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Filing # 194472368 E-Filed 03/20/2024 05:33:18 PM
IN THE CIRCUIT COURT OF THE
20TH JUDICIAL CIRCUIT IN AND
FOR CHARLOTTE COUNTY,
FLORIDA
CASE NO.: 23000551CA
STEPHANIE STABRYLLA,
Plaintiff,
vs.
ELIZABETH WHITKOPF and
SAFECO INSURANCE COMPANY
OF ILLINOIS,
Defendants.
/
DEFENDANTS’ WITNESS LIST
COMES NOW, the Defendant, ELIZABETH WHITKOPF, by and through the
undersigned counsel and in accordance with this Court’s Trial Order, and discloses
the following witnesses expected to testify at the trial of this matter:
1 All parties to this action.
2 Any and all physicians, medical doctors, osteopaths, chiropractors,
nurses, therapists, ambulance personnel or health care providers of any
type that have treated, examined, or evaluated the Plaintiff for the
injuries alleged as a result of this accident.
Any and all physicians, medical doctors, osteopaths, chiropractors,
nurses, therapists, ambulance personnel or health care providers of any
type that have treated, examined, or evaluated the Plaintiff in the past.
All treating, examining, court-appointed and PIP medical personnel who
have seen the Plaintiff at any time.
All medical record custodians of any other facility who examined or
rendered care or treatment to the Plaintiff.
CASE NO.: 23000551CA
All witnesses, owners, drivers, and passengers listed on the police
report.
All witnesses listed by all other parties.
All fact and expert witnesses listed by Plaintiff.
All investigating police officers and records custodian of the accident on
September 29, 2022, including but not limited to:
Record Custodian of Charlotte County Sheriff's Office
10 Dr. John Cassidy Neurosurgeon
Neurosurgical Associates
Cassidy & Guerin, M.D., P.A.
842 Sunset Lake Blvd., Ste. 302
Venice, FL 34292
11 Dr. Michael Foley Radiologist
101 E. Kennedy Blvd.
Suite 3900
Tampa, FL 33602
12 All employers of the Plaintiff, including supervisors, co-workers, and
records custodians.
13. All persons mentioned in depositions, interrogatory answers, and
responses to requests for production.
14 All impeachment and/or rebuttal witnesses.
15 All records custodians of hospitals, medical offices and/or health care
providers as follows:
1 Representatives of all sources of collateral insurance payments
2. Representative of Center for Physical Medicine
Representative of Allstate Insurance Company
Representative of SimonMed Imaging
CASE NO.: 23000551CA
Representative of Radiology Associates of Venice
Representative of Lee Anton, MD
Representative of Tonya Ditrapani-Stephenson, MD
Representative of Sakina Nasir Khalidi, MD
9 Representative of Blue Cross and Blue Sheild of Florida, Inc.
10. Representative of Cigna Health and Life Insurance Company
11.Representative of Advanced Orthopedic Center, Port Charlotte —
Medical, Billing, Radiology
12. Representative of CVS Pharmacy
13. Representative of Express Cannabis Cards
14. Representative of Millennium Physicians Group
15. Representative of Sarasota Memorial Hospital — Medical, Billing
16. Representative of Natalie Iverson, APRN
17. Representative of Safeco Insurance Company of Illinois
18. Representative of Aveanna Home Health/Human Resources
19. Representative of Florida Cancer Specialists/Human Resources
20.Representative of Douglas T. Jacobson State Veterans’ Nursing
Home/Human Resources
21. Representative of Right At Home/Human Resources
16 Defendant reserves the right to amend this Witness List.
17 All objections to Plaintiffs exhibits and witnesses are preserved.
CASE NO.: 23000551CA
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished by email
to: FRANK P. _ DiPLACIDO, II, ESQ., Attorney for Plaintiff, at:
fdiplacido@forthepeople.com and morganservice@forthepeople.com, on this 20"
day of March , 2024.
HILL & LEMONGELLO, P.A.
Attorneys for Defendant
800 Southeast 3rd Avenue, Suite 200
Fort Lauderdale, Florida 33316
954-462-3623 - main
954-523-1940 - fax
Joant@hill-lem-law.com - Primary
linag@ hill-lem-law.com
Da @ com -S ndary
ears
\ IEL LEMONGELLO
“FLORIDA BAR# 0027049
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Filing # 194472368 E-Filed 03/20/2024 05:33:18 PM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CASE NO.: 23000551CA STEPHANIE STABRYLLA, Plaintiff, vs. ELIZABETH WHITKOPF and SAFECO INSURANCE COMPANY OF ILLINOIS, Defendants. / DEFENDANTS’ WITNESS LIST COMES NOW, the Defendant, ELIZABETH WHITKOPF, by and through the undersigned counsel and in accordance with this Court’s Trial Order, and discloses the following witnesses expected to testify at the trial of this matter: 1 All parties to this action. 2 Any and all physicians, medical doctors, osteopaths, chiropractors, nurses, therapists, ambulance personnel or health care providers of any type that have treated, examined, or evaluated the Plaintiff for the injuries alleged as a result of this accident. Any and all physicians, medical doctors, osteopaths, chiropractors, nurses, therapists, ambulance personnel or health care providers of any type that have treated, examined, or evaluated the Plaintiff in the past. All treating, examining, court-appointed and PIP medical personnel who have seen the Plaintiff at any time. All medical record custodians of any other facility who examined or rendered care or treatment to the Plaintiff. CASE NO.: 23000551CA All witnesses, owners, drivers, and passengers listed on the police report. All witnesses listed by all other parties. All fact and expert witnesses listed by Plaintiff. All investigating police officers and records custodian of the accident on September 29, 2022, including but not limited to: Record Custodian of Charlotte County Sheriff's Office 10 Dr. John Cassidy Neurosurgeon Neurosurgical Associates Cassidy & Guerin, M.D., P.A. 842 Sunset Lake Blvd., Ste. 302 Venice, FL 34292 11 Dr. Michael Foley Radiologist 101 E. Kennedy Blvd. Suite 3900 Tampa, FL 33602 12 All employers of the Plaintiff, including supervisors, co-workers, and records custodians. 13. All persons mentioned in depositions, interrogatory answers, and responses to requests for production. 14 All impeachment and/or rebuttal witnesses. 15 All records custodians of hospitals, medical offices and/or health care providers as follows: 1 Representatives of all sources of collateral insurance payments 2. Representative of Center for Physical Medicine Representative of Allstate Insurance Company Representative of SimonMed Imaging CASE NO.: 23000551CA Representative of Radiology Associates of Venice Representative of Lee Anton, MD Representative of Tonya Ditrapani-Stephenson, MD Representative of Sakina Nasir Khalidi, MD 9 Representative of Blue Cross and Blue Sheild of Florida, Inc. 10. Representative of Cigna Health and Life Insurance Company 11.Representative of Advanced Orthopedic Center, Port Charlotte — Medical, Billing, Radiology 12. Representative of CVS Pharmacy 13. Representative of Express Cannabis Cards 14. Representative of Millennium Physicians Group 15. Representative of Sarasota Memorial Hospital — Medical, Billing 16. Representative of Natalie Iverson, APRN 17. Representative of Safeco Insurance Company of Illinois 18. Representative of Aveanna Home Health/Human Resources 19. Representative of Florida Cancer Specialists/Human Resources 20.Representative of Douglas T. Jacobson State Veterans’ Nursing Home/Human Resources 21. Representative of Right At Home/Human Resources 16 Defendant reserves the right to amend this Witness List. 17 All objections to Plaintiffs exhibits and witnesses are preserved. CASE NO.: 23000551CA CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished by email to: FRANK P. _ DiPLACIDO, II, ESQ., Attorney for Plaintiff, at: fdiplacido@forthepeople.com and morganservice@forthepeople.com, on this 20" day of March , 2024. HILL & LEMONGELLO, P.A. Attorneys for Defendant 800 Southeast 3rd Avenue, Suite 200 Fort Lauderdale, Florida 33316 954-462-3623 - main 954-523-1940 - fax Joant@hill-lem-law.com - Primary linag@ hill-lem-law.com Da @ com -S ndary ears \ IEL LEMONGELLO “FLORIDA BAR# 0027049