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Filing # 88328025 E-Filed 04/22/2019 03:14:02 PM
IN THE CIRCUIT COURT OF THE 177!
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
CASE NO: CACE14014218
SEAN DOMNICK, as Guardian Ad Litem for
the minors, KYLIE NGUYEN and KADEN
NGUYEN, KHAI NGUYEN, individually,
and as Personal Representative of the Estate
of MAI TUYET NGUYEN, deceased and
on behalf of KRISTEN HUYNH, KYLIE
NGUYEN, KADEN NGUYEN, the surviving
Children of MAI TUYET NGUYEN, and as
the natural parent of KADEN NGUYEN, a
minor,
Plaintiffs,
vs.
PLANTATION GENERAL HOSPITAL, L.P., d/b/a
PLANTATION GENERAL HOSPITAL; ALEX
BIRMAN, M.D.; SUNLIFE OB/GYN SERVICES
OF FORT LAUDERDALE, P.A.; GEORGES
EDOUARD, M.D.; GEORGES EDOUARD, M.D.,
P.A., d/b/a PLANTATION PAVILION OB/GYN;
MELISSA MACHAN, ARNP; ROBERTA
SANTINI, M.D.; DORI RATHBUN; FLORIDA
UNITED RADIOLOGY, L.C.,
Defendants
DISCLOSURE OF EXPERT WITNESSES
Defendant, PLANTATION GENERAL HOSPITAL, L.P., d/b/a PLANTATION
GENERAL HOSPITAL, by and through undersigned counsel, hereby files its Disclosure of
Expert Witnesses as follows:
1. Daniel E. Buffington, Pharm.D., MBA (Pharmacology)
Clinical Pharmacology Services, Inc.
6285 E. Fowler Avenue
Tampa, FL 33617
Dr. Buffington is a licensed pharmacologist. He will testify regarding all
pharmacological issues. It is anticipated that Dr. Buffington will testify regarding
standard of care, causation and damage issues. His opinions will be based upon his
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/22/2019 3:14:02 PM.****education, training, experience and materials that he has reviewed. Dr. Buffington is
expected to testify that Plantation General Hospital met the standard of care and
treatment of the Mai Tuyet Nguyen. A copy of Dr. Buffington’s curriculum vitae is
attached.
. Elias G. Chalhub, M.D. (Pediatric Neurology)
P.O. Box 8467
Mobile, AL 36689
Dr. Chalhub is a licensed pediatric neurologist. He will testify as to all pediatric
neurology issues. It is anticipated that Dr. Chalhub will testify regarding standard of
care, causation and damage issues. His opinions will be based upon his education,
training, experience, materials that he has reviewed and his IME. Dr. Chalhub is
expected to testify that Plantation General Hospital met the standard of care and
treatment of the Mai Tuyet Nguyen. A copy of Dr. Chalhub’s curriculum vitae is
attached.
. Peter Michael Doubilet, MD (Radiology)
Department of Radiology
Brigham & Women’s Hospital
75 Francis Street, OBC-3-010
Boston, MA 02115
Dr. Doubilet is a licensed radiologist. He will testify regarding all radiology issues.
It is anticipated that Dr. Doubilet will testify regarding standard of care, causation and
damage issues. His opinions will be based upon his education, training, experience
and materials that he has reviewed. Dr. Doubilet is expected to testify that Dori
Rathbun and Plantation General Hospital met the standard of care and treatment of
the Mai Tuyet Nguyen. A copy of Dr. Doubilet’s curriculum vitae is attached.
. Stephen E. Durham, Ph.D. (Economist)
100 North Tampa Street, Suite 2410
Tampa, FL 33602
Dr. Durham is a licensed economist. He will testify regarding all economic issues. It
is anticipated that Dr. Durham will testify regarding damage issues. His opinions will
be based upon his education, training, experience and materials that he has reviewed.
A copy of Dr. Durham’s curriculum vitae is attached.
. Jay Goldsmith, MD (Neonatology)
1625 Joseph Street
New Orleans, LA 70115
Dr. Goldsmith is a licensed neonatologist. He will testify regarding all neonatology
issues. It is anticipated that Dr. Goldsmith will testify regarding standard of care,
causation and damage issues. His opinions will be based upon his education, training,
experience and materials that he has reviewed. Dr. Goldsmith is expected to testify
that Plantation General Hospital met the standard of care and treatment of the Mai
Tuyet Nguyen. A copy of Dr. Goldsmith’s curriculum vitae is attached.6. Mona Brown Ketner, MSN, RN, C-EFM (Nursing)
1033 Wessyngton Road
Winston-Salem, NC 27104
Ms. Ketner is a licensed registered nurse. She will testify as to all nursing issues. It
is anticipated that Ms. Ketner will testify regarding standard of care, causation and
damage issues. Her opinions will be based upon his education, training, experience
and materials that he has reviewed. Ms. Ketner is expected to testify that Plantation
General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A
copy of Ms. Ketner’s curriculum vitae is attached.
7. Eroston Ann Price, MD (Pathologist)
398 East Dania Beach Boulevard
#195
Dania Beach, FL 33004
Dr. Price is a licensed physician. She will testify as to all issues related to pathology.
It is anticipated that Dr. Price will testify regarding standard of care, causation and
damage issues. Her opinions will be based upon his education, training, experience
and materials that he has reviewed. Dr. Price is expected to testify that based on the
pathology placental pathologist, Plantation General Hospital met the standard of care
and treatment of the Mai Tuyet Nguyen. A copy of Dr. Price’s curriculum vitae is
attached.
8. Carolyn Salafia, MD, MS (Pathology)
Placental Analytics, LLC
187 Overlook Circle
New Rochelle, NY 10804
Dr. Salafia is a licensed pathologist. She will testify regarding all issues related to
pathology. It is anticipated that Dr. Salafia will testify regarding standard of care,
causation and damage issues. Her opinions will be based upon his education,
training, experience and materials that he has reviewed. Dr. Salafia is expected to
testify that based on pathology, Plantation General Hospital met the standard of care
and treatment of the Mai Tuyet Nguyen. A copy of Dr. Salafia’s curriculum vitae is
attached.
9. Jean Lea Spitz, RDMS (Sonography)
3017 Brookhollow Road
Oklahoma City, OK 73120
Ms. Spitz is a licensed sonographer. She will testify regarding all issues concerning
the ultrasound interpreted by Dori Rathbun. It is anticipated that Ms. Spitz will
testify regarding standard of care, causation and damage issues. Her opinions will be
based upon her education, training, experience and materials that he has reviewed.
Ms. Spitz is expected to testify that Dori Rathbun and Plantation General Hospital
met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Ms.
Spitz’ curriculum vitae is attached.10. Gordon Sze, M.D. (Neuroradiology)
123 York Street, Apt. 17B
New Haven, CT 06511
Dr. Sze is a licensed neuroradiologist. He will testify as to all neuroradiology issues.
It is anticipated that Dr. Sze will testify regarding standard of care, causation and
damage issues. His opinions will be based upon his education, training, experience
and materials that he has reviewed. Dr. Sze is expected to testify that Plantation
General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A
copy of Dr. Sze’s curriculum vitae is attached.
11. Bruce M. Zafran, M.D., F.A.C.O.G. (Ob/Gyn)
Royal Palm OB/GYN
8110 Royal Palm Blvd.
Suite 108
Coral Springs, FL 33065
Dr. Zafran is a licensed Ob/Gyn. He will testify as to all obstetrical and gynecology
issues. It is anticipated that Dr. Zafran will testify regarding standard of care,
causation and damage issues. His opinions will be based upon his education, training,
experience and materials that he has reviewed. Dr. Zafran is expected to testify that
Plantation General Hospital met the standard of care and treatment of the Mai Tuyet
Nguyen. A copy of Dr. Zafran’s curriculum vitae is attached.
Defendant reserves the right to disclose additional expert witnesses as its necessity
becomes known for discovery upon reasonable notice to all parties and this Honorable Court.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been
delivered via e-service this22 “day of April, 2019, to all addressees set forth on the attached
Service List.
LA CAVA & JACOBSON, P.A.
Attorneys for Def., Plantation General Hospital
501 E. Kennedy Boulevard; Suite 1250
Tampa, FL 33602
Telephone: 813-209-9611
Facsimile: _..
BY:
LOUIS. LaCAVA
Fla. Bar No: 507880
MARCIL, STRAUSS
Fla. Bar No.: 857025SERVICE LIST
Maria D. Tejedor, Esq.
Diez-Arguelles & Tejedor, P.A.
505 North Mills Avenue
Orlando, Florida 32803
407-705-2880
mail@theorlandolawyers.com
leah@theorlandolawyers.com
Attorneys for Plaintiff
Alex Alvarez, Esq.
Phillip Holden, Esq.
The Alvarez Law Firm
355 Palermo Avenue
Coral Gables, FL 33134
305-444-7675
alex@talf.law
maria@talf.law
phillip.holden@integrityforjustice.com
Co-Counsel for Plaintiff
Peter Mineo, Jr., Esq.
The Mineo Salcedo Law Firm, P.A.
5400 S. University Drive, Suite 502
Davie, FL 33328
954-463-8100
service@mineolaw.com
jsoto@mineolaw.com
Counsel for Defendant, Georges Edouard, M.D
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Filing # 88328025 E-Filed 04/22/2019 03:14:02 PM IN THE CIRCUIT COURT OF THE 177! JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE14014218 SEAN DOMNICK, as Guardian Ad Litem for the minors, KYLIE NGUYEN and KADEN NGUYEN, KHAI NGUYEN, individually, and as Personal Representative of the Estate of MAI TUYET NGUYEN, deceased and on behalf of KRISTEN HUYNH, KYLIE NGUYEN, KADEN NGUYEN, the surviving Children of MAI TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, Plaintiffs, vs. PLANTATION GENERAL HOSPITAL, L.P., d/b/a PLANTATION GENERAL HOSPITAL; ALEX BIRMAN, M.D.; SUNLIFE OB/GYN SERVICES OF FORT LAUDERDALE, P.A.; GEORGES EDOUARD, M.D.; GEORGES EDOUARD, M.D., P.A., d/b/a PLANTATION PAVILION OB/GYN; MELISSA MACHAN, ARNP; ROBERTA SANTINI, M.D.; DORI RATHBUN; FLORIDA UNITED RADIOLOGY, L.C., Defendants DISCLOSURE OF EXPERT WITNESSES Defendant, PLANTATION GENERAL HOSPITAL, L.P., d/b/a PLANTATION GENERAL HOSPITAL, by and through undersigned counsel, hereby files its Disclosure of Expert Witnesses as follows: 1. Daniel E. Buffington, Pharm.D., MBA (Pharmacology) Clinical Pharmacology Services, Inc. 6285 E. Fowler Avenue Tampa, FL 33617 Dr. Buffington is a licensed pharmacologist. He will testify regarding all pharmacological issues. It is anticipated that Dr. Buffington will testify regarding standard of care, causation and damage issues. His opinions will be based upon his *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/22/2019 3:14:02 PM.****education, training, experience and materials that he has reviewed. Dr. Buffington is expected to testify that Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Dr. Buffington’s curriculum vitae is attached. . Elias G. Chalhub, M.D. (Pediatric Neurology) P.O. Box 8467 Mobile, AL 36689 Dr. Chalhub is a licensed pediatric neurologist. He will testify as to all pediatric neurology issues. It is anticipated that Dr. Chalhub will testify regarding standard of care, causation and damage issues. His opinions will be based upon his education, training, experience, materials that he has reviewed and his IME. Dr. Chalhub is expected to testify that Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Dr. Chalhub’s curriculum vitae is attached. . Peter Michael Doubilet, MD (Radiology) Department of Radiology Brigham & Women’s Hospital 75 Francis Street, OBC-3-010 Boston, MA 02115 Dr. Doubilet is a licensed radiologist. He will testify regarding all radiology issues. It is anticipated that Dr. Doubilet will testify regarding standard of care, causation and damage issues. His opinions will be based upon his education, training, experience and materials that he has reviewed. Dr. Doubilet is expected to testify that Dori Rathbun and Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Dr. Doubilet’s curriculum vitae is attached. . Stephen E. Durham, Ph.D. (Economist) 100 North Tampa Street, Suite 2410 Tampa, FL 33602 Dr. Durham is a licensed economist. He will testify regarding all economic issues. It is anticipated that Dr. Durham will testify regarding damage issues. His opinions will be based upon his education, training, experience and materials that he has reviewed. A copy of Dr. Durham’s curriculum vitae is attached. . Jay Goldsmith, MD (Neonatology) 1625 Joseph Street New Orleans, LA 70115 Dr. Goldsmith is a licensed neonatologist. He will testify regarding all neonatology issues. It is anticipated that Dr. Goldsmith will testify regarding standard of care, causation and damage issues. His opinions will be based upon his education, training, experience and materials that he has reviewed. Dr. Goldsmith is expected to testify that Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Dr. Goldsmith’s curriculum vitae is attached.6. Mona Brown Ketner, MSN, RN, C-EFM (Nursing) 1033 Wessyngton Road Winston-Salem, NC 27104 Ms. Ketner is a licensed registered nurse. She will testify as to all nursing issues. It is anticipated that Ms. Ketner will testify regarding standard of care, causation and damage issues. Her opinions will be based upon his education, training, experience and materials that he has reviewed. Ms. Ketner is expected to testify that Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Ms. Ketner’s curriculum vitae is attached. 7. Eroston Ann Price, MD (Pathologist) 398 East Dania Beach Boulevard #195 Dania Beach, FL 33004 Dr. Price is a licensed physician. She will testify as to all issues related to pathology. It is anticipated that Dr. Price will testify regarding standard of care, causation and damage issues. Her opinions will be based upon his education, training, experience and materials that he has reviewed. Dr. Price is expected to testify that based on the pathology placental pathologist, Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Dr. Price’s curriculum vitae is attached. 8. Carolyn Salafia, MD, MS (Pathology) Placental Analytics, LLC 187 Overlook Circle New Rochelle, NY 10804 Dr. Salafia is a licensed pathologist. She will testify regarding all issues related to pathology. It is anticipated that Dr. Salafia will testify regarding standard of care, causation and damage issues. Her opinions will be based upon his education, training, experience and materials that he has reviewed. Dr. Salafia is expected to testify that based on pathology, Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Dr. Salafia’s curriculum vitae is attached. 9. Jean Lea Spitz, RDMS (Sonography) 3017 Brookhollow Road Oklahoma City, OK 73120 Ms. Spitz is a licensed sonographer. She will testify regarding all issues concerning the ultrasound interpreted by Dori Rathbun. It is anticipated that Ms. Spitz will testify regarding standard of care, causation and damage issues. Her opinions will be based upon her education, training, experience and materials that he has reviewed. Ms. Spitz is expected to testify that Dori Rathbun and Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Ms. Spitz’ curriculum vitae is attached.10. Gordon Sze, M.D. (Neuroradiology) 123 York Street, Apt. 17B New Haven, CT 06511 Dr. Sze is a licensed neuroradiologist. He will testify as to all neuroradiology issues. It is anticipated that Dr. Sze will testify regarding standard of care, causation and damage issues. His opinions will be based upon his education, training, experience and materials that he has reviewed. Dr. Sze is expected to testify that Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Dr. Sze’s curriculum vitae is attached. 11. Bruce M. Zafran, M.D., F.A.C.O.G. (Ob/Gyn) Royal Palm OB/GYN 8110 Royal Palm Blvd. Suite 108 Coral Springs, FL 33065 Dr. Zafran is a licensed Ob/Gyn. He will testify as to all obstetrical and gynecology issues. It is anticipated that Dr. Zafran will testify regarding standard of care, causation and damage issues. His opinions will be based upon his education, training, experience and materials that he has reviewed. Dr. Zafran is expected to testify that Plantation General Hospital met the standard of care and treatment of the Mai Tuyet Nguyen. A copy of Dr. Zafran’s curriculum vitae is attached. Defendant reserves the right to disclose additional expert witnesses as its necessity becomes known for discovery upon reasonable notice to all parties and this Honorable Court. CERTIFICATE OF SERVICE IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been delivered via e-service this22 “day of April, 2019, to all addressees set forth on the attached Service List. LA CAVA & JACOBSON, P.A. Attorneys for Def., Plantation General Hospital 501 E. Kennedy Boulevard; Suite 1250 Tampa, FL 33602 Telephone: 813-209-9611 Facsimile: _.. BY: LOUIS. LaCAVA Fla. Bar No: 507880 MARCIL, STRAUSS Fla. Bar No.: 857025SERVICE LIST Maria D. Tejedor, Esq. Diez-Arguelles & Tejedor, P.A. 505 North Mills Avenue Orlando, Florida 32803 407-705-2880 mail@theorlandolawyers.com leah@theorlandolawyers.com Attorneys for Plaintiff Alex Alvarez, Esq. Phillip Holden, Esq. The Alvarez Law Firm 355 Palermo Avenue Coral Gables, FL 33134 305-444-7675 alex@talf.law maria@talf.law phillip.holden@integrityforjustice.com Co-Counsel for Plaintiff Peter Mineo, Jr., Esq. The Mineo Salcedo Law Firm, P.A. 5400 S. University Drive, Suite 502 Davie, FL 33328 954-463-8100 service@mineolaw.com jsoto@mineolaw.com Counsel for Defendant, Georges Edouard, M.D