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Filing # 144750938 E-Filed 02/28/2022 04:09:23 PM
IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL
CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA
CASE NO. 2020-CA-002067
JOHN VALIS,
PLAINTIFF,
V.
CHRISTINE HITCHCOCK AND
USAA CASUALTY INSURANCE COMPANY,
DEFENDANTS.
/
DEFENDANT, CHRISTINE HITCHCOCK’S DISCLOSURE OF EXPERT WITNESSES
Defendant, CHRISTINE HITCHCOCK, by and through her undersigned counsel, and in
accordance with the Trial Order, files this disclosure of Expert Witnesses and Treating
Physicians for the use of trial of this matter.
1 Dr. Chaim Rogozinski
Rogozinski Orthopedic Clinic
3716 University Blvd South
Suite 3
Jacksonville, FL 32216
Area of Expertise: Orthopedic Surgeon
Dr. Rogozinski is an orthopedic surgeon. Dr. Rogozinski may testify based on
his review of the Plaintiffs medical records, MRIs and diagnostic tests, his
physical examination, discovery materials and his training and experience in
medicine with a specialization in orthopedics. His testimony may include
opinion of the plaintiffs physical condition as a result of _ the injuries allegedly
sustained in the incident relevant to this case, and/or any prior or subsequent
injuries or conditions, and/or the causal connection between the alleged injuries
and the subject incident, as well as discussion of plaintiff's medical care and the
medical expenses allegedly related to this case, plaintiffs ability concerning
employment and physical activities, and a discussion of whether the injuries are
permanent, and whether future medical care is necessary because of these injuries
and/or related expenses.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/28/2022 06:38:00 PM
Dr. Dennis Wulfeck
MBB Radiology
Prominence 600
8375 Dix Ellis Trail, Suite 201
Jacksonville, FL 32256
Area of Expertise: Radiology
Dr. Wulfeck may testify based on his review of the Plaintiffs medical records,
MRIs and diagnostic tests, discovery materials and his training and experience in
medicine with a specialization in radiology. His testimony may include
opinion of the plaintiffs physical condition as a result of the injuries allegedly
sustained in the incident relevant to this case, and/or any prior or subsequent
injuries or conditions, and/or the causal connection between the alleged injuries
and the subject incident, as well as discussion of plaintiffs medical care and the
medical expenses allegedly related to this case, plaintiff's ability concerning
employment and physical activities, and a discussion of whether the injuries are
permanent, and whether future medical care is necessary because of these injuries
and/or related expenses.
All treating or examining physicians of Plaintiff before and after the date of the
accident.
All radiologists who interpreted Plaintiff's medical films before and after the date
of accident.
All medical providers identified in responses to the parties’ written discovery
requests.
All medical providers disclosed in deposition transcripts.
Any and all expert witnesses who, due to the nature of continuing discovery, may
hereafter be retained in anticipation of giving expert opinion testimony at trial,
subject to prompt and timely disclosure to the Plaintiff.
Any and all physicians who have performed or will perform prior to trial an
independent medical examination of Plaintiff or review of medical records.
Impeachment and/or rebuttal expert witnesses in response to Plaintiff’s expert
witness disclosure.
10. Discovery is ongoing and investigation is continuing and, therefore, Defendant
reserves the right to call any witnesses identified during the discovery process.
11 Discovery is ongoing and investigation continuing, and, therefore, Defendant
reserves the right to amend and/or supplement the above witness list.
12 Defendant reserves the right to amend and/or supplement this list with proper
notice to all parties since discovery is still ongoing.
CERTIFICATE OF SERVICE
The document contains no confidential or sensitive information or that any such
confidential or sensitive language has been properly protected by complying with the provisions
of Rule 2.420 and 2.425. I HEREBY CERTIFY that a true and correct copy of the foregoing has
been furnished by electronic filing to Michael D. Marrese, Esquire, 76 South Laura Street, Ste.
110, Jacksonville, FL 32202, Mmarrese@forthepeople.com; jlow@forthepeople.com;
pceallaremi@forthepeople.com, Kathleen A. Carlson, Esquire, 200 West Forsyth St., Suite 1400,
Jacksonville, FL 32202, KACarlson@MDWCG.com; hahildebrand@MDWCG.com on this 28th
day of February , 2022.
PAUL M. EZA, ESQUIRE
Fla. Bar No. 68708
Law Offices of Sonya S. Wesner
200 East Robinson Street, Suite 510
Orlando, FL 32801
Telephone: (407) 393-9100
Direct Dial: (904) 489-6585
Secretary: (407) 393-9410
Paralegal: (407) 393-9097
Fax: (877) 499-6079
Primary EMail:JAXSMAIL@nationwide.com
Attorneys for Defendants
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Filing # 144750938 E-Filed 02/28/2022 04:09:23 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA CASE NO. 2020-CA-002067 JOHN VALIS, PLAINTIFF, V. CHRISTINE HITCHCOCK AND USAA CASUALTY INSURANCE COMPANY, DEFENDANTS. / DEFENDANT, CHRISTINE HITCHCOCK’S DISCLOSURE OF EXPERT WITNESSES Defendant, CHRISTINE HITCHCOCK, by and through her undersigned counsel, and in accordance with the Trial Order, files this disclosure of Expert Witnesses and Treating Physicians for the use of trial of this matter. 1 Dr. Chaim Rogozinski Rogozinski Orthopedic Clinic 3716 University Blvd South Suite 3 Jacksonville, FL 32216 Area of Expertise: Orthopedic Surgeon Dr. Rogozinski is an orthopedic surgeon. Dr. Rogozinski may testify based on his review of the Plaintiffs medical records, MRIs and diagnostic tests, his physical examination, discovery materials and his training and experience in medicine with a specialization in orthopedics. His testimony may include opinion of the plaintiffs physical condition as a result of _ the injuries allegedly sustained in the incident relevant to this case, and/or any prior or subsequent injuries or conditions, and/or the causal connection between the alleged injuries and the subject incident, as well as discussion of plaintiff's medical care and the medical expenses allegedly related to this case, plaintiffs ability concerning employment and physical activities, and a discussion of whether the injuries are permanent, and whether future medical care is necessary because of these injuries and/or related expenses. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/28/2022 06:38:00 PM Dr. Dennis Wulfeck MBB Radiology Prominence 600 8375 Dix Ellis Trail, Suite 201 Jacksonville, FL 32256 Area of Expertise: Radiology Dr. Wulfeck may testify based on his review of the Plaintiffs medical records, MRIs and diagnostic tests, discovery materials and his training and experience in medicine with a specialization in radiology. His testimony may include opinion of the plaintiffs physical condition as a result of the injuries allegedly sustained in the incident relevant to this case, and/or any prior or subsequent injuries or conditions, and/or the causal connection between the alleged injuries and the subject incident, as well as discussion of plaintiffs medical care and the medical expenses allegedly related to this case, plaintiff's ability concerning employment and physical activities, and a discussion of whether the injuries are permanent, and whether future medical care is necessary because of these injuries and/or related expenses. All treating or examining physicians of Plaintiff before and after the date of the accident. All radiologists who interpreted Plaintiff's medical films before and after the date of accident. All medical providers identified in responses to the parties’ written discovery requests. All medical providers disclosed in deposition transcripts. Any and all expert witnesses who, due to the nature of continuing discovery, may hereafter be retained in anticipation of giving expert opinion testimony at trial, subject to prompt and timely disclosure to the Plaintiff. Any and all physicians who have performed or will perform prior to trial an independent medical examination of Plaintiff or review of medical records. Impeachment and/or rebuttal expert witnesses in response to Plaintiff’s expert witness disclosure. 10. Discovery is ongoing and investigation is continuing and, therefore, Defendant reserves the right to call any witnesses identified during the discovery process. 11 Discovery is ongoing and investigation continuing, and, therefore, Defendant reserves the right to amend and/or supplement the above witness list. 12 Defendant reserves the right to amend and/or supplement this list with proper notice to all parties since discovery is still ongoing. CERTIFICATE OF SERVICE The document contains no confidential or sensitive information or that any such confidential or sensitive language has been properly protected by complying with the provisions of Rule 2.420 and 2.425. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic filing to Michael D. Marrese, Esquire, 76 South Laura Street, Ste. 110, Jacksonville, FL 32202, Mmarrese@forthepeople.com; jlow@forthepeople.com; pceallaremi@forthepeople.com, Kathleen A. Carlson, Esquire, 200 West Forsyth St., Suite 1400, Jacksonville, FL 32202, KACarlson@MDWCG.com; hahildebrand@MDWCG.com on this 28th day of February , 2022. PAUL M. EZA, ESQUIRE Fla. Bar No. 68708 Law Offices of Sonya S. Wesner 200 East Robinson Street, Suite 510 Orlando, FL 32801 Telephone: (407) 393-9100 Direct Dial: (904) 489-6585 Secretary: (407) 393-9410 Paralegal: (407) 393-9097 Fax: (877) 499-6079 Primary EMail:JAXSMAIL@nationwide.com Attorneys for Defendants