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Filing# 162547129 E-Filed 12/07/2022 10:49:11 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
DAVID SCHWITZKE, CASE NO. CACE-21-016658 (12)
Plaintiff,
VS.
TIFFANY M. GRAVES,
Defendants,
1
PLAINTIFF'S WITNESS LIST
COMES NOW Plaintiff,
DAVID SCHWITZKE, by and throughundersignedcounsel,hereby
files his Witness List,and states as follows:
1. David Schwitzke
c/o Robert DiStefano, Esq.
DiStefano Law, LLC
7471 W. Oakland Park Blvd., Suite 106
Fort Lauderdale, FL 33319
Plaintiff
(Testimony Facts and
- details regardingthe accident,medical treatment and
damages)
2. TiffanyM. Graves
2445 SW 19th Terrace
Ft. Lauderdale, FL 33315
(Defendant Facts and regardingthe accident)
- details
3. Officer L. Paul, Badge ID #444
Miami Gardens Police Department
18611 NW 27thAvenue
Miami Gardens, FL 33056
(Officerat the scene
- Facts and details regardingthe accident)
4. Mike Robinson
3365 Cocoa Plum Circle
Coconut Creek, FL 33063
(Witness Knowledge of the accident)
-
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/07/2022 10:49:10 AM.****
CASE NO. CACE-21-016658 (12)
5. C. Palaia-Caltagirone
20 Greene Street
Tappan, NY 10983
(Witness Knowledge of the accident)
-
6. Scott Eric Beckett
452 Silver Spur Trail
Rockwall, TX 75032
(Witness
-
Knowledge of the accident)
7. Any and all treating records custodians who have knowledge
radiologists,
physicians,
of the following:medical diagnosis,treatment, prognosis and billingfor Plaintiff
from the following:
a. West Boca Medical Center
b. Paragon Contracting Services
C. Sheridan Radiology Services
d. Broward Health & Wellness
8. Any and testimony regarding applicationsfor insurance, policies,claims
all
presented,benefits paid from the following:
a. ProgressiveInsurance
b. Allstate Insurance
C Anthem Blue Cross
9. Any and all testimony regardingemployment, personnel information and education
of Plaintiff from the following:
a. Fedex
10. All parties
to this action.
11. Any and all persons listed on any other party'sPre-Trial Catalog.
12. All records custodian for any and all medical records referenced in the schedule of
exhibits,includingbut not limited to, all clinics,physicians,nurses, staffing,
physician'sassistants,chiropractors, radiologists,
orthopedists, neurosurgeons,
pain management physicians,
anesthesiologists, that
therapists treated the Plaintiff
for this accident.
13. All persons listed on any accident reports and incident reports.
2
CASE NO. CACE-21-016658 (12)
14. Any and persons names in responses to Request to Produce, Interrogatories,
all
Depositions other discoveryin this case (includingattachments thereto).
or
15. any and all witnesses listed on Defendant's Witness
Without waiving any objections,
list and Experts list.
16. Any and all witnesses needed for impeachment or rebuttal purposes.
17. Without waiving any objections, all medical records custodians of all health care
providersof the Plaintiff identified in any discoveryand pretrialwitness or exhibit
lists filed in this lawsuit.
18. Without waiving any objections,
all persons who have been deposed or noticed for
depositionby any party in this lawsuit.
19. Any and all persons named in any depositions
in this lawsuit.
20. Without waving any objections, all records custodians ofany
employer of the Plaintiff identified in any discoveryand pretrialwitness or exhibit
lists filed in this lawsuit.
21. Any and all authentication witnesses, includingall Records Custodians for all the
items listed in Plaintiff's and/or Defendant's Exhibit lists.
22. Plaintiffreserves the rightto amend and/or supplement this Witness list priorto trial.
23. Plaintiff reserves the rightto object to any and all witnesses listed by other partiesto
this action and reserve the rightto amend this schedule ofwitnesses should additional
witnesses be identified through discovery subsequent to the date of the Pretrial
Stipulation.
24. Plaintiffreserves the rightto call and/orproduce any and all witnesses and/or call any
and impeachment and/or rebuttal and/or produce any and all newly discovered
all
witnesses and/or documentary evidence upon notice to the Defendant.
25, Plaintiff reserves therightto amend and/or supplement this Witness list with
witnesses as they become known to Plaintiff upon proper notice to Defendant.
3
CASE NO. CACE-21-016658 (12)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy ofthe foregoingdocument was electronically
filed with
mailed on this
the court and electronically 7 day ofDecember, 2022 to Julie Lewis Hauf, Esq.,
Brandi Rossi, Esq, Law Office of Julie Lewis Hauf, P.L., pleadings@lewishauf.com.
DiSTEFANO LAW, LLC
Attorney for Plaintiff
7471 W. Oakland Park Boulevard
Suite 106
Ft.Lauderdale, FL 33319
T: 954.572.8000
F: 954.572.7895
E: robert@distefanolaw.com
litigation@distefanotaw.com
trish@distefanoli
22>y'
Rob:dDJ?ia-0,
Esq.
FBN: 437761
4
Preview
Filing# 162547129 E-Filed 12/07/2022 10:49:11 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA DAVID SCHWITZKE, CASE NO. CACE-21-016658 (12) Plaintiff, VS. TIFFANY M. GRAVES, Defendants, 1 PLAINTIFF'S WITNESS LIST COMES NOW Plaintiff, DAVID SCHWITZKE, by and throughundersignedcounsel,hereby files his Witness List,and states as follows: 1. David Schwitzke c/o Robert DiStefano, Esq. DiStefano Law, LLC 7471 W. Oakland Park Blvd., Suite 106 Fort Lauderdale, FL 33319 Plaintiff (Testimony Facts and - details regardingthe accident,medical treatment and damages) 2. TiffanyM. Graves 2445 SW 19th Terrace Ft. Lauderdale, FL 33315 (Defendant Facts and regardingthe accident) - details 3. Officer L. Paul, Badge ID #444 Miami Gardens Police Department 18611 NW 27thAvenue Miami Gardens, FL 33056 (Officerat the scene - Facts and details regardingthe accident) 4. Mike Robinson 3365 Cocoa Plum Circle Coconut Creek, FL 33063 (Witness Knowledge of the accident) - 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/07/2022 10:49:10 AM.**** CASE NO. CACE-21-016658 (12) 5. C. Palaia-Caltagirone 20 Greene Street Tappan, NY 10983 (Witness Knowledge of the accident) - 6. Scott Eric Beckett 452 Silver Spur Trail Rockwall, TX 75032 (Witness - Knowledge of the accident) 7. Any and all treating records custodians who have knowledge radiologists, physicians, of the following:medical diagnosis,treatment, prognosis and billingfor Plaintiff from the following: a. West Boca Medical Center b. Paragon Contracting Services C. Sheridan Radiology Services d. Broward Health & Wellness 8. Any and testimony regarding applicationsfor insurance, policies,claims all presented,benefits paid from the following: a. ProgressiveInsurance b. Allstate Insurance C Anthem Blue Cross 9. Any and all testimony regardingemployment, personnel information and education of Plaintiff from the following: a. Fedex 10. All parties to this action. 11. Any and all persons listed on any other party'sPre-Trial Catalog. 12. All records custodian for any and all medical records referenced in the schedule of exhibits,includingbut not limited to, all clinics,physicians,nurses, staffing, physician'sassistants,chiropractors, radiologists, orthopedists, neurosurgeons, pain management physicians, anesthesiologists, that therapists treated the Plaintiff for this accident. 13. All persons listed on any accident reports and incident reports. 2 CASE NO. CACE-21-016658 (12) 14. Any and persons names in responses to Request to Produce, Interrogatories, all Depositions other discoveryin this case (includingattachments thereto). or 15. any and all witnesses listed on Defendant's Witness Without waiving any objections, list and Experts list. 16. Any and all witnesses needed for impeachment or rebuttal purposes. 17. Without waiving any objections, all medical records custodians of all health care providersof the Plaintiff identified in any discoveryand pretrialwitness or exhibit lists filed in this lawsuit. 18. Without waiving any objections, all persons who have been deposed or noticed for depositionby any party in this lawsuit. 19. Any and all persons named in any depositions in this lawsuit. 20. Without waving any objections, all records custodians ofany employer of the Plaintiff identified in any discoveryand pretrialwitness or exhibit lists filed in this lawsuit. 21. Any and all authentication witnesses, includingall Records Custodians for all the items listed in Plaintiff's and/or Defendant's Exhibit lists. 22. Plaintiffreserves the rightto amend and/or supplement this Witness list priorto trial. 23. Plaintiff reserves the rightto object to any and all witnesses listed by other partiesto this action and reserve the rightto amend this schedule ofwitnesses should additional witnesses be identified through discovery subsequent to the date of the Pretrial Stipulation. 24. Plaintiffreserves the rightto call and/orproduce any and all witnesses and/or call any and impeachment and/or rebuttal and/or produce any and all newly discovered all witnesses and/or documentary evidence upon notice to the Defendant. 25, Plaintiff reserves therightto amend and/or supplement this Witness list with witnesses as they become known to Plaintiff upon proper notice to Defendant. 3 CASE NO. CACE-21-016658 (12) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy ofthe foregoingdocument was electronically filed with mailed on this the court and electronically 7 day ofDecember, 2022 to Julie Lewis Hauf, Esq., Brandi Rossi, Esq, Law Office of Julie Lewis Hauf, P.L., pleadings@lewishauf.com. DiSTEFANO LAW, LLC Attorney for Plaintiff 7471 W. Oakland Park Boulevard Suite 106 Ft.Lauderdale, FL 33319 T: 954.572.8000 F: 954.572.7895 E: robert@distefanolaw.com litigation@distefanotaw.com trish@distefanoli 22>y' Rob:dDJ?ia-0, Esq. FBN: 437761 4