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Filing # 189460875 E-Filed 01/10/2024 11:18:42 AM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR
OSCEOLA COUNTY, FLORIDA
CASE NO.: 2020 CA 002872 AN
ASBEL ALEXANDER LLERENA,
Plaintiff,
v.
ADRIAN RODRIGUEZ CHAVEZ AND
GRANNY'S GARDEN II, INC.,
Defendants.
_______________________________/
NOTICE OF SERVICE OF DEFENDANT’S SECOND SET OF
EXPERT INTERROGATORIES TO PLAINTIFF
COMES NOW Defendant, ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S
GARDEN II, INC., by and through their undersigned counsel, and hereby notifies this
Court and counsel of record that it has served the attached Second Set of Expert
Interrogatories upon ASBEL ALEXANDER LLERENA to be answered under oath in
writing within thirty (30) days, in accordance with the Florida Rules of Civil Procedure.
[CERTIFICATE OF SERVICE ON NEXT PAGE]
Page 1
COLE, SCOTT & KISSANE, P.A.
CASE NO.: 2020 CA 002872 AN
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of January, 2024, 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-
6990/(407) 452-1597 (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
0487.2384-00
Page 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.: 2020 CA 002872 AN
DEFENDANTS SECOND SET OF EXPERT INTERROGATORIES TO PLAINTIFF,
ASBEL ALEXANDER LLERENA
1. Please state the name and professional address for each expert witness you
expect to testify at trial in this cause as identified in the Amended Expert Witness
list. For each expert state the scope of employment in the pending case and the
compensation for such service.
RESPONSE:
2. For each expert listed in Plaintiff’s Amended Expert Witness List, please state the
expert’s general litigation experience, including the percentage of work performed
for Plaintiffs and Defendants.
RESPONSE:
3. For each expert listed in Plaintiff’s Amended Expert Witness List, please state the
identity of other cases, within the last three (3) years, in which the expert has
testified by deposition or at trial.
RESPONSE:
4. For each expert listed in Plaintiff’s Amended Expert Witness List, please give an
approximation of the portion of the expert’s involvement as an expert witness,
which may be based on the number of hours, percentage of hours, or percentage
of earned income derived from serving as an expert witness.
RESPONSE:
5. For each expert listed in Plaintiff’s Amended Expert Witness List please state the
number of times that each expert’s deposition was taken in the preceding calendar
year when the expert was:
(a) The treating physician;
(b) The defense physician and/or independent medical examiner;
(c) Other.
RESPONSE:
6. For each expert listed in Plaintiff’s Amended Expert Witness List, please state the
number of times each expert appeared in Court to testify within the last calendar
year. Please include times, and where the expert was called to testify in more
Page 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.: 2020 CA 002872 AN
than one courtroom on a particular date, counting each time as a separate Court
appearance.
RESPONSE:
7. For each Court appearance listed in Interrogatory No.6 above, please state the
number of times the expert was called to testify:
(a) By Plaintiffs’ attorney as a treating physician;
(b) By Plaintiffs’ attorney as the defense examiner;
(c) By Defendants’ attorney as a defense examiner;
(d) By Defendants’ attorney as a treating or consulting physician.
RESPONSE:
8. For each expert listed in Plaintiff’s Amended Expert Witness List, state his/her
background, education, and experience which qualifies him/her to testify as an
expert.
RESPONSE:
9. Give the name or title of each paper which each expert has authored in the area
of his/her expertise.
RESPONSE:
10. State the name, volume and page number of the publication in which each article
or paper listed above can be found.
RESPONSE:
11. State the substance of the facts to which each expert listed above is expected to
testify.
RESPONSE:
12. State the opinion to which each expert listed above is expected to testify.
RESPONSE:
13. Give a summary of grounds or basis for each opinion stated above.
Page 4
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.: 2020 CA 002872 AN
RESPONSE:
14. Any and all monies paid to all experts listed within Plaintiff’s Amended Expert
Witness Disclosure by Morgan & Morgan (All Offices).
RESPONSE:
15. Any and all monies paid to all experts listed within Plaintiff’s Amended Expert
Witness Disclosure by Morgan & Morgan (All Offices) in the past three years.
RESPONSE:
Page 5
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.: 2020 CA 002872 AN
VERIFICATION
_________________, being duly sworn, deposes and says that the attached
answers to Defendant’s Expert Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
______________________________
ASBEL ALEXANDER LLERENA
STATE OF ________________
COUNTY OF ______________
Sworn to and subscribed before me by means of physical presence or online
notarization, this _____ day of ________, 2023, who is personally known to me or who
has produced _________________________as identification.
________________________________
NOTARY PUBLIC, State of __________
My Commission Expires: ____________
Page 6
COLE, SCOTT & KISSANE, P.A.
TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX
Preview
Filing # 189460875 E-Filed 01/10/2024 11:18:42 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO.: 2020 CA 002872 AN ASBEL ALEXANDER LLERENA, Plaintiff, v. ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC., Defendants. _______________________________/ NOTICE OF SERVICE OF DEFENDANT’S SECOND SET OF EXPERT INTERROGATORIES TO PLAINTIFF COMES NOW Defendant, ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC., by and through their undersigned counsel, and hereby notifies this Court and counsel of record that it has served the attached Second Set of Expert Interrogatories upon ASBEL ALEXANDER LLERENA to be answered under oath in writing within thirty (30) days, in accordance with the Florida Rules of Civil Procedure. [CERTIFICATE OF SERVICE ON NEXT PAGE] Page 1 COLE, SCOTT & KISSANE, P.A. CASE NO.: 2020 CA 002872 AN CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 10th day of January, 2024, 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- 6990/(407) 452-1597 (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 0487.2384-00 Page 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.: 2020 CA 002872 AN DEFENDANTS SECOND SET OF EXPERT INTERROGATORIES TO PLAINTIFF, ASBEL ALEXANDER LLERENA 1. Please state the name and professional address for each expert witness you expect to testify at trial in this cause as identified in the Amended Expert Witness list. For each expert state the scope of employment in the pending case and the compensation for such service. RESPONSE: 2. For each expert listed in Plaintiff’s Amended Expert Witness List, please state the expert’s general litigation experience, including the percentage of work performed for Plaintiffs and Defendants. RESPONSE: 3. For each expert listed in Plaintiff’s Amended Expert Witness List, please state the identity of other cases, within the last three (3) years, in which the expert has testified by deposition or at trial. RESPONSE: 4. For each expert listed in Plaintiff’s Amended Expert Witness List, please give an approximation of the portion of the expert’s involvement as an expert witness, which may be based on the number of hours, percentage of hours, or percentage of earned income derived from serving as an expert witness. RESPONSE: 5. For each expert listed in Plaintiff’s Amended Expert Witness List please state the number of times that each expert’s deposition was taken in the preceding calendar year when the expert was: (a) The treating physician; (b) The defense physician and/or independent medical examiner; (c) Other. RESPONSE: 6. For each expert listed in Plaintiff’s Amended Expert Witness List, please state the number of times each expert appeared in Court to testify within the last calendar year. Please include times, and where the expert was called to testify in more Page 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.: 2020 CA 002872 AN than one courtroom on a particular date, counting each time as a separate Court appearance. RESPONSE: 7. For each Court appearance listed in Interrogatory No.6 above, please state the number of times the expert was called to testify: (a) By Plaintiffs’ attorney as a treating physician; (b) By Plaintiffs’ attorney as the defense examiner; (c) By Defendants’ attorney as a defense examiner; (d) By Defendants’ attorney as a treating or consulting physician. RESPONSE: 8. For each expert listed in Plaintiff’s Amended Expert Witness List, state his/her background, education, and experience which qualifies him/her to testify as an expert. RESPONSE: 9. Give the name or title of each paper which each expert has authored in the area of his/her expertise. RESPONSE: 10. State the name, volume and page number of the publication in which each article or paper listed above can be found. RESPONSE: 11. State the substance of the facts to which each expert listed above is expected to testify. RESPONSE: 12. State the opinion to which each expert listed above is expected to testify. RESPONSE: 13. Give a summary of grounds or basis for each opinion stated above. Page 4 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.: 2020 CA 002872 AN RESPONSE: 14. Any and all monies paid to all experts listed within Plaintiff’s Amended Expert Witness Disclosure by Morgan & Morgan (All Offices). RESPONSE: 15. Any and all monies paid to all experts listed within Plaintiff’s Amended Expert Witness Disclosure by Morgan & Morgan (All Offices) in the past three years. RESPONSE: Page 5 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.: 2020 CA 002872 AN VERIFICATION _________________, being duly sworn, deposes and says that the attached answers to Defendant’s Expert Interrogatories are true and correct to the best of his/her knowledge, information and belief. ______________________________ ASBEL ALEXANDER LLERENA STATE OF ________________ COUNTY OF ______________ Sworn to and subscribed before me by means of physical presence or online notarization, this _____ day of ________, 2023, who is personally known to me or who has produced _________________________as identification. ________________________________ NOTARY PUBLIC, State of __________ My Commission Expires: ____________ Page 6 COLE, SCOTT & KISSANE, P.A. TOWER PLACE, SUITE 400 - 1900 SUMMIT TOWER BOULEVARD - ORLANDO, FLORIDA 32810 - (321) 972-0000 (321) 972-0099 FAX