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Filing # 49746862 E-Filed 12/07/2016 02:53:53 PM
IN THE CIRCUIT COURT OF THE
17% JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. 14-14218 (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, the surviving children of
MAI TUYET NGUYEN, and as the natural parent
of KADEN NGUYEN, a minor,
Plaintiff,
ve
PLANTATION GENERAL HOSPITAL, L.P. d/b/a
PLANTATION GENERAL HOSPITAL, ALEX BIRMAN, M.D.,
SUNLIFE OB/GYN SERVICES OF FT. 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 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 Expert Witness Disclosure as follows:
1. Please state the name, profession and professional address of each
person you or your attorneys will or may call to testify as an expert
witness at the trial of this matter.
Daniel E. Buffington, Pharm.D., MBA
Clinical Pharmacology Services, Inc.
6285 E. Fowler Avenue
Tampa, FL 33617
Specialty: Pharmacology
Dr. Buffington is a pharmacologist who is expected to render opinions
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/7/2016 2:53:52 PM.****Nguyen v. Plantation General Hospital
CASE NO. 14-14218 (04)
regarding the uses, characteristics and metabolism of Cytotec. 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. 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. In
addition, this expert has been retained for the purpose of addressing and
rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or
treating physicians as such opinions may fall within his purview.
Accordingly, this expert may have additional opinions that cannot be
developed until after Plaintiffs’ experts’ opinions are fully disclosed and
testified to.
Elias G. Chalhub, M.D.
P.O. Box 8467
Mobile, AL 36689
Specialty: Pediatric Neurology
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. Further, this witness will testify in accord with the
CME scheduled to be performed on December 8, 2016.
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, his examination of Kaden Nguyen, any
additional materials and information adduced as discovery continues, and
the expert's own professional training, expertise and experience. In
addition to reviewing the care and treatment provided to Kaden Nguyen
from the standpoint of his expertise, this expert has been retained for the
purpose of addressing and rebutting those opinions offered by the
Plaintiffs’ expert witnesses and/or treating physicians as such opinions
may fall within his purview. Accordingly, this expert may have additional
opinions that cannot be developed until after Plaintiffs’ experts’ opinions
are fully disclosed and testified to.
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.Nguyen v. Plantation General Hospital
CASE NO. 14-14218 (04)
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. In addition, this expert has been retained for the purpose of
addressing and rebutting those opinions offered by the Plaintiffs’ expert
witnesses, as such opinions may fall within his purview. Accordingly, this
expert may have additional opinions that cannot be developed until after
Plaintiffs’ experts’ opinions are fully disclosed and testified to.
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 and Kaden
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. In addition to reviewing the nursing care and treatment
provided to Mai Tuyet Nguyen and Kaden Nguyen from the standpoint of
her expertise, this expert has been retained for the purpose of addressing
and rebutting those opinions offered by the Plaintiffs’ expert witnesses
and/or treating physicians as such opinions may fall within her purview.
Accordingly, this expert may have additional opinions that cannot be
developed until after Plaintiffs’ experts’ opinions are fully disclosed and
testified to.
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 caseNguyen v. Plantation General Hospital
CASE NO. 14-14218 (04)
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. In
addition, this expert has been retained for the purpose of addressing and
rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or
treating physicians as such opinions may fall within her purview.
Accordingly, this expert may have additional opinions that cannot be
developed until after Plaintiffs’ experts’ opinions are fully disclosed and
testified to.
Brett Staller, M.D.
6915 Long Leaf Drive
Parkland, FL 33076
Specialty: Radiology
Dr. Staller is a radiologist and is expected to testify on the issues of
standard of care of Dori Rathbun from the standpoint of his particular
expertise. Dr. Staller is expected to testify regarding interpretations of the
ultrasounds performed on Mai Tuyet Nguyen.
The grounds for Dr. Staller’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. In addition, this expert has been
retained for the purpose of addressing and rebutting those opinions
offered by the Plaintiffs’ expert witnesses and/or treating physicians as
such opinions may fall within his purview. Accordingly, this expert may
have additional opinions that cannot be developed until after Plaintiffs’
experts’ opinions are fully disclosed and testified to.
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
Christopher A. Stones is a radiology technician and is expected to testify
on the issues of standard of care of Dori Rathbun from the standpoint of
his particular expertise. Mr. Stones is expected to testify regarding the
ultrasounds performed on Mai Tuyet Nguyen.Nguyen v. Plantation General Hospital
CASE NO. 14-14218 (04)
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. In addition, this expert has been
retained for the purpose of addressing and rebutting those opinions
offered by the Plaintiffs’ expert witnesses and/or treating physicians as
such opinions may fall within his purview. Accordingly, this expert may
have additional opinions that cannot be developed until after Plaintiffs’
experts’ opinions are fully disclosed and testified to.
Gordon Sze, M.D.
Yale University School of Medicine
Department of Diagnostic Radiology
Section of Neuroradiology
333 Cedar Street
New Haven, CT 06510
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. In addition, this expert has been
retained for the purpose of addressing and rebutting those opinions
offered by the Plaintiffs’ expert witnesses and/or treating physicians as
such opinions may fall within his purview. Accordingly, this expert may
have additional opinions that cannot be developed until after Plaintiffs’
experts’ opinions are fully disclosed and testified to.
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 TuyetNguyen v. Plantation General Hospital
CASE NO. 14-14218 (04)
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. Salkind’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. In addition,
this expert has been retained for the purpose of addressing and rebutting
those opinions offered by the Plaintiffs’ expert witnesses and/or treating
physicians as such opinions may fall within his purview. Accordingly, this
expert may have additional opinions that cannot be developed until after
Plaintiffs’ experts’ opinions are fully disclosed and testified to.
Any and all treating and/or examining physicians of Plaintiff.
Any and all expert witnesses listed by the Plaintiff.
Any and all expert witnesses listed by any party to this action.
This Defendant reserves the right to add further experts before trial, if
necessary.
2. As to each expert witness listed above, please state the field of
his/her expertise.
See #1.
3. State in detail the subject matter on which each expert witness is
expected to testify.
See #1.
4, State the substance of the facts and opinions to which each expert
witness is to testify.
See #1.
5. State a summary of the grounds for each expert’s opinion.
See #1.
6. Please state the style, court and case number of all cases wherein
your expert has testified by either deposition or trial.Nguyen v. Plantation General Hospital
CASE NO. 14-14218 (04)
This information has been requested from Dr. Buffington and a
supplemental response will follow.
Dr. Chalhub does not maintain a list of testimony.
An updated list of cases in which Dr. Durham has provided deposition
and/or trial testimony is attached.
Ms. Ketner does not maintain a list of deposition and/or trial testimony.
An updated list of cases in which Dr. Salafia has provided deposition
and/or trial testimony is attached.
This information has been requested from Dr. Staller and a supplemental
response will be provided.
Mr. Stones does not maintain a list of deposition and/or trial testimony.
Dr. Sze does not maintain a list of deposition and/or trial testimony.
Dr. Zafran does not maintain a list of deposition and/or trial testimony.
7. Please state the scope of employment of each expert witness listed
above in the pending case and the compensation for such service.
A copy of Dr. Buffington’s fee schedule is attached.
Dr. Chalhub charges $350 for review; $500 for deposition with $1,000
minimum; and $5,000 for trial.
A copy of Dr. Durham's fee schedule has been previously provided.
Ms. Ketner charges $150/hour for consultation and review; $175/hour for
trial testimony plus expenses and travel time.
A copy of Dr. Salafia’s fee schedule has been previously provided.
A copy of Dr. Staller’s fee schedule has been previously provided.
Mr. Stones charges $150 hr for review of records, films and depositions.
A copy of Dr. Sze’s fee schedule is attached.
A copy of Dr. Zafran’s fee schedule has been previously provided.
8. Please state for each expert listed above general litigationNguyen v. Plantation General Hospital
CASE NO. 14-14218 (04)
experience, including the percentage of work performed for Plaintiffs
and Defendants.
This information has been requested from Dr. Buffington and a
supplemental response will follow.
Dr. Chalhub reviews 75% for the Defense and 25% for the Plaintiff.
Dr. Durham does not maintain any records to this matter, but estimates
that he reviews 45% for the Plaintiff and 55% for the Defense.
Ms. Ketner reviews primarily for the Defense, approximately 90%.
Dr. Salafia reviews 35% - 40% for the Plaintiff and 60% - 65% for the
Defense.
This information has been requested from Dr. Staller and a supplemental
response will be provided.
Mr. Stones reviews 50% for the Plaintiff and 50% for the Defense.
Dr. Sze reviews 50% for the Plaintiff and 50% for the Defense.
Dr. Zafran reviews 90% for the Defense.
9. Please state an approximation of the portion of the expert’s
involvement as an expert witness, which may be based on the
number of hours, percentage of hours, or percentage of earned
income derived from serving as an expert witness.
This information has been requested from Dr. Buffington and a
supplemental response will follow.
Approximately 10% of Dr. Chalhub’s time is spent serving as an expert
witness.
Dr. Durham does not maintain any records on this matter, but estimates
that 95% - 100% of his income is from litigation consulting/forensic
economic work.
Approximately 15% of Ms. Ketner’s total income is from legal work, some
years it is as low as 10%.
Dr. Salafia does not take any salary from her litigation work. All of the
money goes back into the research portion of the company.
This information has been requested from Dr. Staller and a supplementalNguyen v. Plantation General Hospital
CASE NO. 14-14218 (04)
response will be provided.
Less than 1% of Mr. Stones’ income is derived from serving as an expert
witness.
Approximately 10% of Dr. Sze’s time is spent serving as an expert
witness.
Less than 5% of Dr. Zafran’s income is derived from serving as an expert
witness.
10. Please provide a copy of each expert witnesses curriculum vitae.
A copy of the curriculum vitae of Dr. Chalhub, Dr. Durham, Dr. Salafia, Dr.
Staller, Mr. Stones, Dr. Zafran and Ms. Ketner have been previously
provided.
A copy of the curriculum vitae of Dr. Buffington and Dr. Sze are attached.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing document was
e-filed and e-served to all on the attached Service List this 7" day of December, 2016.
BY: /s/ JOHN W. MAURO, ESQ.
JOHN W. MAURO, ESQ.
jwm@bclmr.com
Florida Bar No: 276634
CAROL J. HEALY GLASGOW, ESQ.
cjg@beclmr.com
Florida Bar No. 026239
BILLING, COCHRAN, LYLES,
MAURO & RAMSEY, P.A.
Attorneys for Defendants, PGH and Rathbun
SunTrust Center, 6" Floor
515 E. Las Olas Blvd.,
Fort Lauderdale, Florida 33301
Ofc: (954) 764-7150; Fax: (954) 764-7279
E-Filing Address: ftl-pleadings@bclmr.com
$:\34412204\PLDS\EW Disc.2.doc/las/klaNguyen v. Plantation General Hospital
CASE NO. 14-14218 (04)
Service List
Nguyen/PGH
344.12204
Maria D. Tejedor, Esq. Counsel for Plaintiff
Diez-Arguelles Tejedor
505 N. Mills Avenue
Orlando, FL 32803
407-705-2880
mail@theorlandolawyers.com
robin@theorlandolawyers.com
jack@theorlandolawyers.com
M. Katherine Hunter, Esq. Counsel for Dr. Santini & Florida United
Chimpoulis, Hunter & Lynn, P.A. Radiology
150 S. Pine Island Road, Suite 510
Plantation, FL 33324
954-463-0033
954-463-9562 — fax
ahoney@chl-law.com
khunter@chl-law.com
cwieland@chl-law.com
Georges Edouard, M.D. (pro se)
4330 W. Broward Blvd. Suite C
Plantation, FL 33317
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Filing # 49746862 E-Filed 12/07/2016 02:53:53 PM IN THE CIRCUIT COURT OF THE 17% JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 14-14218 (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, the surviving children of MAI TUYET NGUYEN, and as the natural parent of KADEN NGUYEN, a minor, Plaintiff, ve PLANTATION GENERAL HOSPITAL, L.P. d/b/a PLANTATION GENERAL HOSPITAL, ALEX BIRMAN, M.D., SUNLIFE OB/GYN SERVICES OF FT. 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 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 Expert Witness Disclosure as follows: 1. Please state the name, profession and professional address of each person you or your attorneys will or may call to testify as an expert witness at the trial of this matter. Daniel E. Buffington, Pharm.D., MBA Clinical Pharmacology Services, Inc. 6285 E. Fowler Avenue Tampa, FL 33617 Specialty: Pharmacology Dr. Buffington is a pharmacologist who is expected to render opinions *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/7/2016 2:53:52 PM.****Nguyen v. Plantation General Hospital CASE NO. 14-14218 (04) regarding the uses, characteristics and metabolism of Cytotec. 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. 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. In addition, this expert has been retained for the purpose of addressing and rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or treating physicians as such opinions may fall within his purview. Accordingly, this expert may have additional opinions that cannot be developed until after Plaintiffs’ experts’ opinions are fully disclosed and testified to. Elias G. Chalhub, M.D. P.O. Box 8467 Mobile, AL 36689 Specialty: Pediatric Neurology 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. Further, this witness will testify in accord with the CME scheduled to be performed on December 8, 2016. 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, his examination of Kaden Nguyen, any additional materials and information adduced as discovery continues, and the expert's own professional training, expertise and experience. In addition to reviewing the care and treatment provided to Kaden Nguyen from the standpoint of his expertise, this expert has been retained for the purpose of addressing and rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or treating physicians as such opinions may fall within his purview. Accordingly, this expert may have additional opinions that cannot be developed until after Plaintiffs’ experts’ opinions are fully disclosed and testified to. 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.Nguyen v. Plantation General Hospital CASE NO. 14-14218 (04) 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. In addition, this expert has been retained for the purpose of addressing and rebutting those opinions offered by the Plaintiffs’ expert witnesses, as such opinions may fall within his purview. Accordingly, this expert may have additional opinions that cannot be developed until after Plaintiffs’ experts’ opinions are fully disclosed and testified to. 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 and Kaden 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. In addition to reviewing the nursing care and treatment provided to Mai Tuyet Nguyen and Kaden Nguyen from the standpoint of her expertise, this expert has been retained for the purpose of addressing and rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or treating physicians as such opinions may fall within her purview. Accordingly, this expert may have additional opinions that cannot be developed until after Plaintiffs’ experts’ opinions are fully disclosed and testified to. 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 caseNguyen v. Plantation General Hospital CASE NO. 14-14218 (04) 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. In addition, this expert has been retained for the purpose of addressing and rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or treating physicians as such opinions may fall within her purview. Accordingly, this expert may have additional opinions that cannot be developed until after Plaintiffs’ experts’ opinions are fully disclosed and testified to. Brett Staller, M.D. 6915 Long Leaf Drive Parkland, FL 33076 Specialty: Radiology Dr. Staller is a radiologist and is expected to testify on the issues of standard of care of Dori Rathbun from the standpoint of his particular expertise. Dr. Staller is expected to testify regarding interpretations of the ultrasounds performed on Mai Tuyet Nguyen. The grounds for Dr. Staller’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. In addition, this expert has been retained for the purpose of addressing and rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or treating physicians as such opinions may fall within his purview. Accordingly, this expert may have additional opinions that cannot be developed until after Plaintiffs’ experts’ opinions are fully disclosed and testified to. 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 Christopher A. Stones is a radiology technician and is expected to testify on the issues of standard of care of Dori Rathbun from the standpoint of his particular expertise. Mr. Stones is expected to testify regarding the ultrasounds performed on Mai Tuyet Nguyen.Nguyen v. Plantation General Hospital CASE NO. 14-14218 (04) 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. In addition, this expert has been retained for the purpose of addressing and rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or treating physicians as such opinions may fall within his purview. Accordingly, this expert may have additional opinions that cannot be developed until after Plaintiffs’ experts’ opinions are fully disclosed and testified to. Gordon Sze, M.D. Yale University School of Medicine Department of Diagnostic Radiology Section of Neuroradiology 333 Cedar Street New Haven, CT 06510 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. In addition, this expert has been retained for the purpose of addressing and rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or treating physicians as such opinions may fall within his purview. Accordingly, this expert may have additional opinions that cannot be developed until after Plaintiffs’ experts’ opinions are fully disclosed and testified to. 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 TuyetNguyen v. Plantation General Hospital CASE NO. 14-14218 (04) 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. Salkind’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. In addition, this expert has been retained for the purpose of addressing and rebutting those opinions offered by the Plaintiffs’ expert witnesses and/or treating physicians as such opinions may fall within his purview. Accordingly, this expert may have additional opinions that cannot be developed until after Plaintiffs’ experts’ opinions are fully disclosed and testified to. Any and all treating and/or examining physicians of Plaintiff. Any and all expert witnesses listed by the Plaintiff. Any and all expert witnesses listed by any party to this action. This Defendant reserves the right to add further experts before trial, if necessary. 2. As to each expert witness listed above, please state the field of his/her expertise. See #1. 3. State in detail the subject matter on which each expert witness is expected to testify. See #1. 4, State the substance of the facts and opinions to which each expert witness is to testify. See #1. 5. State a summary of the grounds for each expert’s opinion. See #1. 6. Please state the style, court and case number of all cases wherein your expert has testified by either deposition or trial.Nguyen v. Plantation General Hospital CASE NO. 14-14218 (04) This information has been requested from Dr. Buffington and a supplemental response will follow. Dr. Chalhub does not maintain a list of testimony. An updated list of cases in which Dr. Durham has provided deposition and/or trial testimony is attached. Ms. Ketner does not maintain a list of deposition and/or trial testimony. An updated list of cases in which Dr. Salafia has provided deposition and/or trial testimony is attached. This information has been requested from Dr. Staller and a supplemental response will be provided. Mr. Stones does not maintain a list of deposition and/or trial testimony. Dr. Sze does not maintain a list of deposition and/or trial testimony. Dr. Zafran does not maintain a list of deposition and/or trial testimony. 7. Please state the scope of employment of each expert witness listed above in the pending case and the compensation for such service. A copy of Dr. Buffington’s fee schedule is attached. Dr. Chalhub charges $350 for review; $500 for deposition with $1,000 minimum; and $5,000 for trial. A copy of Dr. Durham's fee schedule has been previously provided. Ms. Ketner charges $150/hour for consultation and review; $175/hour for trial testimony plus expenses and travel time. A copy of Dr. Salafia’s fee schedule has been previously provided. A copy of Dr. Staller’s fee schedule has been previously provided. Mr. Stones charges $150 hr for review of records, films and depositions. A copy of Dr. Sze’s fee schedule is attached. A copy of Dr. Zafran’s fee schedule has been previously provided. 8. Please state for each expert listed above general litigationNguyen v. Plantation General Hospital CASE NO. 14-14218 (04) experience, including the percentage of work performed for Plaintiffs and Defendants. This information has been requested from Dr. Buffington and a supplemental response will follow. Dr. Chalhub reviews 75% for the Defense and 25% for the Plaintiff. Dr. Durham does not maintain any records to this matter, but estimates that he reviews 45% for the Plaintiff and 55% for the Defense. Ms. Ketner reviews primarily for the Defense, approximately 90%. Dr. Salafia reviews 35% - 40% for the Plaintiff and 60% - 65% for the Defense. This information has been requested from Dr. Staller and a supplemental response will be provided. Mr. Stones reviews 50% for the Plaintiff and 50% for the Defense. Dr. Sze reviews 50% for the Plaintiff and 50% for the Defense. Dr. Zafran reviews 90% for the Defense. 9. Please state an approximation of the portion of the expert’s involvement as an expert witness, which may be based on the number of hours, percentage of hours, or percentage of earned income derived from serving as an expert witness. This information has been requested from Dr. Buffington and a supplemental response will follow. Approximately 10% of Dr. Chalhub’s time is spent serving as an expert witness. Dr. Durham does not maintain any records on this matter, but estimates that 95% - 100% of his income is from litigation consulting/forensic economic work. Approximately 15% of Ms. Ketner’s total income is from legal work, some years it is as low as 10%. Dr. Salafia does not take any salary from her litigation work. All of the money goes back into the research portion of the company. This information has been requested from Dr. Staller and a supplementalNguyen v. Plantation General Hospital CASE NO. 14-14218 (04) response will be provided. Less than 1% of Mr. Stones’ income is derived from serving as an expert witness. Approximately 10% of Dr. Sze’s time is spent serving as an expert witness. Less than 5% of Dr. Zafran’s income is derived from serving as an expert witness. 10. Please provide a copy of each expert witnesses curriculum vitae. A copy of the curriculum vitae of Dr. Chalhub, Dr. Durham, Dr. Salafia, Dr. Staller, Mr. Stones, Dr. Zafran and Ms. Ketner have been previously provided. A copy of the curriculum vitae of Dr. Buffington and Dr. Sze are attached. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing document was e-filed and e-served to all on the attached Service List this 7" day of December, 2016. BY: /s/ JOHN W. MAURO, ESQ. JOHN W. MAURO, ESQ. jwm@bclmr.com Florida Bar No: 276634 CAROL J. HEALY GLASGOW, ESQ. cjg@beclmr.com Florida Bar No. 026239 BILLING, COCHRAN, LYLES, MAURO & RAMSEY, P.A. Attorneys for Defendants, PGH and Rathbun SunTrust Center, 6" Floor 515 E. Las Olas Blvd., Fort Lauderdale, Florida 33301 Ofc: (954) 764-7150; Fax: (954) 764-7279 E-Filing Address: ftl-pleadings@bclmr.com $:\34412204\PLDS\EW Disc.2.doc/las/klaNguyen v. Plantation General Hospital CASE NO. 14-14218 (04) Service List Nguyen/PGH 344.12204 Maria D. Tejedor, Esq. Counsel for Plaintiff Diez-Arguelles Tejedor 505 N. Mills Avenue Orlando, FL 32803 407-705-2880 mail@theorlandolawyers.com robin@theorlandolawyers.com jack@theorlandolawyers.com M. Katherine Hunter, Esq. Counsel for Dr. Santini & Florida United Chimpoulis, Hunter & Lynn, P.A. Radiology 150 S. Pine Island Road, Suite 510 Plantation, FL 33324 954-463-0033 954-463-9562 — fax ahoney@chl-law.com khunter@chl-law.com cwieland@chl-law.com Georges Edouard, M.D. (pro se) 4330 W. Broward Blvd. Suite C Plantation, FL 33317