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Filing # 84934573 E-Filed 02/14/2019 01:30:50 PM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA
CHRISTOPHER CALHOUNE,
CASE NO. CACE-18-002023-09
Plaintiff,
vs.
BROWARD COUNTY,
Defendant.
SREESERSERSSRSSESSESSESSEESERSERSSESY |
PLAINTIFF'S EXPERT WITNESS REQUEST TO PRODUCE TO DEFENDANT
COMES NOW, the Plaintiff, CHRISTOPHER CALHOUNE, by and through his
undersigned attorney, pursuant to Florida Rule of Civil Procedure 1.350, and
hereby requests that the Defendant, BROWARD COUNTY, produce for inspection
and copying at the office of Rodrigo L. Saavedra, Jr., Esquire, 3000 North
Federal Highway, Building Two, Suite 200, Fort Lauderdale, Florida, the
following items, as to all of Defendant’s expert witnesses, within thirty (30)
days, the time period specified by Florida Rule of Civil Procedure 1.350:
1. Records of all financial renumeration, payments and 1099s issued
by the insurance carrier or its affiliates to all of Defendant’s expert witnesses
in connection with defense requested examinations or consultations or reviews
of any plaintiffs or claimants, for IMEs, CMEs and PIP IMEs, and defense
services of any nature, for the last five years, including the current calendar
year.
2. Records of all financial renumeration, payments, and 1099s issued
to all of Defendant’s expert witnesses, in connection with defense requested
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/14/2019 1:30:50 PM.****examinations, consultations, reviews or services of any nature involving the
Plaintiff.
3. Copies of all statements, written or recorded, that the Defendant’s
expert witnesses have examined.
4. All published or non-published standards from any source, texts,
treatises, articles, manuals and journals which Defendant’s expert witnesses
used, relied upon or referred to in formulating their opinion.
5. Copies of all published professional articles and speeches
Defendant's expert witnesses have given.
6. All report(s), notes, photographs, data, and calculations that
Defendant’s expert witnesses have prepared or utilized relating to their expert
opinion in the subject case.
7. All drawings, graphs, charts, illustrations and plans, prepared by
Defendant's expert witnesses in formulating their opinions.
8. All reports, office notes, photographs, videos, records, tests, and
documents that have been prepared by Defendant's expert witnesses or
provided to Defendant’s expert witnesses in this case.
9. A copy of Defendant's expert witnesses’ bills and invoices and any
records indicating time spent on this case and hourly charges.
10. Any published monographs, treatises, manuals, articles, textbooks
or other documents which Defendant’s expert witnesses have used as a
reference and upon which Defendant's expert witnesses base their opinion, in
whole or in part.11. Any correspondence between Defendant's attorney's office and
Defendant's expert witnesses.
12. A copy of all documents provided by Defendant’s attorney’s office
to Defendant's expert witnesses.
13. Acopy of all documents obtained by Defendant's expert witnesses
for the purpose of evaluation of this action.
14. All publications authored by Defendant’s expert witnesses.
15. Defendant’s expert witnesses’ entire files on this matter. (Leave
nothing out.)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing is being
furnished by e-mail only to Shannon Williams-Leon, Esquire, Assistant County
Attorney at swilliamsleon@broward.org and smaldonado@broward.org on this
__ |S day of February, 2019.
RODRIGO L. SAAVEDRA, JR., P.A.
Attorneys for Plaintiff
3000 N. Federal Highway
Building Two, Suite 200
Fort Lauderdale, FL 33306
Telephone: (954)564-0503
rsaavedra@rsaavedralaw.com
ey: Vinal Uh A
RODRIGO L. SAAVEDRA, JR.
Florida Bar No. 679290
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Filing # 84934573 E-Filed 02/14/2019 01:30:50 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CHRISTOPHER CALHOUNE, CASE NO. CACE-18-002023-09 Plaintiff, vs. BROWARD COUNTY, Defendant. SREESERSERSSRSSESSESSESSEESERSERSSESY | PLAINTIFF'S EXPERT WITNESS REQUEST TO PRODUCE TO DEFENDANT COMES NOW, the Plaintiff, CHRISTOPHER CALHOUNE, by and through his undersigned attorney, pursuant to Florida Rule of Civil Procedure 1.350, and hereby requests that the Defendant, BROWARD COUNTY, produce for inspection and copying at the office of Rodrigo L. Saavedra, Jr., Esquire, 3000 North Federal Highway, Building Two, Suite 200, Fort Lauderdale, Florida, the following items, as to all of Defendant’s expert witnesses, within thirty (30) days, the time period specified by Florida Rule of Civil Procedure 1.350: 1. Records of all financial renumeration, payments and 1099s issued by the insurance carrier or its affiliates to all of Defendant’s expert witnesses in connection with defense requested examinations or consultations or reviews of any plaintiffs or claimants, for IMEs, CMEs and PIP IMEs, and defense services of any nature, for the last five years, including the current calendar year. 2. Records of all financial renumeration, payments, and 1099s issued to all of Defendant’s expert witnesses, in connection with defense requested *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/14/2019 1:30:50 PM.****examinations, consultations, reviews or services of any nature involving the Plaintiff. 3. Copies of all statements, written or recorded, that the Defendant’s expert witnesses have examined. 4. All published or non-published standards from any source, texts, treatises, articles, manuals and journals which Defendant’s expert witnesses used, relied upon or referred to in formulating their opinion. 5. Copies of all published professional articles and speeches Defendant's expert witnesses have given. 6. All report(s), notes, photographs, data, and calculations that Defendant’s expert witnesses have prepared or utilized relating to their expert opinion in the subject case. 7. All drawings, graphs, charts, illustrations and plans, prepared by Defendant's expert witnesses in formulating their opinions. 8. All reports, office notes, photographs, videos, records, tests, and documents that have been prepared by Defendant's expert witnesses or provided to Defendant’s expert witnesses in this case. 9. A copy of Defendant's expert witnesses’ bills and invoices and any records indicating time spent on this case and hourly charges. 10. Any published monographs, treatises, manuals, articles, textbooks or other documents which Defendant’s expert witnesses have used as a reference and upon which Defendant's expert witnesses base their opinion, in whole or in part.11. Any correspondence between Defendant's attorney's office and Defendant's expert witnesses. 12. A copy of all documents provided by Defendant’s attorney’s office to Defendant's expert witnesses. 13. Acopy of all documents obtained by Defendant's expert witnesses for the purpose of evaluation of this action. 14. All publications authored by Defendant’s expert witnesses. 15. Defendant’s expert witnesses’ entire files on this matter. (Leave nothing out.) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing is being furnished by e-mail only to Shannon Williams-Leon, Esquire, Assistant County Attorney at swilliamsleon@broward.org and smaldonado@broward.org on this __ |S day of February, 2019. RODRIGO L. SAAVEDRA, JR., P.A. Attorneys for Plaintiff 3000 N. Federal Highway Building Two, Suite 200 Fort Lauderdale, FL 33306 Telephone: (954)564-0503 rsaavedra@rsaavedralaw.com ey: Vinal Uh A RODRIGO L. SAAVEDRA, JR. Florida Bar No. 679290