Preview
CAUSE NO. C—5246-19-D
RAUL J. CANALES § IN THE DISTRICT COURT OF
§
Plaintiff §
§
V- §
§ HIDALGO COUNTY, TEXAS
MS TRANSPORTATION, LLC AND §
SEBASTMN S. MACIAS §
§
Defendants. §
206th JUDICIAL DISTRICT
EXHIBIT “B ”
194.20)(1) Sanjay Misra, MD
Orthopedic Center ofSan Antonio
315 NSANSABA, SUITE 1175
SANANTONIO, TX 78207
Phone: 21 0-2 70-9999
’
194.20%2) Subject matter: Dr. Misra is one ofRaul Canales treating medical providers.
Dr. Misra 1's
a board-certified orthopedic surgeon. Dr. Misra is expected to base
his testimony 0f a reasonable degree 0f medical probability based upon his
education, training, experience and treatment ofRaul Candles.
Dr. Misra ’s
testimony is expected t0 include, but not necessarily be limited t0, the
following topics, Raul Canales’ injuries, medical conditions, and diagnoses, the
cause 0f Raul Canales’ injuries, conditions, and diagnoses, diagnostic testing
which was administered t0 Raul Candles, medical treatments which Raul Canales
received, medical treatment which may have been recommended t0 Raul Candles
but he has not received, the reasonable and necessary costs 0f medical treatment
’
and services, the necessity ofany discussed medical treatment and Raul Candles
future prognosis, including any possible medical treatment, pain, impairment,
limitation and disability, ifany.
Dr. Misra will provide opinions and testimony regarding the causal relationship
between the collision in question and the injuries suflered by Raul Candles, the
reasonable and necessary medical care and treatmentfor those injuries and the
efiect that the injuries have had and will have 0n Raul Canales’ life.
Dr. Misra will provide opinions and testimony regarding any injury Raul Candles
may have suflered in his lumbar Spine and left Shoulder as a result 0f this
collision. Dr. Misra will likely address whether the collision made the basis 0f
’
this suit aggravated any preexisting condition in Raul Canales lumbar Spine and
left shoulder.
Plaintiffis’ Designation ofExpert Witnesses Page 4
[9420(3) Dr. Misra has not been retained, employed 0r otherwise subject t0 the control 0f
Plaintiff t0 provide expert testimony in this case, although Plaintfi does
’s
anticipate taking Dr. Misra deposition in this case.
Please see Dr. Misra’s medical records for mental impressions and opinions 0f
the witnesses.
It is expected Dr. Misra will have knowledge including, but not necessarily
limited t0, thefollowingfacts:
Dr. Misra is expected t0 be aware that Raul Canales was involved in a collision
0n September I2, 2018.
Dr. Misra is expected t0 be aware 0f any facts contained within the medical
history he obtainedfrom Raul Candles.
Dr. Misra will be aware offacts based upon his multiple physical examinations 0f
Raul Candles.
Dr. Misra will be aware offacts contained with his medical records and medical
records ofotherproviders who treated Raul Candles which he has obtained.
Dr. Misra will be aware offacts resultingfrom an MRI 0fthe lumbar Spine which
Raul Candles underwent 0n October 22, 2018 and an MRI 0f the left Shoulder
that Raul Candles underwent 0n May 13, 2019.
Dr. Misra will be aware Raul Canales was diagnosed with a 5 t0 6-millimeler
disc herniation at LI/2; a 4 t0 5-millimeter disc herniation at L2/3; a 5 t0 6-
millimeter disc herniation at L3/4; a 6-millimeter disc herniation tL4/5; and a 5
to 6-millimeter disc herniation at L5/S1. Dr. Misra will also be aware Raul
Candles was diagnosed with a torn muscle runningfrom the shoulder blade t0 the
left arm.
Dr. Misra is expected to be aware that Raul Canales received physical therapy,
anti-inflammatory medications, and various injections in the lumbar region and
left shoulder with minimal relief Dr. Misra is expected t0 be aware that Raul
Candles continued with severe lumbar pain and left shoulder pain in Spite 0f
conservative measures.
Dr. Misra is expected t0 be aware that 0n April 26, 2019, Raul Canales received
bilateral lumbar median branch blocks at L3/4 and L4/5; 0n May 10, 2019, Raul
Candles received an L3/4 and L4/5 left—sz'ded lumbar radiofrequency
thermocoagulation injection; and 0n May 14, 2019, Raul Candles received a
right-sided lumbar medial branch radiofrequency thermocoagulation injection at
L2, L3, and L4. Additionally, Dr. Misra is expected t0 be aware that 0n July 5,
2019, Raul Candles received a left shoulder epidural steroid injection.
Plaintiffls’ Designation ofExpert Witnesses Page 5
Dr. Misra recommended surgical procedures t0 Raul Candles. It is expected Dr.
Misra will describe the nature offhese procedures to Raul Candles, including but
not limited to, potential risks and complications 0fthese procedures.
0n July 23, 2019, Dr. Misra performed a lumbar epidural steroid injection; 0n
July 25, 2019, Dr. Misra performed a cervical epidural steroid injection; and 0n
September 30, 2019, Dr. Misra peiformed a lumbar microdiscectomy,
hemilaminotomy, and nerve root decompression with foramz'notomy at L2/3, L3/4,
L4/5, and L5/SI; and immediately following lumbar spine surgery, Dr. Misra
performed a left shoulder rotator cufl repair surgery Dr. Misra is expected t0
testifi/ regarding how he performed these surgical procedures 0n Raul Candles,
the reason he peiformed these surgeries, what made the surgery necessary in
’
Raul Canales situation and the reasonable and necessary cost 0fthese surgeries.
Dr. Misra is expected t0 address the necessity 0f other medical treatment he
administered t0 Raul Canales and the reasonable cost 0fthat medical treatment.
Dr. Misra may address the necessity 0f medical treatment administered t0 Raul
Candles by otherproviders and the reasonable cost offhat medical treatment.
You are referred t0 the records from Dr. Misra for more detailed information
about the substance oftestimony.
Dr. Misra may address injuries sustained by Raul Candles that he may not have
treated.
’
Forfurther information regarding Raul Canales medical conditions, please see
medical and billing records.
194.20)(4)(A) Not applicable as Dr. Misra is not retained by, employed by, 0r otherwise subject
t0 the control ofPlaintiff
[9420(4) (B) Not applicable as Dr. Misra is not retained by, employed by, 0r otherwise subject
t0 the control ofPlaintz'flT
194mm Dr. Sam Li, MD
Quantum Pain and Orthopedics
8626 TESORO DRIVE, SUITE 112
SANANTONIO, TX 78217
Phone: 210-81 7—601 0
194.2(f)(2) Subject matter: Dr. Li is one ofRaul Candles and Ezequiel Rosales Gonzalez’s
treating medical providers.
Dr. Li is expected t0 base his testimony 0f a reasonable degree 0f medical
Plaintiffis’ Designation ofExpert Witnesses Page 6
probability, based upon his education, training, experience and treatment ofRaul
Candles and Ezequiel Rosales Gonzalez.
Dr. Li’s testimony is expected t0 include, but not necessarily be limited t0, the
following topics, Raul Candles and Ezequiel Rosales Gonzalez’s injuries, medical
conditions, and diagnoses, the cause 0f Raul Canales and Ezequiel Rosales
Gonzalez’s injuries, conditions and diagnoses, diagnostic testing which was
administered t0 Raul Candles and Ezequiel Rosales Gonzalez, medical treatments
which Raul Candles and Ezequiel Rosales Gonzalez received, medical treatment
which may have been recommended t0 Raul Candles and Ezequiel Rosales
Gonzalez but they have not received, the reasonable and necessary costs 0f
medical treatment and services, the necessity 0f any discussed medical treatment
and Raul Candles and Ezequiel Rosales Gonzalez’s future prognosis, including
anypossible medical treatment, pain, impairment, limitation and disability, ifany.
Dr. Li will provide opinions and testimony regarding the causal relationship
between the collision in question and the injuries suffered by Raul Candles and
Ezequiel Rosales Gonzalez, the reasonable and necessary medical care and
treatmentfor those injuries and the effect that the injuries have had and will have
0n Raul Candles and Ezequiel Rosales Gonzalez’s lives.
Dr. Li will provide opinions and testimony regarding any injury Raul Candles
and Ezequiel Rosales Gonzalez may have sufi’ered as a result 0fthis collision. Dr.
Li will likely address whether the collision made the basis 0fthis suit aggravated
any preexisting condition in Raul Candles and Ezequiel Rosales Gonzalez ’s spine
and shoulders.
194.2m(3) Dr. Li has not been retained, employed 0r otherwise subject t0 the control 0f
Plaintiffto provide expert testimony in this case.
Please see Dr. Li’s medical records for mental impressions and opinions 0f the
witnesses.
It is expected Dr. Li will have knowledge including, but not necessarily limited t0,
thefollowingfacts:
Dr. Li isexpected t0 be aware that Raul Candles and Ezequiel Rosales Gonzalez
were involved in a collision 0n September I2, 2018.
Dr. Li is expected t0 be aware ofanyfacts contained within the medical history he
obtainedfrom Raul Candles and Ezequiel Rosales Gonzalez.
Dr. Li will be aware offacts based upon his multiple physical examinations 0f
Raul Candles and Ezequiel Rosales Gonzalez.
Dr. Li will be aware offacts contained with his medical records and medical
records 0f other providers who treated Raul Candles and Ezequiel Rosales
Gonzalez which he has obtained.
Plaintiffls’ Designation ofExpert Witnesses Page 7
Dr. Li is expected t0 be aware that 0n November 9, 2018 and December 21, 2018,
he administered cervical epidural steroid injections t0 Raul Candles; 0n April 26,
2019, he performed bilateral lumbar median branch blocks at L3/4 and L4/5; 0n
May 10, 2019, he performed an L3/4 and L4/5 left-sided lumbar radiofrequency
thermocoagulation injection; 0n May I4, 2019, Dr. Li performed a right—sided
lumbar medial branch radiofrequency thermocoagulation injection at L2, L3, and
L4; and 0n July 5, 2019, Dr. Li performed a left shoulder epidural steroid
injection. Dr. Li is expected t0 describe how these procedures were performed
and the purpose 0fthese procedures.
Dr. Li is expected t0 be aware that 0n November 9, 2018 and December 21, 2018,
he administered cervical epidural steroid injections t0 Ezequiel Rosales Gonzalez.
Dr. Li is expected t0 describe how these procedures were performed and the
purpose 0fthese procedures.
Dr. Li is expected t0 address the necessity 0f other medical treatment he
administered t0 Raul Candles and Ezequiel Rosales Gonzalez and the reasonable
cost 0fthat medical treatment.
Dr. Li may address the necessity 0f medical treatment administered t0 Raul
Candles and Ezequiel Rosales Gonzalez by other providers and the reasonable
cost 0fthat medical treatment.
You are referred to the records from Dr. Lifor more detailed information about
the substance oftestimony.
Dr. Li may address injuries sustained by Raul Candles and Ezequiel Rosales
Gonzalez that he may not have treated.
Forfurther information regarding Raul Candles and Ezequiel Rosales Gonzalez ’s
medical conditions, please see medical and billing records.
I94.209(4)(A) Not applicable as Dr. Li is not retained by, employed by, 0r otherwise subject t0
the control ofPlaintiff.‘
194.2€)(4)(B) Not applicable as Dr. Li is not retained by, employed by, 0r otherwise subject t0
the control ofPlaintifi’.
194.2090) Dr. Edward Lee, MD
Quantum Pain and Orthopedics
8626 TESORO DRIVE, SUITE 112
SANANTONIO, TX 78217
Phone: 210-81 7-601 0
194.2090) Subject matter: Dr. Lee is one oszequz'el Rosales Gonzalez ’s treating medical
Plaintiffls’ Designation ofExpert Witnesses Page 8
providers.
Dr. Lee is expected t0 base his testimony of a reasonable degree 0f medical
probability, based upon his education, training, experience and treatment of
Ezequiel Rosales Gonzalez.
Dr. Lee’s testimony is expected t0 include, but not necessarily be limited t0, the
following topics, Ezequiel Rosales Gonzalez’s injuries, medical conditions, and
diagnoses, the cause 0f Ezequiel Rosales Gonzalez’s injuries, conditions and
diagnoses, diagnostic testing which was administered to Ezequiel Rosales
Gonzalez, medical treatments which Ezequiel Rosales Gonzalez received, medical
treatment which may have been recommended t0 Ezequiel Rosales Gonzalez but
he has not received, the reasonable and necessary costs 0f medical treatment and
services, the necessity 0f any discussed medical treatment and Ezequiel Rosales
Gonzalez’s future prognosis, including any possible medical treatment, pain,
impairment, limitation and disability, ifany.
Dr. Lee will provide opinions and testimony regarding the causal relationship
between the collision in question and the injuries suflered by Ezequiel Rosales
Gonzalez, the reasonable and necessary medical care and treatment for those
injuries and the efi’ect that the injuries have had and will have 0n Ezequiel
Rosales Gonzalez ’s lives.
Dr. Lee will provide opinions and testimony regarding any injury Ezequiel
Rosales Gonzalez may have suffered as a result 0f this collision. Dr. Lee will
likely address whether the collision made the basis 0f this suit aggravated any
preexisting condition in Ezequiel Rosales Gonzalez’s right shoulder.
194.20%3) Dr. Lee has not been retained, employed 0r otherwise subject t0 the control 0f
Plaintiffto provide expert testimony in this case.
Please see Dr. Lee ’s medical recordsfor mental impressions and opinions 0fthe
witnesses.
It is expected Dr. Lee will have knowledge including, but not necessarily limited
t0, thefollowingfacts:
Dr. Lee is expected t0 be aware that Ezequiel Rosales Gonzalez was involved in a
collision 0n September 12, 2018.
Dr. Lee is expected t0 be aware ofanyfacts contained within the medical history
he obtainedfrom Ezequiel Rosales Gonzalez.
Dr. Lee will be aware offacts contained with his medical records and medical
records 0f other providers who treated Ezequiel Rosales Gonzalez which he has
obtained.
Plaintiffls’ Designation ofExpert Witnesses Page 9
Dr. Lee is expected t0 be aware that 0n April 6, 2019, Ezequiel Rosales Gonzalez
underwent an epidural steroid injection to his right Shoulder. Dr. Lee is expected
t0 testifi/ that Ezequiel Rosales Gonzalez continued with severe pain despite this
treatment.
Dr. Lee is expected t0 testifi} that he recommended a right shoulder arthroscopy
for Ezequiel Rosales Gonzalez and that the surgical cost estimatefor this surgery
is $67,000.
You are referred t0 the recordsfrom Dr. Leefor more detailed information about
the substance oftestimony.
I94.209(4) (A) Not applicable as Dr. Lee 1's
not retained by, employed by, 0r otherwise subject t0
the control ofPlaintijj”.
194.20%4) (B) Not applicable as Dr. Lee is not retained by, employed by, 0r otherwise subject t0
the control ofPlaintijf
194.2m(1) Modesto Gutierrez; 1D N0. 0266
San Antonio Police Department
13030 Jones Maltsberger Rd,
San Antonio, TX 78247
Phone: (210) 207-8126
194.2(fl(2) Subject matter: Ofiicer Gutierrez is the investigating officer 0f the crash that
occurred 0n September 12, 2018.
Officer Gutierrez 1's
an investigator with the San Antonio Police Department.
Uficer Gutierrez is expected t0 base his testimony upon his education, training,
experience, and knowledge 0f the events that occurred related t0 the collision
made the basis 0fthz's lawsuit.
Officer Gutierrez’s testimony is expected t0 include, but not necessarily be limited
t0, the following topics: investigative protocols, investigative techniques, and
evidence gathered during motor vehicle collision investigations. Oflicer
Gutierrez’s testimony is expected t0 include any cause(s) and/or contributing
factors 0f the collision in question; his investigation and conclusions concerning
the collision in question; any evidence he discovered regarding the collision;
questioning 0f the parties and/or witnesses and technique in doing so; his
assessment 0f the severity 0f any parties injuries at the scene 0f the collision in
question; rules and regulations 0f the Texas Department 0f Transportation; and
his report offhe collision in question.
Officer Gutierrez will provide opinions and testimony regarding any potential
causes 0f the collision in question and his thought processes in arriving at his
Plaintiffis’ Designation ofExpert Witnesses Page 10
conclusions.
194.2098) Oflicer Gutierrez has not been retained 0r specially employed by Plaintifl t0
provide expert testimony in this case, although Plaintiff does anticipate taking
Oficer Gutierrez’s deposition in this case.
It is expected Oflicer Gutierrez will have knowledge including, but not necessarily
limited t0, thefollowingfacts:
Officer Gutierrez is expected t0 be aware that Raul Canales was involved in a
collision 0n September I2, 2018.
Officer Gutierrez is expected lo be aware ofcmyfacts contained within his report
concerning the collision in question.
Oflicer Gutierrez will be aware offacts based upon his investigation concerning
the collision in question.
Officer Gutierrez is expected t0 address his conclusions contained in his
investigative report that Defendant Sebastian Macias failed t0 control the speed
0f his tractor trailer and took faulty evasive action, which were the only
contributingfactors causing the collision.
You are referred t0 the investigative report from Oflicer Gutierrez for more
detailed information about the substance oftestimony.
194.2m(4) (A) Not applicable as Officer Gutierrez isnot retained by, employed by, 0r otherwise
subject to the control ofPlaintiff
194.20%4) w) Not applicable as Gutierrez Chia is not retained by, employed by, 0r otherwise
subject t0 the control ofPlaintg'ff
194.2090) Whitney Morgan
MCSC, Inc.
2229 First Avenue North
Birmingham, Alabama 35203
Phone: (205) 871-4455
194.2090) Subject matter: Whitney Morgan is a consultant in motor carrier safely andfor
companies operating commercial motor vehicles. Whitney Morgan Specializes in
compliance with Title 49 0f the Code 0f Federal Regulations and establishes
safely compliance programs t0 improve company safezfyfimess standards, as well
as reduce highway accidents and incidents through compliance, education, and
training in all applicable safety and hazardous materials regulations.
Whitney Morgan is expected t0 testifiz t0 his expertise and credentials. Whitney
Plaintiffis’ Designation ofExpert Witnesses Page 11
Morgan is expected t0 testify in the areas 0f commercial motor vehicle
compliance, enforcement, and safely 0f operations. Whitney Morgan will likely
testifi/ regarding the safe operation 0f commercial motor vehicles and the
applicable standardfor the training Ofcommercial motor vehicle drivers. He will
likely testifi/ t0 his opinion related t0 whether Defendant safely operated his
commercial motor vehicle at the time 0f the collision made the basis 0f this
lawsuit and whether that operation meets the applicable safely standards. He is
expected t0 base his testimony upon his education, training, experience, and
knowledge 0f the events that occurred related t0 the incident made the basis 0f
this lawsuit. In addition, Whitney Morgan will likely testifi/ t0 the types 0f
documents required t0 be maintained by Motor Carriers and the driver’s they
employ. Whitney Morgan will likely offer testimony as t0 whether Defendant
complied with the applicable regulations related t0 document retention. Whitney
’
Morgan will likely offer testimony as t0 Defendant Sebastian Macias employment
status with a motor carrier at the time 0fthe collision made the basis 0fthis suit.
Whitney Morgan ’s testimony is expected t0 include, but not necessarily be limited
t0, the following topics: motor carrier safely and safety regarding the operation
0f commercial motor vehicles, compliance with Title 49 0f the Code ofFederal
Regulations, safety compliance programs t0 improve company safety fitness
standards, as well as reduce highway accidents and incidents through
compliance, education, and training in all applicable safety and hazardous
materials regulations.
It is anticipated that Whitney Morgan will testifi/ in conformity with his report.
Whitney Morgan’s will provide opinions and testimony regarding any potential
causes 0f the incident in question and his thought processes in arriving at his
conclusions.
194.2m(3) Whitney Morgan has been retained by Plaintiflto provide expert testimony z'nthis
case.
It is expected Whitney Morgan will have knowledge including, but not necessarily
limited t0, thefollowingfacts:
Whitney Morgan is expected t0 be aware that Raul Canales was involved in a
collision 0n September I2, 2018 and the circumstances 0fthat incident.
Whitney Morgan is expected t0 testify that MS Transportation, Inc. failed t0 have
the necessary safety management controls in place and functioning t0 meet the
safely fitness standards, t0 comply with the applicable safety regulations, and t0
reduce the risks associated with commercial motor vehicle accidents with regard
t0 the operations 0f Defendant Sebastian Macias. Whitney Morgan is further
’
expected t0 testify that that Defendant Sebastian Macias actions and/or inactions
demonstrated a conscious disregardfor the safety ofoperations, as well asfor the
other motorists, including Plaintszs; and that Defendant MS Transportation, Inc.
’
and Defendant Sebastian Macias actions caused and/or contributed 2‘0 the cause
0fthe incident.
Plaintiffls’ Designation ofExpert Witnesses Page 12
You are referred t0 the report from Whitney Morgan produced 0n November 25,
2020f0r more detailed information about the substance oftestimony.
194.20)(4) (B) Please see Whitney Morgan ’s current resume and bibliography produced 0n
November 25, 2020.
I94.209(1) David A. Macpherson, Ph.D.
EM. Stevens Professor ofEconomics, Trinity University
Chair ofEconomics Department, Trinity University
Trinity University
One Trinity Place
San Antonio, TX 78212
(210) 863-4808
194.2(f)(2) Subject matter: David Macpherson is an economist with a PhD. in economics
from Pennsylvania State University. David Macpherson serves as an EM Stevens
Professor 0f Economics and the Chair 0f the Economics Department at Trinity
University.
David Macpherson’s testimony is expected t0 include, but not necessarily be
limited t0, thefollowing topics: his expertise and credentials, economic damages,
lost wages, past andfuture wage earning capacity, lost wage earning capacity,
and the economic impact 0fthe incident.
It is anticipated that David Macpherson will testifi/ in conformity with his report.
The deposition 0f David Macpherson has not been taken. However, Plaintiff
reserves the right to amend his designation after his deposition has been taken.
Plaintiflalso reserves his right t0 amend 0r supplement his designation t0 reflect
his opinions after his review 0f any future deposition transcripts 0r discovery
responses in connection with this case.
194.20%3) David Macpherson has been retained by Plaintifl t0 provide expert testimony in
this case.
It is expected David Macpherson will have knowledge including, but not
necessarily limited t0, thefollowingfacts:
David Macpherson is expected t0 be aware that Raul Candles was involved in an
incident 0n September I2, 2018.
David Macpherson is expected t0 testifi/ that he relied 0n certain assumptions and
how he arrived at those assumptions based 0n the information he has obtained
related t0 Raul Candles as well as his knowledge, training, skill, education and
experience. He is expected t0 address his finding that Raul Canales preinjury
yearly earning capacity was $45,344 in 2019; that his post—injury earning
Plaintiffls’ Designation ofExpert Witnesses Page 13
capacity is $0; and that his years 0f work—life expectancy was 21.58 with a
retirement age 0f66.54.
David Macpherson isexpected t0 testifi/ that the present value ofRaul Canales’
lost earnings is $1,231,859; the present value 0f loss 0f household services is
$14,863; and the combined total oflhese losses is $1,246, 722.
You are referred t0 the report from David Macpherson produced 0n November
25, 2020f0r more detailed information about the substance oftestimony.
194.209(4)$) Please see David Macpherson’s current resume and bibliography produced 0n
November 25, 2020.
NAME, ADDRESS & PHONE
SUBJECT MATTER & RETAINED /
GENERAL SUBSTANCE 0F TESTIMONY NON-RETAINED
194.2(t)(1)
Rule 194.2(i)(2 & 3) Rule 194.(f)(4)
Naiyer Imam, MD Subject matter: Medical issues, injury causation and Non—retained
Phillip McDonald, MD medical billing
Andrea Flores, custodian of records
American Dynamic Imaging General substance of testimony: This healthcare provider
9627 HUEBNER ROAD, SUITE 100 isexpected to testify Via medical records and/or in person
SAN ANTONIO, TX 78240 regarding the injuries suffered by plaintiff, the causal
Phone: 210-690-3400 relationship between the collision in question and the
injuries suffered by plaintiff, the reasonable and necessary
medical care and treatment for those injuries and the effect
that the injuries have had and will have on plaintiff‘slife.
You are referred to the records from this healthcare
provider for more detailed infomation about the
substance of testimony.
The custodian(s) of records is expected to testify Via
affidavit pursuant t0 CPRC Ch. 18.001 that the service
provided by this healthcare provider was necessary and
the amount charged for the service was reasonable at the
time and place that the service was provided.
Richard Anguiano, MD Subject matter: Medical issues, injury causation and Non—retained
Hanna Slomik, custodian of records medical billing
American Health Imaging, LLC
2200 CENTURY PKWY NE, STE. 600 General substance of testimony: This healthcare provider
ATLANTA, GA 30345 isexpected to testify Via medical records and/or in person
PHONE: (404) 297-5237 regarding the injuries suffered by plaintiff, the causal
relationship between the collision in question and the
injuries suffered by plaintiff, the reasonable and necessary
medical care and treatment for those injuries and the effect
that the injuries have had and Will have on plaintiff‘s life.
You are referred to the records from this healthcare
provider for more detailed information about the
substance 0f testimony.
Plaintiffis’ Designation ofExpert Witnesses Page 14
The custodian(s) 0f records is expected t0 testify via
affidavit pursuant t0 CPRC Ch. 18.001 that the service
provided by this healthcare provider was necessary and
the amount charged for the service was reasonable at the
time and place that the service was provided.
Christopher Bracken, MD Subject matter: Medical issues, injury causation and Non—retained
Sherry Gray, custodian 0f records medical billing
EmergencHealth
P.O. BOX 207529 General substance of testimony: This healthcare provider
DALLAS, TX 75320 isexpected t0 testify Via medical records and/or in person
Phone: 817-516-8811 regarding the injuries suffered by plaintiff, the causal
Preview
CAUSE NO. C—5246-19-D RAUL J. CANALES § IN THE DISTRICT COURT OF § Plaintiff § § V- § § HIDALGO COUNTY, TEXAS MS TRANSPORTATION, LLC AND § SEBASTMN S. MACIAS § § Defendants. § 206th JUDICIAL DISTRICT EXHIBIT “B ” 194.20)(1) Sanjay Misra, MD Orthopedic Center ofSan Antonio 315 NSANSABA, SUITE 1175 SANANTONIO, TX 78207 Phone: 21 0-2 70-9999 ’ 194.20%2) Subject matter: Dr. Misra is one ofRaul Canales treating medical providers. Dr. Misra 1's a board-certified orthopedic surgeon. Dr. Misra is expected to base his testimony 0f a reasonable degree 0f medical probability based upon his education, training, experience and treatment ofRaul Candles. Dr. Misra ’s testimony is expected t0 include, but not necessarily be limited t0, the following topics, Raul Canales’ injuries, medical conditions, and diagnoses, the cause 0f Raul Canales’ injuries, conditions, and diagnoses, diagnostic testing which was administered t0 Raul Candles, medical treatments which Raul Canales received, medical treatment which may have been recommended t0 Raul Candles but he has not received, the reasonable and necessary costs 0f medical treatment ’ and services, the necessity ofany discussed medical treatment and Raul Candles future prognosis, including any possible medical treatment, pain, impairment, limitation and disability, ifany. Dr. Misra will provide opinions and testimony regarding the causal relationship between the collision in question and the injuries suflered by Raul Candles, the reasonable and necessary medical care and treatmentfor those injuries and the efiect that the injuries have had and will have 0n Raul Canales’ life. Dr. Misra will provide opinions and testimony regarding any injury Raul Candles may have suflered in his lumbar Spine and left Shoulder as a result 0f this collision. Dr. Misra will likely address whether the collision made the basis 0f ’ this suit aggravated any preexisting condition in Raul Canales lumbar Spine and left shoulder. Plaintiffis’ Designation ofExpert Witnesses Page 4 [9420(3) Dr. Misra has not been retained, employed 0r otherwise subject t0 the control 0f Plaintiff t0 provide expert testimony in this case, although Plaintfi does ’s anticipate taking Dr. Misra deposition in this case. Please see Dr. Misra’s medical records for mental impressions and opinions 0f the witnesses. It is expected Dr. Misra will have knowledge including, but not necessarily limited t0, thefollowingfacts: Dr. Misra is expected t0 be aware that Raul Canales was involved in a collision 0n September I2, 2018. Dr. Misra is expected t0 be aware 0f any facts contained within the medical history he obtainedfrom Raul Candles. Dr. Misra will be aware offacts based upon his multiple physical examinations 0f Raul Candles. Dr. Misra will be aware offacts contained with his medical records and medical records ofotherproviders who treated Raul Candles which he has obtained. Dr. Misra will be aware offacts resultingfrom an MRI 0fthe lumbar Spine which Raul Candles underwent 0n October 22, 2018 and an MRI 0f the left Shoulder that Raul Candles underwent 0n May 13, 2019. Dr. Misra will be aware Raul Canales was diagnosed with a 5 t0 6-millimeler disc herniation at LI/2; a 4 t0 5-millimeter disc herniation at L2/3; a 5 t0 6- millimeter disc herniation at L3/4; a 6-millimeter disc herniation tL4/5; and a 5 to 6-millimeter disc herniation at L5/S1. Dr. Misra will also be aware Raul Candles was diagnosed with a torn muscle runningfrom the shoulder blade t0 the left arm. Dr. Misra is expected to be aware that Raul Canales received physical therapy, anti-inflammatory medications, and various injections in the lumbar region and left shoulder with minimal relief Dr. Misra is expected t0 be aware that Raul Candles continued with severe lumbar pain and left shoulder pain in Spite 0f conservative measures. Dr. Misra is expected t0 be aware that 0n April 26, 2019, Raul Canales received bilateral lumbar median branch blocks at L3/4 and L4/5; 0n May 10, 2019, Raul Candles received an L3/4 and L4/5 left—sz'ded lumbar radiofrequency thermocoagulation injection; and 0n May 14, 2019, Raul Candles received a right-sided lumbar medial branch radiofrequency thermocoagulation injection at L2, L3, and L4. Additionally, Dr. Misra is expected t0 be aware that 0n July 5, 2019, Raul Candles received a left shoulder epidural steroid injection. Plaintiffls’ Designation ofExpert Witnesses Page 5 Dr. Misra recommended surgical procedures t0 Raul Candles. It is expected Dr. Misra will describe the nature offhese procedures to Raul Candles, including but not limited to, potential risks and complications 0fthese procedures. 0n July 23, 2019, Dr. Misra performed a lumbar epidural steroid injection; 0n July 25, 2019, Dr. Misra performed a cervical epidural steroid injection; and 0n September 30, 2019, Dr. Misra peiformed a lumbar microdiscectomy, hemilaminotomy, and nerve root decompression with foramz'notomy at L2/3, L3/4, L4/5, and L5/SI; and immediately following lumbar spine surgery, Dr. Misra performed a left shoulder rotator cufl repair surgery Dr. Misra is expected t0 testifi/ regarding how he performed these surgical procedures 0n Raul Candles, the reason he peiformed these surgeries, what made the surgery necessary in ’ Raul Canales situation and the reasonable and necessary cost 0fthese surgeries. Dr. Misra is expected t0 address the necessity 0f other medical treatment he administered t0 Raul Canales and the reasonable cost 0fthat medical treatment. Dr. Misra may address the necessity 0f medical treatment administered t0 Raul Candles by otherproviders and the reasonable cost offhat medical treatment. You are referred t0 the records from Dr. Misra for more detailed information about the substance oftestimony. Dr. Misra may address injuries sustained by Raul Candles that he may not have treated. ’ Forfurther information regarding Raul Canales medical conditions, please see medical and billing records. 194.20)(4)(A) Not applicable as Dr. Misra is not retained by, employed by, 0r otherwise subject t0 the control ofPlaintiff [9420(4) (B) Not applicable as Dr. Misra is not retained by, employed by, 0r otherwise subject t0 the control ofPlaintz'flT 194mm Dr. Sam Li, MD Quantum Pain and Orthopedics 8626 TESORO DRIVE, SUITE 112 SANANTONIO, TX 78217 Phone: 210-81 7—601 0 194.2(f)(2) Subject matter: Dr. Li is one ofRaul Candles and Ezequiel Rosales Gonzalez’s treating medical providers. Dr. Li is expected t0 base his testimony 0f a reasonable degree 0f medical Plaintiffis’ Designation ofExpert Witnesses Page 6 probability, based upon his education, training, experience and treatment ofRaul Candles and Ezequiel Rosales Gonzalez. Dr. Li’s testimony is expected t0 include, but not necessarily be limited t0, the following topics, Raul Candles and Ezequiel Rosales Gonzalez’s injuries, medical conditions, and diagnoses, the cause 0f Raul Canales and Ezequiel Rosales Gonzalez’s injuries, conditions and diagnoses, diagnostic testing which was administered t0 Raul Candles and Ezequiel Rosales Gonzalez, medical treatments which Raul Candles and Ezequiel Rosales Gonzalez received, medical treatment which may have been recommended t0 Raul Candles and Ezequiel Rosales Gonzalez but they have not received, the reasonable and necessary costs 0f medical treatment and services, the necessity 0f any discussed medical treatment and Raul Candles and Ezequiel Rosales Gonzalez’s future prognosis, including anypossible medical treatment, pain, impairment, limitation and disability, ifany. Dr. Li will provide opinions and testimony regarding the causal relationship between the collision in question and the injuries suffered by Raul Candles and Ezequiel Rosales Gonzalez, the reasonable and necessary medical care and treatmentfor those injuries and the effect that the injuries have had and will have 0n Raul Candles and Ezequiel Rosales Gonzalez’s lives. Dr. Li will provide opinions and testimony regarding any injury Raul Candles and Ezequiel Rosales Gonzalez may have sufi’ered as a result 0fthis collision. Dr. Li will likely address whether the collision made the basis 0fthis suit aggravated any preexisting condition in Raul Candles and Ezequiel Rosales Gonzalez ’s spine and shoulders. 194.2m(3) Dr. Li has not been retained, employed 0r otherwise subject t0 the control 0f Plaintiffto provide expert testimony in this case. Please see Dr. Li’s medical records for mental impressions and opinions 0f the witnesses. It is expected Dr. Li will have knowledge including, but not necessarily limited t0, thefollowingfacts: Dr. Li isexpected t0 be aware that Raul Candles and Ezequiel Rosales Gonzalez were involved in a collision 0n September I2, 2018. Dr. Li is expected t0 be aware ofanyfacts contained within the medical history he obtainedfrom Raul Candles and Ezequiel Rosales Gonzalez. Dr. Li will be aware offacts based upon his multiple physical examinations 0f Raul Candles and Ezequiel Rosales Gonzalez. Dr. Li will be aware offacts contained with his medical records and medical records 0f other providers who treated Raul Candles and Ezequiel Rosales Gonzalez which he has obtained. Plaintiffls’ Designation ofExpert Witnesses Page 7 Dr. Li is expected t0 be aware that 0n November 9, 2018 and December 21, 2018, he administered cervical epidural steroid injections t0 Raul Candles; 0n April 26, 2019, he performed bilateral lumbar median branch blocks at L3/4 and L4/5; 0n May 10, 2019, he performed an L3/4 and L4/5 left-sided lumbar radiofrequency thermocoagulation injection; 0n May I4, 2019, Dr. Li performed a right—sided lumbar medial branch radiofrequency thermocoagulation injection at L2, L3, and L4; and 0n July 5, 2019, Dr. Li performed a left shoulder epidural steroid injection. Dr. Li is expected t0 describe how these procedures were performed and the purpose 0fthese procedures. Dr. Li is expected t0 be aware that 0n November 9, 2018 and December 21, 2018, he administered cervical epidural steroid injections t0 Ezequiel Rosales Gonzalez. Dr. Li is expected t0 describe how these procedures were performed and the purpose 0fthese procedures. Dr. Li is expected t0 address the necessity 0f other medical treatment he administered t0 Raul Candles and Ezequiel Rosales Gonzalez and the reasonable cost 0fthat medical treatment. Dr. Li may address the necessity 0f medical treatment administered t0 Raul Candles and Ezequiel Rosales Gonzalez by other providers and the reasonable cost 0fthat medical treatment. You are referred to the records from Dr. Lifor more detailed information about the substance oftestimony. Dr. Li may address injuries sustained by Raul Candles and Ezequiel Rosales Gonzalez that he may not have treated. Forfurther information regarding Raul Candles and Ezequiel Rosales Gonzalez ’s medical conditions, please see medical and billing records. I94.209(4)(A) Not applicable as Dr. Li is not retained by, employed by, 0r otherwise subject t0 the control ofPlaintiff.‘ 194.2€)(4)(B) Not applicable as Dr. Li is not retained by, employed by, 0r otherwise subject t0 the control ofPlaintifi’. 194.2090) Dr. Edward Lee, MD Quantum Pain and Orthopedics 8626 TESORO DRIVE, SUITE 112 SANANTONIO, TX 78217 Phone: 210-81 7-601 0 194.2090) Subject matter: Dr. Lee is one oszequz'el Rosales Gonzalez ’s treating medical Plaintiffls’ Designation ofExpert Witnesses Page 8 providers. Dr. Lee is expected t0 base his testimony of a reasonable degree 0f medical probability, based upon his education, training, experience and treatment of Ezequiel Rosales Gonzalez. Dr. Lee’s testimony is expected t0 include, but not necessarily be limited t0, the following topics, Ezequiel Rosales Gonzalez’s injuries, medical conditions, and diagnoses, the cause 0f Ezequiel Rosales Gonzalez’s injuries, conditions and diagnoses, diagnostic testing which was administered to Ezequiel Rosales Gonzalez, medical treatments which Ezequiel Rosales Gonzalez received, medical treatment which may have been recommended t0 Ezequiel Rosales Gonzalez but he has not received, the reasonable and necessary costs 0f medical treatment and services, the necessity 0f any discussed medical treatment and Ezequiel Rosales Gonzalez’s future prognosis, including any possible medical treatment, pain, impairment, limitation and disability, ifany. Dr. Lee will provide opinions and testimony regarding the causal relationship between the collision in question and the injuries suflered by Ezequiel Rosales Gonzalez, the reasonable and necessary medical care and treatment for those injuries and the efi’ect that the injuries have had and will have 0n Ezequiel Rosales Gonzalez ’s lives. Dr. Lee will provide opinions and testimony regarding any injury Ezequiel Rosales Gonzalez may have suffered as a result 0f this collision. Dr. Lee will likely address whether the collision made the basis 0f this suit aggravated any preexisting condition in Ezequiel Rosales Gonzalez’s right shoulder. 194.20%3) Dr. Lee has not been retained, employed 0r otherwise subject t0 the control 0f Plaintiffto provide expert testimony in this case. Please see Dr. Lee ’s medical recordsfor mental impressions and opinions 0fthe witnesses. It is expected Dr. Lee will have knowledge including, but not necessarily limited t0, thefollowingfacts: Dr. Lee is expected t0 be aware that Ezequiel Rosales Gonzalez was involved in a collision 0n September 12, 2018. Dr. Lee is expected t0 be aware ofanyfacts contained within the medical history he obtainedfrom Ezequiel Rosales Gonzalez. Dr. Lee will be aware offacts contained with his medical records and medical records 0f other providers who treated Ezequiel Rosales Gonzalez which he has obtained. Plaintiffls’ Designation ofExpert Witnesses Page 9 Dr. Lee is expected t0 be aware that 0n April 6, 2019, Ezequiel Rosales Gonzalez underwent an epidural steroid injection to his right Shoulder. Dr. Lee is expected t0 testifi/ that Ezequiel Rosales Gonzalez continued with severe pain despite this treatment. Dr. Lee is expected t0 testifi} that he recommended a right shoulder arthroscopy for Ezequiel Rosales Gonzalez and that the surgical cost estimatefor this surgery is $67,000. You are referred t0 the recordsfrom Dr. Leefor more detailed information about the substance oftestimony. I94.209(4) (A) Not applicable as Dr. Lee 1's not retained by, employed by, 0r otherwise subject t0 the control ofPlaintijj”. 194.20%4) (B) Not applicable as Dr. Lee is not retained by, employed by, 0r otherwise subject t0 the control ofPlaintijf 194.2m(1) Modesto Gutierrez; 1D N0. 0266 San Antonio Police Department 13030 Jones Maltsberger Rd, San Antonio, TX 78247 Phone: (210) 207-8126 194.2(fl(2) Subject matter: Ofiicer Gutierrez is the investigating officer 0f the crash that occurred 0n September 12, 2018. Officer Gutierrez 1's an investigator with the San Antonio Police Department. Uficer Gutierrez is expected t0 base his testimony upon his education, training, experience, and knowledge 0f the events that occurred related t0 the collision made the basis 0fthz's lawsuit. Officer Gutierrez’s testimony is expected t0 include, but not necessarily be limited t0, the following topics: investigative protocols, investigative techniques, and evidence gathered during motor vehicle collision investigations. Oflicer Gutierrez’s testimony is expected t0 include any cause(s) and/or contributing factors 0f the collision in question; his investigation and conclusions concerning the collision in question; any evidence he discovered regarding the collision; questioning 0f the parties and/or witnesses and technique in doing so; his assessment 0f the severity 0f any parties injuries at the scene 0f the collision in question; rules and regulations 0f the Texas Department 0f Transportation; and his report offhe collision in question. Officer Gutierrez will provide opinions and testimony regarding any potential causes 0f the collision in question and his thought processes in arriving at his Plaintiffis’ Designation ofExpert Witnesses Page 10 conclusions. 194.2098) Oflicer Gutierrez has not been retained 0r specially employed by Plaintifl t0 provide expert testimony in this case, although Plaintiff does anticipate taking Oficer Gutierrez’s deposition in this case. It is expected Oflicer Gutierrez will have knowledge including, but not necessarily limited t0, thefollowingfacts: Officer Gutierrez is expected t0 be aware that Raul Canales was involved in a collision 0n September I2, 2018. Officer Gutierrez is expected lo be aware ofcmyfacts contained within his report concerning the collision in question. Oflicer Gutierrez will be aware offacts based upon his investigation concerning the collision in question. Officer Gutierrez is expected t0 address his conclusions contained in his investigative report that Defendant Sebastian Macias failed t0 control the speed 0f his tractor trailer and took faulty evasive action, which were the only contributingfactors causing the collision. You are referred t0 the investigative report from Oflicer Gutierrez for more detailed information about the substance oftestimony. 194.2m(4) (A) Not applicable as Officer Gutierrez isnot retained by, employed by, 0r otherwise subject to the control ofPlaintiff 194.20%4) w) Not applicable as Gutierrez Chia is not retained by, employed by, 0r otherwise subject t0 the control ofPlaintg'ff 194.2090) Whitney Morgan MCSC, Inc. 2229 First Avenue North Birmingham, Alabama 35203 Phone: (205) 871-4455 194.2090) Subject matter: Whitney Morgan is a consultant in motor carrier safely andfor companies operating commercial motor vehicles. Whitney Morgan Specializes in compliance with Title 49 0f the Code 0f Federal Regulations and establishes safely compliance programs t0 improve company safezfyfimess standards, as well as reduce highway accidents and incidents through compliance, education, and training in all applicable safety and hazardous materials regulations. Whitney Morgan is expected t0 testifiz t0 his expertise and credentials. Whitney Plaintiffis’ Designation ofExpert Witnesses Page 11 Morgan is expected t0 testify in the areas 0f commercial motor vehicle compliance, enforcement, and safely 0f operations. Whitney Morgan will likely testifi/ regarding the safe operation 0f commercial motor vehicles and the applicable standardfor the training Ofcommercial motor vehicle drivers. He will likely testifi/ t0 his opinion related t0 whether Defendant safely operated his commercial motor vehicle at the time 0f the collision made the basis 0f this lawsuit and whether that operation meets the applicable safely standards. He is expected t0 base his testimony upon his education, training, experience, and knowledge 0f the events that occurred related t0 the incident made the basis 0f this lawsuit. In addition, Whitney Morgan will likely testifi/ t0 the types 0f documents required t0 be maintained by Motor Carriers and the driver’s they employ. Whitney Morgan will likely offer testimony as t0 whether Defendant complied with the applicable regulations related t0 document retention. Whitney ’ Morgan will likely offer testimony as t0 Defendant Sebastian Macias employment status with a motor carrier at the time 0fthe collision made the basis 0fthis suit. Whitney Morgan ’s testimony is expected t0 include, but not necessarily be limited t0, the following topics: motor carrier safely and safety regarding the operation 0f commercial motor vehicles, compliance with Title 49 0f the Code ofFederal Regulations, safety compliance programs t0 improve company safety fitness standards, as well as reduce highway accidents and incidents through compliance, education, and training in all applicable safety and hazardous materials regulations. It is anticipated that Whitney Morgan will testifi/ in conformity with his report. Whitney Morgan’s will provide opinions and testimony regarding any potential causes 0f the incident in question and his thought processes in arriving at his conclusions. 194.2m(3) Whitney Morgan has been retained by Plaintiflto provide expert testimony z'nthis case. It is expected Whitney Morgan will have knowledge including, but not necessarily limited t0, thefollowingfacts: Whitney Morgan is expected t0 be aware that Raul Canales was involved in a collision 0n September I2, 2018 and the circumstances 0fthat incident. Whitney Morgan is expected t0 testify that MS Transportation, Inc. failed t0 have the necessary safety management controls in place and functioning t0 meet the safely fitness standards, t0 comply with the applicable safety regulations, and t0 reduce the risks associated with commercial motor vehicle accidents with regard t0 the operations 0f Defendant Sebastian Macias. Whitney Morgan is further ’ expected t0 testify that that Defendant Sebastian Macias actions and/or inactions demonstrated a conscious disregardfor the safety ofoperations, as well asfor the other motorists, including Plaintszs; and that Defendant MS Transportation, Inc. ’ and Defendant Sebastian Macias actions caused and/or contributed 2‘0 the cause 0fthe incident. Plaintiffls’ Designation ofExpert Witnesses Page 12 You are referred t0 the report from Whitney Morgan produced 0n November 25, 2020f0r more detailed information about the substance oftestimony. 194.20)(4) (B) Please see Whitney Morgan ’s current resume and bibliography produced 0n November 25, 2020. I94.209(1) David A. Macpherson, Ph.D. EM. Stevens Professor ofEconomics, Trinity University Chair ofEconomics Department, Trinity University Trinity University One Trinity Place San Antonio, TX 78212 (210) 863-4808 194.2(f)(2) Subject matter: David Macpherson is an economist with a PhD. in economics from Pennsylvania State University. David Macpherson serves as an EM Stevens Professor 0f Economics and the Chair 0f the Economics Department at Trinity University. David Macpherson’s testimony is expected t0 include, but not necessarily be limited t0, thefollowing topics: his expertise and credentials, economic damages, lost wages, past andfuture wage earning capacity, lost wage earning capacity, and the economic impact 0fthe incident. It is anticipated that David Macpherson will testifi/ in conformity with his report. The deposition 0f David Macpherson has not been taken. However, Plaintiff reserves the right to amend his designation after his deposition has been taken. Plaintiflalso reserves his right t0 amend 0r supplement his designation t0 reflect his opinions after his review 0f any future deposition transcripts 0r discovery responses in connection with this case. 194.20%3) David Macpherson has been retained by Plaintifl t0 provide expert testimony in this case. It is expected David Macpherson will have knowledge including, but not necessarily limited t0, thefollowingfacts: David Macpherson is expected t0 be aware that Raul Candles was involved in an incident 0n September I2, 2018. David Macpherson is expected t0 testifi/ that he relied 0n certain assumptions and how he arrived at those assumptions based 0n the information he has obtained related t0 Raul Candles as well as his knowledge, training, skill, education and experience. He is expected t0 address his finding that Raul Canales preinjury yearly earning capacity was $45,344 in 2019; that his post—injury earning Plaintiffls’ Designation ofExpert Witnesses Page 13 capacity is $0; and that his years 0f work—life expectancy was 21.58 with a retirement age 0f66.54. David Macpherson isexpected t0 testifi/ that the present value ofRaul Canales’ lost earnings is $1,231,859; the present value 0f loss 0f household services is $14,863; and the combined total oflhese losses is $1,246, 722. You are referred t0 the report from David Macpherson produced 0n November 25, 2020f0r more detailed information about the substance oftestimony. 194.209(4)$) Please see David Macpherson’s current resume and bibliography produced 0n November 25, 2020. NAME, ADDRESS & PHONE SUBJECT MATTER & RETAINED / GENERAL SUBSTANCE 0F TESTIMONY NON-RETAINED 194.2(t)(1) Rule 194.2(i)(2 & 3) Rule 194.(f)(4) Naiyer Imam, MD Subject matter: Medical issues, injury causation and Non—retained Phillip McDonald, MD medical billing Andrea Flores, custodian of records American Dynamic Imaging General substance of testimony: This healthcare provider 9627 HUEBNER ROAD, SUITE 100 isexpected to testify Via medical records and/or in person SAN ANTONIO, TX 78240 regarding the injuries suffered by plaintiff, the causal Phone: 210-690-3400 relationship between the collision in question and the injuries suffered by plaintiff, the reasonable and necessary medical care and treatment for those injuries and the effect that the injuries have had and will have on plaintiff‘slife. You are referred to the records from this healthcare provider for more detailed infomation about the substance of testimony. The custodian(s) of records is expected to testify Via affidavit pursuant t0 CPRC Ch. 18.001 that the service provided by this healthcare provider was necessary and the amount charged for the service was reasonable at the time and place that the service was provided. Richard Anguiano, MD Subject matter: Medical issues, injury causation and Non—retained Hanna Slomik, custodian of records medical billing American Health Imaging, LLC 2200 CENTURY PKWY NE, STE. 600 General substance of testimony: This healthcare provider ATLANTA, GA 30345 isexpected to testify Via medical records and/or in person PHONE: (404) 297-5237 regarding the injuries suffered by plaintiff, the causal relationship between the collision in question and the injuries suffered by plaintiff, the reasonable and necessary medical care and treatment for those injuries and the effect that the injuries have had and Will have on plaintiff‘s life. You are referred to the records from this healthcare provider for more detailed information about the substance 0f testimony. Plaintiffis’ Designation ofExpert Witnesses Page 14 The custodian(s) 0f records is expected t0 testify via affidavit pursuant t0 CPRC Ch. 18.001 that the service provided by this healthcare provider was necessary and the amount charged for the service was reasonable at the time and place that the service was provided. Christopher Bracken, MD Subject matter: Medical issues, injury causation and Non—retained Sherry Gray, custodian 0f records medical billing EmergencHealth P.O. BOX 207529 General substance of testimony: This healthcare provider DALLAS, TX 75320 isexpected t0 testify Via medical records and/or in person Phone: 817-516-8811 regarding the injuries suffered by plaintiff, the causal