Trial Materials: JOHN WOLF Vs YESENIA QUINONES VS.YESENIA QUINONES ET AL

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                                Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Jun 27 10:20 AM-23CV003129
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                          IN THE COMMON        PLEAS COURT, FRANKLIN COUNTY, OHIO
                                                   CIVIL DIVISION

            JOHN WOLF,                                    No.    23CV003129

                     Plaintiff,                            Judge Andria Noble

            VS.                                                 ITIAL WITNESS DISCLOSURE

            YESENIA QUINONES, ET AL.,

                     Defendant



                   Pursuant to the Court’s Case Scheduling Order, Defendant Jason Carr hereby identifies

            the following witnesses who may be called during trial of this matter:

            1      Plaintiff, as upon cross-examination, concerning the facts surrounding the accident, the

                   alleged injuries and damages, and any issue raised during direct examination;

                   Defendant as upon direct examination, concerning the facts surrounding the accident and

                   the circumstances under which he was operating the motor vehicle;

                   Any   and all co-defendants,   as upon cross-examination, concerning the facts of the

                   accident and any issues raised during direct examination;

                   All other witnesses named on the accident report, as upon cross-examination, concerning

                   the facts surrounding the accident and any injuries or damages alleged by the Plaintiff;

                   All of Plaintiff's examining and/or treating physicians or medical providers;

                   A defense examining physician, if an IME is conducted or other medical testimony is

                   determined to be relevant, on the issues of proximate cause and damages;

                   An accident reconstruction expert, if such expert is retained;

                   All witnesses called by the Plaintiff and any co-defendants, as upon cross-examination;

                   and
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Jun 27 10:20 AM-23CV003129
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                   Any and all police, fire or emergency personnel responding to the scene of the accident,

                   including any persons authoring any             reports relative to the accident, regarding their

                   observations at the scene and the contents of their report.

            10.    Defendant    reserves   the    right   to   identify   additional   witnesses   upon   completion   of

                   discovery.    Defendant       reserves the right to call any witness and/or expert witness

                   disclosed, utilized, retained and/or consulted by or on behalf of Plaintiff.


                                                      Respectfully submitted,


                                                      /s/ Alix J. West
                                                      Alix J. West, 0093310
                                                      Law Office of Daniel P. Whitehead
                                                       175 South Third Street, Suite 1005
                                                      Columbus, Ohio 43215
                                                      Tel: 614-794-0151
                                                      Fax 614-227-5773
                                                                 ¢ -3 5
                                                       ALY
                                                      Attorney for Defendant Jason Carr
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Jun 27 10:20 AM-23CV003129
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                                                  CERTIFICATE OF SERVICE

                    The undersigned hereby certifies that a copy of the foregoing document was sent by ordinary U.S.

            mail, email, and/or this Court’s electronic filing system on June 27, 2023 to:


            A.C. Sallee, Esq.
            Smith Schabo Law
            32 W. Hoster Street, Suite 200
            Columbus, Ohio 43215


                                                      /s/ Alix J. West
                                                      Alix J. West, 0093310
                                                      Attorney for Defendant Jason Carr