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CAUSE NO. 22-05-05951
KELLY SPRIGGS, INDIVIDUALLY, IN THE DISTRICT COURT
And As Next Friend of B.S., a minor
Plaintiff
Vv. 284" JUDICIAL DISTRICT
JULIUS LEO ARIAS
Defendant MONTGOMERY COUNTY, TEXAS
PLAINTIFF’S SUPPLEMENTAL DISCLOSURES
AND EXPERT WITNESS DESIGNATION
COMES NOW Plaintiff Kelly Spriggs, Individually and as Next Friend of B.S., a minor,
and files this, her supplemental disclosures responses and designation of expert witnesses and
designate the following persons as expert witnesses who may be called by the Plaintiff to testify
at the time of trial in this case:
Plaintiff incorporates herein by reference Plaintiff's Response to Required Initial
Disclosure (and all amendments and supplements thereto) together with all other discovery
responses previously served on Defendant and designates her expert witnesses as follows:
NON-RETAINED EXPERTS:
Plaintiff’s Treating Physicians and Other Persons with Knowledge of Relevant Facts That
May Qualify as Experts but Have Not
Been Specially Retained
(Fact Experts - TEx. R. Civ. P. 194.2(f))
The following person(s), or their custodian(s) of records, have not been retained by and
are not employed by, or are otherwise subject to the control of Plaintiff (hereinafter referred to as
"non-retained" experts), but are hereby designated as testifying experts by Plaintiff and the
following information is provided in accordance with Texas Rule of Civil Procedure 194.2.
Although these witnesses have not been specifically retained as expert witnesses by
Plaintiff and while Plaintiff cannot vouch for the expertise or credibility of such witnesses at this
time, it is believed that they may have knowledge, training or expertise which may qualify them
as experts. Accordingly, Plaintiff will designate these witnesses as persons who may be called
upon to give testimony that would be considered expert testimony.
Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 1 of 8
The following healthcare providers, and/or the custodian(s) of their records, may testify
regarding the injuries sustained by Plaintiff Kelly Spriggs, Individually and as Next Friend of
B.S., a minor in the incident made the subject of this suit, their medical diagnosis, prognosis and
the reasonable and necessary cost of hospital, doctor and medical bills for treatment of their
injuries in the past and in the future.
Please refer to the healthcare providers’ records for their mental impressions, opinions,
conclusions, and the factual basis for each opinion.
1 NON-RETAINED MEDICAL EXPERTS.
THE FOLLOWING INDIVIDUALS AND ENTITIES AND THEIR CURRENT AND
FORMER OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVANTS,
PHYSICIANS, NURSES, PARAMEDICS, EMTs, ATTENDANTS, STAFF,
HEALTHCARE PROVIDERS, AND CUSTODIANS OF RECORDS:
The Woodlands Lonestar Emergency Physicians Group
Lisa Yanez, Custodian of Records
32784 FM 2978
Magnolia, TX 77354
B.S.’s a minor’s medical provider
America ER & Urgent Care
Dr. Anita Bangale
Lisa Yanez, Custodian of Records
Holly Madden, Custodian of Records
32784 FM 2978
Magnolia, TX 77354
B.S.’s a minor’s medical provider
The Woodlands Lonestar Emergency Physicians Group
Lisa Yanez, Custodian of Records
32784 FM 2978
Magnolia, TX 77354
Kelly Spriggs’ medical provider
America ER & Urgent Care
Dr. Anita Bangale
Dr. Paul Thompson
Lisa Yanez, Custodian of Records
Holly Madden, Custodian of Records
32784 FM 2978
Magnolia, TX 77354
Kelly Spriggs’ medical provider
Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 2 of 8
Alliance MRI — Woodforest
Dr. Kristin Coleman
Susan Feinberg, Custodian of Records
750 Fish Creek Thoroughfare Suite 180
Montgomery, TX 77316
Kelly Spriggs’ medical provider
Sandstone Chiropractic
Reese J. Ochoa, DC
Rachel Clark, Custodian of Records
125 Blue Heron Dr. Ste. B
Montgomery, TX 77316
Kelly Spriggs’ medical provider
2 Subject Matters of Non-Retained Medical Experts. The subject matters on which said
non-retained non-controlled medical experts will testify are as follows:
a. the existence, nature and/or extent of the injuries sustained by Plaintiff Kelly
Spriggs and B.S., a minor as a result of the subject collision;
the examination and treatment of the injuries sustained by Plaintiff Kelly Spriggs
and B.S., a minor, as a result of the subject collision;
the type, purpose, extent, results, evaluations and/or interpretations of
examinations, treatments and tests regarding Plaintiff Kelly Spriggs and B.S., a
minor;
recommendations, diagnosis and prognosis with regard to the injuries of Plaintiff
Kelly Spriggs and B.S., a minor, including the need for future medical care and
the cost of future medical care;
the existence, nature and/or extent of the injuries sustained by Plaintiff Kelly
Spriggs and B.S., a minor, as a result of the subject incident;
the reasonableness and the necessity of the medical services, medical care and
medications rendered to Plaintiff Kelly Spriggs and B.S., a minor, in the past and
those medical interventions recommended for the future;
the cause of the injuries sustained by Plaintiff Kelly Spriggs and B.S., a minor, to
a reasonable degree of medical probability;
all those subject matters contained, discussed or disclosed in:
(1) the medical records of Plaintiff Kelly Spriggs and B.S., a minor, which
have been, and which may hereafter be, produced in this cause;
Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 3 of 8
(2) any and all medical records affidavits and/or medical billing affidavits
which have been filed, and which may hereafter be filed, in this cause, and
all exhibits thereto;
(3) the depositions on written questions of Plaintiff Kelly Spriggs and B.S., a
minor’s health care providers which have been taken, and which may
hereafter be taken, in this cause, and all exhibits thereto; and
(4) all written reports of healthcare providers produced during the course of
discovery in this cause.
All of said documents are incorporated herein by reference as though set out at length for
all purposes.
3 Impressions and Opinions of Non-Retained Medical Experts. The general substance of
said non-retained/non-controlled medical experts' mental impressions and opinions are expected
to be, and a brief summary of the basis for them are, as follows:
a. the nature, extent and severity of Plaintiff Kelly Spriggs and B.S., a minor’s
injuries;
that Plaintiff Kelly Spriggs and B.S., a minor’s injuries (described in Plaintiff
Kelly Spriggs and B.S., a minor’s medical records), are the result in whole from
the incident made the subject of this suit;
the medical care and treatment rendered Plaintiff Kelly Spriggs and B.S., a minor
were reasonable and/or necessary;
the subject incident did, based on reasonable medical probability, cause all of the
complaints, injuries, and/or incapacities complained of by Plaintiff Kelly Spriggs
and B.S., a minor;
that all medical intervention for treatment/diagnosis of Plaintiff Kelly Spriggs and
B.S., a minor’s injuries was necessitated and proximately caused by the incident
made the subject of this lawsuit;
that the medical expenses of Plaintiff Kelly Spriggs and B.S., a minor, were
reasonable and necessitated by the incident which is the subject of this lawsuit;
that Plaintiff Kelly Spriggs and B.S., a minor, will likely need future medical care
as a result of this incident;
all other impressions and/or opinions that are contained, discussed, and/or
disclosed in the following:
Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 4 of 8
() the medical records of Plaintiff Kelly Spriggs and B.S., a minor, which has
been, and which may hereafter be, produced in this cause;
2) the medical records affidavits and medical billing affidavits which have
been filed, and which may hereafter be filed, in this cause and all exhibits
thereto;
(3) the depositions on written questions of Plaintiff Kelly Spriggs and B.S., a
minor’s health care providers which have been taken, and which may
hereafter be taken, in this cause, and all exhibits thereto; and
(4) all written reports of healthcare providers produced during the course of
discovery in this cause.
All of said documents are incorporated herein by reference as though set out at length for
all purposes.
4 Brief Summary of Basis for Impressions and Opinions. The basis for the foregoing
impressions and opinions of the above named and/or designated expert witnesses are all of the
facts shown by and/or contained in:
a. Physical examinations of Plaintiff Kelly Spriggs and B.S., a minor;
b All of the medical records (including medical imaging) of Plaintiff Kelly Spriggs
and B.S., a minor produced in this cause;
All depositions taken, and hereafter taken, in this cause, either by written
questions or orally, and all exhibits thereto;
The expert reports herein above expressly referred to;
All witness statements which may be produced in this cause;
All of the photographs and videotape recordings produced in this cause;
The Responses to Requests For Disclosure, Responses to Requests For
Production, Answers to Interrogatories, and the Amendments and Supplements
thereto which have been filed by each of the parties in this cause of action;
The Pleadings on file in this cause of action; and
All documents and tangible things produced in this cause.
Plaintiffs Supp. Disclosures and Designation of Expert Witnesses Page 5 of 8
NON-RETAINED EXPERTS, OTHER THAN MEDICAL EXPERTS:
Officer Steve Hurd #3832
Conroe Police Department
Its current and former chief, officers, investigators, detectives, employees, and custodian(s) of
records
2300 Plantation Dr.
Conroe, TX 77301
Investigating Officer.
The officers are expected to testify regarding their investigation of the subject incident,
the cause of the subject incident (including contributing factors) and the statements made by the
parties to the lawsuit.
Plaintiff also incorporates herein by reference all depositions; depositions on written
questions; documents and exhibits attached to or referenced in all depositions; and all documents
produced by any party hereto in disclosures and/or discovery. Any opinions and bases for
opinions discussed in deposition(s) are incorporated herein.
Plaintiff further refers the Defendants to their retained and non-retained experts’ files,
reports and supplemental reports; initial and supplemental disclosures; pleadings of all parties;
discovery of all parties; depositions and exhibits thereto; medical and billing records; rebuttal
opinions, factual observations, opinions, deposition testimony and/or trial testimony and
deposition exhibits of non-retained experts.
Plaintiff further reserves the right through cross-examination or deposition, to call any
expert witness identified herein by the Defendants.
Plaintiff reserves the right to withdraw the designation of any expert witness and to aver
positively that such previously designated expert will not be called as an expert witness at trial
and to redesignate same as a consulting expert, who cannot be called by opposing counsel.
Plaintiff reserves the right to elicit any expert testimony and/or lay opinion testimony that
would assist the jury in determining material issues of fact and that would not violate the Texas
Rules of Civil Procedure.
Plaintiff reserves all additional rights they may have with regard to expert witnesses and
testimony under the Texas Rules of Civil Procedure, case law and rulings of this Honorable
Court.
Plaintiff reserves the right to elicit expert opinion from any of the designated fact
witnesses within any area as to which such person has expertise.
To the extent necessary, this expert designation should be considered a supplement to any
outstanding or future discovery requests served on Plaintiff.
Plaintiffs Supp. Disclosures and Designation of Expert Witnesses Page 6 of 8
This designation shall serve to supplement Plaintiff's disclosures, including fact witness
designations, answers to interrogatories, pretrial disclosures, expert witness designations, and
responses to requests for production propounded to Plaintiff by any party inquiring as to expert
witnesses.
Discovery in this matter is still ongoing and Plaintiff reserves the right to supplement this
designation if further discovery reveals the need for additional testimony.
This designation shall serve to supplement Plaintiff's Responses to Request for
Disclosure, including the identification of individuals likely to have discoverable information
regarding Plaintiff's claims or defenses, Answers to Interrogatories, and Responses to Requests
for Production propounded to Plaintiff by any party inquiring as to expert witnesses.
DATED this \s day of December 2022.
Respectfully submitted,
SLOAN, HATCHER, PERRY,
RUNGE, ROBERTSON & SMITH
Ghtha
CARSON R. RUNGE
State Bar No. 24059262
crunge@sloanfirm.com
SAVANNAH M. RAND
State Bar No. 24121694
srand@sloanfirm.com
101 East Whaley Street
Longview, Texas 75601
Telephone 903-757-7000
Facsimile 903-757-7574
ATTORNEYS FOR PLAINTIFF
Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 7 of 8
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has been
forwarded efile in accordance with the Texas Rules of Civil Procedure on this (% day of
December 2022 to the following attorney of record:
Jimmy Olivas
Law Offices of Fanaff, Hoagland, Gonzales, Baldwin & Cunningham
PO Box 258829
Oklahoma City, OK 73125
C4
ATTORNEY FOR DEFENDANT JULIUS LEO ARIAS
SAVANNAH M. RAND
Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 8 of 8
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CAUSE NO. 22-05-05951 KELLY SPRIGGS, INDIVIDUALLY, IN THE DISTRICT COURT And As Next Friend of B.S., a minor Plaintiff Vv. 284" JUDICIAL DISTRICT JULIUS LEO ARIAS Defendant MONTGOMERY COUNTY, TEXAS PLAINTIFF’S SUPPLEMENTAL DISCLOSURES AND EXPERT WITNESS DESIGNATION COMES NOW Plaintiff Kelly Spriggs, Individually and as Next Friend of B.S., a minor, and files this, her supplemental disclosures responses and designation of expert witnesses and designate the following persons as expert witnesses who may be called by the Plaintiff to testify at the time of trial in this case: Plaintiff incorporates herein by reference Plaintiff's Response to Required Initial Disclosure (and all amendments and supplements thereto) together with all other discovery responses previously served on Defendant and designates her expert witnesses as follows: NON-RETAINED EXPERTS: Plaintiff’s Treating Physicians and Other Persons with Knowledge of Relevant Facts That May Qualify as Experts but Have Not Been Specially Retained (Fact Experts - TEx. R. Civ. P. 194.2(f)) The following person(s), or their custodian(s) of records, have not been retained by and are not employed by, or are otherwise subject to the control of Plaintiff (hereinafter referred to as "non-retained" experts), but are hereby designated as testifying experts by Plaintiff and the following information is provided in accordance with Texas Rule of Civil Procedure 194.2. Although these witnesses have not been specifically retained as expert witnesses by Plaintiff and while Plaintiff cannot vouch for the expertise or credibility of such witnesses at this time, it is believed that they may have knowledge, training or expertise which may qualify them as experts. Accordingly, Plaintiff will designate these witnesses as persons who may be called upon to give testimony that would be considered expert testimony. Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 1 of 8 The following healthcare providers, and/or the custodian(s) of their records, may testify regarding the injuries sustained by Plaintiff Kelly Spriggs, Individually and as Next Friend of B.S., a minor in the incident made the subject of this suit, their medical diagnosis, prognosis and the reasonable and necessary cost of hospital, doctor and medical bills for treatment of their injuries in the past and in the future. Please refer to the healthcare providers’ records for their mental impressions, opinions, conclusions, and the factual basis for each opinion. 1 NON-RETAINED MEDICAL EXPERTS. THE FOLLOWING INDIVIDUALS AND ENTITIES AND THEIR CURRENT AND FORMER OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVANTS, PHYSICIANS, NURSES, PARAMEDICS, EMTs, ATTENDANTS, STAFF, HEALTHCARE PROVIDERS, AND CUSTODIANS OF RECORDS: The Woodlands Lonestar Emergency Physicians Group Lisa Yanez, Custodian of Records 32784 FM 2978 Magnolia, TX 77354 B.S.’s a minor’s medical provider America ER & Urgent Care Dr. Anita Bangale Lisa Yanez, Custodian of Records Holly Madden, Custodian of Records 32784 FM 2978 Magnolia, TX 77354 B.S.’s a minor’s medical provider The Woodlands Lonestar Emergency Physicians Group Lisa Yanez, Custodian of Records 32784 FM 2978 Magnolia, TX 77354 Kelly Spriggs’ medical provider America ER & Urgent Care Dr. Anita Bangale Dr. Paul Thompson Lisa Yanez, Custodian of Records Holly Madden, Custodian of Records 32784 FM 2978 Magnolia, TX 77354 Kelly Spriggs’ medical provider Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 2 of 8 Alliance MRI — Woodforest Dr. Kristin Coleman Susan Feinberg, Custodian of Records 750 Fish Creek Thoroughfare Suite 180 Montgomery, TX 77316 Kelly Spriggs’ medical provider Sandstone Chiropractic Reese J. Ochoa, DC Rachel Clark, Custodian of Records 125 Blue Heron Dr. Ste. B Montgomery, TX 77316 Kelly Spriggs’ medical provider 2 Subject Matters of Non-Retained Medical Experts. The subject matters on which said non-retained non-controlled medical experts will testify are as follows: a. the existence, nature and/or extent of the injuries sustained by Plaintiff Kelly Spriggs and B.S., a minor as a result of the subject collision; the examination and treatment of the injuries sustained by Plaintiff Kelly Spriggs and B.S., a minor, as a result of the subject collision; the type, purpose, extent, results, evaluations and/or interpretations of examinations, treatments and tests regarding Plaintiff Kelly Spriggs and B.S., a minor; recommendations, diagnosis and prognosis with regard to the injuries of Plaintiff Kelly Spriggs and B.S., a minor, including the need for future medical care and the cost of future medical care; the existence, nature and/or extent of the injuries sustained by Plaintiff Kelly Spriggs and B.S., a minor, as a result of the subject incident; the reasonableness and the necessity of the medical services, medical care and medications rendered to Plaintiff Kelly Spriggs and B.S., a minor, in the past and those medical interventions recommended for the future; the cause of the injuries sustained by Plaintiff Kelly Spriggs and B.S., a minor, to a reasonable degree of medical probability; all those subject matters contained, discussed or disclosed in: (1) the medical records of Plaintiff Kelly Spriggs and B.S., a minor, which have been, and which may hereafter be, produced in this cause; Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 3 of 8 (2) any and all medical records affidavits and/or medical billing affidavits which have been filed, and which may hereafter be filed, in this cause, and all exhibits thereto; (3) the depositions on written questions of Plaintiff Kelly Spriggs and B.S., a minor’s health care providers which have been taken, and which may hereafter be taken, in this cause, and all exhibits thereto; and (4) all written reports of healthcare providers produced during the course of discovery in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes. 3 Impressions and Opinions of Non-Retained Medical Experts. The general substance of said non-retained/non-controlled medical experts' mental impressions and opinions are expected to be, and a brief summary of the basis for them are, as follows: a. the nature, extent and severity of Plaintiff Kelly Spriggs and B.S., a minor’s injuries; that Plaintiff Kelly Spriggs and B.S., a minor’s injuries (described in Plaintiff Kelly Spriggs and B.S., a minor’s medical records), are the result in whole from the incident made the subject of this suit; the medical care and treatment rendered Plaintiff Kelly Spriggs and B.S., a minor were reasonable and/or necessary; the subject incident did, based on reasonable medical probability, cause all of the complaints, injuries, and/or incapacities complained of by Plaintiff Kelly Spriggs and B.S., a minor; that all medical intervention for treatment/diagnosis of Plaintiff Kelly Spriggs and B.S., a minor’s injuries was necessitated and proximately caused by the incident made the subject of this lawsuit; that the medical expenses of Plaintiff Kelly Spriggs and B.S., a minor, were reasonable and necessitated by the incident which is the subject of this lawsuit; that Plaintiff Kelly Spriggs and B.S., a minor, will likely need future medical care as a result of this incident; all other impressions and/or opinions that are contained, discussed, and/or disclosed in the following: Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 4 of 8 () the medical records of Plaintiff Kelly Spriggs and B.S., a minor, which has been, and which may hereafter be, produced in this cause; 2) the medical records affidavits and medical billing affidavits which have been filed, and which may hereafter be filed, in this cause and all exhibits thereto; (3) the depositions on written questions of Plaintiff Kelly Spriggs and B.S., a minor’s health care providers which have been taken, and which may hereafter be taken, in this cause, and all exhibits thereto; and (4) all written reports of healthcare providers produced during the course of discovery in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes. 4 Brief Summary of Basis for Impressions and Opinions. The basis for the foregoing impressions and opinions of the above named and/or designated expert witnesses are all of the facts shown by and/or contained in: a. Physical examinations of Plaintiff Kelly Spriggs and B.S., a minor; b All of the medical records (including medical imaging) of Plaintiff Kelly Spriggs and B.S., a minor produced in this cause; All depositions taken, and hereafter taken, in this cause, either by written questions or orally, and all exhibits thereto; The expert reports herein above expressly referred to; All witness statements which may be produced in this cause; All of the photographs and videotape recordings produced in this cause; The Responses to Requests For Disclosure, Responses to Requests For Production, Answers to Interrogatories, and the Amendments and Supplements thereto which have been filed by each of the parties in this cause of action; The Pleadings on file in this cause of action; and All documents and tangible things produced in this cause. Plaintiffs Supp. Disclosures and Designation of Expert Witnesses Page 5 of 8 NON-RETAINED EXPERTS, OTHER THAN MEDICAL EXPERTS: Officer Steve Hurd #3832 Conroe Police Department Its current and former chief, officers, investigators, detectives, employees, and custodian(s) of records 2300 Plantation Dr. Conroe, TX 77301 Investigating Officer. The officers are expected to testify regarding their investigation of the subject incident, the cause of the subject incident (including contributing factors) and the statements made by the parties to the lawsuit. Plaintiff also incorporates herein by reference all depositions; depositions on written questions; documents and exhibits attached to or referenced in all depositions; and all documents produced by any party hereto in disclosures and/or discovery. Any opinions and bases for opinions discussed in deposition(s) are incorporated herein. Plaintiff further refers the Defendants to their retained and non-retained experts’ files, reports and supplemental reports; initial and supplemental disclosures; pleadings of all parties; discovery of all parties; depositions and exhibits thereto; medical and billing records; rebuttal opinions, factual observations, opinions, deposition testimony and/or trial testimony and deposition exhibits of non-retained experts. Plaintiff further reserves the right through cross-examination or deposition, to call any expert witness identified herein by the Defendants. Plaintiff reserves the right to withdraw the designation of any expert witness and to aver positively that such previously designated expert will not be called as an expert witness at trial and to redesignate same as a consulting expert, who cannot be called by opposing counsel. Plaintiff reserves the right to elicit any expert testimony and/or lay opinion testimony that would assist the jury in determining material issues of fact and that would not violate the Texas Rules of Civil Procedure. Plaintiff reserves all additional rights they may have with regard to expert witnesses and testimony under the Texas Rules of Civil Procedure, case law and rulings of this Honorable Court. Plaintiff reserves the right to elicit expert opinion from any of the designated fact witnesses within any area as to which such person has expertise. To the extent necessary, this expert designation should be considered a supplement to any outstanding or future discovery requests served on Plaintiff. Plaintiffs Supp. Disclosures and Designation of Expert Witnesses Page 6 of 8 This designation shall serve to supplement Plaintiff's disclosures, including fact witness designations, answers to interrogatories, pretrial disclosures, expert witness designations, and responses to requests for production propounded to Plaintiff by any party inquiring as to expert witnesses. Discovery in this matter is still ongoing and Plaintiff reserves the right to supplement this designation if further discovery reveals the need for additional testimony. This designation shall serve to supplement Plaintiff's Responses to Request for Disclosure, including the identification of individuals likely to have discoverable information regarding Plaintiff's claims or defenses, Answers to Interrogatories, and Responses to Requests for Production propounded to Plaintiff by any party inquiring as to expert witnesses. DATED this \s day of December 2022. Respectfully submitted, SLOAN, HATCHER, PERRY, RUNGE, ROBERTSON & SMITH Ghtha CARSON R. RUNGE State Bar No. 24059262 crunge@sloanfirm.com SAVANNAH M. RAND State Bar No. 24121694 srand@sloanfirm.com 101 East Whaley Street Longview, Texas 75601 Telephone 903-757-7000 Facsimile 903-757-7574 ATTORNEYS FOR PLAINTIFF Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 7 of 8 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been forwarded efile in accordance with the Texas Rules of Civil Procedure on this (% day of December 2022 to the following attorney of record: Jimmy Olivas Law Offices of Fanaff, Hoagland, Gonzales, Baldwin & Cunningham PO Box 258829 Oklahoma City, OK 73125 C4 ATTORNEY FOR DEFENDANT JULIUS LEO ARIAS SAVANNAH M. RAND Plaintiff's Supp. Disclosures and Designation of Expert Witnesses Page 8 of 8