Trial Materials: GUTIERREZ, FRANK (IND AND AS REPRESENTAT vs. MEMORIAL HERMANN HOSPITAL SYSTEM

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                                07 February
                                                                                                                P.
                                                                                                         27 P1:42
                                                                                                   District Clerk
           .                              CAUSE NO, C-200573415                                    Harris District

     FRANK GUTIERREZ, INDIVIDUALLY                                    IN THE DISTRICT COURT
     and AS REPRESENTATIVE OF THE
     ESTATE OF THERESA GUTIERREZ
     and AS NEXT FRIEND OF MICHELLE
     GUTIERREZ, A MINOR, AMANDA
     GUTIERREZ, FRANK GUTIERREZ, JR., and
     PATRICIA RAMIREZ

     VS.                                                              11™ JUDICIAL DISTRICT

     UNIVERSITY OF TEXAS HEALTH SCIENCE
     CENTER AT HOUSTON                                                HARRIS COUNTY, TEXAS
                                      AMENDED           DESIG)   O                      (TNESS)

     TO THE HONORABLE JUDGE OF SAID COURT:
               NOW COME plaintiffs, and designate the following as persons who may be called as
     expert witnesses in:this case:
               1      Joseph A. Stirt, M.D.
                      2809 Magnolia Drive
                      Charlottesville, VA 22901

             The subject matter of the expert’s testimony is contained in the report previously
     submitted to the defendant. The only documents, tangible things, reports, models, or data
                                                                                      expert in
     compilations that have been provided to, reviewed by, or prepared by or for the
                                                                                          g to
     anticipation of the expert’s testimony are the medical records and autopsy pertainin
     plaintiffs’ decedent.
               The expert’s current resume and bibliography are attached as “Exhibit A”.

               2      Louis F. Silverman, M.D.
                      7777 Southwest Freeway
                      Professional Bldg. 1, Suite 460
                      Houston, Texas 77074

            The subject matter of the expert’s testimony is contained in the report previously
     submitted to the defendant. The only documents, tangible things, reports, models, or data
                                                                                             in
     compilations that have been provided to, reviewed by, or prepared by or for the expert


                                                                     RECORDER's MEMO         RANDUM
                                                                           strument is of ‘poor quall
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anticipation of the expert's testimony are the medical records and autopsy pertaining to
      plaintiffs’ decedent.
              The expert’s current resume and bibliography are attached as “Exhibit B”.
              Plaintiffs’ further reserve the right to call or cross-examine Christiane Vogt-Harenkamp,
      the attending physicians and residents, and all experts designated by defendant as to their expert
      knowledge of facts and issues relevant to this case and/or for purposes ofimpeachment.

                                                   Respectfully submitted,

                                                   MOSS LAW OFFICE
                                                   5350 S. Staples, Suite 209
                                                   Corpus Christi, Texas 78411
                                                   (361) 992-8999 Telephone
                                                   (361) 992-8373 Telecopier




                                                           State Bar No, 14581700


                                                   Fritz Barnett
                                                   BARNETT & CRADDOCK, L.L.P.
                                                   440 Louisiana, Suite 1400
                                                   Houston, Texas 77002
                                                   (713) 425-5300 Telephone
                                                   (713) 425-5301 Telecopier

                                                   ATTORNEYS FOR PLAINTIFFS




woe   eS                                             a                       _—--—__                —-——
CERTIFICATE
                                           OF SERVICE
              I hereby certify that a true and correct copy of the above and foregoing was served
      upon all counsel of record, to wit:

         Jason Warner                                         Telecopied: # 512-463-2224
         Assistant Attorney General
         Tort Litigation Division
          P. O. Box 12548 Capitol Station
         Austin, Texas 78711-2548

          by certified mail, return receipt requested, facsimile transmission, and/or hand delivery
      pursuant to Rules 21 and 21(a), Tex. R. Civ. P. on this the 27" day of February 2007.



                                                      Al        Moss_




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