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Filing # 168582574 E-Filed 03/13/2023 12:42:35 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT, INAND FOR
OSCEOLA COUNTY, FLORIDA
ASBEL ALEXANDER LLERENA, CASE NO.: 2020-CA-002872
Plaintiff,
V.
ADRIAN RODRIGUEZ CHAVEZ AND
GRANNY'S GARDEN Il, INC.,
Defendants.
|
NOTICE OF SERVICE OF DEFENDANT, ADRIAN RODRIGUEZ CHAVEZ’S,
EXPERT INTERROGATORIES TO PLAINTIFF
Defendant, ADRIAN RODRIGUEZ CHAVEZ (“Defendant”), and hereby propounds
these Expert Interrogatories to Plaintiff, ASBEL ALEXANDER LLERENA, to be answered
within 30 days of the service herein, in accordance with the Florida Rules of Civil
Procedure.
An executed copy of this certificate is being filed with the Court as provided by
the Florida Rules of Civil Procedure.
[Certificate of Service on Following Page]
Page 1
COLE, SCOTT & KISSANE, P.A.
CASE NO.: 2020-CA-002872
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 13th day of March, 2023, a true and correct copy
of the foregoing was filed with the Clerk of Osceola County by using the Florida Courts e-
Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: Melissa Alzate, Esq., Morgan & Morgan, P.A.,
malzate@forthepeople.com;imerlos@forthepeople.com, 198 Broadway Avenue,
Kissimmee, FL 34741, (407) 452-1597/(407) 452-1623 (F), Attorney for Plaintiff, Asbel
Alexander Llerena.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant ADRIAN RODRIGUEZ
CHAVEZ AND GRANNY'S GARDEN II, INC.
Tower Place, Suite 400
1900 Summit Tower Boulevard
Orlando, Florida 32810
Telephone (321) 972-0094
Facsimile (321) 972-0099
Primary e-mail: melissa.crowley@csklegal.com
Secondary e-mail: harley.clement@csklegal.com
Alternate e-mail: gabrielle.porcaro@csklegal.com
By: /s/ Harley C. Clement
MELISSA D. CROWLEY
Florida Bar No.: 90984
HARLEY C. CLEMENT
Florida Bar No.: 1019181
0487.2384-00
Page 2
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2020-CA-002872
DEFENDANT’S EXPERT INTERROGATORIES TO PLAINTIFF
1. Please state the name and professional address for each expert witness you
expect to testify at trial in this cause. For each expert state the scope of
employment in the pending case and the compensation for such service.
RESPONSE:
2. For each expert listed, please state the expert’s general litigation experience,
including the percentage of work performed for Plaintiffs and Defendants.
RESPONSE:
3. For each expert listed, please state the identity of other cases, within the last three
(3) years, in which the expert has testified by deposition or at trial.
RESPONSE:
4. For each expert listed, please give an approximation of the portion of the expert’s
involvement as an expert witness, which may be based on the number of hours,
percentage of hours, or percentage of earned income derived from serving as an
expert witness.
RESPONSE:
5. For each expert listed, please state the number of times that each expert's
deposition was taken in the preceding calendar year when the expert was:
(a) The treating physician;
(b) The defense physician and/or independent medical examiner;
(c) Other.
RESPONSE:
6. For each expert listed, please state the number of times each expert appeared in
Court to testify within the last calendar year. Please include times, and where the
Page 3
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2020-CA-002872
expert was called to testify in more than one courtroom on a particular date,
counting each time as a separate Court appearance.
RESPONSE:
7. For each Court appearance listed in Interrogatory No.6 above, please state the
number of times the expert was called to testify:
(a) By Plaintiffs’ attorney as a treating physician;
(b) By Plaintiffs’ attorney as the defense examiner;
(c) By Defendants’ attorney as a defense examiner;
(d) By Defendants’ attorney as a treating or consulting physician.
RESPONSE:
8. With regard to each expert listed above, state his/her background, education, and
experience which qualifies him/her to testify as an expert.
RESPONSE:
9. Give the name or title of each paper which each expert has authored in the area
of his/her expertise.
RESPONSE:
10. State the name, volume and page number of the publication in which each article
or paper listed above can be found.
RESPONSE:
11. | State the substance of the facts to which each expert listed above is expected to
testify.
RESPONSE:
Page 4
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2020-CA-002872
12. | State the opinion to which each expert listed above is expected to testify.
RESPONSE:
13. | Give a summary of grounds or basis for each opinion stated above.
RESPONSE:
14. Any and all monies paid to all experts listed within Plaintiffs Expert Witness
Disclosure by Morgan & Morgan (all offices) in the past three years.
RESPONSE:
Page 5
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
ASBEL ALEXANDER LLERENA
ASBEL ALEXANDER LLERENA, being duly sworn, deposes and says that the
attached answers to Defendant’s Expert Interrogatories are true and correct to the best
of his/ner knowledge, information and belief.
STATE OF
COUNTY OF
Sworn to and subscribed before me by means of [| physical presence or (| online
notarization, this day of , 2023, who is personally known to me or who
has produced as identification.
NOTARY PUBLIC, State of
My Commission Expires:
Page
6
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
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Filing # 168582574 E-Filed 03/13/2023 12:42:35 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, INAND FOR OSCEOLA COUNTY, FLORIDA ASBEL ALEXANDER LLERENA, CASE NO.: 2020-CA-002872 Plaintiff, V. ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN Il, INC., Defendants. | NOTICE OF SERVICE OF DEFENDANT, ADRIAN RODRIGUEZ CHAVEZ’S, EXPERT INTERROGATORIES TO PLAINTIFF Defendant, ADRIAN RODRIGUEZ CHAVEZ (“Defendant”), and hereby propounds these Expert Interrogatories to Plaintiff, ASBEL ALEXANDER LLERENA, to be answered within 30 days of the service herein, in accordance with the Florida Rules of Civil Procedure. An executed copy of this certificate is being filed with the Court as provided by the Florida Rules of Civil Procedure. [Certificate of Service on Following Page] Page 1 COLE, SCOTT & KISSANE, P.A. CASE NO.: 2020-CA-002872 CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 13th day of March, 2023, a true and correct copy of the foregoing was filed with the Clerk of Osceola County by using the Florida Courts e- Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Melissa Alzate, Esq., Morgan & Morgan, P.A., malzate@forthepeople.com;imerlos@forthepeople.com, 198 Broadway Avenue, Kissimmee, FL 34741, (407) 452-1597/(407) 452-1623 (F), Attorney for Plaintiff, Asbel Alexander Llerena. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC. Tower Place, Suite 400 1900 Summit Tower Boulevard Orlando, Florida 32810 Telephone (321) 972-0094 Facsimile (321) 972-0099 Primary e-mail: melissa.crowley@csklegal.com Secondary e-mail: harley.clement@csklegal.com Alternate e-mail: gabrielle.porcaro@csklegal.com By: /s/ Harley C. Clement MELISSA D. CROWLEY Florida Bar No.: 90984 HARLEY C. CLEMENT Florida Bar No.: 1019181 0487.2384-00 Page 2 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2020-CA-002872 DEFENDANT’S EXPERT INTERROGATORIES TO PLAINTIFF 1. Please state the name and professional address for each expert witness you expect to testify at trial in this cause. For each expert state the scope of employment in the pending case and the compensation for such service. RESPONSE: 2. For each expert listed, please state the expert’s general litigation experience, including the percentage of work performed for Plaintiffs and Defendants. RESPONSE: 3. For each expert listed, please state the identity of other cases, within the last three (3) years, in which the expert has testified by deposition or at trial. RESPONSE: 4. For each expert listed, please give an approximation of the portion of the expert’s involvement as an expert witness, which may be based on the number of hours, percentage of hours, or percentage of earned income derived from serving as an expert witness. RESPONSE: 5. For each expert listed, please state the number of times that each expert's deposition was taken in the preceding calendar year when the expert was: (a) The treating physician; (b) The defense physician and/or independent medical examiner; (c) Other. RESPONSE: 6. For each expert listed, please state the number of times each expert appeared in Court to testify within the last calendar year. Please include times, and where the Page 3 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2020-CA-002872 expert was called to testify in more than one courtroom on a particular date, counting each time as a separate Court appearance. RESPONSE: 7. For each Court appearance listed in Interrogatory No.6 above, please state the number of times the expert was called to testify: (a) By Plaintiffs’ attorney as a treating physician; (b) By Plaintiffs’ attorney as the defense examiner; (c) By Defendants’ attorney as a defense examiner; (d) By Defendants’ attorney as a treating or consulting physician. RESPONSE: 8. With regard to each expert listed above, state his/her background, education, and experience which qualifies him/her to testify as an expert. RESPONSE: 9. Give the name or title of each paper which each expert has authored in the area of his/her expertise. RESPONSE: 10. State the name, volume and page number of the publication in which each article or paper listed above can be found. RESPONSE: 11. | State the substance of the facts to which each expert listed above is expected to testify. RESPONSE: Page 4 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX CASE NO.: 2020-CA-002872 12. | State the opinion to which each expert listed above is expected to testify. RESPONSE: 13. | Give a summary of grounds or basis for each opinion stated above. RESPONSE: 14. Any and all monies paid to all experts listed within Plaintiffs Expert Witness Disclosure by Morgan & Morgan (all offices) in the past three years. RESPONSE: Page 5 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX ASBEL ALEXANDER LLERENA ASBEL ALEXANDER LLERENA, being duly sworn, deposes and says that the attached answers to Defendant’s Expert Interrogatories are true and correct to the best of his/ner knowledge, information and belief. STATE OF COUNTY OF Sworn to and subscribed before me by means of [| physical presence or (| online notarization, this day of , 2023, who is personally known to me or who has produced as identification. NOTARY PUBLIC, State of My Commission Expires: Page 6 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX