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Filing # 196523470 E-Filed 04/18/2024 04:31:49 PM
IN THE CIRCUIT COURT IN THE NINTH JUDICIAL CIRCUIT IN AND FOR
OSCEOLA COUNTY, FLORIDA
CASE NO: 2021-CA-0552 ON
SHELLY HATMAKER,
Plaintiff,
vs.
7-ELEVEN and ANNABELLE PENA,
Defendants.
PLAINTIFF'S EXPERT REQUEST FOR PRODUCTION
COME(S) NOW the Plaintiff, Shelly Hatmaker, pursuant to Rule 1.350 the Florida Rules of
Civil Procedure, hereby request(s) that the Defendant, 7-ELEVEN, produce and permit the
undersigned, or someone acting on behalf of the undersigned, to inspect and copy each of the
following items:
1. As to each expert witness whom Defendant expect(s) to call at trial:
(a) All documents provided to any such expert in connection with this case, including
records, reports, literature, memoranda or any other documents.
(b) Any records, reports, notes, memoranda, bills, correspondences, or any other
documents prepared by any expert witness in connection with this case.
(c) Copies of any manuscripts, drafts, galleys, outlines, slides, and the like, concerning
any oral or written presentations made by the expert on any subject relevant to this
case which are not in the public domain.
(d) Transcripts of any deposition or trial testimony in the expert’s possession or control
on any subject relevant to this case.
(e) A current curriculum vitae for each such expert.
(f) Any exhibits prepared by or with the assistance of the expert which are intended to
illustrate aspects of the expert’s testimony.
2. Redacted copies of all Compulsory Medical Examinations (CME/IME) reports, records,
reviews, evaluations, MRI or x-ray re-read reports issued by the expert(s) for the last three (3) years,
to exclude the name, social security number or any other identifying information of the
patient/claimant/plaintiff.
3. All time records, diaries, and bills prepared and rendered in connection with expert’s
investigation and evaluation of the issues involved in the lawsuit.
4. Any written notes, correspondence, tests, texts, pamphlets, or articles reviewed, consulted
or otherwise relied upon by expert in reviewing, evaluating and/or formulating opinions in this
matter.
5. Any and all articles authored, coauthored, or contributed to by expert concerning any of
the conditions, analysis or procedures applicable to this case.
6. Copies of all publications, syllabuses and other handouts or visual aids used during any
lectures or presentations pertaining to any issues about which expert intends to testify in this
matter.
7. Any tables or charts referred to or utilized in rendering expert’s opinions in this matter.
8. Any calculations performed.
9. A listing of all cases within the last three (3) years in which expert has given testimony as
an expert, including identification of the case style; plaintiff’s attorney; defendant’s attorney;
court in which case was pending; and whether the testimony was by deposition, trial or both.
10. A list of all previous depositions given and/or trials in which testimony was given along
with copies of transcripts of depositions for all cases within the three (3) years for each expert.
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11. An approximation of expert’s involvement as an expert witness based on the number of
hours, percent of hours, or income derived from expert services, including percentage of work
performed for plaintiffs vs. defendants.
12. Documents describing the scope of expert’s employment in the pending case.
13. Copies of any advertisements concerning expert’s availability as an expert or consultant
or a listing of any expert locator/referral services in which he has participated or agreed to make
referrals to him.
14. All raw testing data, test responses, answers or psychological tests upon which expert is
relying or which were conducted at their request.
15. Financial documentation showing the total amount of fees the Defendant and/or
Defendant's law firm has paid for the expert’s services in the last three (3) years.
16. Financial documentation showing the total amount of fees the Defendant and/or
Defendant's insurance carrier has paid for the expert’s services in the last three (3) years.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 18, 2024, I electronically filed the foregoing with the
Clerk of the Courts by using the Florida Courts eFiling Portal which will send notice of filing to:
Raychel A. Garcia, Esquire (ORLcrtpleadings@wickersmith.com), Wicker Smith O’Hara Mccoy
& Ford, P.A., 390 n. Orange Avenue, Suite 1000, Orlando, Florida 32801.
___/s/ Brandon M. Smith_______
Brandon M. Smith, Esq.
FBN 118916
Morgan & Morgan, P.A.
20 N. Orange Avenue, Suite 1600
Orlando, FL 32802-4979
Telephone: (407) 420-1414
Facsimile: (407) 423-7928
Primary Email: brandonmsmith@forthepeople.com
Secondary email: egarcia@forthepeople.com
Attorney for Plaintiff
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Filing # 196523470 E-Filed 04/18/2024 04:31:49 PM IN THE CIRCUIT COURT IN THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA CASE NO: 2021-CA-0552 ON SHELLY HATMAKER, Plaintiff, vs. 7-ELEVEN and ANNABELLE PENA, Defendants. PLAINTIFF'S EXPERT REQUEST FOR PRODUCTION COME(S) NOW the Plaintiff, Shelly Hatmaker, pursuant to Rule 1.350 the Florida Rules of Civil Procedure, hereby request(s) that the Defendant, 7-ELEVEN, produce and permit the undersigned, or someone acting on behalf of the undersigned, to inspect and copy each of the following items: 1. As to each expert witness whom Defendant expect(s) to call at trial: (a) All documents provided to any such expert in connection with this case, including records, reports, literature, memoranda or any other documents. (b) Any records, reports, notes, memoranda, bills, correspondences, or any other documents prepared by any expert witness in connection with this case. (c) Copies of any manuscripts, drafts, galleys, outlines, slides, and the like, concerning any oral or written presentations made by the expert on any subject relevant to this case which are not in the public domain. (d) Transcripts of any deposition or trial testimony in the expert’s possession or control on any subject relevant to this case. (e) A current curriculum vitae for each such expert. (f) Any exhibits prepared by or with the assistance of the expert which are intended to illustrate aspects of the expert’s testimony. 2. Redacted copies of all Compulsory Medical Examinations (CME/IME) reports, records, reviews, evaluations, MRI or x-ray re-read reports issued by the expert(s) for the last three (3) years, to exclude the name, social security number or any other identifying information of the patient/claimant/plaintiff. 3. All time records, diaries, and bills prepared and rendered in connection with expert’s investigation and evaluation of the issues involved in the lawsuit. 4. Any written notes, correspondence, tests, texts, pamphlets, or articles reviewed, consulted or otherwise relied upon by expert in reviewing, evaluating and/or formulating opinions in this matter. 5. Any and all articles authored, coauthored, or contributed to by expert concerning any of the conditions, analysis or procedures applicable to this case. 6. Copies of all publications, syllabuses and other handouts or visual aids used during any lectures or presentations pertaining to any issues about which expert intends to testify in this matter. 7. Any tables or charts referred to or utilized in rendering expert’s opinions in this matter. 8. Any calculations performed. 9. A listing of all cases within the last three (3) years in which expert has given testimony as an expert, including identification of the case style; plaintiff’s attorney; defendant’s attorney; court in which case was pending; and whether the testimony was by deposition, trial or both. 10. A list of all previous depositions given and/or trials in which testimony was given along with copies of transcripts of depositions for all cases within the three (3) years for each expert. 2 11. An approximation of expert’s involvement as an expert witness based on the number of hours, percent of hours, or income derived from expert services, including percentage of work performed for plaintiffs vs. defendants. 12. Documents describing the scope of expert’s employment in the pending case. 13. Copies of any advertisements concerning expert’s availability as an expert or consultant or a listing of any expert locator/referral services in which he has participated or agreed to make referrals to him. 14. All raw testing data, test responses, answers or psychological tests upon which expert is relying or which were conducted at their request. 15. Financial documentation showing the total amount of fees the Defendant and/or Defendant's law firm has paid for the expert’s services in the last three (3) years. 16. Financial documentation showing the total amount of fees the Defendant and/or Defendant's insurance carrier has paid for the expert’s services in the last three (3) years. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 18, 2024, I electronically filed the foregoing with the Clerk of the Courts by using the Florida Courts eFiling Portal which will send notice of filing to: Raychel A. Garcia, Esquire (ORLcrtpleadings@wickersmith.com), Wicker Smith O’Hara Mccoy & Ford, P.A., 390 n. Orange Avenue, Suite 1000, Orlando, Florida 32801. ___/s/ Brandon M. Smith_______ Brandon M. Smith, Esq. FBN 118916 Morgan & Morgan, P.A. 20 N. Orange Avenue, Suite 1600 Orlando, FL 32802-4979 Telephone: (407) 420-1414 Facsimile: (407) 423-7928 Primary Email: brandonmsmith@forthepeople.com Secondary email: egarcia@forthepeople.com Attorney for Plaintiff 3