Preview
Filing# 168749326 E-Filed 03/15/2023 09:46:14 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.: CACE-21-016578
JOY FURER,
Plaintiff,
V
GG RE HOLLYWOOD BEACH 613 LLC,
Defendant.
i
DEFENDANT'S EXPERT WITNESS DISCLOSURE
Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through undersigned
counsel and pursuant to this Court's June 30,2022, Uniform Trial Order, hereby files its Expert
Witness Disclosure as follows:
1. Christopher J. Troiano, M.D.
Orthopedic Specialists,P.A.
7710 N.W. 71 St Court
Suite 103
Tamarac, Fl 33321
954-739-9700
Dr. Troiano is a board-certified Orthopedic Surgeon who was retained to review all medical
records and render his opinion regardingthe care, treatment, future needs, and future prognosis of
the Plaintiff as well as to determine if the injuries
allegedlysustained were consistent with and a
direct result of the allegedinjuries
referenced in the Plaintiff's complaint,subjectof this lawsuit.
from medical and healthcare records,includingtests and films both before
Dr. Troiano will testify
and after the subjectincident, and anything else in his files. Dr. Troiano is expected to testify
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/15/2023 09:46:14 AM.****
CASE NO.: CACE-21-016578
concerning any conclusions, any treatment modalities provided, limitations, and any
recommendations and opinions regarding the Plaintiff's future, including but not limited to
worsening, accelerated degenerationand permanence of the injuries,
the related future treatment,
tests, medications, surgery, etc. and the costs associated with such, if any. Dr. Troiano is also
regarding causation,permanency, the prognosis of the reasonableness and the
expected to testify
necessityo f Plaintiff's medical care up until the time o f trial and the need for future medical care
related to the allegedinjurysustained on that is the subjectofthis lawsuit,if any. Dr. Troiano will
as to the matters contained within
testify all medical records includingthe Plaintiff's historyand
A copy o f Dr. Troiano' s
diagnostictesting. CV is attached hereto as Exhibit A.
2. W. Ken Kastaris
400 Capital Circle SE
Suite 18299
Tallahassee, FL 32301
850-224-2929
Mr. Kastaris is a Law Enforcement, Corrections and Private Security Consultant/Trainer
who was retained to review the including,but not limited to the incident report, supplementary
reports, photographs and all related incidents in or around within a reasonable distance from the
incident location of 2012 N. Surf Road, Hollywood Florida 33019, and any other related security
and/or crime aspects needed to make an assessment regardingthe allegedincident referenced in
the Plaintiff' s complaint,subjectofthis lawsuit. Mr. Kastaris will testify
including,but not limited
to previous crime history,securityprotocols,of the incident location 2012 N. Surf Road,
Hollywood Florida 33019, A copy of Mr. Kastaris's CV is attached hereto as Exhibit B.
2
CASE NO.: CACE-21-016578
3. All expert witnesses listed by Co-Defendant.
4. All expert witnesses listed by Plaintiff.
5. All rebuttal expert witnesses necessitated by Plaintiff's disclosure of expert witnesses.
6. All witnesses and expert witnesses discovered priorto trial with timelynotice to opposing
counsel.
7. Defendant reserves the rightto amend/supplement this Expert Witness Disclosure as
necessary.
DATED: March 15, 2023
ANDERSONGLENN LLP
s/.John .J. Glenn
John J. Glenn, Esquire
Florida Bar No.. 957860
jglenn@asglaw.com
Amanda N. Rumker, Esquire
Florida Bar No.: 122580
arumker@asglaw.com
2650 North MilitaryTrail,Suite 430
Boca Raton, Florida 33341
Tel.: (561) 893-9192
Fax: (561) 893-9194
Attorneys for GG RE
Hollywood Beach 613 LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 15, 2023 I electronically
filed the foregoingdocument
with the Clerk of the Court using Florida Court's E-Filing Portal and certifythat all counsel of
record have been served via transmission ofNotice of Electronic Filinggeneratedby Florida Court
E-FilingPortal or in some other authorized manner for those counsel or partieswho are not
Notices of Electronic Filing.
authorized to receive electronically
/s/.John .J. Glenn
John J. Glenn, Esquire
3
EXHIBIT A
A
ORTHOPEDIC CURRICULUM VITAE
SPECIALISTS, P.A.
I. EDUCATION
CHRISTOPHER J. TROIANO, M.D.,
F.A.A.O.S., F.A.C.S.
Diplomate
A. Board Certification and Fellowships:
AMERICAN BOARD OF ORTHOPEDIC SURGERY Fellow-American College of Surgeons, Oct.14 1993
Fellow-American Academy of Orthopaedic Surgeons,
February 18,1993
7710 N.W. 71st Court , Suite 103 Diplomate-American Board of Orthopedic Surgery,
Tamarac, Florida 33321
July 12,1991
954.739.9700
Recertified, January 01,2002
FAX 954.739.1934
Recertified,January 01,2012
Recertified,January 01, 2022
Email B. Post Graduate Medical Training:
Resident in New York Medical College
OrthopedicSurgery Program-Affiliated
June 1985-June 1989
Hospitals,
Westchester County Medical Center, Valhalla, NY
Lincoln Medical and Mental Health Hospital,
Bronx, NY
MetropolitanHospital,New York, NY
Lincoln Medical and Mental Health Hospital
Our Lady of Mercy Hospital,Bronx, NY
(General Surgery) July 1984-June 1985
C. Medical School:
New York Medical College,Valhalla, NY
1980-1984 M.D.
D. College:
Fordham University,Bronx, NY
1976-1980 B.S. Biology Summa Cum Laude
Phi Beta Kappa
Alpha Epsilon Delta
EXHIBIT A
L.?r ORTHOPEDIC II. PROFESSIONAL HISTORY
r SPECIALISTS, RA.
A. Private Practice July 1989 to present
MF
.Z CHRISTOPHER J. TROIANO,M.D., B. HospitalAffiliations:
F.A.A.O.S.,F.A.C.S.
*M' Dtptomate
Florida Medical Center Hospital
#..,AUmcAN
BOARD OF ORTHOPED/C SURGERY
Lauderdale Lakes, FL
f>
:
k.
'
UniversityHospital
: :
7710 N.W. 71st Court, Suite 103
Tamarac, Florida 33321 Tamarac, FL
954.739.9700
FAX 954.739.1934
C. Professional Organizations:
Broward OrthopaedicSociety
Email
Broward County Medical Association
Florida Medical Association
American Medical Association
American Academy of Orthopedic Surgeons
D. Barry UniversityPhysician Assistant Program
Preceptor 2006
Director Rehabilitation Services
Rehabilitation Institute of Florida 2003-2005
Board of Governors Florida Medical Center 2004
Medical Advisory Board St. John's Rehabilitation
Hospital2003-2005
Vice ChiefUniversityHospital2016-2019
Chief of SurgicalReview Committee University
Hospital2016-present
SecretaryTreasurer UniversityHospital2019
- present
E. Appointed Expert Medical Advisor Florida's
Worker's Compensation 1996-present
EXHIBIT A
..i'B
ORTHOPEDIC F. Featured in "The Best Doctors in South Florida"
j SPECIALISTS, RA.
Miami Metro Magazine: 1999
AF. F. Awards:
CHRISTOPHER J. TROIANO,M.D.,
F.A.A.O.S.,F.A.C.S.
New York Medical College-"The Orthopaedic
Diplomaie
Surgery Award", June 3,1984
'
'
AMERICAN BOARD OF ORTHOPEDIC SURGERY .
ChiefResident Orthopaedic Surgery
&f
(July1,1998 to June 30, 1989)
OutstandingYoung Man of America 1996
7710 N.W. 71st Court , Suite 103
Tamarac, Florida 33321
G. Presentations:
954.739.9700
FAX 954.739.1934
"The Use of an AdjustableShoe Orthosis in
The Treatment of Metatarsus Adductus" New
York OrthopaedicPediatric Research Society
Email Resident Competition Night,Hospitalfor Special
Surgery,New York, NY April1988
"The Use of an AdjustableShoe Orthosis in
The Treatment of Metatarsus Adductus' ,,
ChristopherJ. Troiano M.D., Robert L. Cristofaro, M.D.
Andrew H. Meyers, B.S., C.P.P. 55th annual meeting.
American Academy of Orthopaedic Surgeons,
February 8, 1988, Atlanta, GA
H. Community Service:
A. Team PhysicianVarsityFootball, Taravalla High
Coral Springs,FL 1989-1991
Marjory Stoneman Douglas High School
Parkland, FL 1991-2002
Monarch High School 2003 and 2006
B. Coral Springs Lightning Tackle Football Camp
Physician1990-1992
C. Coral SpringsMedical Center, Sportsmedicine
Program 1996-2004
D. PhysicianVolunteer Homestead Field Hospital
Homestead, FL-Hurricane Andrew-1992
E. Tamarac Outreach Program 2015
I
Christopher MD
![.?roiano,
EXHIBT B
W. KEN KATSARIS
Law Enforcement, Corrections
and Private Security
Consultant/Trainer
-
Addresses:
Post OfficeBox 12008
Tallahassee,FL 32317-2008
r
or Street for overnight
deliveryand packages:
400 Capital
Circle SE, Suite 18299
FL 32301
Tallahassee,
(850) 224-2929 Phone
consultkatsaris@,gmail.com
CURRICULUM VITAE
CREDENTIALS AND EXPERIENCE SUMMARY OF W. KEN KATSARIS
PRIVATE SECURITY/PREMISES LIABILITY EXPERIENCE
My background reflects an unusual blend of publicand privateenforcement and security education, training
and practicalexperience. I have provided training for officers working for large
privatesecuritycompanies to very
small guard services. And, I have provided continuingand
expert services on securityconcerns to large national
companies to small businesses as well which would include small strip mails to mails occupying vast acreage. I
have served as a securityand premises liability expert for plaintiffsand defendants throughout the U.S. Many of
these cases involved securityissues in large shopping mails large theme parks, apanment
complexes,
condominiums, office buildings,restaurants, stripmails, privateresidences, and hospitals,as well as
government
maintained offices and properties.I have also provided
consultingservices to similar properties. ] have also been
retained by law enforcement agencies facing liability claims and crime related issues for agencies such as the Los
Angeles County Sheriff, Chicago, Metro-Dade, Florida, Houston, Texas, Atlanta, Ponland Oregon, Las Vegas, and
Kansas City Missouri, Phoenix, Arizona, Tucson, Arizona and Hartford, Connecticut to name
only a few from the
hundreds in all 50 states. I specificallyhold current commercial securitycertifications, and have also been appointed
as a SecurityInspector for Small Businesses, their cash management, camera surveillance,
parking lots, lighting,
employee training?and alarm capabilities. This certificationwas earned by virtue of experience, and
training
apedficallyprovided by the Attorney General's Crime Prevention Institute. And, I have been an active member of the
American Society of Industrial Security(ASIS> for over twenty-five
(25> years. l hold the prestigiousCPP (Crime
Prevention Practitioner) designation,earned after completion of a series of courses and testing. I am a member of
the International Association of Chiefs of Police
(IACP) Crime Prevention Committee which is a presidential
appointment.
As a member of the Florida Department of State Private SecurityAdvisory Council I chaired the Firearms
Committee and drafted policies for guard deployment and use of force and
deadly force by privatesecurityofficers.
The council specifically addressed standards for Private Security Officers, trainingand licensing.
Academic courses in Private Securityand Premises Liability were requirements for my criminologydegree,
and later, as a professor, I taught seminars for college credit on the same
topic. As important as academics, is my
involvement in managing public and private officers assigned county-wide to protect the
premises of businesses,
college campuses, motels, hotels, shopping mails, banks, public events such as football games and concerts, and of
course, parkinglots.
LAW ENFORCEMENT EXPERIENCE
! am currently acertified Florida Law Enforcement Officer/Instructor,and consultant in law enforcement and
privatesecurity. I
regularlyinstruct in a wide area of law enforcement subjects at the
Regional Police/Corrections
Academy, where I have been teaching for over 30 years. For over 25 years, I was also an instructor at the Florida
Highway Patrol Academy. I also participatein law enforcement seminars throughout the USA and representativeof
(50) states, where I have instructed well over 150,000 Police Officers, Private Security Officers,Commanders,
all fifty
EXHIBT B
W. KEN KATSARIS
CURRICULUM VITAE
Page 2
Agency Administrators and the Attorneys representing these Agencies on a number of liability, investigation,tactics,
and policy and procedure related subjects,induding the Internal Procedures followinga
complaint or incident. In the past ] have also specifically
instructed over 25,000 Officers from a1150 states including
Private Securityagencies, the Federal
agencies and the Canadian Royal Mounted Police in a varietyof street
survival police procedures including use of force and deadly force as well as other policy areas that are detailed in
my C.V.
My law enforcement experience indudes service as a Police Officer for the St. Petersburg Florida Police
Department, off-dutyarmed private security,Police Officer with the Tallahassee Florida Police Department, Deputy
Sheriff with the Leon County Sheriff's Office, Trooper with the Florida
Highway Patrol, the elected Constitutional
sheriff who performs as the Chief Law Enforcement Officer of the County of Leon,
City of Tallahassee, Florida, a
jurisdiction of 700 square miles, and I served as the Assistant to the Secretary of Corrections for the State of
Florida,
as an administrator of the third largest prison system in the nation, administeringover 84
prisons and supervising 67
county detention systems.
ACADEMIC INSTRUCTION/CREDENTIALS
My academic instructional background and credentials includes 10 years as the Department Chairman of
the Crimina[ Justice Program at Tallahassee
Community College (Tallahassee, Florida). In this capacity I directed
and taught both the advanced in-service Police training
programs and the degree granting programs, as well as
directingthe crime lab used to support local law enforcement. Extensive teaching and trainingincluded basic
concepts and hands on skill development jn private securityprocedures, police
patroland criminal investigationand
criminalistics courses. Academic subjects included courses in securitymanagement, police procedures,
criminology,and private securitypatroland administration. Additionally,l have served as an adjunct professor in
Criminology and Social Work at Florida State University.My academic achievements include an Associate in Arts
(AA) in Police Administration from St. Petersburg,Florida Junior College, a Bachelor of Science (BS) Degree in
Criminology, Master of Science (MS) Degree in Criminology, Florida State University, Tallahassee, Florida, and [ am
ABD for the Doctorate in Public Adminisration at NOVA Southeast University,Ft. Lauderdale, Florida.
TRAINING INSTRUCTOR EXPERIENCE
My experience includes extensive instruction to over 150,000 officers throughout the United States,
includingall of the concepts, issues, and procedures for threat assessment, approaching,controlling, and restraining
resistingsubjects. For over twenty-five(25) years I instructed at the Florida Highway Patrol Academy on use of force
policyand procedure, as well as serving as the force and deadly force advisor for thirteen (13) years to the Director
of the Highway Patrol. For over 1hirty(30)
years I have instructed at the Pat Thomas Regional Law Enforcement
Academy and the Florida Public Safety Institute. Some of my assigned subjects are use of force, deadly force,crisis
intervention, and dealingwith the mentally illand emotionally disturbed individual, firearms, traffic stops and vehide
pursuits. For over twenty (20) years I have been senior instructor and tactical advisor for AELE, the nationally
recognized organization providing instruction to agency representativesof private security companies, commanders
of law enforcement agencies and the attorneys representing city,county, and state
agencies on civil liabilitydaims,
use of force, deadly force, and officer involved shootings. I also held the position of instructor for the
nationally
acclaimed Calibre Press Street Survival seminar where I presented specificinstruction to police officers and
private
securityofficers on the skills and tactics of use of force and deadly force and the tactics of control, including
handcuffing, neck restraint systems. total appendage restraint, active counter-measures, and tactics for pressure
point control. I also have been the Officer Involved Shooting tnstructor for the State of Texas Law Enforcement
Command College through the Law Enforcement Management Institute at Texas (LEMIT) as well as a presenter at
the Use of Force Summit in Connecticut and the Institutefor the Prevention of In-Custody Deaths, Las Vegas. I hold
certificationsas a firearms instructor, use of force instructor, electronic control device (ECD) instructor, handcuffing
instructor, total appendage restraint instructor, and lateral vascular neck restraint instructor.
VIDEO SURVEILLANCE EXPERIENCE
My experience includes hundreds of evaluations of video surveillance captured content and surveillance
coverage and was certified in December 2019 upon completion of the Certification for 'Video Examinations for Po[ice
Investigators" by Forensic Video Solutions, and have studied and researched all types of securitysystems in most
every type of application.These evaluations included the installation, coverage, recordingand monitoring from
police dash-cams and body cams to bank and ATM systems. Dozens of my evaluations involve bar or club
installations and procedures, but also includes unique situations like theme
parks, hospitals and jails,and of course,
there are installations in restaurants, shopping mails, apartment complexes, condominiums, office
buildings,
convenience stores and gas stations, and even some installations from private residences. During
my twenty five
plus years of consultingand litigation support I have viewed, on sight,these systems, studied the installation and
coverage; and evaluated specifically how the systems were utilized for evidentiaryvalue.
EXHIBT B
W. KEN KATSARIS
CURRICULUM VITAE
Page 3
ELECTRONIC CONTROL WEAPONS INSTRUCTOR EXPERIENCE
My CV reflects certifications as an instructor on the Use of Electronic Control Weapons (ECW), continuing
attendance at dozens of seminars over the [ast two decades, which focused on the use and
procedures of ECW's
(TASER@) that were presented by renowned experts from TASER International and the now renamed company
Axon, the medical research field,attorneys with TASER@ who trained specificlegal experience and expertise, and
Master TASER@ Instructors. I also was selected as only one of fifty, from countries throughout the world, to evaluate
the standards for ECWs by the National Institute of Standards
(NIS>. This world-wide collection of TASER@ experts
met several times in Washington, D.C., and heard from the TASER@ developers, Master Instructors,Medical
Researchers, and Electronic Engineers to resolve and set a standard for TASERS@.
My initialand continuing education and trainingon ECW's provided the basis for qualifyingme to provide
regional,statewide, and national trainingon the Policy and Procedure issues of TASER@ deployments. However,
my retention as an expert in defense of officers,primarilyin civil litigation
claims, as well as my critique of the
deployment of TASERS@ by officers in Plaintiff claims, where the TASER@ was deployed contrary to recognized,
trained, and accepted practices, has exposed me to a plethoraof agency policies throughout the USA as well.
CONSULTING AND LITIGATION EXPERIENCE
I have been retained as a
(50) states. And, in addition to all of the above
procedures expert in all fifty
experience, training, and education, it is important to also assess one specificconsultingpractice that I engage in -
assessing police and private securityofficers basic deployment procedures and their use of force, including physical
force, deadly force, vehicles, and force utilizingvarious policetools such as the policebaton, handcuffs, chemical
restraint sprays, firearms and electronic control weapons. I am either a certified user or instructor of each
tool, and
physicalcontrol tactic, and have been a state certified firearms, and decision shooting instructor, for over thirty(30)
years as well as a drivingand pursuit instructor.
Of equal importance to over 30 years of actual police experience in the field and the forty-five (45) plus
years of teaching tens of thousands of officers from all fifty(50> states, in both practical,hands-on use of force, and
deadly force issues, I have extensive experience doing case evaluations for the purpose of presenting reports and
opinions to the Court. I have also participatedin testifying, under oath, in both deposi#ons and trials in both state
and federal courts, where my testimony reflected I found officer misconduct, and that conduct was considered
criminal and/or civillyresponsible for negligence, gross negligence, deliberate indifference, as well as objectively
unreasonable. ]n the alternate, where the facts and circumstances were present to render favorable opinions as to
officer conduct, such as in the use of force or deadly force, my report,
deposition testimony or trial testimony
reflected those opinions as well. Over a thirty (30) year historyof litigation and court expert consulting, my work
would reflect a near splitbetween my findings and opinions of officer conduct and conformance/non-conformance to
recognized policyand officer accepted, recognized and trained practices.The checks and balances of this
consulting evaluation of officer conduct comes from cross examination, under oath, as to the officer conduct being
critiqued.Therefore, my record of opinions, both supportive of officer conduct or below a recognized standard of
care findings of officer performance have been archived, public,and very transparent.
! have been recognized for
my leadership styleand achievements as Sheriff by U.S. News & World report
as well as the New York Times and newspapero nationwide prior to being thrust into the national
spotlight while
directingthe Theodore Bundy Serial Murder investigation. [ directed the Tallahassee
investigationthat resulted in
Ted Bundy's imprisonment, and the supervision of the incarceration of Ted Bundy in the county jailfor over two
years. Bundy was convicted, sentenced and executed, after the Governor of Florida signed two death warrants, one
of which was for the Tallahassee murders.
POLICE ACADEMY TRAINING TAUGHT by W. Ken Katsaris
INSTRUCTOR: FLORIDA HIGHWAY PATROL ACADEMY, (Recruits and ln-Service Retraining Sessions for
Supervisors,Command Officers, Troopers, Communications Officers and Communications Supervisors) 1968-1997.
Areas of Instruction Provided by W. Ken Katsaris:
,
Vehicle Pursuit Policy/Procedures. ?
Accident Scene Protection
.
Emergency Vehicle Operations. Traffic Homicide Investigation
,
Use of Force and Deadly Force Policy Issues for Command Officers
,
InvestigationProcedures Preliminary/Follow-up Investigations
?
Crime Scene Processing "
Crimes Against Property (Burglary)
Supervision Procedures ,
Child Abuse/Neglect
Investigations
,
Communications Officers Training Sexual Assault/Battery Investigations
.
Communications Supervisors Training ,
Vice Crimes Investigations
,
911 Procedures ,
Traffic Stop Procedures
EXHIBT B
W. KEN KATSARIS
CURRICULUM VITAE
Page 4
INSTRUCTOR: LAW ENFORCEMENT ACADEMY, Pat Thomas Criminal Justice Academy, Six County Area
Police Officers, Deputy Sheriffs, Campus Police and State Officers -- 1968 - present.
Areas of Instruction Provided by W. Ken Katsaris:
Police Ethics ,
Weapons, Explosives, Weapons of Mass
,
Vehicle Pursuit Policy/Procedures Destruction (Law)
, Driver Skills (at Range) .
Warrant Procedures
'
InstructingDrivingInstructors ,
Probable Cause
,
Emergency Vehicle Operations Policy ?
Sexual Battery
(Ambulance and Police) ?
Assault and Battery
,
Firearms Policy/Use of Dead[y Force *
Concepts of Evidence/Evidence Rules
Deadly Force Decisions ?
Preliminary/Follow-Up Investigations
Firearms Shooting Skills (At Range) *
Homicide Investigation Procedures
*
Instructing Firearms Instructors ,
Stalking Investigations/Law
'
Weapons Carry and Use Law ,
Missing Children Investigations
Arrest, Procedures and Law
, ,
Attempts/Conspiracy/Solicitation
, Use of Force Policyand Procedures ,
Search and Seizure Law/Procedures
Criminal Law Informant Control/Procedures
Stop Procedures
,
Traffic
Emergency Commitment Procedure
.
High Risk/Vehicle Stops ?
Obstruction of Justice
Hostage and Barricade Response
' ?
Officer Survival Considerations
,
Crowd Control Procedures/Law '
Crisis I Violence
?
Patrol Hazards, Procedures ?
Recognizing, Approaching and Handling
*
Foot Pursuit Procedures Emotionally Disturbed Persons
?
Prisoner Transport Sexual Harassment/Hostile Work Environment
'
Prisoner Restraint Instructor Techniques: Certification course
,
Mental Illness: Police Procedures for Police Instructors
*
Substance Abuse: Police Procedures ,
Gang Recognition/Tactics
Mental Retardation
INSTRUCTOR: FLORIDA MARINE PATROL ACADEMY
State Officers assigned patrol duties on open ocean water, 1985-1991
.
Pursuit Procedure/Policy: Vehicles and Boats
INSTRUCTOR: FLORIDA GAME AND FRESH WATER FISH COMMISSION ACADEMY
?
Pursuit Procedure/Policy, Use of Force, 1985-1991
NATIONAL POLICE SEMINARS/COURSES TAUGHT by W. Ken Katsaris
INSTRUCTOR: "STREET SURVIVAL" FOR POLICE, CORRECTIONS AND PRIVATE SECURITY OFFICERS.
Seminars throughout the USA sponsored by City,County, State and Federal Police Agencies. Training seminars
in 25 states attended by over 20,000 officersfrom all 50 states,thousands of cities and counties, federal
agencies, the Royal Canadian Mounted Police and Canadian Provinces, as well as hundreds ofjail and prison
and supervisors from county jailsand the U.S. Bureau of Prisons. 1989-1991.
officers
Areas of Instruction Provided by W. Ken Katsaris:
?
Vehicle Pursuits Policy ?
Internal Investlgation Procedures
Emergency Response Policy -
Recognizingh Approaching and Handling the
,
Use of Force Mentally Itland Emotionally Disturbed
,
Prisoner Restraint Person/Inmate
.
Prisoner Transporting High Risk/Risk Unknown Vehicle Stops
Approach and Arrest
,
Domestic Violence Intervention
,
Impact Weapons Drug Interdiction Tactics and Procedures
?
Chemical Sprays Procedures used to Officers
*
Investigate
Compression Asphyxia Conduct Administrativelyand Criminally,
Procedures for Investigatingand arrestingmembers of involving Police, Jail and Prison Officers
Satanic Cults and Street Gang members Handcuffing Tactics
,
Defensive Tactics for Arrest and Control .
Single and Multiple Officer Patrol Tactics
EXHIBT B
W. KEN KATSARIS
CURRICULUM VITAE
Page 5
INSTRUCTOR AND SEMINAR COORDINATOR: IACP
IACP: International Association of Chiefs of Police. Management of the Investigative Function: Investigation of
Serial Murders (Specialty
developed as result of directing the Theodore Bundy Murders, Tallahassee, Florida)
Attended by investigationCommanders from throughoutthe USA. 1984-1986 in Nashville, Tennessee and
Tampa,
Florida.
INSTRUCTOR: AELE: Americans for Effective Law Enforcement, Senior Instructor for national seminars. The
attendees are primarily police governmental defense attorneys and law enforcement
managers and commanders.
1992 -
present.
AELE is a non-profit
organizationproviding educational, legal and other professionalservices and assistance to the
nations taw enforcement and corrections agencies, and files Amicus Briefs in cases
involving law enforcement and
corrections issues.
POLICE CIVIL LIABILITY SEMINAR (AELE) 1992-2002
Areas of /nstructjon Provided by W. Ken Katsarfs. (Senior Instructor)
In
Custody Deaths from RestrainingMethods/Issues
Restraint/Transporting Methods/Issues
.
In-Custody Injuries (Handcuffs, Chemicals, K-9, Batons, Physical Force) Suicides.
'
Police Pursuits (Tactics,Policies,Procedures, Investigations)
*
Emergency Response Procedures/Policy
'
Use of Force (Deadly-Non-Deadly) Training,Decision Making, Weapons, Tactics, Batons, Handcuffs, Chemical,
Restraints, K-9, Electronic Restraints (Taser,Stun Gun)
,
Less Lethal Munitions/Applications and Issues
RACE AND THE POLICE SEMINAR (AELE) 2001-2003
Areas of instruction ProWded by W. Ken Katsans- (Senior Instructor)
?
Racial Profling Claims and Definitions
Police Detention and Inquiry
Police Communications Issues (Radio/MDT's)
*
Race Identification Issues
*
Police Vehicle Stops/Searches
,
Use of K-9's at Stops
,
Probable Cause vs. Reasonable Suspicion vs. Racial Profiling
?
Use of Expert Witnesses for Plaintiff and Defense
.
Complaint Processing
CRITICAL INCIDENT RESPONSE: MANAGEMENT AND LEGAL LIABILITY SEMINAR
(AELE) 2002 - 2006
Areas of Instruction and Course Development Provided by W. Ken Katsaris
(Course Director and Senior Instructor)
Course Director Role
Development of Course Topics
Overall Direction of Training Issues
Review of Course Outlines and Instructors
Monitoring of Course Presentation
Facilitation Between Presenters and Attendees
Areas of Instruction
High Risk Entries Preparation,Surveillance,Assignments and Equipment Use
High Risk Warrant Service vs. High Risk Response to known Violent Subjects
,
?
Responding to the Mentally Ill and the Substance Abuser
,
Responding to the Suicidal/Suicide by Cop
Responding to the Active Shooter
?
?
Use of K-9's Policy and Procedure
Affects of Critioa[ tnoident on Officers
Reaction Time/Suspect Movements, and Shot Placement
EXHIBT B
W. KEN KATSARIS
CURRICULUM ViTAE
Page 6
EMPLOYEE DISCIPLINE AND LABOR SEMINAR (AELE) 1996-Present
Areas of Instruction Provided by W. Ken Katsaris:
*
Organization/Administration of Internal Outside Employment
?
Affairs Unit
of
Interviews/lnterrogations Accused/Implicated
,
Search and Monitoring Procedures/Policy
Officers ?
Progressive Discipline
? ?
Off-Duty Activities Conducting Internal Investigations
LAW MEDIA INSTRUCTOR (AELE) 2001-Present (Distributed nationally)
CD Rom Training Programs Instructed by W. Ken Katsatis
-
Officer Safety at Traffic Stops Miranda for Patrol Officers
Strip Searches by Police
.
[nterrogationLaw: Special Situations
?
Shooting Mistakes and Qualified Immunity
.
Interrogation Law: Reinterrogation and Trickery
,
Interrogation Law for Patrol Officers
,
POLICE/LAW ENFORCEMENT EXPERIENCE
FULL TIME POLICE EXPERIENCE
O St Petersburg Police Department, St. Petersburg, Florida Police Department, 1962-1966.
Uniform Patrol Investigations
,
Preliminary Investigations
.
Preview
Filing# 168749326 E-Filed 03/15/2023 09:46:14 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-016578 JOY FURER, Plaintiff, V GG RE HOLLYWOOD BEACH 613 LLC, Defendant. i DEFENDANT'S EXPERT WITNESS DISCLOSURE Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through undersigned counsel and pursuant to this Court's June 30,2022, Uniform Trial Order, hereby files its Expert Witness Disclosure as follows: 1. Christopher J. Troiano, M.D. Orthopedic Specialists,P.A. 7710 N.W. 71 St Court Suite 103 Tamarac, Fl 33321 954-739-9700 Dr. Troiano is a board-certified Orthopedic Surgeon who was retained to review all medical records and render his opinion regardingthe care, treatment, future needs, and future prognosis of the Plaintiff as well as to determine if the injuries allegedlysustained were consistent with and a direct result of the allegedinjuries referenced in the Plaintiff's complaint,subjectof this lawsuit. from medical and healthcare records,includingtests and films both before Dr. Troiano will testify and after the subjectincident, and anything else in his files. Dr. Troiano is expected to testify 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/15/2023 09:46:14 AM.**** CASE NO.: CACE-21-016578 concerning any conclusions, any treatment modalities provided, limitations, and any recommendations and opinions regarding the Plaintiff's future, including but not limited to worsening, accelerated degenerationand permanence of the injuries, the related future treatment, tests, medications, surgery, etc. and the costs associated with such, if any. Dr. Troiano is also regarding causation,permanency, the prognosis of the reasonableness and the expected to testify necessityo f Plaintiff's medical care up until the time o f trial and the need for future medical care related to the allegedinjurysustained on that is the subjectofthis lawsuit,if any. Dr. Troiano will as to the matters contained within testify all medical records includingthe Plaintiff's historyand A copy o f Dr. Troiano' s diagnostictesting. CV is attached hereto as Exhibit A. 2. W. Ken Kastaris 400 Capital Circle SE Suite 18299 Tallahassee, FL 32301 850-224-2929 Mr. Kastaris is a Law Enforcement, Corrections and Private Security Consultant/Trainer who was retained to review the including,but not limited to the incident report, supplementary reports, photographs and all related incidents in or around within a reasonable distance from the incident location of 2012 N. Surf Road, Hollywood Florida 33019, and any other related security and/or crime aspects needed to make an assessment regardingthe allegedincident referenced in the Plaintiff' s complaint,subjectofthis lawsuit. Mr. Kastaris will testify including,but not limited to previous crime history,securityprotocols,of the incident location 2012 N. Surf Road, Hollywood Florida 33019, A copy of Mr. Kastaris's CV is attached hereto as Exhibit B. 2 CASE NO.: CACE-21-016578 3. All expert witnesses listed by Co-Defendant. 4. All expert witnesses listed by Plaintiff. 5. All rebuttal expert witnesses necessitated by Plaintiff's disclosure of expert witnesses. 6. All witnesses and expert witnesses discovered priorto trial with timelynotice to opposing counsel. 7. Defendant reserves the rightto amend/supplement this Expert Witness Disclosure as necessary. DATED: March 15, 2023 ANDERSONGLENN LLP s/.John .J. Glenn John J. Glenn, Esquire Florida Bar No.. 957860 jglenn@asglaw.com Amanda N. Rumker, Esquire Florida Bar No.: 122580 arumker@asglaw.com 2650 North MilitaryTrail,Suite 430 Boca Raton, Florida 33341 Tel.: (561) 893-9192 Fax: (561) 893-9194 Attorneys for GG RE Hollywood Beach 613 LLC CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 15, 2023 I electronically filed the foregoingdocument with the Clerk of the Court using Florida Court's E-Filing Portal and certifythat all counsel of record have been served via transmission ofNotice of Electronic Filinggeneratedby Florida Court E-FilingPortal or in some other authorized manner for those counsel or partieswho are not Notices of Electronic Filing. authorized to receive electronically /s/.John .J. Glenn John J. Glenn, Esquire 3 EXHIBIT A A ORTHOPEDIC CURRICULUM VITAE SPECIALISTS, P.A. I. EDUCATION CHRISTOPHER J. TROIANO, M.D., F.A.A.O.S., F.A.C.S. Diplomate A. Board Certification and Fellowships: AMERICAN BOARD OF ORTHOPEDIC SURGERY Fellow-American College of Surgeons, Oct.14 1993 Fellow-American Academy of Orthopaedic Surgeons, February 18,1993 7710 N.W. 71st Court , Suite 103 Diplomate-American Board of Orthopedic Surgery, Tamarac, Florida 33321 July 12,1991 954.739.9700 Recertified, January 01,2002 FAX 954.739.1934 Recertified,January 01,2012 Recertified,January 01, 2022 Email B. Post Graduate Medical Training: Resident in New York Medical College OrthopedicSurgery Program-Affiliated June 1985-June 1989 Hospitals, Westchester County Medical Center, Valhalla, NY Lincoln Medical and Mental Health Hospital, Bronx, NY MetropolitanHospital,New York, NY Lincoln Medical and Mental Health Hospital Our Lady of Mercy Hospital,Bronx, NY (General Surgery) July 1984-June 1985 C. Medical School: New York Medical College,Valhalla, NY 1980-1984 M.D. D. College: Fordham University,Bronx, NY 1976-1980 B.S. Biology Summa Cum Laude Phi Beta Kappa Alpha Epsilon Delta EXHIBIT A L.?r ORTHOPEDIC II. PROFESSIONAL HISTORY r SPECIALISTS, RA. A. Private Practice July 1989 to present MF .Z CHRISTOPHER J. TROIANO,M.D., B. HospitalAffiliations: F.A.A.O.S.,F.A.C.S. *M' Dtptomate Florida Medical Center Hospital #..,AUmcAN BOARD OF ORTHOPED/C SURGERY Lauderdale Lakes, FL f> : k. ' UniversityHospital : : 7710 N.W. 71st Court, Suite 103 Tamarac, Florida 33321 Tamarac, FL 954.739.9700 FAX 954.739.1934 C. Professional Organizations: Broward OrthopaedicSociety Email Broward County Medical Association Florida Medical Association American Medical Association American Academy of Orthopedic Surgeons D. Barry UniversityPhysician Assistant Program Preceptor 2006 Director Rehabilitation Services Rehabilitation Institute of Florida 2003-2005 Board of Governors Florida Medical Center 2004 Medical Advisory Board St. John's Rehabilitation Hospital2003-2005 Vice ChiefUniversityHospital2016-2019 Chief of SurgicalReview Committee University Hospital2016-present SecretaryTreasurer UniversityHospital2019 - present E. Appointed Expert Medical Advisor Florida's Worker's Compensation 1996-present EXHIBIT A ..i'B ORTHOPEDIC F. Featured in "The Best Doctors in South Florida" j SPECIALISTS, RA. Miami Metro Magazine: 1999 AF. F. Awards: CHRISTOPHER J. TROIANO,M.D., F.A.A.O.S.,F.A.C.S. New York Medical College-"The Orthopaedic Diplomaie Surgery Award", June 3,1984 ' ' AMERICAN BOARD OF ORTHOPEDIC SURGERY . ChiefResident Orthopaedic Surgery &f (July1,1998 to June 30, 1989) OutstandingYoung Man of America 1996 7710 N.W. 71st Court , Suite 103 Tamarac, Florida 33321 G. Presentations: 954.739.9700 FAX 954.739.1934 "The Use of an AdjustableShoe Orthosis in The Treatment of Metatarsus Adductus" New York OrthopaedicPediatric Research Society Email Resident Competition Night,Hospitalfor Special Surgery,New York, NY April1988 "The Use of an AdjustableShoe Orthosis in The Treatment of Metatarsus Adductus' ,, ChristopherJ. Troiano M.D., Robert L. Cristofaro, M.D. Andrew H. Meyers, B.S., C.P.P. 55th annual meeting. American Academy of Orthopaedic Surgeons, February 8, 1988, Atlanta, GA H. Community Service: A. Team PhysicianVarsityFootball, Taravalla High Coral Springs,FL 1989-1991 Marjory Stoneman Douglas High School Parkland, FL 1991-2002 Monarch High School 2003 and 2006 B. Coral Springs Lightning Tackle Football Camp Physician1990-1992 C. Coral SpringsMedical Center, Sportsmedicine Program 1996-2004 D. PhysicianVolunteer Homestead Field Hospital Homestead, FL-Hurricane Andrew-1992 E. Tamarac Outreach Program 2015 I Christopher MD ![.?roiano, EXHIBT B W. KEN KATSARIS Law Enforcement, Corrections and Private Security Consultant/Trainer - Addresses: Post OfficeBox 12008 Tallahassee,FL 32317-2008 r or Street for overnight deliveryand packages: 400 Capital Circle SE, Suite 18299 FL 32301 Tallahassee, (850) 224-2929 Phone consultkatsaris@,gmail.com CURRICULUM VITAE CREDENTIALS AND EXPERIENCE SUMMARY OF W. KEN KATSARIS PRIVATE SECURITY/PREMISES LIABILITY EXPERIENCE My background reflects an unusual blend of publicand privateenforcement and security education, training and practicalexperience. I have provided training for officers working for large privatesecuritycompanies to very small guard services. And, I have provided continuingand expert services on securityconcerns to large national companies to small businesses as well which would include small strip mails to mails occupying vast acreage. I have served as a securityand premises liability expert for plaintiffsand defendants throughout the U.S. Many of these cases involved securityissues in large shopping mails large theme parks, apanment complexes, condominiums, office buildings,restaurants, stripmails, privateresidences, and hospitals,as well as government maintained offices and properties.I have also provided consultingservices to similar properties. ] have also been retained by law enforcement agencies facing liability claims and crime related issues for agencies such as the Los Angeles County Sheriff, Chicago, Metro-Dade, Florida, Houston, Texas, Atlanta, Ponland Oregon, Las Vegas, and Kansas City Missouri, Phoenix, Arizona, Tucson, Arizona and Hartford, Connecticut to name only a few from the hundreds in all 50 states. I specificallyhold current commercial securitycertifications, and have also been appointed as a SecurityInspector for Small Businesses, their cash management, camera surveillance, parking lots, lighting, employee training?and alarm capabilities. This certificationwas earned by virtue of experience, and training apedficallyprovided by the Attorney General's Crime Prevention Institute. And, I have been an active member of the American Society of Industrial Security(ASIS> for over twenty-five (25> years. l hold the prestigiousCPP (Crime Prevention Practitioner) designation,earned after completion of a series of courses and testing. I am a member of the International Association of Chiefs of Police (IACP) Crime Prevention Committee which is a presidential appointment. As a member of the Florida Department of State Private SecurityAdvisory Council I chaired the Firearms Committee and drafted policies for guard deployment and use of force and deadly force by privatesecurityofficers. The council specifically addressed standards for Private Security Officers, trainingand licensing. Academic courses in Private Securityand Premises Liability were requirements for my criminologydegree, and later, as a professor, I taught seminars for college credit on the same topic. As important as academics, is my involvement in managing public and private officers assigned county-wide to protect the premises of businesses, college campuses, motels, hotels, shopping mails, banks, public events such as football games and concerts, and of course, parkinglots. LAW ENFORCEMENT EXPERIENCE ! am currently acertified Florida Law Enforcement Officer/Instructor,and consultant in law enforcement and privatesecurity. I regularlyinstruct in a wide area of law enforcement subjects at the Regional Police/Corrections Academy, where I have been teaching for over 30 years. For over 25 years, I was also an instructor at the Florida Highway Patrol Academy. I also participatein law enforcement seminars throughout the USA and representativeof (50) states, where I have instructed well over 150,000 Police Officers, Private Security Officers,Commanders, all fifty EXHIBT B W. KEN KATSARIS CURRICULUM VITAE Page 2 Agency Administrators and the Attorneys representing these Agencies on a number of liability, investigation,tactics, and policy and procedure related subjects,induding the Internal Procedures followinga complaint or incident. In the past ] have also specifically instructed over 25,000 Officers from a1150 states including Private Securityagencies, the Federal agencies and the Canadian Royal Mounted Police in a varietyof street survival police procedures including use of force and deadly force as well as other policy areas that are detailed in my C.V. My law enforcement experience indudes service as a Police Officer for the St. Petersburg Florida Police Department, off-dutyarmed private security,Police Officer with the Tallahassee Florida Police Department, Deputy Sheriff with the Leon County Sheriff's Office, Trooper with the Florida Highway Patrol, the elected Constitutional sheriff who performs as the Chief Law Enforcement Officer of the County of Leon, City of Tallahassee, Florida, a jurisdiction of 700 square miles, and I served as the Assistant to the Secretary of Corrections for the State of Florida, as an administrator of the third largest prison system in the nation, administeringover 84 prisons and supervising 67 county detention systems. ACADEMIC INSTRUCTION/CREDENTIALS My academic instructional background and credentials includes 10 years as the Department Chairman of the Crimina[ Justice Program at Tallahassee Community College (Tallahassee, Florida). In this capacity I directed and taught both the advanced in-service Police training programs and the degree granting programs, as well as directingthe crime lab used to support local law enforcement. Extensive teaching and trainingincluded basic concepts and hands on skill development jn private securityprocedures, police patroland criminal investigationand criminalistics courses. Academic subjects included courses in securitymanagement, police procedures, criminology,and private securitypatroland administration. Additionally,l have served as an adjunct professor in Criminology and Social Work at Florida State University.My academic achievements include an Associate in Arts (AA) in Police Administration from St. Petersburg,Florida Junior College, a Bachelor of Science (BS) Degree in Criminology, Master of Science (MS) Degree in Criminology, Florida State University, Tallahassee, Florida, and [ am ABD for the Doctorate in Public Adminisration at NOVA Southeast University,Ft. Lauderdale, Florida. TRAINING INSTRUCTOR EXPERIENCE My experience includes extensive instruction to over 150,000 officers throughout the United States, includingall of the concepts, issues, and procedures for threat assessment, approaching,controlling, and restraining resistingsubjects. For over twenty-five(25) years I instructed at the Florida Highway Patrol Academy on use of force policyand procedure, as well as serving as the force and deadly force advisor for thirteen (13) years to the Director of the Highway Patrol. For over 1hirty(30) years I have instructed at the Pat Thomas Regional Law Enforcement Academy and the Florida Public Safety Institute. Some of my assigned subjects are use of force, deadly force,crisis intervention, and dealingwith the mentally illand emotionally disturbed individual, firearms, traffic stops and vehide pursuits. For over twenty (20) years I have been senior instructor and tactical advisor for AELE, the nationally recognized organization providing instruction to agency representativesof private security companies, commanders of law enforcement agencies and the attorneys representing city,county, and state agencies on civil liabilitydaims, use of force, deadly force, and officer involved shootings. I also held the position of instructor for the nationally acclaimed Calibre Press Street Survival seminar where I presented specificinstruction to police officers and private securityofficers on the skills and tactics of use of force and deadly force and the tactics of control, including handcuffing, neck restraint systems. total appendage restraint, active counter-measures, and tactics for pressure point control. I also have been the Officer Involved Shooting tnstructor for the State of Texas Law Enforcement Command College through the Law Enforcement Management Institute at Texas (LEMIT) as well as a presenter at the Use of Force Summit in Connecticut and the Institutefor the Prevention of In-Custody Deaths, Las Vegas. I hold certificationsas a firearms instructor, use of force instructor, electronic control device (ECD) instructor, handcuffing instructor, total appendage restraint instructor, and lateral vascular neck restraint instructor. VIDEO SURVEILLANCE EXPERIENCE My experience includes hundreds of evaluations of video surveillance captured content and surveillance coverage and was certified in December 2019 upon completion of the Certification for 'Video Examinations for Po[ice Investigators" by Forensic Video Solutions, and have studied and researched all types of securitysystems in most every type of application.These evaluations included the installation, coverage, recordingand monitoring from police dash-cams and body cams to bank and ATM systems. Dozens of my evaluations involve bar or club installations and procedures, but also includes unique situations like theme parks, hospitals and jails,and of course, there are installations in restaurants, shopping mails, apartment complexes, condominiums, office buildings, convenience stores and gas stations, and even some installations from private residences. During my twenty five plus years of consultingand litigation support I have viewed, on sight,these systems, studied the installation and coverage; and evaluated specifically how the systems were utilized for evidentiaryvalue. EXHIBT B W. KEN KATSARIS CURRICULUM VITAE Page 3 ELECTRONIC CONTROL WEAPONS INSTRUCTOR EXPERIENCE My CV reflects certifications as an instructor on the Use of Electronic Control Weapons (ECW), continuing attendance at dozens of seminars over the [ast two decades, which focused on the use and procedures of ECW's (TASER@) that were presented by renowned experts from TASER International and the now renamed company Axon, the medical research field,attorneys with TASER@ who trained specificlegal experience and expertise, and Master TASER@ Instructors. I also was selected as only one of fifty, from countries throughout the world, to evaluate the standards for ECWs by the National Institute of Standards (NIS>. This world-wide collection of TASER@ experts met several times in Washington, D.C., and heard from the TASER@ developers, Master Instructors,Medical Researchers, and Electronic Engineers to resolve and set a standard for TASERS@. My initialand continuing education and trainingon ECW's provided the basis for qualifyingme to provide regional,statewide, and national trainingon the Policy and Procedure issues of TASER@ deployments. However, my retention as an expert in defense of officers,primarilyin civil litigation claims, as well as my critique of the deployment of TASERS@ by officers in Plaintiff claims, where the TASER@ was deployed contrary to recognized, trained, and accepted practices, has exposed me to a plethoraof agency policies throughout the USA as well. CONSULTING AND LITIGATION EXPERIENCE I have been retained as a (50) states. And, in addition to all of the above procedures expert in all fifty experience, training, and education, it is important to also assess one specificconsultingpractice that I engage in - assessing police and private securityofficers basic deployment procedures and their use of force, including physical force, deadly force, vehicles, and force utilizingvarious policetools such as the policebaton, handcuffs, chemical restraint sprays, firearms and electronic control weapons. I am either a certified user or instructor of each tool, and physicalcontrol tactic, and have been a state certified firearms, and decision shooting instructor, for over thirty(30) years as well as a drivingand pursuit instructor. Of equal importance to over 30 years of actual police experience in the field and the forty-five (45) plus years of teaching tens of thousands of officers from all fifty(50> states, in both practical,hands-on use of force, and deadly force issues, I have extensive experience doing case evaluations for the purpose of presenting reports and opinions to the Court. I have also participatedin testifying, under oath, in both deposi#ons and trials in both state and federal courts, where my testimony reflected I found officer misconduct, and that conduct was considered criminal and/or civillyresponsible for negligence, gross negligence, deliberate indifference, as well as objectively unreasonable. ]n the alternate, where the facts and circumstances were present to render favorable opinions as to officer conduct, such as in the use of force or deadly force, my report, deposition testimony or trial testimony reflected those opinions as well. Over a thirty (30) year historyof litigation and court expert consulting, my work would reflect a near splitbetween my findings and opinions of officer conduct and conformance/non-conformance to recognized policyand officer accepted, recognized and trained practices.The checks and balances of this consulting evaluation of officer conduct comes from cross examination, under oath, as to the officer conduct being critiqued.Therefore, my record of opinions, both supportive of officer conduct or below a recognized standard of care findings of officer performance have been archived, public,and very transparent. ! have been recognized for my leadership styleand achievements as Sheriff by U.S. News & World report as well as the New York Times and newspapero nationwide prior to being thrust into the national spotlight while directingthe Theodore Bundy Serial Murder investigation. [ directed the Tallahassee investigationthat resulted in Ted Bundy's imprisonment, and the supervision of the incarceration of Ted Bundy in the county jailfor over two years. Bundy was convicted, sentenced and executed, after the Governor of Florida signed two death warrants, one of which was for the Tallahassee murders. POLICE ACADEMY TRAINING TAUGHT by W. Ken Katsaris INSTRUCTOR: FLORIDA HIGHWAY PATROL ACADEMY, (Recruits and ln-Service Retraining Sessions for Supervisors,Command Officers, Troopers, Communications Officers and Communications Supervisors) 1968-1997. Areas of Instruction Provided by W. Ken Katsaris: , Vehicle Pursuit Policy/Procedures. ? Accident Scene Protection . Emergency Vehicle Operations. Traffic Homicide Investigation , Use of Force and Deadly Force Policy Issues for Command Officers , InvestigationProcedures Preliminary/Follow-up Investigations ? Crime Scene Processing " Crimes Against Property (Burglary) Supervision Procedures , Child Abuse/Neglect Investigations , Communications Officers Training Sexual Assault/Battery Investigations . Communications Supervisors Training , Vice Crimes Investigations , 911 Procedures , Traffic Stop Procedures EXHIBT B W. KEN KATSARIS CURRICULUM VITAE Page 4 INSTRUCTOR: LAW ENFORCEMENT ACADEMY, Pat Thomas Criminal Justice Academy, Six County Area Police Officers, Deputy Sheriffs, Campus Police and State Officers -- 1968 - present. Areas of Instruction Provided by W. Ken Katsaris: Police Ethics , Weapons, Explosives, Weapons of Mass , Vehicle Pursuit Policy/Procedures Destruction (Law) , Driver Skills (at Range) . Warrant Procedures ' InstructingDrivingInstructors , Probable Cause , Emergency Vehicle Operations Policy ? Sexual Battery (Ambulance and Police) ? Assault and Battery , Firearms Policy/Use of Dead[y Force * Concepts of Evidence/Evidence Rules Deadly Force Decisions ? Preliminary/Follow-Up Investigations Firearms Shooting Skills (At Range) * Homicide Investigation Procedures * Instructing Firearms Instructors , Stalking Investigations/Law ' Weapons Carry and Use Law , Missing Children Investigations Arrest, Procedures and Law , , Attempts/Conspiracy/Solicitation , Use of Force Policyand Procedures , Search and Seizure Law/Procedures Criminal Law Informant Control/Procedures Stop Procedures , Traffic Emergency Commitment Procedure . High Risk/Vehicle Stops ? Obstruction of Justice Hostage and Barricade Response ' ? Officer Survival Considerations , Crowd Control Procedures/Law ' Crisis I Violence ? Patrol Hazards, Procedures ? Recognizing, Approaching and Handling * Foot Pursuit Procedures Emotionally Disturbed Persons ? Prisoner Transport Sexual Harassment/Hostile Work Environment ' Prisoner Restraint Instructor Techniques: Certification course , Mental Illness: Police Procedures for Police Instructors * Substance Abuse: Police Procedures , Gang Recognition/Tactics Mental Retardation INSTRUCTOR: FLORIDA MARINE PATROL ACADEMY State Officers assigned patrol duties on open ocean water, 1985-1991 . Pursuit Procedure/Policy: Vehicles and Boats INSTRUCTOR: FLORIDA GAME AND FRESH WATER FISH COMMISSION ACADEMY ? Pursuit Procedure/Policy, Use of Force, 1985-1991 NATIONAL POLICE SEMINARS/COURSES TAUGHT by W. Ken Katsaris INSTRUCTOR: "STREET SURVIVAL" FOR POLICE, CORRECTIONS AND PRIVATE SECURITY OFFICERS. Seminars throughout the USA sponsored by City,County, State and Federal Police Agencies. Training seminars in 25 states attended by over 20,000 officersfrom all 50 states,thousands of cities and counties, federal agencies, the Royal Canadian Mounted Police and Canadian Provinces, as well as hundreds ofjail and prison and supervisors from county jailsand the U.S. Bureau of Prisons. 1989-1991. officers Areas of Instruction Provided by W. Ken Katsaris: ? Vehicle Pursuits Policy ? Internal Investlgation Procedures Emergency Response Policy - Recognizingh Approaching and Handling the , Use of Force Mentally Itland Emotionally Disturbed , Prisoner Restraint Person/Inmate . Prisoner Transporting High Risk/Risk Unknown Vehicle Stops Approach and Arrest , Domestic Violence Intervention , Impact Weapons Drug Interdiction Tactics and Procedures ? Chemical Sprays Procedures used to Officers * Investigate Compression Asphyxia Conduct Administrativelyand Criminally, Procedures for Investigatingand arrestingmembers of involving Police, Jail and Prison Officers Satanic Cults and Street Gang members Handcuffing Tactics , Defensive Tactics for Arrest and Control . Single and Multiple Officer Patrol Tactics EXHIBT B W. KEN KATSARIS CURRICULUM VITAE Page 5 INSTRUCTOR AND SEMINAR COORDINATOR: IACP IACP: International Association of Chiefs of Police. Management of the Investigative Function: Investigation of Serial Murders (Specialty developed as result of directing the Theodore Bundy Murders, Tallahassee, Florida) Attended by investigationCommanders from throughoutthe USA. 1984-1986 in Nashville, Tennessee and Tampa, Florida. INSTRUCTOR: AELE: Americans for Effective Law Enforcement, Senior Instructor for national seminars. The attendees are primarily police governmental defense attorneys and law enforcement managers and commanders. 1992 - present. AELE is a non-profit organizationproviding educational, legal and other professionalservices and assistance to the nations taw enforcement and corrections agencies, and files Amicus Briefs in cases involving law enforcement and corrections issues. POLICE CIVIL LIABILITY SEMINAR (AELE) 1992-2002 Areas of /nstructjon Provided by W. Ken Katsarfs. (Senior Instructor) In Custody Deaths from RestrainingMethods/Issues Restraint/Transporting Methods/Issues . In-Custody Injuries (Handcuffs, Chemicals, K-9, Batons, Physical Force) Suicides. ' Police Pursuits (Tactics,Policies,Procedures, Investigations) * Emergency Response Procedures/Policy ' Use of Force (Deadly-Non-Deadly) Training,Decision Making, Weapons, Tactics, Batons, Handcuffs, Chemical, Restraints, K-9, Electronic Restraints (Taser,Stun Gun) , Less Lethal Munitions/Applications and Issues RACE AND THE POLICE SEMINAR (AELE) 2001-2003 Areas of instruction ProWded by W. Ken Katsans- (Senior Instructor) ? Racial Profling Claims and Definitions Police Detention and Inquiry Police Communications Issues (Radio/MDT's) * Race Identification Issues * Police Vehicle Stops/Searches , Use of K-9's at Stops , Probable Cause vs. Reasonable Suspicion vs. Racial Profiling ? Use of Expert Witnesses for Plaintiff and Defense . Complaint Processing CRITICAL INCIDENT RESPONSE: MANAGEMENT AND LEGAL LIABILITY SEMINAR (AELE) 2002 - 2006 Areas of Instruction and Course Development Provided by W. Ken Katsaris (Course Director and Senior Instructor) Course Director Role Development of Course Topics Overall Direction of Training Issues Review of Course Outlines and Instructors Monitoring of Course Presentation Facilitation Between Presenters and Attendees Areas of Instruction High Risk Entries Preparation,Surveillance,Assignments and Equipment Use High Risk Warrant Service vs. High Risk Response to known Violent Subjects , ? Responding to the Mentally Ill and the Substance Abuser , Responding to the Suicidal/Suicide by Cop Responding to the Active Shooter ? ? Use of K-9's Policy and Procedure Affects of Critioa[ tnoident on Officers Reaction Time/Suspect Movements, and Shot Placement EXHIBT B W. KEN KATSARIS CURRICULUM ViTAE Page 6 EMPLOYEE DISCIPLINE AND LABOR SEMINAR (AELE) 1996-Present Areas of Instruction Provided by W. Ken Katsaris: * Organization/Administration of Internal Outside Employment ? Affairs Unit of Interviews/lnterrogations Accused/Implicated , Search and Monitoring Procedures/Policy Officers ? Progressive Discipline ? ? Off-Duty Activities Conducting Internal Investigations LAW MEDIA INSTRUCTOR (AELE) 2001-Present (Distributed nationally) CD Rom Training Programs Instructed by W. Ken Katsatis - Officer Safety at Traffic Stops Miranda for Patrol Officers Strip Searches by Police . [nterrogationLaw: Special Situations ? Shooting Mistakes and Qualified Immunity . Interrogation Law: Reinterrogation and Trickery , Interrogation Law for Patrol Officers , POLICE/LAW ENFORCEMENT EXPERIENCE FULL TIME POLICE EXPERIENCE O St Petersburg Police Department, St. Petersburg, Florida Police Department, 1962-1966. Uniform Patrol Investigations , Preliminary Investigations .