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Filing # 170390185 E-Filed 04/05/2023 11:57:08 AM
IN THE COUNTY COURT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
GRAPPIN CLINIC OF CHIROPRACTIC, CASE NO: 2022-014501 SP 26 (05)
P.A. A/A/O LISA WILLIAMSON, CIVIL DIVISION
Plaintiff,
Vs.
PROGRESSIVE SELECT INSURANCE
COMPANY,
Defendant.
___________________________________/
DEFENDANT’S NOTICE OF FILING WITNESS AND EXHIBIT LIST
COMES NOW, the Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, by
and through the undersigned attorney, hereby gives Notice of Filing Witness and Exhibit List in
Compliance with this Honorable Court’s Case Management Order.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished via E-Mail on April 5, 2023 to Gregory J. Blackburn, Esq., Reifkind, Thompson &
Rudzinski, LLP, Attorney for Plaintiff, Grappin Clinic of Chiropractic, P.A., a/a/o Lisa
Williamson, PipService@rtrlaw.com;pipscheduling@rtrlaw.com, (954) 370-5152/(954) 370-1992
(F).
Progressive PIP House Counsel
Attorneys for Defendant
9675 NW 117 Avenue
Suite 200
Medley, FL 33178
(305) 423-3890 (Asst.)/(305) 908-8441 (Direct)
Fax: (305) 887-2781
SERVICE DESIGNATIONS:
Primary: FLPIPHC-Miami@progressive.com
Secondary Andres_Millon@progressive.com
By: Andres Millon__________________
ANDRES MILLON, ESQUIRE
Florida Bar No. 112649
“Salaried Employees of Progressive Casualty Insurance Company”
217791267
Filed 02/15/2024 04:40 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL
DEFENDANT WITNESS LIST
1. Lisa M Williamson, claimant/patient/named insured.
2. Tony Bolado, Litigation Adjuster and Current Records Custodian of the Personal Injury
Protection File for this claim.
3. The Corporate Representative for Defendant if not already listed herein.
4. Any representatives on behalf of Defendant determined to be fact witness as a result of
ongoing discovery in the instant matter.
5. Any representatives on behalf of Plaintiff determined to be fact witness as a result of
ongoing discovery in the instant matter.
6. The corporate representative for Plaintiff.
7. The owner of Plaintiff company.
8. Any and all corporate officers of Plaintiff.
9. The medical director (if applicable) for Plaintiff.
10. Any and all medical providers who rendered treatment to the claimant on behalf of
Plaintiff’s Facility (whether or not direct employees of Plaintiff’s facility)
11. Any and all individuals from Plaintiff’s facility who have knowledge regarding treatment
rendered to the claimant.
12. Any and all individuals from Plaintiff who had any involvement regarding the billing and
handled/accepted payment on behalf of Plaintiff regarding the claim for the
insured/claimant (at issue in this lawsuit).
13. Any and all individuals from Plaintiff who handled the patient intake for claimant. (i.e.
front desk employees, employees assist with patient intake/insurance verification, patient
initial paperwork).
14. Any and all individuals who authored any affidavits filed in this matter.
15. Any and all individuals who provided deposition testimony.
16. Any and all individuals mentioned in depositions as having involvement in this claim.
17. Any and all individuals referenced in response to any and all discovery served/filed in
this matter.
18. Any and all individuals who answered any discovery in this matter.
19. Any and all individuals who signed jurat pages/verified interrogatory responses in this
matter.
20. Plaintiff’s records custodian(s).
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21. Records custodians for Plaintiff’s witnesses.
22. Any and all records custodian(s) for any and all medical providers that rendered treatment.
23. Defendant records custodians(s).
24. Records custodians for Defendant’s witnesses.
25. Any and all records custodians from all expert witness facilities.
26. Records custodians for third party witnesses.
27. Any and all other medical providers that provided treatment to Lisa M Williamson.
28. Any and all witnesses to the subject accident.
29. Any and all witnesses listed on the police report.
30. Any and all investigating offices at the scene of the accident.
31. Any and all fact witnesses as determined through ongoing discovery in the instant action.
32. Any and all impeachment or rebuttal witnesses.
33. Any and all witnesses listed on Plaintiff’s Witness List.
34. Any and all third party witnesses.
35. Any and all expert witnesses.
36. Any and all expert witnesses for Plaintiff.
37. Any and all expert witnesses for other parties/including but not limited to third parties.
38. Any and all experts listed on any other party’s Expert Witness List.
39. Defendant has not yet retained an expert as discovery is still ongoing, Defendant asserts
that this case involves legal issues which may be resolved via Motion for Summary
Judgment. If/when Defendant retains an expert witness, Defendant, will file an Expert
Witness list in accordance with the Pre-Trial Order.
40. Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, reserves the right to
amend/supplement this Witness List in accordance with the Pre-Trial Order as further
discovery is conducted.
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DEFENDANT'S EXHIBIT LIST
1. Plaintiff’s Complaint, including any and all amended Complaint(s) if applicable, including
any and all attachments to said Complaint and/or Amended Complaint(s).
2. Defendant’s Answer and Affirmative Defenses, including any and all amended Answers
and Affirmative Defenses, if applicable.
3. Any and all documents to support Defendant’s Answer and Affirmative Defenses.
4. Any and all requests for admissions and responses thereto.
5. Any and all interrogatory questions and answers thereto.
6. Any and all jurat pages filed.
7. Any and all requests for production and responses thereto, including all exhibits attached
thereto.
8. Any and all depositions transcripts and/or video tape depositions (if applicable) taken in
this case.
9. Any and all responses to subpoenas which were directed to parties and/or non-parties.
10. Any and all documents produced in response to subpoena duces tecum(s) in this case.
11. Any and all affidavits filed by the Plaintiff.
12. Any and all affidavits filed by the Defendant.
13. Any and all records custodian affidavits.
14. Any and all third party affidavits.
15. Any and all supplemental discovery requests and responses thereto, including exhibits
attached.
16. Any and all expert discovery request and responses thereto, including exhibits attached.
17. Any and all non-privileged correspondence between Plaintiff and the claimant and/or
counsel for claimant.
18. Any and all non-privileged correspondence between Defendant and claimant and/or
counsel for claimant.
19. Any and all non-privileged written/electronic correspondence between the parties and/or
counsel for said parties.
20. Any and all Motions filed by either party in the instant action.
21. Any and all pleadings filed by either party in the instant action.
22. Any and all Notices filed by either party in the instant action.
23. Any and all Stipulations filed by the parties in the instant action.
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24. Any and all notices of service of Proposal for Settlements.
25. A copy of the policy declarations pages for the named insured regarding the underlying
claim (at issue in this lawsuit).
26. A copy of the insurance policy, including any and all endorsements/amendments for the
named insured in effect regarding this claim (at issue in this lawsuit).
27. Plaintiff’s complete Medical file including and all medical records regarding the claimant,
for any and all treatment allegedly rendered. This includes but is not limited to: medical
bills, patient ledgers, patient intake forms, diagnostic reports and results, histories patient
questionnaires, reports, radiographic films (x-rays, x-ray copies, x-ray positive, CT, MRI,
bone scan), radiographic reports, printouts, correspondence, clinical charts, folders, and
supplemental files and folders.
28. A copy of all medical records and medical bills for any and all medical providers (including
but not limited to hospital, outpatient, clinic, therapy, nursing, medical, chiropractic,
massage, consultations) that rendered treatment to Lisa M Williamson regarding this claim.
Said records include but are not limited to: medical bills, patient ledgers, patient intake
forms, diagnostic reports and results, histories patient questionnaires, reports, radiographic
films (x-rays, x-ray copies, x-ray positive, CT, MRI, bone scan), radiographic reports,
printouts, correspondence, clinical charts, folders, and supplemental files and folders.
29. A copy of any and all Health Insurance Claim (CMS 1500) Forms and Billing Ledgers
from Plaintiff.
30. A copy of any and all Health Insurance Claim (CMS 1500) Forms and Billing Ledgers
from any and all medical providers that rendered treatment in this claim.
31. A copy of any and all x-rays, MRI’s diagnostic reports for Lisa M Williamson regarding
this claim.
32. A copy of any and all medical reports for Lisa M Williamson. Said reports include but not
limited to: initial office visit reports, follow up office visit reports, final office visit reports,
emergency medical visit reports, consultation reports, diagnostic reports and reading
reports, impairment rating reports, reports regarding reasonableness, relatedness and
medical necessity, expert reports, witness reports, and/or rebuttal reports.
33. Any and all Explanation of Benefits Forms for this claim.
34. Any and all drafts/checks and/or payments issued to Plaintiff regarding this Personal Injury
Protection claim.
35. A copy of any and all cashed/endorsed checks related to this Personal Injury Protection
claim.
36. A copy of the Medical Payment Details (PIP Log)
37. If applicable, a copy of any Wage Loss Details Page.
38. A copy of Plaintiff’s Pre-Suit Demand Letter(s), including any and all attachments thereto.
39. A copy of any and all responses to Plaintiff’s Pre-Suit Demand Letter(s), including any and
all attachments thereto.
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40. A copy of Plaintiff’s Assignment of Benefits Forms.
41. Any and all Assignment of Benefits forms for the insured/assignor to his/her medical
providers relating to this claim.
42. A copy of any and all proof of mailing, envelopes, fax confirmation pages, e-service email
receipts for any and all documents, pleadings, correspondence, emails in this claim.
43. Any and all records of e-service and/or e-filing.
44. A copy of any and all documentation reflecting ownership and officer information for
Plaintiff’s facility.
45. A copy of any and all licenses, accreditations, certificates, certifications and reports for
Plaintiff’s facility.
46. A copy of any and all licenses, accreditations, certificates, certifications and reports for
any/all medical providers that rendered treatment to claimant on behalf of Plaintiff.
47. A copy of any and all licenses, accreditations, certificates, certifications for any/all medical
providers that rendered treatment to claimant.
48. A copy of any and all website pages and/or advertisements for Plaintiff’s facility, including
but not limited, insurance accepted, services offered, location, employees, officers,
payment plans.
49. Any and all applicable Florida Statutes.
50. A copy of any and all manuals, reports, and/or publications regarding the applicable Florida
Statutes.
51. Any and all Staff Analyses pertaining to amendments made to applicable Florida Statues.
52. A copy of the Florida No-Fault Statute Section 627.736 and any and all manuals, reports,
publications, case law pertaining to Section 627.736.
53. Any and all Case law, Regulations, and/or Ordinances, memorandums, reports relied upon
by either party.
54. Any and all applicable State and Federal Fee Schedules from the Center for Medicare and
Medicaid Services, including but not limited to manuals, publications, reports.
55. Any and all applicable Medicare Payment Methodologies from the Center for Medicare
and Medicaid Services, including but not limited to manuals, publications, reports.
56. Any and all evidence of the charges by Plaintiff and payments accepted by Plaintiff by
other insurance carriers regarding Personal Injury Protection claims, including but not
limited to: GEICO, Allstate, Infinity, Esurance, Mercury, USAA, United Auto, Kingsway,
State Farm.
57. Any and all evidence of PPO, HMO or other in network insurance plains the Plaintiff has
with other insurance carriers.
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58. The reimbursement rate for the determination of reasonableness of the charges at issue in
this matter utilized by Plaintiff.
59. Any and all evidence of usual and customary charges and payments accepted by the
provider or similar providers, including discounts to different classes of patients, or payors,
the clinic internal cost structure, and what the provider or other providers in the industry
accepts as payment from personal injury protection insurers and non-personal injury
protection insurers.
60. Any and all admissible evidence of reimbursement levels in the community applicable to
automobile and other insurance coverages.
61. Any and all documents showing Plaintiff’s overhead and/or practice expenses during the
time treatment was allegedly rendered to this claimant.
62. Any and all expert reports, including but not limited to, any reports, records, data, exhibits,
and/or documents reviewed, prepared or relied upon by said experts.
63. Curriculum Vitae/Resume of any witnesses retained or called by any party.
64. Curriculum Vitae of any expert witness retained or called by any party.
65. Any and all papers, writings, articles and publications of those listed as witnesses on the
witness list by any party.
66. Any and all demonstrative aids to assist witnesses in testifying in this action. Defendant
reserves the right to enlarge any exhibit
67. Any and all graphs, charts, mock-up drawings, graphic representations to assist witnesses
in testifying or either parties opening/closing statements, arguments.
68. Any and all demonstrative aids to assist either party and/or counsel for either party
pertaining to this action.
69. Any and all accident reports.
70. Any and all emergency medical and transportation reports for this accident.
71. Any and all video tape/films and still photos taken by, of or for Plaintiff.
72. Any and all impeachment and/or rebuttal exhibits.
73. Any and all exhibits listed by any other party to this action, including but not limited to
Plaintiff and/or any Third Party Witnesses.
74. Defendant reserves the right to amend and/or supplement this exhibit list in accordance
with the Pre-Trial Order as discovery is still ongoing at this time.
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Preview
Filing # 170390185 E-Filed 04/05/2023 11:57:08 AM IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GRAPPIN CLINIC OF CHIROPRACTIC, CASE NO: 2022-014501 SP 26 (05) P.A. A/A/O LISA WILLIAMSON, CIVIL DIVISION Plaintiff, Vs. PROGRESSIVE SELECT INSURANCE COMPANY, Defendant. ___________________________________/ DEFENDANT’S NOTICE OF FILING WITNESS AND EXHIBIT LIST COMES NOW, the Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, by and through the undersigned attorney, hereby gives Notice of Filing Witness and Exhibit List in Compliance with this Honorable Court’s Case Management Order. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished via E-Mail on April 5, 2023 to Gregory J. Blackburn, Esq., Reifkind, Thompson & Rudzinski, LLP, Attorney for Plaintiff, Grappin Clinic of Chiropractic, P.A., a/a/o Lisa Williamson, PipService@rtrlaw.com;pipscheduling@rtrlaw.com, (954) 370-5152/(954) 370-1992 (F). Progressive PIP House Counsel Attorneys for Defendant 9675 NW 117 Avenue Suite 200 Medley, FL 33178 (305) 423-3890 (Asst.)/(305) 908-8441 (Direct) Fax: (305) 887-2781 SERVICE DESIGNATIONS: Primary: FLPIPHC-Miami@progressive.com Secondary Andres_Millon@progressive.com By: Andres Millon__________________ ANDRES MILLON, ESQUIRE Florida Bar No. 112649 “Salaried Employees of Progressive Casualty Insurance Company” 217791267 Filed 02/15/2024 04:40 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL DEFENDANT WITNESS LIST 1. Lisa M Williamson, claimant/patient/named insured. 2. Tony Bolado, Litigation Adjuster and Current Records Custodian of the Personal Injury Protection File for this claim. 3. The Corporate Representative for Defendant if not already listed herein. 4. Any representatives on behalf of Defendant determined to be fact witness as a result of ongoing discovery in the instant matter. 5. Any representatives on behalf of Plaintiff determined to be fact witness as a result of ongoing discovery in the instant matter. 6. The corporate representative for Plaintiff. 7. The owner of Plaintiff company. 8. Any and all corporate officers of Plaintiff. 9. The medical director (if applicable) for Plaintiff. 10. Any and all medical providers who rendered treatment to the claimant on behalf of Plaintiff’s Facility (whether or not direct employees of Plaintiff’s facility) 11. Any and all individuals from Plaintiff’s facility who have knowledge regarding treatment rendered to the claimant. 12. Any and all individuals from Plaintiff who had any involvement regarding the billing and handled/accepted payment on behalf of Plaintiff regarding the claim for the insured/claimant (at issue in this lawsuit). 13. Any and all individuals from Plaintiff who handled the patient intake for claimant. (i.e. front desk employees, employees assist with patient intake/insurance verification, patient initial paperwork). 14. Any and all individuals who authored any affidavits filed in this matter. 15. Any and all individuals who provided deposition testimony. 16. Any and all individuals mentioned in depositions as having involvement in this claim. 17. Any and all individuals referenced in response to any and all discovery served/filed in this matter. 18. Any and all individuals who answered any discovery in this matter. 19. Any and all individuals who signed jurat pages/verified interrogatory responses in this matter. 20. Plaintiff’s records custodian(s). 2 217791267 21. Records custodians for Plaintiff’s witnesses. 22. Any and all records custodian(s) for any and all medical providers that rendered treatment. 23. Defendant records custodians(s). 24. Records custodians for Defendant’s witnesses. 25. Any and all records custodians from all expert witness facilities. 26. Records custodians for third party witnesses. 27. Any and all other medical providers that provided treatment to Lisa M Williamson. 28. Any and all witnesses to the subject accident. 29. Any and all witnesses listed on the police report. 30. Any and all investigating offices at the scene of the accident. 31. Any and all fact witnesses as determined through ongoing discovery in the instant action. 32. Any and all impeachment or rebuttal witnesses. 33. Any and all witnesses listed on Plaintiff’s Witness List. 34. Any and all third party witnesses. 35. Any and all expert witnesses. 36. Any and all expert witnesses for Plaintiff. 37. Any and all expert witnesses for other parties/including but not limited to third parties. 38. Any and all experts listed on any other party’s Expert Witness List. 39. Defendant has not yet retained an expert as discovery is still ongoing, Defendant asserts that this case involves legal issues which may be resolved via Motion for Summary Judgment. If/when Defendant retains an expert witness, Defendant, will file an Expert Witness list in accordance with the Pre-Trial Order. 40. Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, reserves the right to amend/supplement this Witness List in accordance with the Pre-Trial Order as further discovery is conducted. 3 217791267 DEFENDANT'S EXHIBIT LIST 1. Plaintiff’s Complaint, including any and all amended Complaint(s) if applicable, including any and all attachments to said Complaint and/or Amended Complaint(s). 2. Defendant’s Answer and Affirmative Defenses, including any and all amended Answers and Affirmative Defenses, if applicable. 3. Any and all documents to support Defendant’s Answer and Affirmative Defenses. 4. Any and all requests for admissions and responses thereto. 5. Any and all interrogatory questions and answers thereto. 6. Any and all jurat pages filed. 7. Any and all requests for production and responses thereto, including all exhibits attached thereto. 8. Any and all depositions transcripts and/or video tape depositions (if applicable) taken in this case. 9. Any and all responses to subpoenas which were directed to parties and/or non-parties. 10. Any and all documents produced in response to subpoena duces tecum(s) in this case. 11. Any and all affidavits filed by the Plaintiff. 12. Any and all affidavits filed by the Defendant. 13. Any and all records custodian affidavits. 14. Any and all third party affidavits. 15. Any and all supplemental discovery requests and responses thereto, including exhibits attached. 16. Any and all expert discovery request and responses thereto, including exhibits attached. 17. Any and all non-privileged correspondence between Plaintiff and the claimant and/or counsel for claimant. 18. Any and all non-privileged correspondence between Defendant and claimant and/or counsel for claimant. 19. Any and all non-privileged written/electronic correspondence between the parties and/or counsel for said parties. 20. Any and all Motions filed by either party in the instant action. 21. Any and all pleadings filed by either party in the instant action. 22. Any and all Notices filed by either party in the instant action. 23. Any and all Stipulations filed by the parties in the instant action. 4 217791267 24. Any and all notices of service of Proposal for Settlements. 25. A copy of the policy declarations pages for the named insured regarding the underlying claim (at issue in this lawsuit). 26. A copy of the insurance policy, including any and all endorsements/amendments for the named insured in effect regarding this claim (at issue in this lawsuit). 27. Plaintiff’s complete Medical file including and all medical records regarding the claimant, for any and all treatment allegedly rendered. This includes but is not limited to: medical bills, patient ledgers, patient intake forms, diagnostic reports and results, histories patient questionnaires, reports, radiographic films (x-rays, x-ray copies, x-ray positive, CT, MRI, bone scan), radiographic reports, printouts, correspondence, clinical charts, folders, and supplemental files and folders. 28. A copy of all medical records and medical bills for any and all medical providers (including but not limited to hospital, outpatient, clinic, therapy, nursing, medical, chiropractic, massage, consultations) that rendered treatment to Lisa M Williamson regarding this claim. Said records include but are not limited to: medical bills, patient ledgers, patient intake forms, diagnostic reports and results, histories patient questionnaires, reports, radiographic films (x-rays, x-ray copies, x-ray positive, CT, MRI, bone scan), radiographic reports, printouts, correspondence, clinical charts, folders, and supplemental files and folders. 29. A copy of any and all Health Insurance Claim (CMS 1500) Forms and Billing Ledgers from Plaintiff. 30. A copy of any and all Health Insurance Claim (CMS 1500) Forms and Billing Ledgers from any and all medical providers that rendered treatment in this claim. 31. A copy of any and all x-rays, MRI’s diagnostic reports for Lisa M Williamson regarding this claim. 32. A copy of any and all medical reports for Lisa M Williamson. Said reports include but not limited to: initial office visit reports, follow up office visit reports, final office visit reports, emergency medical visit reports, consultation reports, diagnostic reports and reading reports, impairment rating reports, reports regarding reasonableness, relatedness and medical necessity, expert reports, witness reports, and/or rebuttal reports. 33. Any and all Explanation of Benefits Forms for this claim. 34. Any and all drafts/checks and/or payments issued to Plaintiff regarding this Personal Injury Protection claim. 35. A copy of any and all cashed/endorsed checks related to this Personal Injury Protection claim. 36. A copy of the Medical Payment Details (PIP Log) 37. If applicable, a copy of any Wage Loss Details Page. 38. A copy of Plaintiff’s Pre-Suit Demand Letter(s), including any and all attachments thereto. 39. A copy of any and all responses to Plaintiff’s Pre-Suit Demand Letter(s), including any and all attachments thereto. 5 217791267 40. A copy of Plaintiff’s Assignment of Benefits Forms. 41. Any and all Assignment of Benefits forms for the insured/assignor to his/her medical providers relating to this claim. 42. A copy of any and all proof of mailing, envelopes, fax confirmation pages, e-service email receipts for any and all documents, pleadings, correspondence, emails in this claim. 43. Any and all records of e-service and/or e-filing. 44. A copy of any and all documentation reflecting ownership and officer information for Plaintiff’s facility. 45. A copy of any and all licenses, accreditations, certificates, certifications and reports for Plaintiff’s facility. 46. A copy of any and all licenses, accreditations, certificates, certifications and reports for any/all medical providers that rendered treatment to claimant on behalf of Plaintiff. 47. A copy of any and all licenses, accreditations, certificates, certifications for any/all medical providers that rendered treatment to claimant. 48. A copy of any and all website pages and/or advertisements for Plaintiff’s facility, including but not limited, insurance accepted, services offered, location, employees, officers, payment plans. 49. Any and all applicable Florida Statutes. 50. A copy of any and all manuals, reports, and/or publications regarding the applicable Florida Statutes. 51. Any and all Staff Analyses pertaining to amendments made to applicable Florida Statues. 52. A copy of the Florida No-Fault Statute Section 627.736 and any and all manuals, reports, publications, case law pertaining to Section 627.736. 53. Any and all Case law, Regulations, and/or Ordinances, memorandums, reports relied upon by either party. 54. Any and all applicable State and Federal Fee Schedules from the Center for Medicare and Medicaid Services, including but not limited to manuals, publications, reports. 55. Any and all applicable Medicare Payment Methodologies from the Center for Medicare and Medicaid Services, including but not limited to manuals, publications, reports. 56. Any and all evidence of the charges by Plaintiff and payments accepted by Plaintiff by other insurance carriers regarding Personal Injury Protection claims, including but not limited to: GEICO, Allstate, Infinity, Esurance, Mercury, USAA, United Auto, Kingsway, State Farm. 57. Any and all evidence of PPO, HMO or other in network insurance plains the Plaintiff has with other insurance carriers. 6 217791267 58. The reimbursement rate for the determination of reasonableness of the charges at issue in this matter utilized by Plaintiff. 59. Any and all evidence of usual and customary charges and payments accepted by the provider or similar providers, including discounts to different classes of patients, or payors, the clinic internal cost structure, and what the provider or other providers in the industry accepts as payment from personal injury protection insurers and non-personal injury protection insurers. 60. Any and all admissible evidence of reimbursement levels in the community applicable to automobile and other insurance coverages. 61. Any and all documents showing Plaintiff’s overhead and/or practice expenses during the time treatment was allegedly rendered to this claimant. 62. Any and all expert reports, including but not limited to, any reports, records, data, exhibits, and/or documents reviewed, prepared or relied upon by said experts. 63. Curriculum Vitae/Resume of any witnesses retained or called by any party. 64. Curriculum Vitae of any expert witness retained or called by any party. 65. Any and all papers, writings, articles and publications of those listed as witnesses on the witness list by any party. 66. Any and all demonstrative aids to assist witnesses in testifying in this action. Defendant reserves the right to enlarge any exhibit 67. Any and all graphs, charts, mock-up drawings, graphic representations to assist witnesses in testifying or either parties opening/closing statements, arguments. 68. Any and all demonstrative aids to assist either party and/or counsel for either party pertaining to this action. 69. Any and all accident reports. 70. Any and all emergency medical and transportation reports for this accident. 71. Any and all video tape/films and still photos taken by, of or for Plaintiff. 72. Any and all impeachment and/or rebuttal exhibits. 73. Any and all exhibits listed by any other party to this action, including but not limited to Plaintiff and/or any Third Party Witnesses. 74. Defendant reserves the right to amend and/or supplement this exhibit list in accordance with the Pre-Trial Order as discovery is still ongoing at this time. 7 217791267