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  • Jeffery C Lambert, MD VS. Leonard MuehrInj/Damage-Motor Vehicle <$100,000, incl. damages document preview
  • Jeffery C Lambert, MD VS. Leonard MuehrInj/Damage-Motor Vehicle <$100,000, incl. damages document preview
  • Jeffery C Lambert, MD VS. Leonard MuehrInj/Damage-Motor Vehicle <$100,000, incl. damages document preview
  • Jeffery C Lambert, MD VS. Leonard MuehrInj/Damage-Motor Vehicle <$100,000, incl. damages document preview
  • Jeffery C Lambert, MD VS. Leonard MuehrInj/Damage-Motor Vehicle <$100,000, incl. damages document preview
  • Jeffery C Lambert, MD VS. Leonard MuehrInj/Damage-Motor Vehicle <$100,000, incl. damages document preview
  • Jeffery C Lambert, MD VS. Leonard MuehrInj/Damage-Motor Vehicle <$100,000, incl. damages document preview
  • Jeffery C Lambert, MD VS. Leonard MuehrInj/Damage-Motor Vehicle <$100,000, incl. damages document preview
						
                                

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CAUSE NO. 20 06632 JEFFERY C. LAMBERT, MD § IN THE DISTRICT COURT OF § § MONTGOMERY COUNTY, TEXAS § LEONARD MUEHR § JUDICIAL DISTRICT DEFENDANT’S SECOND AMENDED DESIGNATION OF EXPERT WITNESSES Defendant LEONARD MUEHR files this Designation of Expert Witnesses, and in that regard would respectfully designate the following individuals as expert witnesses: DEFENDANT’S RETAINED EXPERTS Each of the witnesses named below may testify in rebuttal to the testimony of Plaintiff s fact and expert witnesses: Gilbert Martinez, Ph.D., ABPP – 16014 Via Shavano San Antonio, Texas 78249 Retained europsychologist Expert Dr. Martinez is a medical doctor and board certified neuropsychologist. Dr. Martinez is expected to offer testimony on his expert qualifications including, but not limited to, his education, training and experience. Dr. Martinez will review and evaluate all medical records of Dr. Pollock including any raw data tests results as administered by Dr. Pollock (the request for Dr. Pollock’s raw data to be forwarded to Dr. Martinez is currently pending but not completed to date). Further, it is expected Dr. Martinez will testify on the results of his own neuropsychological assessment and test battery generated during clinical evaluation of the Plaintiff, along with review of any and all medical records relating to Plaintiff’s claimed injuries and resulting complications both past and future and will evaluate the diagnosis, prognosis and causation allegations as it relates specifically to claims of a traumatic brain injury or head injury sustained by Plaintiff in the incident forming the basis of this suit. It is anticipated Dr. Martinez will offer opinions about the allegation of a traumatic brain injury or head injury and the extent to which he concurs that such an injury exists, if any. This designation will also be supplemented once Dr. Martinez completes the administering of his neuropsychological test battery, review of Dr. Pollock medical records and raw data, and the review of medical and educational records of Plaintiff at issue. Please see Dr. Martinez’s report of preliminary neuropsychological record review attached hereto Along with the previous mentioned documents, Dr. Martinez will review the following: Petition, Plaintiff s discovery responses, deposition transcripts of Plaintiff. Please see the CV of Dr. Martinez attached hereto NON RETAINED EXPERTS The physicians named below are non retained treating physicians of Plaintiff, in the regular course of business and may testify concerning the health of Plaintiff, as well as injuries, treatment and prognoses. In particular, Plaintiff s doctors are expected to testify about Plaintiff s medical conditions and any disorders or illnesses present at the time of the accident, the onset of any disorders or illnesses experienced by Plaintiff at the time of the accident and treatment received by Plaintiff for any disorders or illnesses he was experiencing at the time of the accident. These opinions are based on the physicians' care and treatment of Plaintiff and their review of medical records. Said physicians are not retained by, employed by or otherwise subject to the control of Defendant. Please see the medical records of said healthcare providers as well as all other medical records and reports of Plaintiff for further information relative to the substance of such physicians' mental impressions and opinions, as well as a brief summary of the basis for them. The custodians listed below will testify in accordance with his/her Deposition on Written Questions and will be called to testify that the records in question are business records and meet the "business records" exception to the hearsay rule and, if applicable, the amount of medical expenses of Plaintiff which have been written off or adjusted pursuant to an agreement with the provider paying Plaintiff s medical expenses and/or pursuant to the healthcare provider's policies and procedures. PLAINTIFF’S MEDICAL PROVIDERS: Baylor St. Luke’s Medical Group (Billing And/or its Custodians of Patient Accounts Box 679429 Dallas, Texas 75267 (877) 824 7741 Houston Methodist Hospital The Woodlands Hospital And/or its Custodians of Medical Records and Patient Accounts And/or any other healthcare providers, including: Michael Nguyen, MD Jonathan Neal Levine, MD Dr. Vasant Garg Dr. Michael Donaldson Luck 17201 I 45 S Shenandoah, Texas 77385 (936) 270 000 Woodlands Emergency Physicians (Billing) And/or its Custodians of Patient Accounts P.O. Box 2487 Houston, Texas 77252 281) 274 7000 Houston Methodist Hospital And/or its Custodians of Medical Records and Patient Accounts And/or any other healthcare providers, including: Rob G Parrish, MD William George Ondo, MD Benjamin Gordon Northcutt, MD 6565 Fannin Street Houston, Texas 77030 (713) 790 3311 Springwoods Village Family Medicine And/or its Custodians of Medical Records and Patient Accoun And/or any other healthcare providers, including: Dr. Arlean Michelle Bullard 2255 E. Mossy Oaks Rd., Ste. 320 Spring, Texas 77389 (832) 534 7860 The Neurology Center And/or its Custodians of Medical Records and Patient Accounts And/or any other healthcare providers, including: Dr. Igor Cherches 6655 Travis St., Ste. 600 Houston, Texas 77030 (713) 795 0074 Houston Radiology Associated (Billing) And/or its Custodians of Medical Records and Patient Accounts And/or any other healthcare providers: Box 4613 Houston, Texas 77210 (281) 206 9050 INVESTIGATING RESPONDERS/OFFICERS The following witness may testify as to liability and opinions as to causation, damages, and facts surrounding the accident. The custodians of records will testify as to the authenticity of records: Deputy Matthew Sweeney, ID Num. 4P1027 Montgomery County Sheriff’s Office #1 Criminal Justice Drive Conroe, Texas 77301 (936) 760 5800 The custodians of records for the following witnesses may testify as to the authenticity of records: Texas Department of Public Safety and/or custodian of records PO Box 4087 Austin, Texas 78775 While not stipulating to their expertise, Defendant also identifies and may call to testify, in person or by deposition through a Custodian of Records, certain witnesses that Plaintiff may designate as expert witnesses. Those individuals have not been retained by, employed by, and are not otherwise subject to the control of Defendant. Further, Defendant does not adopt any of these individuals’ opinions by virtue of this designation. Defendant may elicit testimony from these experts, designated and called by other parties to the suit, by way of cross examination. Defendants may call, and reserves the right to call, un designated rebuttal expert witnesses, whose testimony cannot be reasonably foreseen until the presentation of evidence in this trial. Defendant may call persons with knowledge of relevant facts who are qualified by their training, experience, and/or education. Defendant reserves the right to supplement this designation with additional designations and identification of experts within the time limits imposed by the Court, or any alterations of same by subsequent Court Order or agreement of the parties, or pursuant to the Texas Rules of Evidence, including but not limited to, witnesses identified during deposition or further discovery. Defendant reserves the right to amend or supplement this designation before trial by amending or supplementing previously designated experts’ reports and the topics on which they may testify. Gilbert Martinez, Ph.D., ABPP Texas License # 3 0743 Louisiana License # 1269 Board Certified in Clinical Neuropsychology American Board of Professional Psychology American Board of Clinical Neuropsychology South Texas Neuropsychological Associate , PLLCPhone (210) 614 16014 Via Shavano Fax (210) 615 San Antonio, Texas78249glbrmart@aol.com EDUCATION Ph.D. in Clinical Neuropsychology, Department of Psychology, University of Houston, University Park, Houston, Texas Clinical Psychology Internship/Residency, Departments of Allied Health Sciences/Psychiatry University of Texas Medical Branch at Galveston, Galveston, T exas M.A. in Clinical Neuropsychology, Department of Psychology University of Houston, University Park, Houston, Texas B.A. in Psychology/Zoology, Departments of Psychology, Zoology University of Texas at Austin, Austin, Texas CURRENT PROFESSIONAL POSITIONS May 2006 Director /OwnerSouth Texas Neuropsychological Associates , PLLC, San Present Antonio, Texas June 2020 Consulting Rehabilitation Neuropsychologist, Warm Springs Hospital Present System/Post Acute Medical, San Antonio, Texas February 2012 Staff Neuropsychol ogist, Mentis Neurorehab of San Antonio/Neurorestorative, PresentSan Antonio, Texas January 2014 Consulting Research Neuropsychologist, University of Texas at Austin PresentAustin, Texas ctober Independent Practice, Clinical and Rehabilitation Neuropsychology Present Geriatric Neuropsychology, San Antonio, Texas July Neuropsychological Consultant,Easter Seals Vocational Brain Injury Present Rehabilitation Program, San Antonio, Texas OTHER PROFESSIONAL HISTORY 2020 Medical Director, Neuropsychology Services, Warm Springs Rehabilitation/Post Acute Medical President, Hispanic Neuropsychological Society (Multi National) 2009 Staff Rehabilitation Neuropsychologist, HealthSouth Rehabilitation Institute of San Antonio, Texas 2012 Sub Investigator, Integra Clinical Research, San Antonio, Texas Staff Neuropsychologist, Nix Healthcare System of San Antonio, Texas Clinical Psychologist, Parent Child Incorporated, San Antonio, Texas 2005 Neuropsychologist, Memory Loss Clinic, San Antonio, Texas Clinical Psychologist, LivliteSurgical Weight Loss Program , Nix Healthcare System of San Antonio, Texas Neuropsychologist, Neuropsychology Department, Christus Santa Rosa Northwest Rehabilitation Hospital, San Antonio, Texas 1996 Clinical Neuropsychological Associate, Neuropsychology Department, Transitional Learning Center, Galveston Texas Clinical Psychology Resident, Departments of Psychiatry and Allied Health Sciences, Department of Surgery, University of Texas Medical Branch at Galveston, Galveston Tex Clinical Research Associate, Neuropsychology Service, Department of Neurology, Baylor College of Medicine, Houston Texas Pre doctoral Clinical Intern,Department of Physical Medicine and Rehabilitation, Southeast Memori al Hospital, Houston Texas Pre doctoral Clinical Intern, Department of Psychiatry, Veteran’s Administration Medical Center, Houston, Texas Pre doctoral Clinical Intern, Outpatient Neuropsychology Service, Institute for Reha bilitation, Houston, Texas Pre doctoral Clinical Intern, Head Injury Unit, Del Oro Institute for Rehabilitation, Houston, Texas Pre doctoral Research Associate, Neuropsychology Service, Department of Neurology, Baylor College of Medicine, Houston, Texas Pre doctoral Research Assistant, Regional Cerebral Blood Flow Laboratory, Veteran’s Administration Medical Center/Baylor College of Medicine, Houston, Texas Research Assistant, Biopsychology Research Laboratory, Department of Psychology, University of Texas at Austin, Austin, Texas Research Assistant, Department of Psychology, University of Texas at San Antonio, San Antonio, Texas TEACHING HISTORY Teaching Fellow Introduction to Psychology, Biopsychology Department of Psychology, University of Houston University Park Houston, Texas Graduate Studen t Training Director, South Texas Neuropsychology, San Present Antonio, Texas PUBLICATIONS Martinez, G. (1996). The Relationship Between Verbal Learning, Language, Attention, and Executive Function in Chronic Brain Injury Survivors: A Factor Analytic Study, Doctoral Dissertation, University of Houston Press Anderson, T.R., Thompson, J.P., Boeringa, J.A., Flores, E., Gallegos, H., Martinez, G. (1992). Mexican American Veterans’ Performance on the Mississippi Scale for Combat Related PTSD: Eng lish and Spanish Administrations. A paper presented to the EighthAnnual Meeting of the International Society for Post Traumatic Stress Studies, Los Angeles lifornia. Martinez, G. (1991). Interobserver Reliability in the Judgmentof Periventricular White Matter Hyper intensitieson Magnetic Resonance Images in Subjects with Multi Infarct Dementia or Dementia of the Alzheimer Type. Master’s Thesis, University of Houston Press. Meyer, J.S., Lotfi, J., Martinez, G., Caroselli, J.S., Mortel, K.F., & Thornby, J.I. (1990). Effects of Medical and Surgical Treatment on Cerebral Perfusion in Patients with Chronic Cerebral Ischemia. Surgical Neurology , 34: 301 CLINICAL RESEARCH EXPERIENCE Sub Investigator (2007) A Randomized, Double Blind, Placebo Controlled, Dose Titration Study to Assess the Safety, Tolerability, and Efficacy of C105 in Persons with Multiple Sclerosis with Cognitive Impairment COGNITION PHARMACEUTICALS Sub Investigator (2008) A 54 week, Double Blind, Randomized, Placebo Controlled, Parallel Group Study to Investigate the Effects of Rosiglitazone (extended release tablets) as Adjunctive Therapy to Acetylcholinesterase Inhibitors on Cognition and Overall Clinical Response on APOE Stratified Subjects with Mild to Moderate Alzheimer’s Disease (REFLECT 3) GLAXOSMITHKLINE Sub Investigator A Phase III, Multicenter, Randomized, Double Blind, Placebo Controlled, Parallel Group, Efficacy and Safety Trail of Bapineuzumab (AAB 001, ELN1 15727) in Patients with Mild to Moderate Alzheimer’s Disease who are Apolipoprotein E 4 Carriers GRANTSAND LEADERSHIP Texas State Board of Examiners of Psychologists, Board Service Award for Outstanding Service and Dedication to the Board’s Mission of Protecting the Public Through Participation in the Board’s Examinations and Serving on it s Committees Junior and Senior Graduate Student Representative, Doctoral Neuropsychology Program, University of Houston University Park, Houston, Texas American Psychological Association Minority Fellowship Award in Clinical Psychology. N ational Institutes of Health OTHER RECENT PROFESSIONAL ACTIVITIES Present Consulting Neuropsychologist, Memory, Attention, and Problem Solving Skills for Persons with MS, Funded by The National institutes of Health 1R014362 President , Hispanic Neuropsychological Society Oral Examiner for Doctoral Licensure, Texas State Board of Examiner s of Psychologists, Austin,Texas Present Member, Gerontology Advisory Board, San Antonio College, Alamo Community College District, San Antonio, Texas Supervisor of Licensed Professional CounselingCandidates aster Seals Early Childhood Intervention and Vocational Brain Injury Program, San Antonio, Texas Presenter (Recent Lectures/Seminars): Overview of DSM TR Clinical Criteria in the Diagnosis of Mental Disorders Differentiating Between Alzheimer’s and Other Dementias. Current Status of Neuropsychological Assessment of Children. Personality Disorders Working With Difficult Clients in a Rehabilitation Setting. Bereavement Following Traumatic Brain Injury. Assessment of Cognitive Disorders in Individuals With Dementia. Neuropsychological Assessment of the Spanish Speaking Patient. Neuropsychological Issues in the Assessment if Individua ls with Seizure Disorders Management of TBI Neurobehavioral Disorders in Rehabilitation PROFESSIONAL AFFILIATIONS American Academy of Clinical Neuropsychology (Board Certified Full Member) Hispanic Neuropsychological Society (Past President) International Neuropsychological Society National Academy of Neuropsychology Ame rican Psychological Association Division 41: American Psychology Law Society PROFESSIONAL SPECIALTIES/INTERESTS Bilingual (Spanish) Neuropsychological Assessment of Adults and Children Rehabilitation Neuropsychology Geriatric Neuropsychology Forensic Neuropsychology Traumatic Brain Injury, Dementia, Emotional Adjustment to Disability Neuropsychological Assessment of Death Penalty Defendants LICENSING August 1997 Licensed Psychologist, State of Texas, License # Present February 2014 Licensed Psychologist, State of Louisiana, Specialty: Clinical PresentNeuropsychology, License # 1297 References available upon request