Preview
CAUSE NO. 20-03-04112
JAIME SALINAS THE DISTRICT COURT OF
VS. MONTGOMERY COUNTY, TEXAS
DARLA WILSON AND FARMERS
TEXAS COUNTY MUTUAL INSURANCE 284TH JUDICIAL DISTRICT
PLAINTIFF’S FIRST SUPPLEMENTAL DESIGNATION EXPERT WITNESSES
SECOND SUPPLMENTAL DISCLSOURE
Plaintiff Jaime Salinas serves his Designation of Expert Witnesses and Supplemental Dis-
closure as follows:
194.2.(d) The Amount and any method of calculating economic damages:
SUPPLEMENTAL RESPONSE:
MEDICAL PROVIDER INCURRED
HCA Houston Healthcare Kingwood $53,237.00
Insight MRI Advantis MRI & Diagnostic Imag- $3,200.00
ing
Sterling Pharmacy $257.41
Beltway 8 Accident Clinic $4,495.00
Capstone Surgery Center $600.00
Compass Point ER Physicians, P.L.L.C. $2,055.00
Singleton Associates PA Radiology $930.00
Montgomery County Hospital District EMS $805.90
ESTIMATED FUTURE TREATMENT:
Capstone Surgery Center $22,995.00
TOTAL: 8,575.37
194.2(f) For any testifying expert:
1) the expert’s name, address and telephone number;
2) the subject matter on which the expert will testify;
3) the general substance of the expert’s mental impressions and opinions
and a brief summary of the basis for them, or if the expert is not retained
Designation of Expert Witnesses and Supplemental Disclosure Page 1 of
by, employed by, or otherwise subject to the control of the responding
party, documents reflecting such information;
if the expert is retained by, employed by, or otherwise subject to the con-
trol of the responding party:
A. all documents, tangible things, reports, models, or data compila-
tions that have been provided to, reviewed by, or prepared by or
for the expert in anticipation of the expert’s testimony; and
the expert’s current resume and bibliography.
RESPONSE: Plaintiff incorporates herein by reference Plaintiff’s Supplemental Re-
sponses to Defendant’s Request for Disclosure (and all amendments and supplements thereto) to-
gether with all other discovery responses previously served on Defendant and designates his expert
witnesses as follows:
ETAINED XPERTS
I. Non Retained Medical Experts. The following person(s), or their custodian(s) of rec-
ords, have not been retained by and are not employed by, or are otherwise subject to the control
of Plaintiffs (hereinafter referred to as “non retained” experts), but are hereby designated as
testifying experts by Plaintiffs 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 Plaintiffs 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, Plaintiffs will designate these witnesses as persons who may be called
upon to give testimony that would be considered expert testimony.
The following healthcare providers, and/or the custodian(s) of their records, may testify regard-
ing the injuries sustained by Plaintiffs as a result of 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 Plaintiffs’ injuries in the past and in the future.
Please refer to the healthcare providers’ records for their mental impressions, opinions, conclu-
sions, and the factual basis for each opinion.
I.1 Identity of Non Retained Medical Experts. The names of Plaintiffs’ non retained, non con
trolled medical experts and their addresses and telephone numbers are as follows:
THE FOLLOWING INDIVIDUALS AND ENTITIES AND THEIR CURRENT AND FOR-
MER OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVANTS, PHYSICIANS,
NURSES, PARAMEDICS, EMTs, ATTENDANTS, STAFF, HEALTHCARE PROVID-
ERS, AND CUSTODIANS OF RECORDS:
HCA Houston Healthcare Kingwood
Designation of Expert Witnesses and Supplemental Disclosure Page of
(f)(1): James C. Barton
Christopher Bathurst, M.D.
Jesse Proett, M.D.
Sankaman Praisoody, MD
22999 US HWY59
Kingwood, Texas 77
(f)(2): The subject matters on which said non retained, non controlled medical experts
will testify are as follows:
Their knowledge, skill, training, education, and/or experience as they relate to the
subject matter of this lawsuit;
Their qualifications to render an expert opinion;
laintiff's injuries at issue in this case;
the medical care provided and/or prescribed to plaintiff;
the existence, nature and/or extent of, and pain associated with the injuries sus-
tained by Plaintiff;
the examination and treatment of the injuries sustained by Plaintiff;
pre existing injuries to and/or pre existing medical conditions of Plaintiff, or lack
thereof;
the type, purpose, extent, results, evaluations and/or interpretations of examinations
and treatments;
recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff
in the past, and the reasonable probability and extent of the disabilities and/or inca-
pacities which Plaintiff may suffer from in the future;
the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
medical care and treatment and medications that have been required by Plaintiff in
the past for the treatment of the injuries allegedly sustained by Plaintiff as a result
of the incident made the basis of this lawsuit and for rehabilitation from such inju-
ries;
Designation of Expert Witnesses and Supplemental Disclosure Page of
medical care and treatment and medications that will be required by Plaintiff in the
future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the
incident made the subject of this lawsuit and for rehabilitation from such injuries;
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical prob-
ability, will need in the future for the injuries sustained by Plaintiff as a result of
the incident made the basis of this lawsuit;
all those subject matters contained, discussed or disclosed in:
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause;
all medical records affidavits and/or medical billing affidavits which have
been served and which may hereafter be served in this cause, and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
all written reports of healthcare providers produced during the course of
discovery in this cause.
All of the above documents are incorporated herein by reference as though set ou
verbatim for all purposes.
(f)(3):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:
The medical care and treatme t rendered to Plaintiff for his injuries was rea-
sonable and/or necessary;
The subject incident did, based on reasonable medical probability, cause all of
the complaints, disabilities, injuries, and or incapacities of Plaintiff;
Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in
part of the injuries received by Plaintiff and made the subject of this suit;
Designation of Expert Witnesses and Supplemental Disclosure Page of
that any surgical intervention for treatment of Plaintiff’s symptoms was neces-
sitated and proximately caused by the incident made the subject of this lawsuit;
that the medical expenses of Plaintiff were necessitated by the incident which
is the subject of this lawsuit;
that the amount Plaintiff was charged for medical expenses was reasonable;
all other impressions and/or opinions that are contained, discussed, and/or dis-
closed in the following:
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause including the following:
Records from HCA Healthcare Kingwood
See Plaintiff’s production Salinas6; Salinas59 Salinas144 and
Records from Quality Care Family Clinic, P.A. Plaintiff will sup-
plement.
all medical records affidavits and medical billing affidavits which have
been served and which may hereafter be served in this cause and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
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.
The basis for the foregoing impressions and opinions of the above named and/or
designated expert witnesses are based on the following:
The experts’ knowledge, skill, training, education, and experience;
Designation of Expert Witnesses and Supplemental Disclosure Page of
All of the medical records of Plaintiff produced in this cause by any
party;
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;
e Responses to Requests for Disclosure, Responses to Requests for
Production, Answers to Interrogatories, and the Amendments and Sup-
plements thereto which have been served by each of the parties in this
action;
The pleadings on file in this action; and
All documents and tangible things produced in this cause.
All of said documents are incorporated herein by reference as though set
out at length for all purposes.
Advantis MRI & Diagnostic Imaging aka Insight MRI & Diagnostics
(f)(1): the expert’s name, address, and telephone number
Santiago Guajardo , M.D.
Chad T. Porter, M.D.
14405 Walters Road, Suite A
Houston, Texas 77014
(f)(2): The subject matters on which said non retained, non controlled medical experts
will testify are as follows:
Their knowledge, skill, training, education, and/or experience as they relate to the
subject matter of this lawsuit;
Their qualifications to render an expert opinion;
plaintiff's injuries at issue in this case;
Designation of Expert Witnesses and Supplemental Disclosure Page of
the medical care provided and/or prescribed to plaintiff;
the existence, nature and/or extent of, and pain associated with the injuries sus-
tained by Plaintiff;
the examination and treatment of the injuries sustained by Plaintiff;
pre existing injuries to and/or p existing medical conditions of Plaintiff, or lack
thereof;
the type, purpose, extent, results, evaluations and/or interpretations of examinations
and treatments; rays and MRIs tests regarding Plaintiff.
recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff
in the past, and the reasonable probability and extent of the disabilities and/or inca-
pacities which Plaintiff may suffer from in the future;
the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
medical care and treatment and medications that have been required by Plaintiff in
the past for the treatment of the injuries allegedly sustained by Plaintiff as a result
of the incident made the basis of this lawsuit and for rehabilitation from such inju-
ries;
medical care and treatment and medications that will be required by Plaintiff in the
future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the
incident made the subject of this lawsuit and for rehabilitation from such injuries;
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical prob-
ability, will need in the future for the injuries sustained by Plaintiff as a result of
the incident made the basis of this lawsuit;
all those subject matters contained, discussed or disclosed in:
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause;
Designation of Expert Witnesses and Supplemental Disclosure Page of
all medical records affidavits and/or medical billing affidavits which have
been served and which may hereafter be served in this cause, and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
all written reports of healthcare providers produced during the course of
discovery in this cause.
All of the above documents are incorporated herein by reference as though set out
verbatim for all purposes.
(f)(3):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:
The medical care and treatment rendered to Plaintiff for his injuries was rea-
sonable and/or necessary;
The subject incident did, based on reasonable medical probability, cause all of
the complaints, disabilities, injuries, and or incapacities of Plaintiff;
Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in
part of the injuries received by Plaintiff and made the subject of this suit;
that any surgical intervention for treatment of Plaintiff’s symptoms was neces-
sitated and proximately caused by the incident made the subject of this lawsuit;
that the medical expenses of Plaintiff were necessitated by the incident which
is the subject of this lawsuit;
that the amount Plaintiff was charged for medical expenses was reasonable;
all other impressions and/or opinions that are contained, discussed, and/or dis-
closed in the following:
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause including the following:
Designation of Expert Witnesses and Supplemental Disclosure Page of
Records from Advantis MRI/Insight MRI
See Plaintiff’s production (Salinas7 Salinas8; Salinas19 Sa-
linas22 and
Records from Beltway 8 Accident Clinic
See Plaintiff’s Production (Salinas23 Salinas58).
all medical records affidavits and medical billing affidavits which have
been served and which may hereafter be served in this cause and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
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.
The basis for the foregoing impressions and opinions of the above named and/or
esignated expert witnesses are based on the following:
The experts’ knowledge, skill, training, education, and experience;
All of the medical records of Plaintiff produced in this cause by any
party;
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 caus
Designation of Expert Witnesses and Supplemental Disclosure Page of
The Responses to Requests for Disclosure, Responses to Requests for
Production, Answers to Interrogatories, and the Amendments and Sup-
plements thereto which have been served by each of the parties in this
action;
The pleadings on file in this action; and
All documents and tangible things produced in this cause.
All of said documents are incorporated herein by reference as though set
out at length for all purposes.
Sterling Pharmacy
(f)(1): the expert’s name, address, and telephone number
onald Kimmel, M.D
6609 W. Sam Houston, Pkwy, S. Suite 98B
Houston , Texas 77
(f)(2): The subject matters on which said non retained, non controlled medical experts
will testify are as follows:
Their knowledge, skill, training, education, and/or experience as they relate to the
subject matter of this lawsuit;
Their qualifications to render an expert opinion;
plaintiff's injuries at issue in this case;
the medical care provided and/or prescribed to plaintiff;
the existence, nature and/or extent of, and pain associated with the injuries sus-
tained by Plaintiff;
the examination and treatment of the injuries sustained by Plaintiff;
pre existing injuries to and/or pre existing medical conditions of Plaintiff, or lack
thereof;
the type, purpose, extent, results, evaluations and/or interpretations of examinations
and treatments; rays and MRIs tests regarding Plaintiff.
recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
Designation of Expert Witnesses and Supplemental Disclosure Page of
the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff
in the past, and the reasonable probability and extent of the disabilities and/or inca-
pacities which Plaintiff may suffer from in the future;
the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
medical care and treatment and medications that have been required by Plaintiff in
the past for the treatment of the injuries allegedly sustained by Plaintiff as a result
of the incident made the basis of this lawsuit and for rehabilitation from such inju-
ries;
medical care and treatment and medications that will be required by Plaintiff in the
future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the
incident made the subject of this lawsuit and for rehabilitation from such injuries;
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical prob-
ability, will need in the future for the injuries sustained by Plaintiff as a result of
the incident made the basis of this lawsuit;
all those subject matters contained, discussed or disclosed in:
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause;
all medical records affidavits and/or medical billing affidavits which have
been served and which may hereafter be served in this cause, and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
all written reports of healthcare providers produced during the course of
discovery in this cause.
All of the above documents are incorporated herein by reference as though set out
verbatim for all purposes.
(f)(3):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:
Designation of Expert Witnesses and Supplemental Disclosure Page of
The medical care and treatment rendered to Plaintiff for his injuries was rea-
sonable and/or necessary;
he subject incident did, based on reasonable medical probability, cause all of
the complaints, disabilities, injuries, and or incapacities of Plaintiff;
Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in
part of the injuries received by Plaintiff and made the subject of this suit;
that any surgical intervention for treatment of Plaintiff’s symptoms was neces-
sitated and proximately caused by the incident made the subject of this lawsuit;
that the medical expenses of Plaintiff were necessitated by the incident which
is the subject of this lawsuit;
that the amount Plaintiff was charged for medical expenses was reasonable;
all other impressions and/or opinions that are contained, discussed, and/or dis-
closed in the followi
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause including the following:
Records from Sterling Pharmacy
See Plaintiff’s production Salinas9; Salinas15 Salinas18
all medical records affidavits and medical billing affidavits which have
been served and which may hereafter be served in this cause and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
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.
Designation of Expert Witnesses and Supplemental Disclosure Page of
The basis for the foregoing impressions and opinions of the above named and/or
designated expert witnesses are based on the following:
The experts’ knowledge, skill, training, education, and experience;
All of the medical records of Plaintiff produced in this cause by any
party;
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 Sup-
plements thereto which have been served by each of the parties in this
action;
The pleadings on file in this action; and
All documents and tangible things produced in this cause.
All of said documents are incorporated herein by reference as though set
out at length for all purposes
Beltway 8 Accident & Clinic
(f)(1): the expert’s name, address, and telephone number
Santiago Guajardo, B.S, D.C.,
5750 N. Sam Houston Pkwy East, Suite 301
Houston, Texas 77032
(f)(2): The subject matters on which said non retained, non controlled medical experts
will testify are as follows:
Designation of Expert Witnesses and Supplemental Disclosure Page of
Their knowledge, skill, training, education, and/or experience as they relate to the
subject matter of this lawsuit;
Their qualifications to render an expert opinion;
plaintiff's injuries at issue in this case;
the medical care provided and/or prescribed to plaintiff;
the existence, nature and/or extent of, and pain associated with the injuries sus-
tained by Plaintiff;
the examination and treatment of the injuries sustained by Plaintiff;
pre existing injuries to and/or pre existing medical conditions of Plaintiff, or lack
thereof;
the type, purpose, extent, results, evaluations and/or interpretations of examinations
and treatments; rays and MRIs tests regarding Plaintiff.
recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff
in the past, and the reasonable probability and extent of the disabilities and/or inca-
acities which Plaintiff may suffer from in the future;
the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
medical care and treatment and medications that have been required by Plaintiff in
the past for the treatment of the injuries allegedly sustained by Plaintiff as a result
of the incident made the basis of this lawsuit and for rehabilitation from such inju-
ries;
medical care and treatment and medications that will be required by Plaintiff in the
future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the
incident made the subject of this lawsuit and for rehabilitation from such injuries;
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical prob-
ability, will need in the future for the injuries sustained by Plaintiff as a result of
the incident made the basis of this lawsuit;
Designation of Expert Witnesses and Supplemental Disclosure Page of
all those subject matters contained, discussed or disclosed in:
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause;
all medical records affidavits and/or medical billing affidavits which have
been served and which may hereafter be served in this cause, and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
all written reports of healthcare providers produced during the course of
discovery in this cause.
All of the above documents are incorporated herein by reference as though set out
verbatim for all purposes.
(f)(3):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:
The medical care and treatment rendered to Plaintiff for h injuries was rea-
sonable and/or necessary;
The subject incident did, based on reasonable medical probability, cause all of
the complaints, disabilities, injuries, and or incapacities of Plaintiff
Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in
part of the injuries received by Plaintiff and made the subject of this suit;
that any surgical intervention for treatment of Plaintiff’s symptoms was neces-
sitated and proximately caused by the incident made the subject of this lawsuit;
that the medical expenses of Plaintiff were necessitated by the incident which
is the subject of this lawsuit;
that the amount Plaintiff was charged for medical expenses was reasonable;
all other impressions and/or opinions that are contained, discussed, and/or dis-
closed in the following:
Designation of Expert Witnesses and Supplemental Disclosure Page of
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause including the following:
Records from Beltway 8 Accident & Clinic
See Plaintiff’s Production (Salinas23 Salinas58 and
Records from Advantis MRI/ Insight MRI
See Plaintiff’s Production (Salinas7 Salinas8; Salinas19 Sa-
linas22).
all medical records affidavits and medical billing affidavits which have
been served and which may hereafter be served in this cause and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
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.
The basis for the foregoing impressions and opinions of the above named and/or
designated expert witnesses are based on the following:
The experts’ knowledge, skill, training, education, and experience;
All of the medical records of Plaintiff produced in this cause by any
party;
ll 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;
Designation of Expert Witnesses and Supplemental Disclosure Page of
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 Sup-
plements thereto which have been served by each of the parties in this
action;
The pleadings on file in this action; and
All documents and tangible things produced in this cause.
All of said documents are incorporated herein by reference as though set
out at length for all purposes.
Capstone Surgery Center
(f)(1): the expert’s name, address, and telephone number
Teodulo Eves, M.D.
Samir Fahed , M.D.
8700 South Gessner Road, #200
Houston, Texas 77074
(f)(2): The subject matters on which said non retained, non controlled medical experts
will testify are as follows:
Their knowledge, skill, training, education, and/or experience as they relate to the
subject matter of this lawsuit;
Their qualifications to render an expert opinion;
plaintiff's injuries at issue in this case;
the medical care provided and/or prescribed to plaintiff;
the existence, nature and/or extent of, and pain associated with the injuries sus-
tained by Plaintiff;
the examination and treatment of the injuries sustained by Plaintiff;
pre existing injuries to and/or pre existing medical conditions of Plaintiff, or lack
thereof;
Designation of Expert Witnesses and Supplemental Disclosure Page of
the type, purpose, extent, results, evaluations and/or interpretations of examinations
and treatments; x rays and MRIs tests regarding Plaintiff.
recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff
in the past, and the reasonable probability and extent of the disabilities and/or inca-
pacities which Plaintiff may suffer from in the future;
the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
medical care and treatment and medications that have been required by Plaintiff in
the past for the treatment of the injuries allegedly sustained by Plaintiff as a result
of the incident made the basis of this lawsuit and for rehabilitation from such inju-
ries;
medical care and treatment and medications that will be required by Plaintiff in the
future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the
incident made the subject of this lawsuit and for rehabilitation from such injuries;
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical prob-
ability, will need in the future for the injuries sustained by Plaintiff as a result of
the incident made the basis of this lawsuit;
all those subject matters contained, discussed or disclosed in:
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause;
all medical records affidavits and/or medical billing affidavits which have
been served and which may hereafter be served in this cause, and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
all written reports of healthcare providers produced during the course of
discovery in this cause.
All of the above documents are incorporated herein by reference as though set out
verbatim for all purposes.
Designation of Expert Witnesses and Supplemental Disclosure Page of
(f)(3):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:
The medical care and treatment rendered to Plaintiff for his injuries was rea-
sonable and/or necessary;
The subject incident did, based on reasonable medical probability, cause all of
the complaints, disabilities, injuries, and or incapacities of Plaintiff;
Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in
part of the injuries received by Plaintiff and made the subject of this suit;
that any surgical intervention for treatment of Plaintiff’s symptoms was neces-
sitated and proximately caused by the incident made the subject of this lawsuit;
that the medical expenses of Plaintiff were necessitated by the incident which
is the subject of this lawsuit;
that the amount Plaintiff was charged for medical expenses was reasonable;
all other impressions and/or opinions that are contained, discussed, and/or dis-
closed in the following:
the medical and billing records of Plaintiff which have been and which
may hereafter be produced in this cause including the following:
Records from Capstone Surgery Center
Plaintiff’s production (Salinas145 Salinas151 and Sa-
linas156
all medical records affidavits and medical billing affidavits which have
been served and which may hereafter be served in this cause and all ex-
hibits thereto;
the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
Designation of Expert Witnesses and Supplemental Disclosure Page of
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.
The basis for the foregoing impressions and opinions of the above named and/or
designated expert witnesses are based on the following:
The experts’ knowledge, skill, training, education, and experience;
All of the medical records of Plaintiff produced in this cause by any
party;
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 Sup-
plements thereto which have been served by each of the parties in this
action;
The pleadings on file in this ac
Preview
CAUSE NO. 20-03-04112 JAIME SALINAS THE DISTRICT COURT OF VS. MONTGOMERY COUNTY, TEXAS DARLA WILSON AND FARMERS TEXAS COUNTY MUTUAL INSURANCE 284TH JUDICIAL DISTRICT PLAINTIFF’S FIRST SUPPLEMENTAL DESIGNATION EXPERT WITNESSES SECOND SUPPLMENTAL DISCLSOURE Plaintiff Jaime Salinas serves his Designation of Expert Witnesses and Supplemental Dis- closure as follows: 194.2.(d) The Amount and any method of calculating economic damages: SUPPLEMENTAL RESPONSE: MEDICAL PROVIDER INCURRED HCA Houston Healthcare Kingwood $53,237.00 Insight MRI Advantis MRI & Diagnostic Imag- $3,200.00 ing Sterling Pharmacy $257.41 Beltway 8 Accident Clinic $4,495.00 Capstone Surgery Center $600.00 Compass Point ER Physicians, P.L.L.C. $2,055.00 Singleton Associates PA Radiology $930.00 Montgomery County Hospital District EMS $805.90 ESTIMATED FUTURE TREATMENT: Capstone Surgery Center $22,995.00 TOTAL: 8,575.37 194.2(f) For any testifying expert: 1) the expert’s name, address and telephone number; 2) the subject matter on which the expert will testify; 3) the general substance of the expert’s mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained Designation of Expert Witnesses and Supplemental Disclosure Page 1 of by, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; if the expert is retained by, employed by, or otherwise subject to the con- trol of the responding party: A. all documents, tangible things, reports, models, or data compila- tions that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony; and the expert’s current resume and bibliography. RESPONSE: Plaintiff incorporates herein by reference Plaintiff’s Supplemental Re- sponses to Defendant’s Request for Disclosure (and all amendments and supplements thereto) to- gether with all other discovery responses previously served on Defendant and designates his expert witnesses as follows: ETAINED XPERTS I. Non Retained Medical Experts. The following person(s), or their custodian(s) of rec- ords, have not been retained by and are not employed by, or are otherwise subject to the control of Plaintiffs (hereinafter referred to as “non retained” experts), but are hereby designated as testifying experts by Plaintiffs 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 Plaintiffs 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, Plaintiffs will designate these witnesses as persons who may be called upon to give testimony that would be considered expert testimony. The following healthcare providers, and/or the custodian(s) of their records, may testify regard- ing the injuries sustained by Plaintiffs as a result of 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 Plaintiffs’ injuries in the past and in the future. Please refer to the healthcare providers’ records for their mental impressions, opinions, conclu- sions, and the factual basis for each opinion. I.1 Identity of Non Retained Medical Experts. The names of Plaintiffs’ non retained, non con trolled medical experts and their addresses and telephone numbers are as follows: THE FOLLOWING INDIVIDUALS AND ENTITIES AND THEIR CURRENT AND FOR- MER OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVANTS, PHYSICIANS, NURSES, PARAMEDICS, EMTs, ATTENDANTS, STAFF, HEALTHCARE PROVID- ERS, AND CUSTODIANS OF RECORDS: HCA Houston Healthcare Kingwood Designation of Expert Witnesses and Supplemental Disclosure Page of (f)(1): James C. Barton Christopher Bathurst, M.D. Jesse Proett, M.D. Sankaman Praisoody, MD 22999 US HWY59 Kingwood, Texas 77 (f)(2): The subject matters on which said non retained, non controlled medical experts will testify are as follows: Their knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; Their qualifications to render an expert opinion; laintiff's injuries at issue in this case; the medical care provided and/or prescribed to plaintiff; the existence, nature and/or extent of, and pain associated with the injuries sus- tained by Plaintiff; the examination and treatment of the injuries sustained by Plaintiff; pre existing injuries to and/or pre existing medical conditions of Plaintiff, or lack thereof; the type, purpose, extent, results, evaluations and/or interpretations of examinations and treatments; recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or inca- pacities which Plaintiff may suffer from in the future; the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; medical care and treatment and medications that have been required by Plaintiff in the past for the treatment of the injuries allegedly sustained by Plaintiff as a result of the incident made the basis of this lawsuit and for rehabilitation from such inju- ries; Designation of Expert Witnesses and Supplemental Disclosure Page of medical care and treatment and medications that will be required by Plaintiff in the future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the incident made the subject of this lawsuit and for rehabilitation from such injuries; the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical prob- ability, will need in the future for the injuries sustained by Plaintiff as a result of the incident made the basis of this lawsuit; all those subject matters contained, discussed or disclosed in: the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause; all medical records affidavits and/or medical billing affidavits which have been served and which may hereafter be served in this cause, and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and all written reports of healthcare providers produced during the course of discovery in this cause. All of the above documents are incorporated herein by reference as though set ou verbatim for all purposes. (f)(3):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: The medical care and treatme t rendered to Plaintiff for his injuries was rea- sonable and/or necessary; The subject incident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and or incapacities of Plaintiff; Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in part of the injuries received by Plaintiff and made the subject of this suit; Designation of Expert Witnesses and Supplemental Disclosure Page of that any surgical intervention for treatment of Plaintiff’s symptoms was neces- sitated and proximately caused by the incident made the subject of this lawsuit; that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; that the amount Plaintiff was charged for medical expenses was reasonable; all other impressions and/or opinions that are contained, discussed, and/or dis- closed in the following: the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause including the following: Records from HCA Healthcare Kingwood See Plaintiff’s production Salinas6; Salinas59 Salinas144 and Records from Quality Care Family Clinic, P.A. Plaintiff will sup- plement. all medical records affidavits and medical billing affidavits which have been served and which may hereafter be served in this cause and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and 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. The basis for the foregoing impressions and opinions of the above named and/or designated expert witnesses are based on the following: The experts’ knowledge, skill, training, education, and experience; Designation of Expert Witnesses and Supplemental Disclosure Page of All of the medical records of Plaintiff produced in this cause by any party; 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; e Responses to Requests for Disclosure, Responses to Requests for Production, Answers to Interrogatories, and the Amendments and Sup- plements thereto which have been served by each of the parties in this action; The pleadings on file in this action; and All documents and tangible things produced in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes. Advantis MRI & Diagnostic Imaging aka Insight MRI & Diagnostics (f)(1): the expert’s name, address, and telephone number Santiago Guajardo , M.D. Chad T. Porter, M.D. 14405 Walters Road, Suite A Houston, Texas 77014 (f)(2): The subject matters on which said non retained, non controlled medical experts will testify are as follows: Their knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; Their qualifications to render an expert opinion; plaintiff's injuries at issue in this case; Designation of Expert Witnesses and Supplemental Disclosure Page of the medical care provided and/or prescribed to plaintiff; the existence, nature and/or extent of, and pain associated with the injuries sus- tained by Plaintiff; the examination and treatment of the injuries sustained by Plaintiff; pre existing injuries to and/or p existing medical conditions of Plaintiff, or lack thereof; the type, purpose, extent, results, evaluations and/or interpretations of examinations and treatments; rays and MRIs tests regarding Plaintiff. recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or inca- pacities which Plaintiff may suffer from in the future; the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; medical care and treatment and medications that have been required by Plaintiff in the past for the treatment of the injuries allegedly sustained by Plaintiff as a result of the incident made the basis of this lawsuit and for rehabilitation from such inju- ries; medical care and treatment and medications that will be required by Plaintiff in the future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the incident made the subject of this lawsuit and for rehabilitation from such injuries; the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical prob- ability, will need in the future for the injuries sustained by Plaintiff as a result of the incident made the basis of this lawsuit; all those subject matters contained, discussed or disclosed in: the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause; Designation of Expert Witnesses and Supplemental Disclosure Page of all medical records affidavits and/or medical billing affidavits which have been served and which may hereafter be served in this cause, and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and all written reports of healthcare providers produced during the course of discovery in this cause. All of the above documents are incorporated herein by reference as though set out verbatim for all purposes. (f)(3):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: The medical care and treatment rendered to Plaintiff for his injuries was rea- sonable and/or necessary; The subject incident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and or incapacities of Plaintiff; Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in part of the injuries received by Plaintiff and made the subject of this suit; that any surgical intervention for treatment of Plaintiff’s symptoms was neces- sitated and proximately caused by the incident made the subject of this lawsuit; that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; that the amount Plaintiff was charged for medical expenses was reasonable; all other impressions and/or opinions that are contained, discussed, and/or dis- closed in the following: the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause including the following: Designation of Expert Witnesses and Supplemental Disclosure Page of Records from Advantis MRI/Insight MRI See Plaintiff’s production (Salinas7 Salinas8; Salinas19 Sa- linas22 and Records from Beltway 8 Accident Clinic See Plaintiff’s Production (Salinas23 Salinas58). all medical records affidavits and medical billing affidavits which have been served and which may hereafter be served in this cause and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and 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. The basis for the foregoing impressions and opinions of the above named and/or esignated expert witnesses are based on the following: The experts’ knowledge, skill, training, education, and experience; All of the medical records of Plaintiff produced in this cause by any party; 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 caus Designation of Expert Witnesses and Supplemental Disclosure Page of The Responses to Requests for Disclosure, Responses to Requests for Production, Answers to Interrogatories, and the Amendments and Sup- plements thereto which have been served by each of the parties in this action; The pleadings on file in this action; and All documents and tangible things produced in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes. Sterling Pharmacy (f)(1): the expert’s name, address, and telephone number onald Kimmel, M.D 6609 W. Sam Houston, Pkwy, S. Suite 98B Houston , Texas 77 (f)(2): The subject matters on which said non retained, non controlled medical experts will testify are as follows: Their knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; Their qualifications to render an expert opinion; plaintiff's injuries at issue in this case; the medical care provided and/or prescribed to plaintiff; the existence, nature and/or extent of, and pain associated with the injuries sus- tained by Plaintiff; the examination and treatment of the injuries sustained by Plaintiff; pre existing injuries to and/or pre existing medical conditions of Plaintiff, or lack thereof; the type, purpose, extent, results, evaluations and/or interpretations of examinations and treatments; rays and MRIs tests regarding Plaintiff. recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; Designation of Expert Witnesses and Supplemental Disclosure Page of the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or inca- pacities which Plaintiff may suffer from in the future; the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; medical care and treatment and medications that have been required by Plaintiff in the past for the treatment of the injuries allegedly sustained by Plaintiff as a result of the incident made the basis of this lawsuit and for rehabilitation from such inju- ries; medical care and treatment and medications that will be required by Plaintiff in the future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the incident made the subject of this lawsuit and for rehabilitation from such injuries; the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical prob- ability, will need in the future for the injuries sustained by Plaintiff as a result of the incident made the basis of this lawsuit; all those subject matters contained, discussed or disclosed in: the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause; all medical records affidavits and/or medical billing affidavits which have been served and which may hereafter be served in this cause, and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and all written reports of healthcare providers produced during the course of discovery in this cause. All of the above documents are incorporated herein by reference as though set out verbatim for all purposes. (f)(3):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: Designation of Expert Witnesses and Supplemental Disclosure Page of The medical care and treatment rendered to Plaintiff for his injuries was rea- sonable and/or necessary; he subject incident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and or incapacities of Plaintiff; Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in part of the injuries received by Plaintiff and made the subject of this suit; that any surgical intervention for treatment of Plaintiff’s symptoms was neces- sitated and proximately caused by the incident made the subject of this lawsuit; that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; that the amount Plaintiff was charged for medical expenses was reasonable; all other impressions and/or opinions that are contained, discussed, and/or dis- closed in the followi the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause including the following: Records from Sterling Pharmacy See Plaintiff’s production Salinas9; Salinas15 Salinas18 all medical records affidavits and medical billing affidavits which have been served and which may hereafter be served in this cause and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and 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. Designation of Expert Witnesses and Supplemental Disclosure Page of The basis for the foregoing impressions and opinions of the above named and/or designated expert witnesses are based on the following: The experts’ knowledge, skill, training, education, and experience; All of the medical records of Plaintiff produced in this cause by any party; 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 Sup- plements thereto which have been served by each of the parties in this action; The pleadings on file in this action; and All documents and tangible things produced in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes Beltway 8 Accident & Clinic (f)(1): the expert’s name, address, and telephone number Santiago Guajardo, B.S, D.C., 5750 N. Sam Houston Pkwy East, Suite 301 Houston, Texas 77032 (f)(2): The subject matters on which said non retained, non controlled medical experts will testify are as follows: Designation of Expert Witnesses and Supplemental Disclosure Page of Their knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; Their qualifications to render an expert opinion; plaintiff's injuries at issue in this case; the medical care provided and/or prescribed to plaintiff; the existence, nature and/or extent of, and pain associated with the injuries sus- tained by Plaintiff; the examination and treatment of the injuries sustained by Plaintiff; pre existing injuries to and/or pre existing medical conditions of Plaintiff, or lack thereof; the type, purpose, extent, results, evaluations and/or interpretations of examinations and treatments; rays and MRIs tests regarding Plaintiff. recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or inca- acities which Plaintiff may suffer from in the future; the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; medical care and treatment and medications that have been required by Plaintiff in the past for the treatment of the injuries allegedly sustained by Plaintiff as a result of the incident made the basis of this lawsuit and for rehabilitation from such inju- ries; medical care and treatment and medications that will be required by Plaintiff in the future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the incident made the subject of this lawsuit and for rehabilitation from such injuries; the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical prob- ability, will need in the future for the injuries sustained by Plaintiff as a result of the incident made the basis of this lawsuit; Designation of Expert Witnesses and Supplemental Disclosure Page of all those subject matters contained, discussed or disclosed in: the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause; all medical records affidavits and/or medical billing affidavits which have been served and which may hereafter be served in this cause, and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and all written reports of healthcare providers produced during the course of discovery in this cause. All of the above documents are incorporated herein by reference as though set out verbatim for all purposes. (f)(3):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: The medical care and treatment rendered to Plaintiff for h injuries was rea- sonable and/or necessary; The subject incident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and or incapacities of Plaintiff Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in part of the injuries received by Plaintiff and made the subject of this suit; that any surgical intervention for treatment of Plaintiff’s symptoms was neces- sitated and proximately caused by the incident made the subject of this lawsuit; that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; that the amount Plaintiff was charged for medical expenses was reasonable; all other impressions and/or opinions that are contained, discussed, and/or dis- closed in the following: Designation of Expert Witnesses and Supplemental Disclosure Page of the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause including the following: Records from Beltway 8 Accident & Clinic See Plaintiff’s Production (Salinas23 Salinas58 and Records from Advantis MRI/ Insight MRI See Plaintiff’s Production (Salinas7 Salinas8; Salinas19 Sa- linas22). all medical records affidavits and medical billing affidavits which have been served and which may hereafter be served in this cause and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and 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. The basis for the foregoing impressions and opinions of the above named and/or designated expert witnesses are based on the following: The experts’ knowledge, skill, training, education, and experience; All of the medical records of Plaintiff produced in this cause by any party; ll 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; Designation of Expert Witnesses and Supplemental Disclosure Page of 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 Sup- plements thereto which have been served by each of the parties in this action; The pleadings on file in this action; and All documents and tangible things produced in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes. Capstone Surgery Center (f)(1): the expert’s name, address, and telephone number Teodulo Eves, M.D. Samir Fahed , M.D. 8700 South Gessner Road, #200 Houston, Texas 77074 (f)(2): The subject matters on which said non retained, non controlled medical experts will testify are as follows: Their knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; Their qualifications to render an expert opinion; plaintiff's injuries at issue in this case; the medical care provided and/or prescribed to plaintiff; the existence, nature and/or extent of, and pain associated with the injuries sus- tained by Plaintiff; the examination and treatment of the injuries sustained by Plaintiff; pre existing injuries to and/or pre existing medical conditions of Plaintiff, or lack thereof; Designation of Expert Witnesses and Supplemental Disclosure Page of the type, purpose, extent, results, evaluations and/or interpretations of examinations and treatments; x rays and MRIs tests regarding Plaintiff. recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or inca- pacities which Plaintiff may suffer from in the future; the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; medical care and treatment and medications that have been required by Plaintiff in the past for the treatment of the injuries allegedly sustained by Plaintiff as a result of the incident made the basis of this lawsuit and for rehabilitation from such inju- ries; medical care and treatment and medications that will be required by Plaintiff in the future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the incident made the subject of this lawsuit and for rehabilitation from such injuries; the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical prob- ability, will need in the future for the injuries sustained by Plaintiff as a result of the incident made the basis of this lawsuit; all those subject matters contained, discussed or disclosed in: the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause; all medical records affidavits and/or medical billing affidavits which have been served and which may hereafter be served in this cause, and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and all written reports of healthcare providers produced during the course of discovery in this cause. All of the above documents are incorporated herein by reference as though set out verbatim for all purposes. Designation of Expert Witnesses and Supplemental Disclosure Page of (f)(3):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: The medical care and treatment rendered to Plaintiff for his injuries was rea- sonable and/or necessary; The subject incident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and or incapacities of Plaintiff; Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in part of the injuries received by Plaintiff and made the subject of this suit; that any surgical intervention for treatment of Plaintiff’s symptoms was neces- sitated and proximately caused by the incident made the subject of this lawsuit; that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; that the amount Plaintiff was charged for medical expenses was reasonable; all other impressions and/or opinions that are contained, discussed, and/or dis- closed in the following: the medical and billing records of Plaintiff which have been and which may hereafter be produced in this cause including the following: Records from Capstone Surgery Center Plaintiff’s production (Salinas145 Salinas151 and Sa- linas156 all medical records affidavits and medical billing affidavits which have been served and which may hereafter be served in this cause and all ex- hibits thereto; the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and Designation of Expert Witnesses and Supplemental Disclosure Page of 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. The basis for the foregoing impressions and opinions of the above named and/or designated expert witnesses are based on the following: The experts’ knowledge, skill, training, education, and experience; All of the medical records of Plaintiff produced in this cause by any party; 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 Sup- plements thereto which have been served by each of the parties in this action; The pleadings on file in this ac