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Filing # 166898096 E-Filed 02/15/2023 05:13:45 PM
IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 082021CA000968XXXXXX
Plaintiff,
Vv.
MICHAEL G. EDWARDS and HHS
ENVIRONMENTAL SERVICES, LLC
Defendants.
/
DEFENDANTS’ AMENDED EXHIBIT LIST
Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES,
LLC., by and through the undersigned attorneys, and pursuant to this Court’s Trial Order,
submits the following Amended Exhibit List as follows:
EXHIBIT LIST
Any and all photographs, diagrams, charts, maps, or depictions of the scene of the
incident.
Any and all charts, diagrams, models, or treatises utilized by any of Plaintiffs physicians
and/or healthcare providers, or by Plaintiff or his witnesses.
Curriculum vitae of any experts or witnesses.
Without waiving any objection, all records relied upon by the parties’ experts.
All pleadings in this lawsuit.
Any and all medical bills, medical records, medical reports, hospital records and
diagnostic tests relating to Plaintiff.
Any and all x-rays, MRI studies, arthrograms or other diagnostic tests pertaining to
Plaintiff.
Any and all transcripts of depositions taken in this case and exhibits to same.
Without waiving any objection, any and all exhibits listed by all other parties.
10. Any and all discovery which has taken place in this case.
11 Any and all interrogatories, requests for production and requests for admissions and
responses to same.
12. Any and all documents produced pursuant to subpoenas in this case.
13 Any and all documents produced by plaintiff during the course of this lawsuit.
14 Any and all applicable Ordinances or Statues.
15 Any and all applicable Florida Statutes.
16 Any and all records and/or evidence of collateral source payments to the Plaintiff.
17 Without waiving any objection, any and all reports prepared by the parties’ expert
witnesses.
18. Any and all demonstrative aids, drawings, illustrations, models, exemplars, and/or
photographs of same.
19. Enlargements of any exhibit otherwise listed.
20. Any and all doctors or medical care providers who have seen the Plaintiff both before and
after the accident which is the subject of this lawsuit.
21 Any and all income tax returns, W-2s, Social Security earnings statements of Plaintiff
and all written evidence of Plaintiff's income.
22. Without waiving any objection, any and all exhibits listed in all Pre-Trial Witness &
Exhibit Lists of parties in this case.
23 Such other and further impeachment or rebuttal exhibits as may be developed or may be
necessary.
24. Demonstrative Aids and Exhibits.
25 Video of Incident.
26. Plaintiff's Certified Conviction.
27. Any and all records from Bayfront Health Port Charlotte F/K/A, Risk Management
28, Any and all records from Bayfront Health Port Charlotte F/K/A, Human Resources
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29. Any and all records from Bayfront Health Port Charlotte F/K/A. Medical, Billing and
Radiology
30. Any and all records from Peace River Regional Medical Center
31 Any and all records from Advanced Orthopedic Center
32. Any and all records from Jason Mlnarik, DO
33 Any and all records from Tanweer Memon, MD, PA
34, Any and all records from Justino Silvestre, MD, PA.
35 Any and all records from MBB Radiology
36. Any and all records from Tampa Bay Radiology Associates
37. Any and all records from Gallagher Bassett Services Inc.
38, Any and all records from One Call Care
39, Any and all records from Genex Services, Inc
40. Any and all records from Priority Care Solutions, LLC
4l Any and all records from Charlotte County Fire & EMS.
42 Any and all records from Dr. Ivan Olarte, MD.
43 Any and all records from Florida Hand Center
44 Any and all records from JOF LLC (McDonalds)
45 Any and all records from Dollar Tree Stores, Inc.
46. Any and all records from Douglas T Jacobson State Veterans' Nursing Home
47. Any and all records from Fawcett Memorial Hospital
48, Any and all records from Sarasota Memorial Hospital
49 Any and all records from Division of Workers Compensation
50. Any and all records from BlueCross BlueShield of South Carolina
Si Any and all records from Murdock Surgery Center
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52 Any and all records from Douglas M. Hershkowitz, MD.
53 Any and all records from State Farm
54, Any and all records from Gulf Coast Medical Group
55 Any and all records from MBB Radiology
56. Any and all records from NurseCore
57 Any and all records from Akumin Port Charlotte
58 Any and all records from Pulmonary Sleep and Critical Care
59 Any and all records from Port Charlotte HMA Physician
60. Any and all records from Accurate Pathology Services
61 Any and all records from One Call Medical
62 Any and all records from Ashvin Patel, M.D. /Kennedy White Orthopaedic Center
63 Any and all records from The Orthopaedic Center of Southwest Florida PLLC.
64. Any and all records from Riverwalk Surgery Center
65 Any and all records from Universal Spine and Joint
66. Any and all records from Fitness Quest
67. Any and all records from Non-Operative Spine and Neuromuscular
68. Any and all records from Fatin Albezargan, M.D.
69. Any and all records from Cora Physical
70. Any and all records from Orthopedic Center of Florida
71 Any and all records from Mayur Lahkani MD.
72. Any and all records from Social Security.
73 Any and all records from the Internal Revenue Service.
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Defendant reserves the right to add, modify, supplement or amend its exhibit list upon proper
notice to all parties.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all
counsel of the attached Service List this 15th day of February, 2023.
KUBICKI DRAPER
9100 South Dadeland Blvd.
Suite 1800
Miami, FL 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
Pleadings: FIC-KD@kubickidraper.com
By:_/s/ Francesca Ippolito-Craven
FRANCESCA IPPOLITO-CRAVEN
fic@kubickidraper.com
Florida Bar Number: 0145361
LISANDRA GUERRERO
Ig@kubickidraper.com
Florida Bar Number: 0098521
SERVICE LIST
Co-counsel for Plaintiff:
Michael J. Rossi, Esq.
MICHAEL J. ROSSI, P.A.
115 South Albany Avenue
Tampa, FL 33606
michael@michaelrossilaw.com
Helen Stratigakos, Esq.
STRATIGAKOS LAW, P.A.
412 East Madison Street, Suite 814
Tampa, FL 33602
Primary: Helen@stratigakoslaw.com
Secondary: admin@stratigakoslaw.com
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Filing # 166898096 E-Filed 02/15/2023 05:13:45 PM IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 082021CA000968XXXXXX Plaintiff, Vv. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC Defendants. / DEFENDANTS’ AMENDED EXHIBIT LIST Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC., by and through the undersigned attorneys, and pursuant to this Court’s Trial Order, submits the following Amended Exhibit List as follows: EXHIBIT LIST Any and all photographs, diagrams, charts, maps, or depictions of the scene of the incident. Any and all charts, diagrams, models, or treatises utilized by any of Plaintiffs physicians and/or healthcare providers, or by Plaintiff or his witnesses. Curriculum vitae of any experts or witnesses. Without waiving any objection, all records relied upon by the parties’ experts. All pleadings in this lawsuit. Any and all medical bills, medical records, medical reports, hospital records and diagnostic tests relating to Plaintiff. Any and all x-rays, MRI studies, arthrograms or other diagnostic tests pertaining to Plaintiff. Any and all transcripts of depositions taken in this case and exhibits to same. Without waiving any objection, any and all exhibits listed by all other parties. 10. Any and all discovery which has taken place in this case. 11 Any and all interrogatories, requests for production and requests for admissions and responses to same. 12. Any and all documents produced pursuant to subpoenas in this case. 13 Any and all documents produced by plaintiff during the course of this lawsuit. 14 Any and all applicable Ordinances or Statues. 15 Any and all applicable Florida Statutes. 16 Any and all records and/or evidence of collateral source payments to the Plaintiff. 17 Without waiving any objection, any and all reports prepared by the parties’ expert witnesses. 18. Any and all demonstrative aids, drawings, illustrations, models, exemplars, and/or photographs of same. 19. Enlargements of any exhibit otherwise listed. 20. Any and all doctors or medical care providers who have seen the Plaintiff both before and after the accident which is the subject of this lawsuit. 21 Any and all income tax returns, W-2s, Social Security earnings statements of Plaintiff and all written evidence of Plaintiff's income. 22. Without waiving any objection, any and all exhibits listed in all Pre-Trial Witness & Exhibit Lists of parties in this case. 23 Such other and further impeachment or rebuttal exhibits as may be developed or may be necessary. 24. Demonstrative Aids and Exhibits. 25 Video of Incident. 26. Plaintiff's Certified Conviction. 27. Any and all records from Bayfront Health Port Charlotte F/K/A, Risk Management 28, Any and all records from Bayfront Health Port Charlotte F/K/A, Human Resources -2- 29. Any and all records from Bayfront Health Port Charlotte F/K/A. Medical, Billing and Radiology 30. Any and all records from Peace River Regional Medical Center 31 Any and all records from Advanced Orthopedic Center 32. Any and all records from Jason Mlnarik, DO 33 Any and all records from Tanweer Memon, MD, PA 34, Any and all records from Justino Silvestre, MD, PA. 35 Any and all records from MBB Radiology 36. Any and all records from Tampa Bay Radiology Associates 37. Any and all records from Gallagher Bassett Services Inc. 38, Any and all records from One Call Care 39, Any and all records from Genex Services, Inc 40. Any and all records from Priority Care Solutions, LLC 4l Any and all records from Charlotte County Fire & EMS. 42 Any and all records from Dr. Ivan Olarte, MD. 43 Any and all records from Florida Hand Center 44 Any and all records from JOF LLC (McDonalds) 45 Any and all records from Dollar Tree Stores, Inc. 46. Any and all records from Douglas T Jacobson State Veterans' Nursing Home 47. Any and all records from Fawcett Memorial Hospital 48, Any and all records from Sarasota Memorial Hospital 49 Any and all records from Division of Workers Compensation 50. Any and all records from BlueCross BlueShield of South Carolina Si Any and all records from Murdock Surgery Center -3- 52 Any and all records from Douglas M. Hershkowitz, MD. 53 Any and all records from State Farm 54, Any and all records from Gulf Coast Medical Group 55 Any and all records from MBB Radiology 56. Any and all records from NurseCore 57 Any and all records from Akumin Port Charlotte 58 Any and all records from Pulmonary Sleep and Critical Care 59 Any and all records from Port Charlotte HMA Physician 60. Any and all records from Accurate Pathology Services 61 Any and all records from One Call Medical 62 Any and all records from Ashvin Patel, M.D. /Kennedy White Orthopaedic Center 63 Any and all records from The Orthopaedic Center of Southwest Florida PLLC. 64. Any and all records from Riverwalk Surgery Center 65 Any and all records from Universal Spine and Joint 66. Any and all records from Fitness Quest 67. Any and all records from Non-Operative Spine and Neuromuscular 68. Any and all records from Fatin Albezargan, M.D. 69. Any and all records from Cora Physical 70. Any and all records from Orthopedic Center of Florida 71 Any and all records from Mayur Lahkani MD. 72. Any and all records from Social Security. 73 Any and all records from the Internal Revenue Service. -4- Defendant reserves the right to add, modify, supplement or amend its exhibit list upon proper notice to all parties. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all counsel of the attached Service List this 15th day of February, 2023. KUBICKI DRAPER 9100 South Dadeland Blvd. Suite 1800 Miami, FL 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 Pleadings: FIC-KD@kubickidraper.com By:_/s/ Francesca Ippolito-Craven FRANCESCA IPPOLITO-CRAVEN fic@kubickidraper.com Florida Bar Number: 0145361 LISANDRA GUERRERO Ig@kubickidraper.com Florida Bar Number: 0098521 SERVICE LIST Co-counsel for Plaintiff: Michael J. Rossi, Esq. MICHAEL J. ROSSI, P.A. 115 South Albany Avenue Tampa, FL 33606 michael@michaelrossilaw.com Helen Stratigakos, Esq. STRATIGAKOS LAW, P.A. 412 East Madison Street, Suite 814 Tampa, FL 33602 Primary: Helen@stratigakoslaw.com Secondary: admin@stratigakoslaw.com -5-