No Value: ALEXANDER LLERENA, ASHEL vs. RODRIGUEZ CHAVEZ, ADRIAN

On May 10, 115 a No Value was filed involving a dispute between Llerena, Ashel Alexander, and Granny'S Garden Ii Inc, Rodriguez Chavez, Adrian, for CIRCUIT CIVIL in the District Court of Osceola County.

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Filing # 185676334 E-Filed 11/07/2023 04:57:59 PM

IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR
OSCEOLA COUNTY, FLORIDA

CASE NO.: 2020-CA-002872-AN
CIVIL DIVISION: 20
ASBEL ALEXANDER LLERENA,

Plaintiff,

ADRIAN RODRIGUEZ CHAVEZ and
GRANNY'S GARDEN II, INC.,

Defendants.
_______________________________/

DEFENDANTS’ EXPERT WITNESS DISCLOSURE

Defendants, ADRIAN RODRIGUEZ CHAVEZ and GRANNY’S GARDEN II, INC.,

by and through the undersigned counsel, and pursuant to the Court’s Uniform Order

Setting Case for Jury Trial; Pre-Trial Conference and Requiring Pretrial Matters to be

Completed, hereby files Defendants’ Expert Witness Disclosure:

EXPERT WITNESSES:

1. John A. Jenkins, MD
Zeus Spine, LLC
8815 Conroy Windermere Road, #405
Orlando, FL 32835
Phone: (407) 406-3202

Specialty/Field of Expertise and Specific Subjects upon which may testify
and offer opinions: John A. Jenkins, MD, is a board-certified orthopaedic surgeon
who is expected to testify against Plaintiff on causation and damages based on his
review of Plaintiff’s medical records and physical examination of the Plaintiff
regarding the alleged injuries. Dr. Jenkins is expected to testify as to the necessity
and reasonableness of Plaintiff’s treatment and/or surgeries, if any. He will opine as
to the accuracy of Plaintiff’s diagnosis, prognosis, and as to whether any medical
treatment received was reasonable or related to the subject incident. He will testify
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2022-CA-004682-O

as to causation of Plaintiff’s injuries concerning the subject incident. His opinions will
include those contained in his written reports, if any, deposition testimony, if taken,
and on his personal evaluation of Plaintiff as well as those who are similarly situated.
He will rely on his education, training, and experience as well as testimony, medical
records, accident report, and photographs of the subject incident.

A copy of Dr. Jenkin’s curriculum vitae is attached as Exhibit “A”.

Dr. Jenkins has the following availability for the purpose of deposition:

01/04/2014 @ 4:30-5:30 p.m.
01/25/2014 @ 4:30-5:30 p.m.
02/01/2024 @ 4:30-5:30 p.m.
02/08/2024 @ 4:30-5:30 p.m.

2. Marc D. Kaye, MD
2805 East Oakland Park Blvd #452
Ft. Lauderdale, FL 33306
Phone: (866) 878-1997

Specialty/Field of Expertise and Specific Subjects upon which may testify
and offer opinions: Marc D. Kaye, MD, is a board-certified radiologist who is
expected to testify on causation and damages based on his findings on diagnostic
studies of the Plaintiff, whether such findings are causally related to the subject
incident, and the findings related to any symptoms, physical restrictions, medical
necessity of past and future medical treatment and cause for surgery, if any. Dr.
Kaye’s testimony will be based on his background, experience, training and
education as well as his review of pertinent medical records and radiographic films.

A copy of Dr. Kaye’s curriculum vitae is attached as Exhibit “B”.

Dr. Kaye has the following availability for the purpose of deposition:

12/04/2023 @ 10:00 a.m.
12/06/2023 @ 10:00 a.m.
12/07/2023 @ 10:00 a.m.

3. Ming Xiao, Ph.D., P.E., ACTAR
560 SW 12th Avenue
Deerfield Beach, FL 33442
Phone: (954) 801-1700

Specialty/Field of Expertise and Specific Subjects upon which may testify and
offer opinions: Ming Xiao, Ph.D., P.E., ACTAR is a registered professional
engineer, and an Accredited Traffic Accident Reconstructionist. It is expected that
2
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2022-CA-004682-O

Dr. Xiao will testify as to what occurred during the alleged collision and provide a
biomechanical analysis regarding what Plaintiff may have experienced during the
collision.

A copy of Dr. Xiao’s curriculum vitae is attached as Exhibit “C”.

Dr. Xiao has the following availability for the purpose of deposition:

12/22/2023 @ 10:00 a.m.
12/22/2023 @ 5:00 p.m.
12/28/2023 @ 10:00 a.m.
12/28/2023 @ 5:00 p.m.
12/29/2023 @ 10:00 a.m.
12/29/2023 @ 5:00 p.m.

4. Rebuttal Expert Witnesses: Any and all experts or rebuttal witnesses whom these
Defendants may employ as to any party's tendered experts, if and when these
Defendants learn of any and all Plaintiff's experts stated opinions and grounds
therefore, as no expert witnesses have thus far been disclosed by Plaintiff.

5. Impeachment Expert Witnesses: All expert witnesses whose purpose is to impeach
the testimony proffered by a fact or expert witness.

6. Rebuttal Witnesses to Plaintiff's Treating Physicians: Any and all experts to rebut the
testimony offered by Plaintiff's treating physicians, if and when these Defendants are
made aware of the stated opinions of Plaintiff's treating physicians and the grounds
each treating physician relies upon in support of their respective opinions.

7. Impeachment Witnesses to Plaintiff's Treating Physicians: Any and all experts
Defendants may employ to impeach the testimony offered by Plaintiff's treating
physicians if and when this Defendants is made aware of the stated opinions of
Plaintiff's treating physicians and the grounds each treating physician relies upon in
support of their respective opinions.

8. Defendants reserve the right to supplement this Disclosure as discovery in this matter
may reveal or require subsequent filing of the same.

9. Defendants reserve the right to call as expert witnesses any and all expert witnesses
listed in any expert witness disclosure and/or pretrial catalogue filed in this matter.

10. Defendants reserve the right to call as expert witnesses any and all persons who
have been deposed or noticed of deposition in this suit.

11. Defendants reserve the right to object to any and all expert witnesses listed by any
other party.
3
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
CASE NO.: 2022-CA-004682-O

12. Defendants reserve the right to call any and all additional expert witnesses in rebuttal
and/or for impeachment purposes.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this th day of November, 2023, a true and correct

copy of the foregoing was filed with the Clerk of Osceola County by using the Florida

Courts e-Filing Portal, which will send an automatic e-mail message to the following

parties registered with the e-Filing Portal system: Melissa Alzate, Esq., Morgan &

Morgan, P.A., malzate@forthepeople.com; imerlos@forthepeople.com;

anajera@forthepeople.com, 198 Broadway Avenue, Kissimmee, FL 34741, (407) 452-

1597/(407) 452-1623 (F), Attorney for Plaintiff, Asbel Alexander Llerena.

COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant ADRIAN RODRIGUEZ
CHAVEZ AND GRANNY'S GARDEN II, INC.
Tower Place, Suite 400
1900 Summit Tower Boulevard
Orlando, Florida 32810
Telephone (321) 972-0011
Facsimile (321) 972-0099
Primary e-mail: scott.shelton@csklegal.com
Secondary e-mail: gary.lewis@csklegal.com
Alternate e-mail:
sandra.mcintosh@csklegal.com

By: /s/ Gary L. Lewis
SCOTT A. SHELTON
Florida Bar No.: 36486
GARY L. LEWIS
Florida Bar No.: 158887

4
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
EXHIBIT “A”
CURRICULUM VITAE

JOHN A. JENKINS, M.D.

BIRTHPLACE / DATE:

Santa Monica, CA
September 26, 1964

BOARD CERTIFICATION:

American Board of Neurological Surgery
Certification: November 22, 2000
Re-certification: 2010, 2020

LICENSURE:

Florida ME77991
Texas J2110

WORK EXPERIENCE:

August 1, 2016 – present Orlando Neurosurgery

April 1, 2015 – present Zeus Spine LLC
8815 Conroy Windermere Rd. #405
Orlando, FL 32835

July 2003 – July 31, 2016 FHMG
d/b/a/ Winter Park Neurosurgery
1925 Mizell Ave., Suite 301
Winter Park, FL 32792

June 1999 – June 2003 Orlando Neurosurgery, P.A.
1801 Cook Avenue
Orlando, FL 32806

August 1997 – November 1998 Neurosurgical Group of Greater
Louisville & Southern Indiana
225 Abraham Flexner Way #505
Louisville, KY 40202

EDUCATION AND TRAINING:

Undergraduate:
Bachelor of Arts (Biochemistry and Cell Biology) University of California
1982 – 1986 San Diego, California

Post Graduate studies:
Molecular Biology Rice University
1986 – 1987 Houston, Texas

EDUCATION AND TRAINING CONTINUED:

Medical School: University of Texas Medical Branch
Doctor of Medicine Galveston, Texas
1987 – 1991

Internship:
July 1991 – June 1992 Ohio State University
Columbus, Ohio

Residency:
July 1992 – June 1997 Ohio State University
Columbus, Ohio

SPECIALIZED TRAINING:

Six months of training in Interventional Neuroradiology under the supervision of L.N. Hopkins,
MD; Millard Fillmore Hospital; Buffalo, New York; 1995.

PUBLICATIONS:

L.R. Guterman, PhD, MD, J.A. Jenkins, MD, J.D. Borchers, MD, L.N. Hopkins MD:
Vascular Neurosurgery: Aneurysms, AVM’s, Subarachnoid Hemorrhage, and Intracranial
Hemorrhage. Current Opinion in Neurology 9 (1): 57-61, 1996.

A.K. Wakhloo, MD, J.A. Jenkins, MD, L.R. Guterman, MD, L.N. Hopkins, MD:
Endovascular Treatment of Cerebral and Spinal Vascular Diseases. Principles of
Neurosurgery. Philadelphia: Lippincott-Raven, 1999: 353-370.

PRESENTATIONS:

“Effects of Extracellular pH on Calcium Channel Currents in Basilar Artery Smooth Muscle
Cells of a Guinea Pig”; University of Texas Medical Branch, Student Research Poster Session,
July, 1988. Sponsored by the National Institute of Health Medical Student Research Grant.

“Low Back Pain”; CAN Conference; Louisville, KY, March 1998.

“Lower Back Pain and Workers Compensation”; Governor’s Conference; Louisville, KY;
May 6, 1998.

“Carpal Tunnel and Low Back Pain”; Bluegrass Health Network Conference; Louisville, KY;
August 14, 1998.
2
“Indications for Lumbar Fusion”; Central Florida Association of Rehabilitation Nurses Meeting;
Orlando, FL; August 20, 1999

“Traumatic Brain Injury”; ORMC Trauma Conference; Orlando, FL; November 13, 1999.

“Vagal Nerve Stimulation”; ORMC Neuroscience Institute; Orlando, FL; February 15, 2000.

“Frameless Stereotactic Neurosurgery”; Action Center of Orlando; Orlando, FL; December 07,
2002.

“General Neurosurgical Conditions”; Nursing Seminar; Orlando, FL; September 30, 2003 and
October 2, 2003.

“Kyphoplasty”; Nursing Seminar; Orlando, FL; March 15, 2004.

“The Nuts and Bolts of Spine Surgery”; Celebration Health; Celebration, FL; June 22, 2005 and
February 8, 2007.

“Lumbar Fusion”; Celebration Health; Celebration, FL; June 30, 2005.

“Neurosurgical Treatment of Neck and Back Pain”; Spine Service Line Education Meeting;
Orlando, FL; November 2, 2006.

“The Nuts and Bolts of Spine Surgery”; Celebration Health; Celebration, FL; February 08, 2007.

“Neck and Back Pain”; Celebration Health, FL; April 12, 2007 and July 12, 2007.

“Lumbar Spine Surgical and Anatomy Dissection”; Nicholson Center for Surgical Advancement;
Celebration, FL; September 21, 2007.

“Lumbar Spinal Stenosis”; Multidisciplinary Spine Conference; Celebration, FL; September 21,
2007.

“Artificial Disc Replacement in the Cervical Spine”; Multidisciplinary Spine Conference;
Celebration, FL; September 21, 2007.

“Treatment of Cervical Surgical Complications”; Celebration Health; Celebration, FL; July 19,
2010.

“Treatment of Cervical Surgical Complications”; Celebration Health; Celebration, FL; July 21,
2010.

“Post-Operative Care of the Spine Patient”; Celebration Health; Celebration, FL; November 16,
2010.

“Artificial Disc Replacement”; Celebration Health; Celebration, FL; November 16, 2010.

3
“Artificial Disc Replacement in the Cervical Spine”; Physician Referral Dinner; Orlando, FL;
June 3, 2011

“Cervical Diskectomy-when is a surgical option right for you?”; Best in Care Lecture Series;
Celebration Town Hall; Celebration, FL; June 9, 2011.

“Post-Operative Care of the Spine Patient”; New Patient Tower Education Series; Celebration
Health; Celebration, FL; July 21, 2011.

“Artificial Disc Replacement”; New Patient Tower Education Series; Celebration Health;
Celebration, FL; July 21, 2011.

“Artificial Disc Replacement in the Cervical Spine”; Physician Referral Dinner; Orlando, FL;
August 25, 2011

HONORS:

National Institute of Health Medical Research Grant, 1988 (NIH funded research while at
UTMB)

J.M. Foundation and Scaife Family Foundation Scholarship, 1989

Space Shuttle Medical Support Training Course, 1999

ORGANIZATIONS:

American Association of Neurological Surgeons

4
EXHIBIT “�”
Exhibit A

MARC D. KAYE, M.D.
Collier Radiology Consultants
2805 East Oakland Park Blvd
Suite 452
Ft. Lauderdale, FL. 33306
(866) 878 1997
Email:kayemarc@gmail.com

CURRICULUM VITAE

PROFESSIONAL: License: Florida – Active
Virginia- Active
South Carolina-Active
Ohio-Inactive
California-Inactive

Private Practice Radiology, Dr. Hurt Issacs,
Cranford, Johnston, P.A. Jacksonville, Florida
1980 to 1990

Chairman, Division of Radiology,
Cleveland Clinic Florida
September 1991 to July 2002

Chief of Radiology, Cleveland Clinic
Hospital
Ft. Lauderdale, Florida, 1993-2002

Chairman, Radiology, Cleveland Clinic
Naples
2000-2002

Cleveland Clinic Florida, Adjunct Staff
July 2002-June 2003

Cleveland Clinic Naples, Adjunct Staff
July 2002-June 2003

Boecher RFP 0003
Exhibit A
Medical Director, Imaging
Sciences/Radiology, Indian River Memorial
Hospital, Vero Beach, Florida
July 2002 – February 2003

Chairman, Department of Radiology
Columbia Hospital, West Palm Beach, Florida
February 2003 to June 2003

Chief of Radiology,
Cleveland Clinic Hospital &
Chairman, Radiology
Cleveland Clinic Naples
2003-2006

Vice Chief of Staff
Cleveland Clinic Florida Naples
2004-2006

Vice Chief of Staff
Physicians Regional Medical Center
Naples, Florida
May 1, 2006 to January 2007

Chief of Radiology
Physicians Regional Medical Center (formally
Cleveland Clinic Naples)
Naples, Florida
May 2006 to August 2009

Chairman, Credentials Committee
Physicians Regional Medical Center
Naples, Florida 2005-2009

Collier United Radiology/Sheridan Healthcorp
July 2009-April 2012

Lawnwood Regional Medical Center
Level II Trauma Center
Principle VIR for Trauma Center

2
Boecher RFP 0004
Exhibit A
Fort Pierce, Florida
October 2010-January 2012

Medical Director
Ft. Lauderdale Vascular Access Center
3601 W. Commercial Blvd
Ft. Lauderdale, FL. 33309
September 2009-November 2010

Chief of Radiology
Hendry Regional Medical Center
Clewiston, Florida
2010-2012

Cleveland Clinic Hospital Weston
Weston, FL.
Active Staff

Florida Medical Center
Fort Lauderdale, FL.
2001-2013

Staff, Cleveland Clinic Florida, Jan. 1991-Present
Staff, Division of Radiology, Cleveland Clinic
Foundation
Cleveland, Ohio, August 1991-2002

Active Staff, Cleveland Clinic Foundation,
Cleveland, Ohio
1991-2006

Jackson Memorial Hospital, Jackson North &
South, Miami, Florida
Active Staff

Kendall Regional Medical Center and Trauma
Center; Vascular and Interventional Radiologist
for Level II Trauma Center.

3
Boecher RFP 0005
Exhibit A
American Access Care of Florida; October 2013
to present. Vascular & Interventional
Radiology.

President, Collier Radiology Consultants
September 2006-present

Clinical Faculty: Florida International University
College of Medicine

EDUCATION:

HIGH SCHOOL: Southwest Miami High School

COLLEGE: University of Florida, 1969-1972
Omicron Delta Kappa, National Honor Leadership and
Scholastic Society, 1971

MEDICAL SCHOOL: University of Miami School of Medicine, 1972-1976

INTERNSHIP: Stanford University Medical Center, Stanford, California
1976-1977

RESIDENCY: Stanford University Medical Center, Radiology
1977-1980

CERTIFICATION:
AMERICAN BOARD OF RADIOLOGY, VASCULAR AND
INTERVENTIONAL RADIOLOGY, 1995

RECERTIFICATION: AMERICAN BOARD OF RADIOLOGY
VASCULAR AND INTERVENTIONAL RADIOLOGY 2005

AMERICAN BOARD OF RADIOLOGY, DIAGNOSTIC
RADIOLOGY, 1980

NATIONAL BOARD OF MEDICAL EXAMINERS 1977

BOARD EXAMINER: AMERICAN BOARD OF RADIOLOGY IN VASCULAR AND
INTERVENTIONAL RADIOLOGY

MILITARY: Lieutenant, USNR, 1972-1982

4
Boecher RFP 0006
Exhibit A
CONSULTANT: Expert Witness
Florida Department of Heath
Board of Medicine, State of Florida
1986 to present

PROFESSIONAL ORGANIZATIONS;

DUVAL COUNTY Vice President 1989-1990
MEDICAL SOCIETY

CHAIRMAN: Legislative Committee, DCMS, 1986-1990

MEMBER: Legislative Committee, Florida Medical Association
1985-1991

BOARD Florida Medical Political Action Committee, 1988-
1991
MEMBER:

CHAIRMAN: Jacksonville Area Physicians for Better Government
1987-1990

AMA MEMBER, 1980-PRESENT

Society of Interventional Member 1994-Present
Radiology

Cardiovascular and Interventional
Society of Europe (CIRSE) Member 1997-Present

FLORIDA RADIOLOGICAL Member, Vascular and Interventional
SOCIETY Radiology Society Committee

South Florida Society for
Vascular Surgery: Member 2003-Present

APPOINTMENT:

Member: Admissions Committee, University of Miami
Miller School of Medicine.

5
Boecher RFP 0007
Exhibit A
Chairman: Medical Education Committee, Kendall Regional
Medical Center.

MEMBER: Jacksonville Health Facilities Authority, 1988-1990

HONORS: “Best Doctors in America”, named in 1998, 1999, and
2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, &
2008. Survey Compiled by Center for the Study of
Services, Washington, D.C.

BEST DOCTORS IN SOUTHEASTERN UNITED STATES,
Castle Connelly, 2000, 2001, 2002, 2004, 2005, 2006,
2007, & 2008.

SPECIALTY ORGANIZATIONS:

SOCIETY OF INTERVENTIONAL RADIOLOGY

AMERICAN COLLEGE OF RADIOLOGY

CARDIOVASCULAR AND INTERVENTIONAL
RADIOLOGICAL SOCIETY OF EUROPE

SOUTH FLORIDA INTERVENTIONAL RADIOLOGY
SOCIETY

FLORIDA RADIOLOGICAL SOCIETY

SOUTH FLORIDA SOCIETY FOR VASCULAR SURGERY

MEDICAL ADVISOR, Keiser College School of Radiology
1992-2002

REVIEWER: JOURNAL OF CLINICAL GASTROENTEROLGOY

DISEASES OF THE COLON & RECTUM

6
Boecher RFP 0008
Exhibit A
PUBLICATIONS:

Kaye MD, Young SW, Haywood R, Castellino RA; Gastric
Pseudotumor on CT Scanning, AJR July 1980, Vol. 135 No.
1: 190-193

Kaye MD, Use of Ultrasound in the Diagnosis of Ectopic
Pregnancy, Jour of the Duval County Medical Society, Jan.
1982

Harrell RM, Kaye MD, Pseudoinsulinoma: Splenic Artery
Tortuosity Masquerading As Multiple Pancreatic Islet Cell
Tumors. Endocrine Practice Vol 1 No. 4 July/August 1995:
257-259

Kaye MD, Adami CA, Sullivan ML, Mammographic
Findings Following Stereotactic Breast Biopsy, Radiology,
1994; 192:149-151 (Selected for publication in Year
Book of Radiology 1996).

Kaye MD, Stereotactic Needle Localization of Nonpalpable
Breast Lesions. MammoTest News May 1995 p.2

Fear and Loathing in Louisville A Different Perspective on
The CAQ Exams., Diagnostic Imaging, Feb 1996 :25-81

The Role of Vena Cava Filters in the Prevention of Pulmonary
Embolism., Cohen GS, Kaye MD, Kiproff PM, Clincal
Dialogues Feb. 1997

Angiographic Diagnosis and Treatment of GI Hemorrhage.
Syllabus for Colorectal Disease Course. Eighth Annual
Sypmposium, Feb. 1997, Ft. Lauderdale, Fl.

Desai M, Kaye M, Margosian, Duraji, Eastwood L, Resse J,
3 Dimensional Breath Hold Post Contrast MR Angiography
Desai M, Kaye M, Margosian, Duraji, Eastwood L, Resse J,
British Jour of Radiology, Suppliment to 1997 Scientific
Meeting

Desai M, Nair SMD, Kaye MD, et al.
3D-CT Guided Percutanious Glycerol Rhizolysis for
Trigemminal Neuralgia in the Geriatric Population,
Interventional Neuroradiology, Sept. 1997, Vol. 3,
Supplement 1:137

Joo JS, Ehrenpreis ED, Gonzalez L, Kaye MD, Breno S,

7
Boecher RFP 0009
Exhibit A
Wexner SD, Alterations in Colonic Anatomy Induced by
Chronic Stimulant Laxatives. J Clin Gastroenterology 1998
26(4):283-286

Fernandez BB, Zavaleta E, Grove MK, Kaye MD, Ergotamine
Induced Leg Ischemia. Abstract, World Congress of
Angiology October 1998, New Orleans.

Fernandez B, Jr, Smilley LA, Swirsky SM, Kaye MD. Relief of
Sleep Apnea after Intravascular Stenting for Superior Vena
Cava Syndrome. Vasc. Med 1999 Feb;4(1):33-36

RESEARCH;

Co-investigator Talent Endograft Phase III Trial,
Endograft for Abdominal Aortic Aneurysms, March 2002-
Present

Principal Investigator: Phase IV Protocol. Open label use
of Omniscan in Special Populations: Incidence of
Adverse 1994-1995

Co-investigator, TOPAS PHASE II, Thrombolysis vs.
Surgery for Acute Arterial Occlusion, 1993-1994

Co-investigator, Protocol 307, “Double Blind, Placebo-
Controlled Clinical Trial Comparing the Efficacy and
Safety of Prolonged Outpatient Enoxaparin and Placebo
Therapies in the Prevention of Venous Thromboembolic
Disease in Patients Undergoing Elective Primary Hip or
Knee Replacement”, 1995

Co-investigator, Letrozole Protocol 26, Letrozole
treatment in post menopausal women with advanced
Breast Cancer, Ciba Pharmaceuticals, 1996-1997

PRESENTATIONS AND LECTURES:

Vena Cava Filters: Bard Radiology Annual Sales Meeting
Atlanta, GA., February 6, 1995

8
Boecher RFP 0010
Exhibit A
Stereotactic Needle localizations for Nonpalpable Breast
Lesions: 4th Annual Mammotest Users Meeting, Nov. 27,
1994, Chicago, Ill.

Stereotactic Breast Biopsy: Grand Rounds, Coliseum
Medical Center Macon, Ga. Nov. 9, 1994

Florida Pharmacy Association 102 Annual Meeting and
Conference, July 15, 1994 Boca Raton, Fl. Radiologic
Contrast Agents, Ionic Vs. Nonionic Agents.

University of Miami School of Medicine Fourth Annual
Winter Seminar, Aspin, Co.,January 1992, Diagnosis of
Pulmonary Embolism

Centinnal Medical Center, Los Angeles, Ca. Grand Rounds
Sept. 1991, Diagnosis and Treatment of Pulmonary
Embolism

Cleveland Clinic Florida Symposium on Foot and Ankle
Disorders , Feb. 1993; Interventional Techniques in
treatment of Lower Extremity Vascular Disease.

Florida Radiological Technologists Association, Annual
Meeting, Ft. Lauderdale Florida , May 1993: Stereotactic
Biopsy of the Breast, and Radiologic Diagnosis of
Inflammatory Bowel Disease.

Surgery Grand Rounds Cleveland Clinic Hospital, August
1996, “Embolization of Vascular Tumors and Vascular
Malformations”.

Northern California Kaiser Annual Radiology Course,
September 1996, Berkely, California:“Contrast Agent
Developement and Toxicity.”

“Magnetics in Medicine” Exhibit. Museum of Discovery
and Science. Ft. Lauderdale, Fl. Project Director for
exhibit. September 1996-January 1997.

“Mesenteric Angiography in the Diagnosis and Treatment
of Gastrointestinal Hemorrhage.” Eighth Annual
International Colorectal Disease Symposium. February
1997, Ft. Lauderdale, Fl.

Thrombolytic Therapy in Peripheral Vascular Disease,
Vascular Intervention Course: Society of Vascular and

9
Boecher RFP 0011
Exhibit A
Interventional Radiology , 22nd Annual Scientific
Meeting, Washington, DC, March 8-13, 1997

3 Dimensional Breath Hold Post Contrast Time of Flight
Magnetic Resonance Angiogram of the Body on a 1.0
Tesla MR System, British Radiology Annual Meeting,
Birmingham, England, May 1997

Medical Grand Rounds, Cleveland Clinic Hospital,
“Indications, Alternatives, and Risks of Interventional
Vascular Procedures.” July 2, 1997

“3D-CT Guided Percutanious Glycerol Rhizolysis for
Trigemminal Neuralgia in the Geriatric Population”
American Society of Interventional and Therapeutic
Neuroradiology/World Federation of Interventional and
Therapeutic Neuroradiology Scientific Conference
September 13, 1997, New York, New York.

“Contemporary Endovascular Therapy” Annual Meeting of
the South Florida Society for Vascular Surgery, Captiva
Island, Florida, October 1997

Treatment of Thromboembolic Disease and Pulmonary
Embolism, Michigan State University College of
Osteopathic Medicine General Surgery Conference, East
Lansing, Michigan, August 26, 1998

Interventional Techniques for the Treatment of
Gastrointestinal Disease. Gastroenterology Update 1999,
February 6-7, 1999 Ft. Lauderdale, Florida

Uterine Artery Embolization for Treatment of
Symptomatic
Uterine leiomyoma. Womens Health Seminar, Cleveland
Clinic Florida. July 8, 2000

Impact of Recent Advances in CT Angiography on the
Practice of Vascular Surgery & Interventional Radiology.
Presented at the South Florida Society of Vascular
Surgery Annual Meeting, Oct 23-25, 2003
Key Largo, Florida.

Treatment of Spinal Fractures with Vertebroplasty and
Kyphoplasty: Clinical Conference, Cleveland Clinic Naples
December 2003.

10
Boecher RFP 0012
Exhibit A
Endovascular Treatment of Gastrointestinal Hemorrhage
Lecture to Colorectal Fellows and Staff, Cleveland Clinic
Foundation, January 2006

64 SLICE CT CORONARY ANGIOGRAPHY; CLINICAL
CONFERENCE, CLEVELAND CLINIC NAPLES, MARCH
2006.

RADIOGRAPHIC EVALUATION OF INFLAMATORY BOWEL
DISEASE; Lecture to Colorectal Surgeons and Fellow,
Cleveland Clinic Foundation, April 2006.

Uterine Artery Embolization for Symptomatic Fibroids;
Cutting Edge Diagnosis and Treatment Course for
Practicing Physicians, February 9, 2007, Naples Beach
Resort and Hotel.

Advances in Interventional Radiology: American
Association of Legal Nurse Consultants, Boca Raton, FL
October 9, 2007.

Diagnosis & Management of Complications of
Interventional Procedures; Physicians Conference,
Physicians Regional Medical Center, Naples, FL.
September 26, 2008

Management of Hemorrhage with Endovascular
Techniques; University of Arizona Medical Center
Radiology Residents Conference, October 7, 2008,
Tucson, Az.

CIVIC: CAMP FIESTA CHILDREN’S CAMP, summer camp for the
CHILDREN’S CARING CANCER CENTER, Board member
and camp counselor. 1998-2002

Member, Sabre Society, United States Air Force Academy
Association of Graduates.

11
Boecher RFP 0013
EXHIBIT “�”
RIMKUS
Ming Xiao, Ph.D., P.E.
Biomechanical Practice Leader

560 SW12,h Avenue
Deerfield Beach, FL 33442

(954)801-1700

mxiao(S)rimkus.com

Background
Dr. Xiao holds a B.S. degree Mechanical Engineering and a Ph.D. in Biomechanics. He is a registered
in
professional engineer, an Accredited Traffic Accident Reconstructionist (ACTAR), and a Certified Playground
Safety Inspector (CPSI). His primary areas of consulting expertise include injury consistency biomechanics,
accident reconstruction, and playground safety.

Dr. Xiao performs biomechanical analyses on cases involving vehicle accidents, pedestrian/bicycle-vehicle
accidents, seatbelt or helmet usage, child seat, driver determination, driver perception/reaction behavior, falling
objects, slips/trips/falls, playground or amusement rides, water parks, and other injury accident/incidents. He has
reconstructed accidents involving low-speed collisions, high-speed (including fatality) collisions,
pedestrian/bicycle-vehicle accidents, vehicle rollovers, and other types of accidents. He also identifies hazards
on public playground equipment, ranks the hazards according to injury potential, and applies the knowledge to
remove the hazards.

Prior to joining Rimkus, Dr. Xiao worked at a medical school and a hospital. While working at Yale University
Medical School, he led a research project funded by the Center for Disease Control to evaluate occupant spinal
injury potential in rear-end collisions. He also collaborated with neurosurgeons to determine the mechanical
strength of spinal tissue to choose the proper surgical instrumentation. He was part of the rehabilitation program
for spinal cord injury patients while working at the Rehabilitation Institute of Chicago, which is affiliated with
Northwestern University.

Dr. Xiaohas published peer-reviewed journal papers and presented at numerous national/international science
conferences. He has testified in both depositions and at trials in federal court, as well as in state courts in Florida,
Colorado, Illinois, and the Commonwealth of Puerto Rico.

Professional Engagements
Rehabilitation Institute of Chicago -
Chicago, IL (2010-2011), Performed biomechanical and
electromyography analyses on human subjects with mathematical modeling along with design and
application of biomedical robotic devices.

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EUrimkus

· Rehabilitation Institute of Chicago – Chicago, IL (2010-2011), Provided engineering-based rehabilitative
strategy for human subjects with spinal cord injuries.
· Yale University, Medical School – New Haven, CT (2009-2010), Conducted research on occupant motion
analyses and injury potential as a result of rear-end collisions.
· Yale University, Medical School – New Haven, CT (2009-2010), Conducted research and scientific
evaluation for advanced vehicle safety features.
· Yale University, Medical School – New Haven, CT (2009-2010), Conducted research to implement multi-axis
pedicle screw in spine surgery.
· University of Delaware – Newark, DE (2005-2009), Conducted research to characterize the biomechanics of
muscles and bones during human walking.
· University of Delaware – Newark, DE (2005-2009), Performed motion capture and electromyography
analyses on human subjects. Developed computer simulation technique to identify muscle weakness and
formed rehabilitative strategies for stroke survivors.

• Technical/Scientific Support
· Since 2009, has provided technical peer-review for various scientific journals such as Journal of
Biomechanics, Journal of Clinical Biomechanics, and Gait and Posture.

Forensic Engagements
• Biomechanical Analyses of Vehicle Accidents
· Determined occupant motions, loads to body tissues, and injury consistency in low-speed vehicle collisions.
· Determined injury consistency in accidents with multiple high-speed impacts.
· Analyzed effects of seatbelt on injuries from high-speed vehicle collisions.
· Analyzed effects of helmet on injuries from motorcycle, scooters, or ATV accidents.
· Determined occupant seating positions based on injury patterns.

• Traffic Accident Reconstruction
· Determined vehicle speeds, driver perception/reaction behaviors, and collision avoidance.
· Evaluated line of sight, and performed nighttime vision analysis.
· Performed site mapping, 3D scanning, and vehicle CDR downloads.
· Analyzed traffic signal sequences.

• Biomechanical Analyses of Fall Incidents
· Determined dynamics and causes of fall incidents (whether it was a slip or a trip).
· Determined injury consistency from fall incidents (slip or trip).
· Determined injury consistency from falling objects or falling from a height.

• Biomechanical Analyses of Other Incidents
· Determined injury consistency in skin burn incidents.
· Determined injury consistency from explosive objects (such as firecrackers).
· Determined sharpness of objects resulting in skin lacerations.

• Playground Safety Inspections
· Identified hazards on public playground equipment.
· Ranked the hazards according to injury potential.

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EUrimkus

· Determined injury consistency and contributing factors in incidents involving playground equipment (such as
swings, slides, water slide, etc.).

• Expert Witness/Testimony
· Provided expert testimony in federal court and state courts (state of Florida, state of Colorado, state of Illinois,
and the Commonwealth of Puerto Rico).

Professional Experience
• Rimkus 2011 – Present
· Biomechanical Practice Leader
Provides consulting services to insurance carriers, law firms, schools, and corporate clients. Evaluates and
analyzes biomechanical systems, including voluntary and involuntary human motions. Provides human-injury
impact analysis in vehicular accidents and cases involving slips/trips/falls or falling objects. Performs
occupant motion studies to determine injury potential/consistency, seatbelt/helmet use, the effects of airbag
interaction, and determination of occupant positions. Provides vehicle accident analysis, including forensic
site mapping, vehicle inspection, computer-aided vehicle accident reconstruction, and downloads of
commercial vehicle engine control modules and passenger crash data recorders. Identifies hazards on public
playground equipment and the playground, and ranks the hazards according to injury potential.

• Rehabilitation Institute of Chicago 2010 – 2011
· Research Fellow
Performed biomechanical and electromyography analyses on human subjects with mathematical modeling
along with design and application of biomedical robotic devices. Provided engineering-based rehabilitative
strategy for human subjects with spinal cord injuries.

• Yale University, School of Medicine 2009 – 2010
· Research Associate
Conducted research on occupant motion analyses and injury potential/causation as a result of rear-end
impact. Evaluated and analyzed occupant dynamics with motion capture of cadaver specimen and impact
dummy. Provided biomechanical analysis of energy-absorbing car seat and advanced safety feature.
Conducted research to implement multi-axis pedicle screw in spine surgery; responsible for the
biomechanical analyses of the pedicle screw.

• University of Delaware, Center for Biomedical Engineering Research 2005 – 2009
· Research Assistance
Conducted research to characterize the mechanics of muscles and bones during human walking. Performed
motion capture and electromyography analyses on human subjects. Developed computer simulation
technique to identify muscles weakness and formed rehabilitative strategies for stroke survivors.

Education and Certifications
• Biomechanics, Ph.D.: University of Delaware (2009)
• Mechanical Engineering, B.S.: Tsinghua University in Beijing, China (2004)
• Licensed Professional Engineer: Colorado and Florida
• Certified Crash Data Retrieval Technician (Level 2): Bosch
• Certified Playground Safety Inspector: National Recreation and Park Association

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EUrimkus

• Accredited Traffic Accident Reconstructionist (ACTAR)
• American Society of Biomechanics: Member
• Society of Automotive Engineers: Member
• National Society of Professional Engineers: Member
• National Academy of Forensic Engineers: Board-Certified Senior Member
• Craig H. Neilsen Foundation Fellowship (2010)
• Injury Biomechanics Symposium Travel Award (2009)
• University Graduate Fellowship (2007)

Graduate Coursework and Continuing Education
• University of Delaware Graduate Courses: Orthopedic Biomechanics; Control of Human Movement; Human
Physiology and Anatomy; Signal Processing in Neural Systems
• Northwestern University Center for Public Safety Courses: Crash Investigation I and II (80 hrs.); CDR Data
Analyst (40 hrs.); Advanced Crash Reconstruction Utilizing Human Factors Research (40 hrs.)
• Other Continuing Education Courses: Crash Date Retrieval Technician Level 1 and 2 (16 hours), Collison
Safety Institute; Commercial Vehicle Event Data Recorder (12 hrs.), Rimkus Consulting Group, Inc.; EDC
Simulation with HVE (40 hrs.), Engineering Dynamics Corporation; Injuries, Anatomy, Biomechanics & Federal
Regulation (24 hrs.), SAE International; Pedestrian/Bicycle Crash Investigation (40 hrs.), Institute of Police
Technology and Management; Advanced Photogrammetry for Collision Reconstruction (24 hrs.), LightPoint
Scientific, LLC; Motorcycle Collision Reconstruction (31 hrs.), Lightpoint Learning

Publications In Peer-Reviewed Journals
• “Biomechanical comparison of endplate forces generated by uniaxial screws and monoaxial pedicle
screws.”, Orthopedics, 2012.
• “Soleus H-reflex phase-dependent modulation is preserved during stepping within a robotic
exoskeleton.” Clinical Neurophysiology, 2011.
• “Understanding whiplash injury and prevention mechanisms using a human model of the neck.”
Accident Analysis and Prevention, 2011.
• “Cervical spine curvature during simulated rear crashes with energy-absorbing seat.” The Spine
Journal, 2011.
• “WHIPS seat and occupant motions during simulated rear crashes.” Traffic Injury Prevention, 2010.
• “Sensitivity of predicted muscle force in forward simulation of normal walking.” Journal of Applied
Biomechanics, 2010.
• “Muscle function may depend on model selection in forward simulation of normal walking.” Journal of
Biomechanics, 2008.

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Case Info

Judge

ARENDAS, CHRISTINE E Track Judge’s New Case

Case No.

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Document Filed Date

March 26, 2024

Case Filing Date

May 10, 115

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Parties

GRANNY'S GARDEN II INC Defendant
LLERENA, ASHEL ALEXANDER Plaintiff
RODRIGUEZ CHAVEZ, ADRIAN Defendant
Melissa Alzate Attorneys for Plaintiffs
Melissa Crowley Attorneys for Defendants
Scott Shelton Attorneys for Defendants
Gary Lewis Attorneys for Defendants
Harley Clement Attorneys for Defendants
Louis DeFreitas Attorneys for Plaintiffs
Allison VanValkenburg Attorney
Sharon Henry Attorney
Richard Russo Attorneys for Plaintiffs
Bryce Spano Attorney
Howard Scholl Attorney
Christopher D'Amico Attorney
Trevor Hawes Attorney
Elizabeth Moore Attorney
Brian McClain Attorney

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No Value: ALEXANDER LLERENA, ASHEL vs. RODRIGUEZ CHAVEZ, ADRIAN

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