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Filing # 185045929 E-Filed 10/30/2023 12:59:14 PM
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 SERVING
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 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 30th day of October, 2023, 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
DEFENDANT, ADRIAN RODRIGUEZ CHAVEZ AND GRANNY'S GARDEN II, INC.,
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. For each expert state the scope of
employment in the pending case and the compensation for such service.
RESPONSE:
2. For each expert listed, please state the expert’s general litigation experience,
including the percentage of work performed for Plaintiffs and Defendants.
RESPONSE:
3. For each expert listed, 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, 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, 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, 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 than one courtroom on a particular date,
counting each time as a separate Court appearance.
RESPONSE:
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
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. With regard to each expert listed above, 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.
RESPONSE:
14. Any and all monies paid to all experts listed within Plaintiff’s Expert Witness
Disclosure by Morgan & Morgan (All Offices).
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:
15. Any and all monies paid to all experts listed within Plaintiff’s 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