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Filing # 63198831 E-Filed 10/23/2017 04:00:21 PM
IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA.
CASE NO: CACE14014218 (04)
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 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.
/
DEFENDANT, PLANTATION GENERAL HOSPITAL, L.P. d/b/a
PLANTATION GENERAL HOSPITAL’S SUPPLEMENTAL
EXPERT WITNESS DISCLOSURE
COMES NOW the Defendant, PLANTATION GENERAL HOSPITAL, L.P. d/b/a
PLANTATION GENERAL HOSPITAL, by and through its undersigned counsel, and files this,
its Supplemental Expert Witness Disclosure as follows:
1. Elias G. Chalhub, M.D.
P.O. Box 8467
Mobile, AL 36689
Specialty: Pediatric Neurology
La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309
Telephone (754) 301-5060; Facsimile (754) 551-6884
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/23/2017 4:00:21 PM.****Nguyen v. Plantation General Hospital
CASE NO. 14-14218
Dr. Elias Chalhub is pediatric neurologist and is expected to testify on the issues
of standard of care, causation and damages from the standpoint of his particular
expertise.
The grounds for Dr. Chalhub’s opinions are the medical records produced in this
action, diagnostic studies, radiographic evidence, depositions taken or to be taken
in this matter, any additional materials and information adduced as discovery
continues, and the expert’s own professional training, expertise and experience.
Stephen Durham, Ph.D.
100 North Tampa Street, Suite 2410
Tampa, FL 33602
Specialty: Economist
Dr. Durham is an economist and is expected to testify as to damages. This
witness is further expected to testify regarding his training, background and
expertise, and any other issue relevant to the case within this witness’ purview.
The grounds for Dr. Durham’s opinions are the pleadings, insurance records
produced in this action, depositions taken or to be taken in this matter, any
additional materials and information adduced as discovery continues, and the
expert’s own professional training, expertise and experience.
Mona Brown Ketner, R.N., M.S.N.
Deacon Tower, 3“! Floor
475 Deacon Blvd.
Winston-Salem, NC 27105
Specialty: Nursing
Mona Ketner is a Registered Nurse who is expected to testify that the nursing care
and treatment rendered to MAI TUYET NGUYEN at Plantation General Hospital
was within the standard of care.
The grounds for Nurse Ketner’s opinions are the review of hospital records,
deposition testimony, and her own professional training, expertise and experience.
La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309
Telephone (754) 301-5060; Facsimile (754) 551-6884Nguyen v. Plantation General Hospital
CASE NO. 14-14218
Carolyn Salafia, MD, MS
Placental Analytics
187 Overlook Circle
New Rochelle, NY 10804
Specialty: Developmental Pathologist
Dr. Carolyn Salafia is expected to testify regarding the interpretations of various
pathological slides and/or reports pertaining to MAI TUYET NGUYEN. This
witness further is expected to testify regarding her training, background and
experience, and any other issue involved in this case within this witness’ purview.
The grounds for Dr. Salafia’s opinions are the medical records, pathology slides,
pathology reports, depositions taken or to be taken in this matter, any additional
materials and information adduced as discovery continues, and the expert’s own
professional training, expertise and experience.
Gordon Sze, M.D.
123 York Street, Apt. 17B
New Haven, CT 06511
Specialty: Neuroradiology
Dr. Sze is a neuro-radiologist and is expected to testify on the issues of standard
of care and causation from the standpoint of his particular expertise. Dr. Sze is
expected to testify regarding interpretations of various diagnostic studies
performed on Kaden Nguyen.
The grounds for Dr. Sze’s opinions are the medical records produced in this
action, diagnostic studies, radiographic evidence, depositions taken or to be taken
in this matter, any additional materials and information adduced as discovery
continues, and the expert’s own professional training, expertise and experience.
Christopher A. Stones, R.T., R.D.M.S., R.D.C.S.
6541 N.E. 20" Terrace
Ft. Lauderdale, FL 33308
Specialty: Radiology Technician
Registered Specialties: OB/GYN, Abdominal, Neurosonology, Adult
Echocardiography
La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309
Telephone (754) 301-5060; Facsimile (754) 551-6884Nguyen v. Plantation General Hospital
CASE NO. 14-14218
Christopher A. Stones is a certified Diagnostic Medical sonographer and is
expected to testify on the issues of standard of care and causation from the
standpoint of his particular expertise. Mr. Stones is expected to testify regarding
various diagnostic studies performed on MAI TUYET NGUYEN.
The grounds for Mr. Stones’ opinions are the medical records produced in this
action, diagnostic studies, radiographic evidence, depositions taken or to be taken
in this matter, any additional materials and information adduced as discovery
continues, and the expert’s own professional training, expertise and experience.
Bruce M. Zafran, M.D.
8110 Royal Palm Boulevard
Suite 108
Coral Springs, FL 33065
Specialty: OB/GYN
Dr. Bruce Zafran is an obstetrician/gynecologist who is expected to testify that the
physicians and nursing staff at Plantation General Hospital acted within the
standard of care with regard to the treatment of MAI TUYET NGUYEN, and that
no alleged act or omission was a deviation from the standard of care which caused
or contributed to any injury and/or damages. This witness is further expected to
testify regarding his training, background and expertise, and any other issue
relevant to the case within this witness’ purview.
The grounds for Dr. Zafran’s opinions are based on the medical records produced
in this action, diagnostic studies, radiographic evidence, depositions taken or to be
taken in this matter, and any additional materials and information adduced as
discovery continues, and the expert’s own professional training, expertise and
experience.
Jay Goldsmith, MD
1625 Joseph Street
New Orleans, LA 70115
Specialty: Neonatology
Dr. Jay Goldsmith is a neonatologist and is expected to testify on the issues of
causation and damages from the standpoint of his particular expertise and that the
treatment rendered to KADEN NGUYEN at Plantation General Hospital was
within the standard of care.
La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309
Telephone (754) 301-5060; Facsimile (754) 551-688410.
Nguyen v. Plantation General Hospital
CASE NO. 14-14218
The grounds for Dr. Goldsmith’s opinions are the medical records produced in
this action, diagnostic studies, radiographic evidence, depositions taken or to be
taken in this matter, any additional materials and information adduced as
discovery continues, and the expert’s own professional training, expertise and
experience.
Peter Doubilet, MD
Department of Radiology
Brigham & Women’s Hospital
75 Francis Street, OBC-3-010
Boston, MA 02115
Specialty: Radiology
Dr. Peter Doubilet is a radiologist specializing in Obstetrical Ulrasounds and is
expected to testify on the issues of standard of care and causation from the
standpoint of his particular expertise. Dr. Doubilet is expected to testify regarding
interpretations of various ultrasound studies performed on Mai Tuyet Nguyen.
The grounds for Dr. Doubilet’s opinions are the medical records produced in this
action, diagnostic studies, radiographic evidence, depositions taken or to be taken
in this matter, any additional materials and information adduced as discovery
continues, and the expert’s own professional training, expertise and experience.
Daniel E. Buffington, Pharm.D., MBA
Clinical Pharmacology Services, Inc.
6285 E. Fowler Avenue
Tampa, FL 33617
Specialty: Pharmacology
Dr. Daniel E. Buffington is a Doctor of Pharmacoloy and is expected to testify on
the issues of standard of care, causation and damages from the standpoint of his
particular expertise.
The grounds for Dr. Buffington’s opinions are the medical records produced in
this action, depositions taken or to be taken in this matter, any additional materials
and information adduced as discovery continues, and the expert’s own
professional training, expertise and experience.
La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309
Telephone (754) 301-5060; Facsimile (754) 551-688413.
14,
15.
16.
Nguyen v. Plantation General Hospital
CASE NO. 14-14218
Eroston Price, MD
398 Dania Beach Boulevard, #195
Dania Beach, FL 33004
Dr. Price is expected to testify as to autopsy findings. This witness is further
expected to testify regarding his training, background and expertise, and any other
issue relevant to the case within this witness’ purview.
Defendant reserves the right to call each and every expert witness listed by any
other party whether they are still a party to this lawsuit at the time of trial.
Defendant reserves the right to any and all objections to any and all expert
witnesses listed by any other party.
Defendant reserves the right to call additional expert witnesses in specialty
relating to Plaintiff's claims for damages, for rebuttal and/or for impeachment
purposes.
Defendant further advises all counsel of record that they reserve the right to call
any and all of Plaintiffs treating physicians, including physicians rendering
treatment at hospitals, clinics or outpatient centers, as expert witnesses at the time
of trial.
This Defendant reserves the right to amend and/or supplement this Expert
Witness Disclosure upon proper notice to the parties and this Court.
CERTIFICATE OF SERVICE
IT IS CERTIFIED that a correct copy of the foregoing has been delivered via Electronic
Mail this 23 day of October, 2017 to all counsel of record set forth on the attached Service List.
La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309
Telephone (754) 301-5060; Facsimile (754) 551-6884Nguyen v. Plantation General Hospital
CASE NO. 14-14218
LA CAVA & JACOBSON, P.A.
Attorneys for Def., Plantation General Hospital
4901 NW 17" Way, Suite 302
Ft. Lauderdale, FL 33309
Telephone: 754-301-5060
Facsimile: 754-551-6884
Eservice: ftlpleadings@lacavajacobson.com
holeski@lacavajacobson.com
BA
BY:
LOUIS J. LaCAVA
Fla. Bar No: 507880
WILLIAM V. CARCIOPPOLO
Fla. Bar No: 510051
SERVICE LIST
Maria D. Tejedor, Esq.
Diez-Arguelles & Tejedor, P.A.
505 North Mills Avenue
Orlando, Florida 32803
Telephone: 407-705-2880
Eservice: mail@theorlandolawyers.com
keisha@theorlandolawyers.com
uiffani@theorlandolawyers.com
Attorneys for Plaintiff
Georges Edouard, M.D.
4330 W. Broward Blvd. Suite C
Plantation, FL 33317
Pro Se Defendant
La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309
Telephone (754) 301-5060; Facsimile (754) 551-6884
Preview
Filing # 63198831 E-Filed 10/23/2017 04:00:21 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA. CASE NO: CACE14014218 (04) 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 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. / DEFENDANT, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL’S SUPPLEMENTAL EXPERT WITNESS DISCLOSURE COMES NOW the Defendant, PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, by and through its undersigned counsel, and files this, its Supplemental Expert Witness Disclosure as follows: 1. Elias G. Chalhub, M.D. P.O. Box 8467 Mobile, AL 36689 Specialty: Pediatric Neurology La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309 Telephone (754) 301-5060; Facsimile (754) 551-6884 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/23/2017 4:00:21 PM.****Nguyen v. Plantation General Hospital CASE NO. 14-14218 Dr. Elias Chalhub is pediatric neurologist and is expected to testify on the issues of standard of care, causation and damages from the standpoint of his particular expertise. The grounds for Dr. Chalhub’s opinions are the medical records produced in this action, diagnostic studies, radiographic evidence, depositions taken or to be taken in this matter, any additional materials and information adduced as discovery continues, and the expert’s own professional training, expertise and experience. Stephen Durham, Ph.D. 100 North Tampa Street, Suite 2410 Tampa, FL 33602 Specialty: Economist Dr. Durham is an economist and is expected to testify as to damages. This witness is further expected to testify regarding his training, background and expertise, and any other issue relevant to the case within this witness’ purview. The grounds for Dr. Durham’s opinions are the pleadings, insurance records produced in this action, depositions taken or to be taken in this matter, any additional materials and information adduced as discovery continues, and the expert’s own professional training, expertise and experience. Mona Brown Ketner, R.N., M.S.N. Deacon Tower, 3“! Floor 475 Deacon Blvd. Winston-Salem, NC 27105 Specialty: Nursing Mona Ketner is a Registered Nurse who is expected to testify that the nursing care and treatment rendered to MAI TUYET NGUYEN at Plantation General Hospital was within the standard of care. The grounds for Nurse Ketner’s opinions are the review of hospital records, deposition testimony, and her own professional training, expertise and experience. La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309 Telephone (754) 301-5060; Facsimile (754) 551-6884Nguyen v. Plantation General Hospital CASE NO. 14-14218 Carolyn Salafia, MD, MS Placental Analytics 187 Overlook Circle New Rochelle, NY 10804 Specialty: Developmental Pathologist Dr. Carolyn Salafia is expected to testify regarding the interpretations of various pathological slides and/or reports pertaining to MAI TUYET NGUYEN. This witness further is expected to testify regarding her training, background and experience, and any other issue involved in this case within this witness’ purview. The grounds for Dr. Salafia’s opinions are the medical records, pathology slides, pathology reports, depositions taken or to be taken in this matter, any additional materials and information adduced as discovery continues, and the expert’s own professional training, expertise and experience. Gordon Sze, M.D. 123 York Street, Apt. 17B New Haven, CT 06511 Specialty: Neuroradiology Dr. Sze is a neuro-radiologist and is expected to testify on the issues of standard of care and causation from the standpoint of his particular expertise. Dr. Sze is expected to testify regarding interpretations of various diagnostic studies performed on Kaden Nguyen. The grounds for Dr. Sze’s opinions are the medical records produced in this action, diagnostic studies, radiographic evidence, depositions taken or to be taken in this matter, any additional materials and information adduced as discovery continues, and the expert’s own professional training, expertise and experience. Christopher A. Stones, R.T., R.D.M.S., R.D.C.S. 6541 N.E. 20" Terrace Ft. Lauderdale, FL 33308 Specialty: Radiology Technician Registered Specialties: OB/GYN, Abdominal, Neurosonology, Adult Echocardiography La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309 Telephone (754) 301-5060; Facsimile (754) 551-6884Nguyen v. Plantation General Hospital CASE NO. 14-14218 Christopher A. Stones is a certified Diagnostic Medical sonographer and is expected to testify on the issues of standard of care and causation from the standpoint of his particular expertise. Mr. Stones is expected to testify regarding various diagnostic studies performed on MAI TUYET NGUYEN. The grounds for Mr. Stones’ opinions are the medical records produced in this action, diagnostic studies, radiographic evidence, depositions taken or to be taken in this matter, any additional materials and information adduced as discovery continues, and the expert’s own professional training, expertise and experience. Bruce M. Zafran, M.D. 8110 Royal Palm Boulevard Suite 108 Coral Springs, FL 33065 Specialty: OB/GYN Dr. Bruce Zafran is an obstetrician/gynecologist who is expected to testify that the physicians and nursing staff at Plantation General Hospital acted within the standard of care with regard to the treatment of MAI TUYET NGUYEN, and that no alleged act or omission was a deviation from the standard of care which caused or contributed to any injury and/or damages. This witness is further expected to testify regarding his training, background and expertise, and any other issue relevant to the case within this witness’ purview. The grounds for Dr. Zafran’s opinions are based on the medical records produced in this action, diagnostic studies, radiographic evidence, depositions taken or to be taken in this matter, and any additional materials and information adduced as discovery continues, and the expert’s own professional training, expertise and experience. Jay Goldsmith, MD 1625 Joseph Street New Orleans, LA 70115 Specialty: Neonatology Dr. Jay Goldsmith is a neonatologist and is expected to testify on the issues of causation and damages from the standpoint of his particular expertise and that the treatment rendered to KADEN NGUYEN at Plantation General Hospital was within the standard of care. La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309 Telephone (754) 301-5060; Facsimile (754) 551-688410. Nguyen v. Plantation General Hospital CASE NO. 14-14218 The grounds for Dr. Goldsmith’s opinions are the medical records produced in this action, diagnostic studies, radiographic evidence, depositions taken or to be taken in this matter, any additional materials and information adduced as discovery continues, and the expert’s own professional training, expertise and experience. Peter Doubilet, MD Department of Radiology Brigham & Women’s Hospital 75 Francis Street, OBC-3-010 Boston, MA 02115 Specialty: Radiology Dr. Peter Doubilet is a radiologist specializing in Obstetrical Ulrasounds and is expected to testify on the issues of standard of care and causation from the standpoint of his particular expertise. Dr. Doubilet is expected to testify regarding interpretations of various ultrasound studies performed on Mai Tuyet Nguyen. The grounds for Dr. Doubilet’s opinions are the medical records produced in this action, diagnostic studies, radiographic evidence, depositions taken or to be taken in this matter, any additional materials and information adduced as discovery continues, and the expert’s own professional training, expertise and experience. Daniel E. Buffington, Pharm.D., MBA Clinical Pharmacology Services, Inc. 6285 E. Fowler Avenue Tampa, FL 33617 Specialty: Pharmacology Dr. Daniel E. Buffington is a Doctor of Pharmacoloy and is expected to testify on the issues of standard of care, causation and damages from the standpoint of his particular expertise. The grounds for Dr. Buffington’s opinions are the medical records produced in this action, depositions taken or to be taken in this matter, any additional materials and information adduced as discovery continues, and the expert’s own professional training, expertise and experience. La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309 Telephone (754) 301-5060; Facsimile (754) 551-688413. 14, 15. 16. Nguyen v. Plantation General Hospital CASE NO. 14-14218 Eroston Price, MD 398 Dania Beach Boulevard, #195 Dania Beach, FL 33004 Dr. Price is expected to testify as to autopsy findings. This witness is further expected to testify regarding his training, background and expertise, and any other issue relevant to the case within this witness’ purview. Defendant reserves the right to call each and every expert witness listed by any other party whether they are still a party to this lawsuit at the time of trial. Defendant reserves the right to any and all objections to any and all expert witnesses listed by any other party. Defendant reserves the right to call additional expert witnesses in specialty relating to Plaintiff's claims for damages, for rebuttal and/or for impeachment purposes. Defendant further advises all counsel of record that they reserve the right to call any and all of Plaintiffs treating physicians, including physicians rendering treatment at hospitals, clinics or outpatient centers, as expert witnesses at the time of trial. This Defendant reserves the right to amend and/or supplement this Expert Witness Disclosure upon proper notice to the parties and this Court. CERTIFICATE OF SERVICE IT IS CERTIFIED that a correct copy of the foregoing has been delivered via Electronic Mail this 23 day of October, 2017 to all counsel of record set forth on the attached Service List. La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309 Telephone (754) 301-5060; Facsimile (754) 551-6884Nguyen v. Plantation General Hospital CASE NO. 14-14218 LA CAVA & JACOBSON, P.A. Attorneys for Def., Plantation General Hospital 4901 NW 17" Way, Suite 302 Ft. Lauderdale, FL 33309 Telephone: 754-301-5060 Facsimile: 754-551-6884 Eservice: ftlpleadings@lacavajacobson.com holeski@lacavajacobson.com BA BY: LOUIS J. LaCAVA Fla. Bar No: 507880 WILLIAM V. CARCIOPPOLO Fla. Bar No: 510051 SERVICE LIST Maria D. Tejedor, Esq. Diez-Arguelles & Tejedor, P.A. 505 North Mills Avenue Orlando, Florida 32803 Telephone: 407-705-2880 Eservice: mail@theorlandolawyers.com keisha@theorlandolawyers.com uiffani@theorlandolawyers.com Attorneys for Plaintiff Georges Edouard, M.D. 4330 W. Broward Blvd. Suite C Plantation, FL 33317 Pro Se Defendant La Cava & Jacobson, P.A., 4901 NW 17" Way, Suite 302, Fort Lauderdale, Florida, 33309 Telephone (754) 301-5060; Facsimile (754) 551-6884