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CAUSE NO. 2014-38326
IRMA SANTIBANEZ A/N/F OF IN THE DISTRICT COURT
NATHAN SANTIBANEZ, A MINOR
Vv. HARRIS COUNTY, TEXAS
WITTE OAKS APARTMENTS; WITTE
OAKS APARTMENTS, LLC D/B/A
WITTE OAKS APARTMENTS; MPM
MANAGEMENT, LLC; 1608 WELCH
AND BYRNE, LLC 2818" JUDICIAL DISTRICT
DEFENDANTS’ DESIGNATION OF EXPERT WITNESSES
NOW COMES Defendants Witte Oaks Apartments, Witte Oaks Apartments, LLC d/b/a
Witte Oaks Apartments and MPM Management, LLC, and pursuant to this Court’s ruling, files
this Designation of Expert Witnesses. Said designation is as follows:
I, NON-RETAINED EXPERTS
The following treating physicians have been designated by Defendants in this litigation:
Dr. Maryan Tabhadosi, M.D.
1213 Hermann Drive, Suite 770
Houston, Texas 77004
(713) 807-8921
Healthcare Provider
This expert is a non-retained expert that will provide testimony regarding
Plaintiff's injuries, if any, sustained as a result of the incident made the basis of
this lawsuit, and any treatment necessitated as a result of such injuries. The
medical records produced by Plaintiff will reflect the opinions of this expert.
Dr. Holly Annette Owens
Memorial Hermann Hospital
Medical Center
6411 Fannin Street
Houston, Texas 77030
(713) 704-4000
Healthcare Provider
This expert is a non-retained expert that will provide testimony regarding
Plaintiff's injuries, if any, sustained as a result of the incident made the basis of
this lawsuit, and any treatment necessitated as a result of such injuries. The
medical records produced by Plaintiff will reflect the opinions of this expert.
Dr. Michelle D. Holick, M.D.
Texas Children's Hospital
6621 Fannin Street
Houston, TX 77030
(832) 824-1000
Healthcare Provider
This expert is a non-retained expert that will provide testimony regarding
Plaintiffs injuries, if any, sustained as a result of the incident made the basis of
this lawsuit, and any treatment necessitated as a result of such injuries. The
medical records produced by Plaintiff will reflect the opinions of this expert.
ACS Primary Care Physicians
Dr. Holly Owens
P.O. Box 636018
Cincinnati, OH 34263
(888) 952-6772
Healthcare Provider
This expert is a non-retained expert that will provide testimony regarding
Plaintiff's injuries, if any, sustained as a result of the incident made the basis of
this lawsuit, and any treatment necessitated as a result of such injuries. The
medical records produced by Plaintiff will reflect the opinions of this expert.
Dr. Djamchid Lotfi, M.D.
United Neurology
2321 Southwest Freeway
Houston, Texas 77098
(713) 533-1250
Healthcare Provider
This expert is a non-retained expert that will provide testimony regarding
Plaintiff's injuries, if any, sustained as a result of the incident made the basis of
this lawsuit, and any treatment necessitated as a result of such injuries. The
medical records produced by Plaintiff will reflect the opinions of this expert.
Defendants reserve the right to supplement this designation further within the time
limitations imposed by the Court and/or by any alterations of same by subsequent Court Order
and/or by agreement of the parties pursuant to the Texas Rules of Civil Procedure and/or the
Texas Rules of Evidence.
il.
Defendants reserve the right to withdraw the designation of any expert witness and to
aver positively that such previously designated expert will not be called as an expert witness at
trial and to re-designate same as a consulting expert, who cannot be called by opposing
counsel.
Il.
Defendants reserve the right to elicit the opinion testimony of experts designated and
called by other parties to this suit.
Iv.
Defendants reserve the right to elicit technical or other specialized knowledge or expert
opinion testimony, through direct or cross-examination, from the potential fact witnesses,
based on the witness’ knowledge, skill, experience, training or education, and concerning the
subject of the witness’s personal knowledge and involvement in the matters at issue, including
but not limited to individuals retained by, employed by and/or working on behalf of any other
party to this suit, whether past or present.
Respectfully Submitted,
Cozen O’Connor, LLP
By: /s/ Tammy Wavle Shea
Tammy Wavle Shea
State Bar No. 24008908
1221 McKinney Street, Suite 2900
Houston, Texas 77002
Tel: (713) 750-3148
Fax (832) 214-3905
Email: tshea@cozen.com
ATTORNEYS FOR DEFENDANTS
WITTE OAKS APARTMENTS, WITTE OAKS
APARTMENTS, LLC D/B/A WITTE OAKS
APARTMENTS AND MPM MANAGEMENT,
LLC
CERTIFICATE OF SERVICE
This pleading was served in compliance with Rules 21 and 21a of the Texas Rules of
Civil Procedure on March 16, 2015, to the following counsel:
Allison H. Gabbert Jason L. Fowell
Godsey Martin, PC 1298 N. Post Oak Road
2550 North Loop West, Suite 102 Houston, Texas 77055
Houston, Texas 77092 Telephone: 832.581.3399
Telephone: 713.446.8448 Facsimile: 713.623.6300
Facsimile: 713.581.8700 Jason@pbplle.com
agabbert@gmfirm.com
Attorneys for Plaintiff Irma Santibanez a/n/f of
Nathan Santibanez, A Minor
/s/ Tammy Wavle Shea
Tammy Wavle Shea
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CAUSE NO. 2014-38326 IRMA SANTIBANEZ A/N/F OF IN THE DISTRICT COURT NATHAN SANTIBANEZ, A MINOR Vv. HARRIS COUNTY, TEXAS WITTE OAKS APARTMENTS; WITTE OAKS APARTMENTS, LLC D/B/A WITTE OAKS APARTMENTS; MPM MANAGEMENT, LLC; 1608 WELCH AND BYRNE, LLC 2818" JUDICIAL DISTRICT DEFENDANTS’ DESIGNATION OF EXPERT WITNESSES NOW COMES Defendants Witte Oaks Apartments, Witte Oaks Apartments, LLC d/b/a Witte Oaks Apartments and MPM Management, LLC, and pursuant to this Court’s ruling, files this Designation of Expert Witnesses. Said designation is as follows: I, NON-RETAINED EXPERTS The following treating physicians have been designated by Defendants in this litigation: Dr. Maryan Tabhadosi, M.D. 1213 Hermann Drive, Suite 770 Houston, Texas 77004 (713) 807-8921 Healthcare Provider This expert is a non-retained expert that will provide testimony regarding Plaintiff's injuries, if any, sustained as a result of the incident made the basis of this lawsuit, and any treatment necessitated as a result of such injuries. The medical records produced by Plaintiff will reflect the opinions of this expert. Dr. Holly Annette Owens Memorial Hermann Hospital Medical Center 6411 Fannin Street Houston, Texas 77030 (713) 704-4000 Healthcare Provider This expert is a non-retained expert that will provide testimony regarding Plaintiff's injuries, if any, sustained as a result of the incident made the basis of this lawsuit, and any treatment necessitated as a result of such injuries. The medical records produced by Plaintiff will reflect the opinions of this expert. Dr. Michelle D. Holick, M.D. Texas Children's Hospital 6621 Fannin Street Houston, TX 77030 (832) 824-1000 Healthcare Provider This expert is a non-retained expert that will provide testimony regarding Plaintiffs injuries, if any, sustained as a result of the incident made the basis of this lawsuit, and any treatment necessitated as a result of such injuries. The medical records produced by Plaintiff will reflect the opinions of this expert. ACS Primary Care Physicians Dr. Holly Owens P.O. Box 636018 Cincinnati, OH 34263 (888) 952-6772 Healthcare Provider This expert is a non-retained expert that will provide testimony regarding Plaintiff's injuries, if any, sustained as a result of the incident made the basis of this lawsuit, and any treatment necessitated as a result of such injuries. The medical records produced by Plaintiff will reflect the opinions of this expert. Dr. Djamchid Lotfi, M.D. United Neurology 2321 Southwest Freeway Houston, Texas 77098 (713) 533-1250 Healthcare Provider This expert is a non-retained expert that will provide testimony regarding Plaintiff's injuries, if any, sustained as a result of the incident made the basis of this lawsuit, and any treatment necessitated as a result of such injuries. The medical records produced by Plaintiff will reflect the opinions of this expert. Defendants reserve the right to supplement this designation further within the time limitations imposed by the Court and/or by any alterations of same by subsequent Court Order and/or by agreement of the parties pursuant to the Texas Rules of Civil Procedure and/or the Texas Rules of Evidence. il. Defendants reserve the right to withdraw the designation of any expert witness and to aver positively that such previously designated expert will not be called as an expert witness at trial and to re-designate same as a consulting expert, who cannot be called by opposing counsel. Il. Defendants reserve the right to elicit the opinion testimony of experts designated and called by other parties to this suit. Iv. Defendants reserve the right to elicit technical or other specialized knowledge or expert opinion testimony, through direct or cross-examination, from the potential fact witnesses, based on the witness’ knowledge, skill, experience, training or education, and concerning the subject of the witness’s personal knowledge and involvement in the matters at issue, including but not limited to individuals retained by, employed by and/or working on behalf of any other party to this suit, whether past or present. Respectfully Submitted, Cozen O’Connor, LLP By: /s/ Tammy Wavle Shea Tammy Wavle Shea State Bar No. 24008908 1221 McKinney Street, Suite 2900 Houston, Texas 77002 Tel: (713) 750-3148 Fax (832) 214-3905 Email: tshea@cozen.com ATTORNEYS FOR DEFENDANTS WITTE OAKS APARTMENTS, WITTE OAKS APARTMENTS, LLC D/B/A WITTE OAKS APARTMENTS AND MPM MANAGEMENT, LLC CERTIFICATE OF SERVICE This pleading was served in compliance with Rules 21 and 21a of the Texas Rules of Civil Procedure on March 16, 2015, to the following counsel: Allison H. Gabbert Jason L. Fowell Godsey Martin, PC 1298 N. Post Oak Road 2550 North Loop West, Suite 102 Houston, Texas 77055 Houston, Texas 77092 Telephone: 832.581.3399 Telephone: 713.446.8448 Facsimile: 713.623.6300 Facsimile: 713.581.8700 Jason@pbplle.com agabbert@gmfirm.com Attorneys for Plaintiff Irma Santibanez a/n/f of Nathan Santibanez, A Minor /s/ Tammy Wavle Shea Tammy Wavle Shea