953 35 Ashley Patrick, 911 operator 36 Daniel Wild, 911 operator 00567334.DOCX 37. Michelle Tutterow, ER nurse who withdrew blood samples from subjects at hospital 2345 Bobcat Village Center North Port FL 34288 38 Jeffrey Reich, Ambitrans and/or Sarasota Memorial Hospital North Port ER, withdrew blood samples from Lauff 2345 Bobcat Village Center Nort Port FL 34288 a 3 9 Kristie A. Shaw, FDLE Laboratory Analyst, analyzed Barcia blood draw sample FDLE 500 W. Robinson St. Orlando FL 32801 40. Sgt. Mark Stone Sarasota County Jail 2020 Main Street Sarasota FL 34237 41 North Port Fire Rescue EMS, Gerardo Rodriguez, expert EMT paramedic who pronounced David B. Flick; Joshua Clements, expert EMT paramedic; James Byrd, expert EMT; Nick Dezzi; Shawn Krajic; Stephen Kerr; Jorden McPherson; Mark Postel; Michael Roman PO Box 917320 Orlando FL 32891 42 Wilson A. Broussard, Jr., MD, expert medical examiner 43 Abby Andrus, Investigator 44 M. Helman, Autopsy Technician District Twelve Medical Examiner 2001 Siesta Dr., Ste. 302 Sarasota FL 34239 45, University of Florida, Bruce A. Goldberger, Ph.D., F-ABFT, toxicologist for medical examiner Dept. of Pathology and Laboratory Medicine 4800 SW 35" Dr. Gainesville FL 32608 46, SaraPath Diagnostics, Records Custodian, tissue samples for medical examiner 2001 Webber St. Sarasota FL 34239 00567334. DOCX 47 Brasota Mortuary Transfer, Inc., Records Custodian, transferred Decedent’s body to ME 509 15™ Ave. W. Palmetto FL 34221 48 HOOTERS OF PORT CHARLOTTE, INC., Defendant, manager, and employees on duty 2035 Colonial Blvd. Fort Myers FL 33907 OR 13600 Tamiami Trail Port Charlotte FL 33948 49 Byron Holley, Manager of Hooters who provided security video, names of staff, and bar receipts, and identified Barcia on video. 50. Veronica Santiago, worked 12/31/19 10:30am, served alcoholic beverages to Barcia 51 Leanelis Garcia, worked 12/31/19 10:30am and 4:15pm 52 Lindsey Hunt, worked 12/31/19 10:30am and 4:15pm 53 Samantha Monnier, worked 12/31/19 10:30am, “Obar” 54 Becca Anastasi, worked 12/31/19 10:30am, inside bar 55 Brittany Livingston, worked 12/31/19 10:30am 56. Katie Hinds, worked 12/31/19 10:30am 57. Thomas Hughes, Opening Mgr., DEF produced “Fly Notes” that he posted on D/A 58 Timothy Burgess, possibly a manager, DEF produced “Fly Notes” that he posted regarding service on D/A 59. Adriana Locus, worked 12/31/19 4:15pm, outside bar 60. Wendy Otero, worked 12/31/19 4:15pm “Obar” 61 Daniela Applegate, worked 12/31/19 4:15pm 62 Emily Watson, worked 12/31/19 4:15pm 63 Lauren Poliachik, worked 12/31/19 4:15pm 64 Marissa Eubanks, worked 12/31/19 4:15pm 65 Larissa Calligirui, worked 12/31/19 1pm - 7pm, To Go 66. All parties to the lawsuit. 67. All persons listed in interrogatories or mentioned in the depositions taken herein. 68 All witnesses listed by any other party. 69. All witnesses necessary for impeachment or rebuttal purposes. 70 All witnesses listed by all parties. 71 All fact witnesses listed by Plaintiffs, without waiving objections thereto. 72. All persons named in the traffic accident report. 00567334.DOCX 73 All records custodians for all documents listed on Defendant’s exhibit list (and all other witnesses needed to authenticate such documents. 74 Representatives from Plaintiff's PIP carrier. 75 Kolins Security Group, Russell Kolins, CCDI, BSSM, ICACP National Security Experts & Consultants 1528 Walnut St., Ste. 600 Philadelphia PA 19102 Plaintiff's expert on topics of liquor liability, Dram Shop, premises security/liability/safety, service and monitoring of alcohol use, alcohol policies and procedures, alcohol related death, premises liability, crime prevention 716 Sherry Williams, translated and wrote Louis’ written statement Address Unknown 77 Kiewet Corporation, Decedent’s employer 5100 W. Kennedy Blvd. Tampa FL 33609 78 Corporate Representative of BWR NORTH PORT, LLC, d/b/a BUFFALO WINGS AND RINGS. 79 Corporate Representative of HOOTERS OF PORT CHARLOTTE, INC. 80. Corporate Representative of ATLANTA RESTAURANT PARTNERS, LLC d/b/a TGI FRIDAYS. 81 Corporate Representative of JACKMONT HOSPITALITY, INC. d/b/a TGI FRIDAYS. 82. Any and all BWR employees as identified in Plaintiff's Amended Witness List filed herein on July 12, 2022. 83 Any and all ATLANTA RESTAURANT PARTNERS, LLC d/b/a TGI FRIDAYS’ employees as identified in Plaintiff's Amended Witness List filed herein on July 12, 2022. 84 Any and all JACKMONT HOSPITALITY, INC. d/b/a TGI FRIDAYS’ employees as identified in Plaintiff's Amended Witness List filed herein on July 12, 2022. 85 Any and all Records Custodians as identified in Plaintiff's Amended Witness List filed herein on July 12, 2022. 86. All witnesses listed by any Defendant together with any amendments thereto. 00567334.DOCX 87. Plaintiff, VENISSA DRIGGERS, as Personal Representative of the Estate of DAVID B. FLICK, Deceased. 88 Defendants, MARK BARCIA, HOOTERS OF PORT CHARLOTTE, INC., BWR NORTH PORT, LLC d/b/a BUFFALO WINGS AND RINGS, ATLANTA RESTAURANT PARTNERS, LLC d/b/a TGI FRIDAYS, and JACKMONT HOSPITALITY, INC. d/b/a TGI FRIDAYS. 89. Any and all radiologists, pathologists, and/or physical therapists who have treated Decedent, performed diagnostic testing or interpreted test results pertaining to the Plaintiff's medical condition. 90. Any and all medical doctors and/or technicians who have treated Decedent, performed diagnostic testing or interpreted test results pertaining to the Decedent’s medical condition including rehab personnel. o1 Any and all custodians of records for any and all medical or other health care providers who treated Decedent. 92. Any videographer, photographer, of any surgery, medical procedure, and any other medical treatment, or accident scene, Decedent’s injuries, Decedent’s lifestyle. 93 Any and all custodians of records for any and all vehicle repair establishments who repaired and/or prepared estimates for repairs to all vehicles involved in the accident. 94 Any and all officers who examined the scene of the accident and reported on the accident. 95 Any and all individuals who took photographs or videos of the accident and the surrounding area. The Defendant reserves the right to list additional witnesses with immediate notice to all other parties to this lawsuit. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent via email to Randall L. Spivey, Esquire (randall@spiveylaw.com), SPIVEY LAW FIRM, 13400 Parker Commons Boulevard, Fort Myers, Florida 33912; Cristobal A. Casal, Esquire 00567334.DOCX (eserviceftm@conroysimberg.com), CONROY SIMBERG, 12730 New Brittany Blvd., Suite 300, Fort Myers FL 33907; Mitchel Chusid, Esquire mchusid@ritterchusid.com), RITTER CHUSID LLP, 5850 Coral Ridge Drive, Suite 201, Coral Springs FL 33076; and Howard W. Holden, Esquire (LUKSFTM-Pleadings@Is-law.com), LUKS, SANTANIELLO, PETRILLO & COHEN, LZ,Joe 1422 Hendry Street, Third Floor, Fort Myers FL 33901, on this 7 day of July 2022. T.R. UNIC vo Florida B mb 58169 UNI JENSEN, P.A. SoythSt Ban uilding, Second Floor 1$1 le Road rinity, > Florida 34655 hone (727)723 -3772 ax (727)723-1421 Attorney for Defendant Primary Email: service@unicesalzman.com Secondary Emails: jjensen@unicesalzman.com asiller@unicesalzman.com dcantwell@unicesalzman.com 00567334.DOCX