Document for Christopher Calhoune Plaintiff vs. Broward County Defendant

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                                Filing # 83777856 E-Filed 01/23/2019 02:23:40 PM

IN THE CIRCUIT COURT, OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND

FOR BROWARD COUNTY, FLORIDA

CHRISTOPHER CALHOUNE,

Plaintiff,
vs. CASE NO. CACE18-002023-09
BROWARD COUNTY,

Defendant. :

DEFENDANT BROWARD COUNTY’S FACT WITNESS LIST

Defendants, Broward County (“Defendant”), through the undersigned counsel and

pursuant to this Court’s Trial Order, files its Fact Witness list as follows:

1.

2.

All parties to this lawsuit.

Any impeachment and/or rebuttal witnesses.

Any expert and non-expert witnesses listed Plaintiff.

All persons identified in depositions, Answers to Interrogatories, Responses to Request for
Production, Responses to Request for Admissions, other discovery, and/or pleadings in this

case.

Christopher Calhoune
c/o counsel

Any and all of Plaintiff's treating medical providers.

Tim Garling
c/o undersigned counsel

Tim Garling has knowledge of there being no record of the incident claimed in this
action.

Jackie Lewis
Cheryl Reckley
c/o undersigned counsel

Both witnesses have knowledge regarding the Broward County Transit Customer Service
Representative involvement for this action.

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/23/2019 2:23:40 PM.****CASE NO.CACE18-002023-09

9. Wanda Del Toro
c/o undersigned counsel

Wanda Del Toro has knowledge regarding the Broward County Transit Compliance and
Safety involvement for this action.

10. Mara Wildman
Kenneth Legler
c/o undersigned counsel

Both witnesses were Transit Operators on the day of the incident and may be called to
testify at trial to dispute the occurrence of this incident.

11. The Defendant reserves the right to amend and/or supplement this list.

CERTIFICATE OF SERVICE

Thereby certify that on January 23, 2019, a copy hereof was served by an automatic email
generated by the Florida Courts E-Filing Portal to Rodrigo L. Saavedra, Jr., Esq., 3000 North
Federal Highway, Building Two, Suite 200, Fort Lauderdale, Florida 33306,
rsaavedra@rsaavedralaw.com.

Respectfully submitted,

Andrew J. Meyers

Broward County Attorney
Governmental Center, Suite 423
115 South Andrews Avenue
Fort Lauderdale, Florida 33301
Telephone: (954) 357-7600
Facsimile: (954) 357-7641

By: 4/ Shannon Williams-Leon
SHANNON WILLIAMS-LEON
Assistant County Attorney

Florida Bar No. 111819
swilliamsleon@broward.org
smaldonado@broward.org