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Filing # 187800598 E-Filed 12/11/2023 05:06:34 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR OSCEOLA COUNTY, FLORIDA
ASBEL ALEXANDER LLERENA, CASE NO.: 2020-CA-002872-AN
Plaintiff,
vs.
ADRIAN RODRIGUEZ CHAVEZ and
GRANNY’S GARDEN II, INC.,
Defendants. /
PLAINTIFF'S AMENDED DISCLOSURE OF EXPERT WITNESSES TO ADD
REBUTTAL EXPERT
COMES NOW, the Plaintiff, ASBEL ALEXANDER LLERENA, by and through the
undersigned counsel and files Plaintiff’s Amended Disclosure of Expert Witnesses to Add Rebuttal
Expert, and provides the following disclosure of expert witnesses anticipated to testify at the trial of
this action:
1. Any and all medical providers/personnel at:
Joint Maneuvers Chiropractic
Brett E. Petty, D.C.
4797 Old Canoe Creek Road
St. Cloud, FL 34769
Speciality/expertise: Chiropractic
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and
permanency of injuries, including future treatment needed.
This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding
its care and treatment of the plaintiff, and offer opinions on causation and/or damages,
including, but not limited to, diagnoses, prognosis, impairment, permanency, disability,
aggravation of any pre-existing conditions, costs, reasonableness, necessity, and
relationship of past and future medical care, as well as any other relevant matters
customarily testified to by treating physicians and other medical care providers within a
reasonable degree of medical probability.
For further explanation, please see medical records chronicling treatment of Plaintiff,
already in Defendant’s possession. However, Plaintiff does not intend to limit this treating
physician’s testimony to the verbatim language contained in the medical records.
None of these medical records were prepared in anticipation of litigation.
2. Any and all medical providers/personnel at:
Spine and Orthopedics Specialist
Aaron Smith, D.O.
Sandeep Pillarisetty, M.D.
814 North John Young Parkway
Kissimmee FL USA 34741
Speciality/expertise: Orthopedic Surgeon, Orthopedics, Neurosurgeon, Pain Management
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and
permanency of injuries, including future treatment needed.
This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding
its care and treatment of the plaintiff, and offer opinions on causation and/or damages,
including, but not limited to, diagnoses, prognosis, impairment, permanency, disability,
aggravation of any pre-existing conditions, costs, reasonableness, necessity, and
relationship of past and future medical care, as well as any other relevant matters
customarily testified to by treating physicians and other medical care providers within a
reasonable degree of medical probability.
For further explanation, please see medical records chronicling treatment of Plaintiff,
already in Defendant’s possession. However, Plaintiff does not intend to limit this treating
physician’s testimony to the verbatim language contained in the medical records.
None of these medical records were prepared in anticipation of litigation.
3. Any and all medical providers/personnel at:
Integrity Medical Group
Thomas Cooper, M.D.
Rafael Romero, PA-C
Terel Newton, M.D.
Donald Behrmann, M.D.
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and
permanency of injuries, including future treatment needed.
This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding
its care and treatment of the plaintiff, and offer opinions on causation and/or damages,
including, but not limited to, diagnoses, prognosis, impairment, permanency, disability,
aggravation of any pre-existing conditions, costs, reasonableness, necessity, and
relationship of past and future medical care, as well as any other relevant matters
customarily testified to by treating physicians and other medical care providers within a
reasonable degree of medical probability.
For further explanation, please see medical records chronicling treatment of Plaintiff,
already in Defendant’s possession. However, Plaintiff does not intend to limit this treating
physician’s testimony to the verbatim language contained in the medical records.
None of these medical records were prepared in anticipation of litigation.
4. Any and all medical providers/personnel at:
AKUMIN
Jose Pizzaro, M.D.
1503 W Oak St.
Kissimmee, FL 34744
Speciality/expertise: Radiology/Diagnostics
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and
permanency of injuries, including future treatment needed.
This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding
its care and treatment of the plaintiff, and offer opinions on causation and/or damages,
including, but not limited to, diagnoses, prognosis, impairment, permanency, disability,
aggravation of any pre-existing conditions, costs, reasonableness, necessity, and
relationship of past and future medical care, as well as any other relevant matters
customarily testified to by treating physicians and other medical care providers within a
reasonable degree of medical probability.
For further explanation, please see medical records chronicling treatment of Plaintiff,
already in Defendant’s possession. However, Plaintiff does not intend to limit this treating
physician’s testimony to the verbatim language contained in the medical records.
None of these medical records were prepared in anticipation of litigation.
5. Timonthy Bundy, D.O., CLCP, ATC (Treating Physician/Retained Expert)
324 S. Hyde Park Avenue, Ste 275
Tampa, FL 33606
Specialty/expertise: Rehabilitation, Vocational Rehabilitation and Life Care Planning
Testifying Subject: Causation and permanency of injuries, including future treatment
needed as detailed in a Life Care Plan, review of past medical records and treatment
records.
Dates: January 9, 2024, January 16, 2024, January 18, 2024.
This physician is a treating physician and retained expert who is expected to testify on
behalf of the Plaintiff regarding his care and treatment of the Plaintiff, and offer opinions
on causation and/or damages, including, but not limited to, diagnoses, prognosis,
impairment, permanency, disability, aggravation of any pre-existing conditions, costs,
reasonableness, necessity, and relationship of past and future medical care, as well as any
other relevant matters customarily testified to by treating physicians and other medical care
providers within a reasonable degree of medical probability/certainty. This non-retained
expert has reviewed any and all medical records pertaining to the care and treatment
received by the Plaintiff.
For further explanation please see the medical records chronicling the treatment of
Plaintiff, already in Defendant’s possession. However, Plaintiff does not intend to limit this
treating physician’s testimony to the verbatim language contained in the medical records.
This physician has rendered reports of the medical treatment and/or radiological reads, and
Plaintiff defers to the reports and/or testimony as to a summary of the subject matter of the
testimony, as well as the substance of the facts and opinions this physician may have. None
of these medical records were prepared in anticipation of litigation.
In addition, this physician, based upon education, training and experience, based upon
treatment of the Plaintiff, based upon the history obtained, based upon the medical records
reviewed, and based upon the diagnostic studies reviewed, will testify that the trauma
sustained by Plaintiff in the subject motor vehicle crash caused injuries which are
permanent in nature. He will also offer opinions as to life care plan, rehabilitation and any
other relevant expert opinions within the course and scope of his expertise.
6. Any and all medical providers/personnel at:
BudDocs
Marino A. Chanlatte, M.D.
917 Rinehart Rd. #2061
Lake Mary, FL 32746
Speciality/expertise: Medical Marijuana
Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and
permanency of injuries, including future treatment needed.
This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding
its care and treatment of the plaintiff, and offer opinions on causation and/or damages,
including, but not limited to, diagnoses, prognosis, impairment, permanency, disability,
aggravation of any pre-existing conditions, costs, reasonableness, necessity, and
relationship of past and future medical care, as well as any other relevant matters
customarily testified to by treating physicians and other medical care providers within a
reasonable degree of medical probability.
For further explanation, please see medical records chronicling treatment of Plaintiff,
already in Defendant’s possession. However, Plaintiff does not intend to limit this treating
physician’s testimony to the verbatim language contained in the medical records.
None of these medical records were prepared in anticipation of litigation.
7. Michael Freeman Ph.D. (Retained Expert)
Forensic Research & Analysis
4500 Kruse Way, Plaza I, Suite 385
Lake Oswego, Oregon 97035
Will discuss: Dr. Freeman is a retained expert and rebuttal witness who is expected to
testify on behalf of the Plaintiff regarding injury causation, crash reconstruction, injury
biomechanics, injury risk, and any other relevant expert opinions within the course and
scope of his expertise.
Deposition dates have been requested and C.V. will be provided upon receipt.
8. Farhad Booeshaghi, Ph.D., P.E. (Retained Expert)
Global Engineering & Scientific Solutions
2777 Miccosukee Road, Suite 1
Tallahassee, FL 32308
Specialty/Expertise: Accident Reconstruction/Engineering/Human Factors/Biomechanics
Testifying Subject: Accident Reconstruction/Mechanism of Injury/Human Factors, as well
as authentication of mechanism of injury animation.
Deposition dates have been requested and C.V. will be provided upon receipt.
The said above-listed experts are expected to testify in their respective fields of expertise
as to their medical care, treatment and or services rendered to Plaintiff; including but not limiting
their testimony to the issues of the injuries suffered from the subject incident, reasonableness and
necessity of care and treatment in the past and into the future, cost for future care, diagnosis and
prognosis, as well as the issue of causation and permanency of the injury(ies). The curriculum
vitae of each above-listed retained expert witness has been requested and will be furnished, if not
already received and attached as composite exhibit hereto, to Defendant as soon as the same has
been made available to counsel for Plaintiff.
** Please contact Plaintiff’s counsel at (407) 563-3694 to coordinate scheduling of any of the
above noted providers/expert witnesses.
1. As both Plaintiff’s treatment for her incident-related injuries and discovery are ongoing,
Plaintiff reserves the right to identify, as expert witnesses, any additional health care
providers who render(ed) treatment to Plaintiff for accident-related injuries that become
known prior to the discovery cut-off date in this action.
2. Any expert witnesses discovered in formal discovery prior to the discovery cut-off date in
this action.
3. Any other applicable expert witness necessary to authenticate any item of evidence or exhibit
listed on the Plaintiff’s Exhibit List.
4. Any applicable records custodian for any record or document listed on the Plaintiff’s Exhibit
List.
5. Any witness listed by the Defendants to this cause in their Expert Witness Lists previously
filed or to be filed.
6. Any expert witness who rendered deposition testimony in the discovery of this cause of action.
7. Any expert witness necessary to rebut testimony provided by any witness disclosed by the
Defendant in its Expert Witness lists previously filed or yet to be filed.
8. Any and all expert witnesses listed or retained by the Defendants, whether formally listed,
withdrawn as expert witnesses and regardless of whether called at trial by the Defendants, or
later withdrawn by the Defendants.
9. Any and all compulsory medical examiners of the Defendants and/or any and all later or
additionally disclosed compulsory medical examiners, whether formally listed on
Defendants’ expert witness list and/or withdrawn as expert witnesses by the Defendants.
10. Any appropriate expert rebuttal witness necessitated by the proof of these issues.
11. Representatives of any alleged collateral source as raised by the Defendant. Such witnesses
may or may not be considered expert, but rather informational within their field of interest.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on December 11, 2023, I electronically filed the forgoing with
the Clerk of the Courts by using the Florida Courts eFiling Portal. I further certify that Pursuant
to Rule 2051(b)(1) I forwarded the foregoing this same day via Email to: Scott A. Shelton, Esq.
Gary L. Lewis, Esq., of Cole, Scott & Kissane, P.A., scott.shelton@csklegal.com;
gary.lewis@csklegal.com; sanra.mcintosh@csklegal.com.
/s/ Melissa Alzate
Melissa Alzate, Esquire
FBN 1013530
Morgan & Morgan Orlando P.A.
198 Broadway Avenue
Kissimmee, Florida 34741
Telephone: (407) 452-1597
Facsimile: (407) 452-1623
Primary Email: MAlzate@forthepeople.com
Secondary Email: MCoriano-Lopez@forthepeople.com
Tertiary Email: VPagan @forthepeople.com
Attorney for Plaintiff
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Filing # 187800598 E-Filed 12/11/2023 05:06:34 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA ASBEL ALEXANDER LLERENA, CASE NO.: 2020-CA-002872-AN Plaintiff, vs. ADRIAN RODRIGUEZ CHAVEZ and GRANNY’S GARDEN II, INC., Defendants. / PLAINTIFF'S AMENDED DISCLOSURE OF EXPERT WITNESSES TO ADD REBUTTAL EXPERT COMES NOW, the Plaintiff, ASBEL ALEXANDER LLERENA, by and through the undersigned counsel and files Plaintiff’s Amended Disclosure of Expert Witnesses to Add Rebuttal Expert, and provides the following disclosure of expert witnesses anticipated to testify at the trial of this action: 1. Any and all medical providers/personnel at: Joint Maneuvers Chiropractic Brett E. Petty, D.C. 4797 Old Canoe Creek Road St. Cloud, FL 34769 Speciality/expertise: Chiropractic Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and permanency of injuries, including future treatment needed. This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding its care and treatment of the plaintiff, and offer opinions on causation and/or damages, including, but not limited to, diagnoses, prognosis, impairment, permanency, disability, aggravation of any pre-existing conditions, costs, reasonableness, necessity, and relationship of past and future medical care, as well as any other relevant matters customarily testified to by treating physicians and other medical care providers within a reasonable degree of medical probability. For further explanation, please see medical records chronicling treatment of Plaintiff, already in Defendant’s possession. However, Plaintiff does not intend to limit this treating physician’s testimony to the verbatim language contained in the medical records. None of these medical records were prepared in anticipation of litigation. 2. Any and all medical providers/personnel at: Spine and Orthopedics Specialist Aaron Smith, D.O. Sandeep Pillarisetty, M.D. 814 North John Young Parkway Kissimmee FL USA 34741 Speciality/expertise: Orthopedic Surgeon, Orthopedics, Neurosurgeon, Pain Management Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and permanency of injuries, including future treatment needed. This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding its care and treatment of the plaintiff, and offer opinions on causation and/or damages, including, but not limited to, diagnoses, prognosis, impairment, permanency, disability, aggravation of any pre-existing conditions, costs, reasonableness, necessity, and relationship of past and future medical care, as well as any other relevant matters customarily testified to by treating physicians and other medical care providers within a reasonable degree of medical probability. For further explanation, please see medical records chronicling treatment of Plaintiff, already in Defendant’s possession. However, Plaintiff does not intend to limit this treating physician’s testimony to the verbatim language contained in the medical records. None of these medical records were prepared in anticipation of litigation. 3. Any and all medical providers/personnel at: Integrity Medical Group Thomas Cooper, M.D. Rafael Romero, PA-C Terel Newton, M.D. Donald Behrmann, M.D. Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and permanency of injuries, including future treatment needed. This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding its care and treatment of the plaintiff, and offer opinions on causation and/or damages, including, but not limited to, diagnoses, prognosis, impairment, permanency, disability, aggravation of any pre-existing conditions, costs, reasonableness, necessity, and relationship of past and future medical care, as well as any other relevant matters customarily testified to by treating physicians and other medical care providers within a reasonable degree of medical probability. For further explanation, please see medical records chronicling treatment of Plaintiff, already in Defendant’s possession. However, Plaintiff does not intend to limit this treating physician’s testimony to the verbatim language contained in the medical records. None of these medical records were prepared in anticipation of litigation. 4. Any and all medical providers/personnel at: AKUMIN Jose Pizzaro, M.D. 1503 W Oak St. Kissimmee, FL 34744 Speciality/expertise: Radiology/Diagnostics Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and permanency of injuries, including future treatment needed. This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding its care and treatment of the plaintiff, and offer opinions on causation and/or damages, including, but not limited to, diagnoses, prognosis, impairment, permanency, disability, aggravation of any pre-existing conditions, costs, reasonableness, necessity, and relationship of past and future medical care, as well as any other relevant matters customarily testified to by treating physicians and other medical care providers within a reasonable degree of medical probability. For further explanation, please see medical records chronicling treatment of Plaintiff, already in Defendant’s possession. However, Plaintiff does not intend to limit this treating physician’s testimony to the verbatim language contained in the medical records. None of these medical records were prepared in anticipation of litigation. 5. Timonthy Bundy, D.O., CLCP, ATC (Treating Physician/Retained Expert) 324 S. Hyde Park Avenue, Ste 275 Tampa, FL 33606 Specialty/expertise: Rehabilitation, Vocational Rehabilitation and Life Care Planning Testifying Subject: Causation and permanency of injuries, including future treatment needed as detailed in a Life Care Plan, review of past medical records and treatment records. Dates: January 9, 2024, January 16, 2024, January 18, 2024. This physician is a treating physician and retained expert who is expected to testify on behalf of the Plaintiff regarding his care and treatment of the Plaintiff, and offer opinions on causation and/or damages, including, but not limited to, diagnoses, prognosis, impairment, permanency, disability, aggravation of any pre-existing conditions, costs, reasonableness, necessity, and relationship of past and future medical care, as well as any other relevant matters customarily testified to by treating physicians and other medical care providers within a reasonable degree of medical probability/certainty. This non-retained expert has reviewed any and all medical records pertaining to the care and treatment received by the Plaintiff. For further explanation please see the medical records chronicling the treatment of Plaintiff, already in Defendant’s possession. However, Plaintiff does not intend to limit this treating physician’s testimony to the verbatim language contained in the medical records. This physician has rendered reports of the medical treatment and/or radiological reads, and Plaintiff defers to the reports and/or testimony as to a summary of the subject matter of the testimony, as well as the substance of the facts and opinions this physician may have. None of these medical records were prepared in anticipation of litigation. In addition, this physician, based upon education, training and experience, based upon treatment of the Plaintiff, based upon the history obtained, based upon the medical records reviewed, and based upon the diagnostic studies reviewed, will testify that the trauma sustained by Plaintiff in the subject motor vehicle crash caused injuries which are permanent in nature. He will also offer opinions as to life care plan, rehabilitation and any other relevant expert opinions within the course and scope of his expertise. 6. Any and all medical providers/personnel at: BudDocs Marino A. Chanlatte, M.D. 917 Rinehart Rd. #2061 Lake Mary, FL 32746 Speciality/expertise: Medical Marijuana Testifying Subject: Treating physician(s)/provider(s) of Plaintiff; causation and permanency of injuries, including future treatment needed. This is a non-retained expert who is expected to testify on behalf of the plaintiff regarding its care and treatment of the plaintiff, and offer opinions on causation and/or damages, including, but not limited to, diagnoses, prognosis, impairment, permanency, disability, aggravation of any pre-existing conditions, costs, reasonableness, necessity, and relationship of past and future medical care, as well as any other relevant matters customarily testified to by treating physicians and other medical care providers within a reasonable degree of medical probability. For further explanation, please see medical records chronicling treatment of Plaintiff, already in Defendant’s possession. However, Plaintiff does not intend to limit this treating physician’s testimony to the verbatim language contained in the medical records. None of these medical records were prepared in anticipation of litigation. 7. Michael Freeman Ph.D. (Retained Expert) Forensic Research & Analysis 4500 Kruse Way, Plaza I, Suite 385 Lake Oswego, Oregon 97035 Will discuss: Dr. Freeman is a retained expert and rebuttal witness who is expected to testify on behalf of the Plaintiff regarding injury causation, crash reconstruction, injury biomechanics, injury risk, and any other relevant expert opinions within the course and scope of his expertise. Deposition dates have been requested and C.V. will be provided upon receipt. 8. Farhad Booeshaghi, Ph.D., P.E. (Retained Expert) Global Engineering & Scientific Solutions 2777 Miccosukee Road, Suite 1 Tallahassee, FL 32308 Specialty/Expertise: Accident Reconstruction/Engineering/Human Factors/Biomechanics Testifying Subject: Accident Reconstruction/Mechanism of Injury/Human Factors, as well as authentication of mechanism of injury animation. Deposition dates have been requested and C.V. will be provided upon receipt. The said above-listed experts are expected to testify in their respective fields of expertise as to their medical care, treatment and or services rendered to Plaintiff; including but not limiting their testimony to the issues of the injuries suffered from the subject incident, reasonableness and necessity of care and treatment in the past and into the future, cost for future care, diagnosis and prognosis, as well as the issue of causation and permanency of the injury(ies). The curriculum vitae of each above-listed retained expert witness has been requested and will be furnished, if not already received and attached as composite exhibit hereto, to Defendant as soon as the same has been made available to counsel for Plaintiff. ** Please contact Plaintiff’s counsel at (407) 563-3694 to coordinate scheduling of any of the above noted providers/expert witnesses. 1. As both Plaintiff’s treatment for her incident-related injuries and discovery are ongoing, Plaintiff reserves the right to identify, as expert witnesses, any additional health care providers who render(ed) treatment to Plaintiff for accident-related injuries that become known prior to the discovery cut-off date in this action. 2. Any expert witnesses discovered in formal discovery prior to the discovery cut-off date in this action. 3. Any other applicable expert witness necessary to authenticate any item of evidence or exhibit listed on the Plaintiff’s Exhibit List. 4. Any applicable records custodian for any record or document listed on the Plaintiff’s Exhibit List. 5. Any witness listed by the Defendants to this cause in their Expert Witness Lists previously filed or to be filed. 6. Any expert witness who rendered deposition testimony in the discovery of this cause of action. 7. Any expert witness necessary to rebut testimony provided by any witness disclosed by the Defendant in its Expert Witness lists previously filed or yet to be filed. 8. Any and all expert witnesses listed or retained by the Defendants, whether formally listed, withdrawn as expert witnesses and regardless of whether called at trial by the Defendants, or later withdrawn by the Defendants. 9. Any and all compulsory medical examiners of the Defendants and/or any and all later or additionally disclosed compulsory medical examiners, whether formally listed on Defendants’ expert witness list and/or withdrawn as expert witnesses by the Defendants. 10. Any appropriate expert rebuttal witness necessitated by the proof of these issues. 11. Representatives of any alleged collateral source as raised by the Defendant. Such witnesses may or may not be considered expert, but rather informational within their field of interest. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 11, 2023, I electronically filed the forgoing with the Clerk of the Courts by using the Florida Courts eFiling Portal. I further certify that Pursuant to Rule 2051(b)(1) I forwarded the foregoing this same day via Email to: Scott A. Shelton, Esq. Gary L. Lewis, Esq., of Cole, Scott & Kissane, P.A., scott.shelton@csklegal.com; gary.lewis@csklegal.com; sanra.mcintosh@csklegal.com. /s/ Melissa Alzate Melissa Alzate, Esquire FBN 1013530 Morgan & Morgan Orlando P.A. 198 Broadway Avenue Kissimmee, Florida 34741 Telephone: (407) 452-1597 Facsimile: (407) 452-1623 Primary Email: MAlzate@forthepeople.com Secondary Email: MCoriano-Lopez@forthepeople.com Tertiary Email: VPagan @forthepeople.com Attorney for Plaintiff