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CAUSE NO. 2017-25488
WEMBERTH FERRAZ IN THE DISTRICT COURT
VSS. HARRIS COUNTY, TEXAS
TIFFANI MICHELLE ABSHIRE § JUDICIAL DISTRICT
CAUSE NO. 2018-29917
LISA MASTERS IN THE DISTRICT COURT
VS. HARRIS COUNTY, TEXAS
TIFFANI ABSHIRE JUDICIAL DISTRICT
PLAINTIFF’S HIRDSUPPLEMENTALDESIGNATION
XPERT WITNESSESSUPPLEMENTAL DISCLOSURE
ocket
xpertnd
losures afollows:
RULE 194.2(f): For all testifying experts:
(1) he expert’s name, address and telephone number;
(2) The subject matter on which the expert will testify;
(3) The general substance of the expert’s mental impressions and opinions and a
brief summary of the basis for them, or if the expert is not retained by, em-
ployed by, or otherwise subject to the control of the responding party, docu
ments reflecting such information;
(4) If the expert is retained by, employed by, or otherwise subject to your control:
(A) All documents, tangible things, reports, models, or data compilations
that have been provided to, reviewed by, or prepared by or for the
expert in anticipation of the expert’s testimony; and
(B) The expert’s current resume and bibliography.
RESPONSE:
Plaintiff incorporates herein by reference Plaintiff’s Response to Defendant’s Request for
Disclosures (and all amendments and supplements thereto), together with all other discovery re-
sponses previously served on Defendant, and designates expert witnesses as follows:
hird Designation of Expert Witnesses Page 1 of
laintiff’s Treating Physicians
and Other Persons with Knowledge of Relevant Facts
Who May Qualify as Experts but Have Not
Been Specially Retained
(Fact Experts - Tex. R. Civ. P. 194.2(f))
he following person(s), or their custodian(s) of records, have not been retained by and are
not employed by, or are otherwise subject to the control of Plaintiff (hereinafter referred to as
“non retained” experts), but are hereby designated as testifying experts by Plaintiff and the fol-
lowing information is provided in accordance with Texas Rule of Civil Procedure 194.2.
lthough these witnesses have not been specifically retained as expert witnesses by Plain-
tiff, and while Plaintiff cannot vouch for the expertise or credibility of such witnesses at this time,
it is believed that they may have knowledge, training or expertise which may qualify them as
experts. Accordingly, Plaintiff will designate these witnesses as persons who may be called upon
to give testimony that would be considered expert testimony.
RETAINED MEDICAL EXPERTS. The following healthcare providers,
and/or the custodian(s) of their records, may testify regarding the injuries sustained by Plaintiff
as a result of the incident made the subject of this suit, their medical diagnosis, prognosis and the
reasonable and necessary cost of hospital, doctor and medical bills for treatment of Plaintiff’s in-
juries in the past and in the future. Please refer to the healthcare providers’ records for their
mental impressions, opinions, conclusions, and the factual basis for each opinion.
1. Identity of Non Retained Medical Experts. The names of Plaintiff’s non re-
tained, non controlled medical experts and their addresses and telephone numbers are as fol-
lows:
HE FOLLOWING INDIVIDUALS AND ENTITIES AND THEIR CURRENT AND
FORMER OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVANTS, PHYSI-
CIANS, NURSES, PARAMEDICS, EMTs, ATTENDANTS, STAFF, HEALTHCARE
PROVIDERS, AND CUSTODIANS OF RECORDS:
ll Florida Family and Sports Medicine PA
Ahmed Aidoo, M.D., MPH
3501 13 Street
Saint Cloud, Florida 34769
407-891-6463
entral Florida Neurosurgery Institute
Hyndaldo V llalobos, MD
801 N. Orange Ave., Suite 720
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Orange, Florida 32832
407-288-8638
ast Lake Chiropractic and Injury Center, Inc.
Westin Schmidt, D.C.
Cristopher McNichols, D.C.
Street
St. Cloud, Florida 34769
407-957-9995
avita Medical Group
JSA Healthcare Corporation
Yvonne Boston, NP
Munir Ammari, PA
Megha Parekh, PA
Donna S. Lester, MD
Efrain Segura, M
Street
St. Cloud, Florida 34759
407-957-0090
imonMed
Andrew Akerman, M.D.
208 West Oak
Kissimmee, Florida 34741
407-846-8700
ynergy Radiology
Arif Rahman, M.D.
7026 Old Katy Road, Suite 276
Houston, Texas 77024
713-621-7436
exas Emergency Care Center
Greg Hall, D.O.
Marvin Rogers, R.N.
P.O. Box 3401
Dept. 10
Houston, Texas 77253
832-653-3200
uest Diagnostics PSC
Street
Saint Cloud, Florida 34769
407-891-0341
Wi eCare of Florida
hird Designation of Expert Witnesses Page 3 of
Ahmed Aidoo, MD, MPH
Street
St. Cloud, Florida 34769
Gustavo Arriola, M.D.
905 N. Central Ave.
Kissimmee, Florida 34741
AdventHealth
Sean Dodson, M.D.
2450 N. Orange Blossom Trail
Kissimmee, Florida 34744
Professional Imaging Centers
911 E. Oak St.
Kissimmee, Florida 34744
Rose Healthcare Centre, P.A.
6638 Old Winter Garden Road
Orlando, Florida 32835
Plaintiff will supplement upon receipt of ordered records.
2. Subject Matters of Non Retained Medical Experts. The subject matters on which
said non retained non controlled medical experts will testify are as follows:
the existence, nature and/or extent of, and pain associated with the injuries sus-
tained by Plaintiff;
the examination and treatment of the injuries sustained by Plaintiff;
pre existing injuries to and/or pre existing medical conditions of Plaintiff;
the type, purpose, extent, results, evaluations and/or interpretations of examina-
tions, treatments, x rays and MRI’s tests regarding Plaintiff;
ecommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
the existence, nature and/or extent of the disabilities and/or incapacities of Plain-
tiff in the past, and the reasonable probability and extent of the disabilities and/or
incapacities which Plaintiff may suffer from in the future;
the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
medical care and treatment and medications that have been required by Plaintiff
in the past for the treatment of the injuries allegedly sustained by Plaintiff in the
subject collision and for rehabilitation from such injuries;
hird Designation of Expert Witnesses Page of
medical care and treatment and medications that will be required by Plaintiff in
the future, if any, for the treatment of the injuries allegedly sustained by Plaintiff
in the subject collision and for rehabilitation from such injuries;
the reasonableness of the costs, and the necessity of the medical services and
medical care and medications rendered to Plaintiff in the past, and that they will
in reasonable probability receive in the future, for the injuries sustained by Plain-
tiff in the subject collision;
all those subject matters contained, discussed or disclosed in:
(1) the medical records of Plaintiff which have been and which may here-
after be produced in this cause;
(2) all medical records affidavits and/or medical billing affidavits which
have been served and which may hereafter be served in this cause, and
all exhibits thereto;
(3) the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
(4) all written reports of healthcare providers produced during the course
of discovery in this cause.
All of said documents are incorporated herein by reference as though set out at length for
all purposes.
3. Impressions and Opinions of Non Retained Medical Experts. The general sub-
stance of said non retained/non controlled medical experts’ mental impressions and opinions are
expected to be, and a brief summary of the basis for them are, as follows:
the nature, extent, and severity of Plaintiff’s alleged injuries, incapacities, and
disabilities;
Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in
part of the injuries received by the Plaintiff and made the subject of this suit;
the medical care and treatment rendered to Plaintiff was reasonable and/or nec-
essary;
the subject accident did, based on reasonable medical probability, cause all of
the complaints, disabilities, injuries, and/or incapacities of Plaintiff;
that any surgical intervention for treatment of Plaintiff’s symptoms was neces-
sitated and proximately caused by the incident made the subject of this lawsuit;
that the medical expenses of the Plaintiff were necessitated by the incident
which is the subject of this lawsuit;
all other impressions and/or opinions that are contained, discussed, and/or dis-
closed in the following:
(1) the medical records of Plaintiff which have been and which may here-
after be produced in this cause;
(2) the medical records affidavits and medical billing affidavits which have
been served and which may hereafter be served in this cause and all ex-
hibits thereto;
hird Designation of Expert Witnesses Page of
(3) the depositions on written questions of Plaintiff’s health care providers
which have been taken and which may hereafter be taken in this cause,
and all exhibits thereto; and
(4) all written reports of healthcare providers produced during the course
of discovery in this cause.
All of said documents are incorporated herein by reference as though set out at length for
all purposes.
rief Summary of Basis or Impressions And Opinions. The basis for the fore-
going impressions and opinions of the above named and/or designated expert witnesses are the
experts' education, training and experience and all of the facts shown by and/or contained in:
All of the medical records of Plaintiff produced in this cause;
All depositions taken and hereafter taken in this cause, either by written ques-
tions or orally, and all exhibits thereto;
The expert reports herein above expressly referred to;
All witness statements which may be produced in this cause;
All of the photographs and videotape recordings produced in this cause;
The Responses to Requests For Disclosure, Responses to Requests For Produc-
tion, Answers to Interrogatories, and the Amendments and Supplements
thereto which have been served by each of the parties in this action;
The Pleadings on file in this action; and
All documents and tangible things produced in this cause.
All of which records, reports, documents, depositions, photographs and videotape record-
ings are incorporated herein by reference and made a part hereof for all purposes as if set out at
length herein.
NON RETAINED PEACE OFFICER EXPERT. The following peace officer, and/or the cus-
todian of his records, may testify regarding the facts of the wreck made the subject matter of this
case, the causation of the wreck, and statements made by the persons involved in the wreck, or
witnesses thereto. Please refer to the Texas Peace Officer’s Crash Report and his oral deposition
for his mental impressions, opinions, conclusions, and the factual basis for each opinion.
Identity of Non Retained Peace Officer. The names of the non retained/non
controlled Peace Officer experts and their addresses and telephone numbers are as follows:
Officer Twyla F. Kimberlin
ID No. 1499
Humble Police Department
Its Custodian of Records, Employees, Agents, Representatives and/or Servants
hird Designation of Expert Witnesses Page of
310 N. Bender Ave.
Humble, Texas 77338
Subject Matters of Non Retained Peace Officer. The subject matters on which
said non retained non controlled peace officer will testify are as follows:
the facts surrounding the wreck;
the cause of the wreck;
the results of his accident investigation/recreation of the wreck;
the facts obtained during his investigation of this wreck;
any observations made by him at the scene of the wreck or during the course of his
investigation;
the substance of any witness statements taken during the course of his investigation;
any analysis of the vehicles involved in this collision; and
h. all those subject matters contained, discussed or disclosed in:
(1) the Texas Peace Officer’s Report of the wreck made the subject of this suit;
(2) the depositions taken in this cause, orally and on written questions;
(3) all written reports produced during the course of discovery in this cause;
(4) any and all accident reports created by any governmental agency and all at-
tachments thereto;
(5) any and all pictures taken of the wreck, the vehicles involved in the wreck, or
the injuries received in the wreck, including all photographs produced during the
course of discovery in this cause;
(6) all statements produced during the course of discovery in this cause;
(7) any deposition testimony given in this cause by any of the above designated
individuals or any individual who also investigated this wreck but who is not specifi-
cally identified above.
All of which documents are incorporated herein by reference as though set out at length
for all purposes.
Impressions and Opinions of Non Retained Peace Officer. The general sub-
stance of said non retained / non controlled Peace Officer expert mental impressions and opinions
are expected to be, and a brief summary of the basis for them are, as follows:
the facts of the wreck made the subject of this suit;
the identity of the drivers involved in the wreck made the subject of this suit;
the causative factors regarding the wreck made the subject of this suit.
the extent of the damage to the vehicles involved in the wreck made the subject of
this suit;
the traffic conditions, terrain, and weather conditions at the time of the wreck made
the subject of this suit.
f. all other impressions and opinions that are contained, discussed or disclosed in:
(1) the Texas Peace Officer’s Crash Report of the wreck made the subject of this
suit;
(2) the depositions taken in this cause, orally and on written questions;
(3) all written reports produced during the course of discovery in this cause;
hird Designation of Expert Witnesses Page of
(4) any and all accident reports created by any governmental agency and all attach-
ments thereto;
(5) any and all pictures taken of the wreck, the vehicles involved in the wreck, or
the injuries received in the wreck, including all photographs produced during
the course of discovery in this cause;
(6) all statements produced during the course of discovery in this cause;
(7) any deposition testimony given in this cause by any of the above designated
individuals or any individual who also investigated this wreck but who is not
specifically identified above.
All of which documents are incorporated herein by reference as though set out at length
for all purposes.
rief Summary of Basis for Impressions and Opinions: The basis for the fore-
going impressions and opinions of the above named and/or designated expert witness are all of the
facts shown by and/or contained in:
the Peace Officer’s investigation of the wreck including the scene of the wreck;
the vehicles involved; the statements of the drivers and passengers in the vehicles;
statements of witnesses to the wreck; emergency medical care rendered to the
parties;
the Peace Officer’s report and notes pertaining to the wreck made the subject of
this suit;
all depositions taken and hereafter taken in this cause, either by written questions
or orally, and all exhibits thereto;
the expert reports herein above expressly referred to;
all witness statements which may be produced in this cause;
all of the photographs and videotape recordings produced in this cause or obtained
by the designated individuals during the course of their investigation;
the Responses to Requests or Disclosure, Responses to Requests For Production,
Answers to Interrogatories, and the Amendments and Supplements thereto which
have been filed by each of the parties to this cause;
the Pleadings on file in this cause;
all documents and tangible things produced in this cause;
All depositions taken and hereafter taken in this cause, either by written questions
or orally, and all exhibits thereto;
Any and all accident reports created by any governmental agency and all attach-
ments thereto;
the knowledge and experience of the investigating officer along with any special-
ized training received by him and his observations, deductions and calculations
performed during her investigation of this wreck.
All of which records, reports, documents, depositions, photographs and videotape record-
ings are incorporated herein by reference and made a part hereof for all purposes as if set out at
length herein.
TIONAL DESIGNATIONS. Plaintiff also incorporates herein by reference all
depositions; depositions on written questions; documents and exhibits attached to or referenced
hird Designation of Expert Witnesses Page 8 of
in all depositions; and all documents produced by any party hereto in disclosures and/or discov-
ery. Any opinions and bases for opinions discussed in deposition(s) are likewise incorporated
herein.
Plaintiff further reserves the right through cross examination or deposition, to call any ex-
pert witness identified herein by the Defendant.
laintiff reserves the right to withdraw the designation of any expert witness and to aver
positively that such previously designated expert will not be called as an expert witness at trial and
to redesignate same as a consulting expert, who cannot be called by opposing counsel.
laintiff reserves the right to elicit any expert testimony and/or lay opinion testimony that
would assist the jury in determining material issues of fact and that would not violate the Texas
Rules of Civil Procedure.
laintiff reserves all additional rights that Plaintiff may have regarding expert witnesses
and testimony under the Texas Rules of Civil Procedure, the Texas Rules of Evidence, case law,
and the rulings of this Honorable Court.
laintiff reserves the right to elicit expert opinion from any of the designated fact witnesses
within any area as to which such person has expertise.
o the extent necessary, this expert designation should be considered a supplement to any
outstanding or future discovery requests served on Plaintiff.
his designation shall serve to supplement Plaintiff’s Responses to Defendant’s Request
for Disclosures, Answers to Interrogatories, and Responses to Requests for Production propounded
to Plaintiff by a party inquiring as to expert witnesses.
iscovery in this matter is still ongoing and Plaintiff reserves the right to supplement this
esignation if further discovery reveals the need for additional testimony.
hird Designation of Expert Witnesses Page 9 of
Respectfully submitted,
/s/ Joe Jones
JOSEPH K. ONES
State ar o. 24076466
LOAN IRM
FM
Houston, exas
Phone: -520-8833
Fax: 713-520-9933
E-service: houstonservice@sloanfirm.com
ATTORNEYS LAINTIFF
I hereby certified that on the to the Texas Rules of
Civil Procedure, a true and correct copy of the foregoing document has been served on the follow-
ng:
Luis abrega
Hughes rrellKinchen LP
1221 McKinney, ite
Houston, exas
lfabrega@hakllp.com
Evette Hooper
Berchelmann
Jason uen
teward s ttorney
Jones oad, Suite
Houston, exas
jason@attorneyguss.com
Evette.hooper@attorneyguss.com
Ryan.berchelmann@attorneyguss.com
/s/ Joe Jones
JOSEPH K. JONES
hird Designation of Expert Witnesses Page of
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CAUSE NO. 2017-25488 WEMBERTH FERRAZ IN THE DISTRICT COURT VSS. HARRIS COUNTY, TEXAS TIFFANI MICHELLE ABSHIRE § JUDICIAL DISTRICT CAUSE NO. 2018-29917 LISA MASTERS IN THE DISTRICT COURT VS. HARRIS COUNTY, TEXAS TIFFANI ABSHIRE JUDICIAL DISTRICT PLAINTIFF’S HIRDSUPPLEMENTALDESIGNATION XPERT WITNESSESSUPPLEMENTAL DISCLOSURE ocket xpertnd losures afollows: RULE 194.2(f): For all testifying experts: (1) he expert’s name, address and telephone number; (2) The subject matter on which the expert will testify; (3) The general substance of the expert’s mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, em- ployed by, or otherwise subject to the control of the responding party, docu ments reflecting such information; (4) If the expert is retained by, employed by, or otherwise subject to your control: (A) All documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony; and (B) The expert’s current resume and bibliography. RESPONSE: Plaintiff incorporates herein by reference Plaintiff’s Response to Defendant’s Request for Disclosures (and all amendments and supplements thereto), together with all other discovery re- sponses previously served on Defendant, and designates expert witnesses as follows: hird Designation of Expert Witnesses Page 1 of laintiff’s Treating Physicians and Other Persons with Knowledge of Relevant Facts Who May Qualify as Experts but Have Not Been Specially Retained (Fact Experts - Tex. R. Civ. P. 194.2(f)) he following person(s), or their custodian(s) of records, have not been retained by and are not employed by, or are otherwise subject to the control of Plaintiff (hereinafter referred to as “non retained” experts), but are hereby designated as testifying experts by Plaintiff and the fol- lowing information is provided in accordance with Texas Rule of Civil Procedure 194.2. lthough these witnesses have not been specifically retained as expert witnesses by Plain- tiff, and while Plaintiff cannot vouch for the expertise or credibility of such witnesses at this time, it is believed that they may have knowledge, training or expertise which may qualify them as experts. Accordingly, Plaintiff will designate these witnesses as persons who may be called upon to give testimony that would be considered expert testimony. RETAINED MEDICAL EXPERTS. The following healthcare providers, and/or the custodian(s) of their records, may testify regarding the injuries sustained by Plaintiff as a result of the incident made the subject of this suit, their medical diagnosis, prognosis and the reasonable and necessary cost of hospital, doctor and medical bills for treatment of Plaintiff’s in- juries in the past and in the future. Please refer to the healthcare providers’ records for their mental impressions, opinions, conclusions, and the factual basis for each opinion. 1. Identity of Non Retained Medical Experts. The names of Plaintiff’s non re- tained, non controlled medical experts and their addresses and telephone numbers are as fol- lows: HE FOLLOWING INDIVIDUALS AND ENTITIES AND THEIR CURRENT AND FORMER OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVANTS, PHYSI- CIANS, NURSES, PARAMEDICS, EMTs, ATTENDANTS, STAFF, HEALTHCARE PROVIDERS, AND CUSTODIANS OF RECORDS: ll Florida Family and Sports Medicine PA Ahmed Aidoo, M.D., MPH 3501 13 Street Saint Cloud, Florida 34769 407-891-6463 entral Florida Neurosurgery Institute Hyndaldo V llalobos, MD 801 N. Orange Ave., Suite 720 hird Designation of Expert Witnesses Page 2 of Orange, Florida 32832 407-288-8638 ast Lake Chiropractic and Injury Center, Inc. Westin Schmidt, D.C. Cristopher McNichols, D.C. Street St. Cloud, Florida 34769 407-957-9995 avita Medical Group JSA Healthcare Corporation Yvonne Boston, NP Munir Ammari, PA Megha Parekh, PA Donna S. Lester, MD Efrain Segura, M Street St. Cloud, Florida 34759 407-957-0090 imonMed Andrew Akerman, M.D. 208 West Oak Kissimmee, Florida 34741 407-846-8700 ynergy Radiology Arif Rahman, M.D. 7026 Old Katy Road, Suite 276 Houston, Texas 77024 713-621-7436 exas Emergency Care Center Greg Hall, D.O. Marvin Rogers, R.N. P.O. Box 3401 Dept. 10 Houston, Texas 77253 832-653-3200 uest Diagnostics PSC Street Saint Cloud, Florida 34769 407-891-0341 Wi eCare of Florida hird Designation of Expert Witnesses Page 3 of Ahmed Aidoo, MD, MPH Street St. Cloud, Florida 34769 Gustavo Arriola, M.D. 905 N. Central Ave. Kissimmee, Florida 34741 AdventHealth Sean Dodson, M.D. 2450 N. Orange Blossom Trail Kissimmee, Florida 34744 Professional Imaging Centers 911 E. Oak St. Kissimmee, Florida 34744 Rose Healthcare Centre, P.A. 6638 Old Winter Garden Road Orlando, Florida 32835 Plaintiff will supplement upon receipt of ordered records. 2. Subject Matters of Non Retained Medical Experts. The subject matters on which said non retained non controlled medical experts will testify are as follows: the existence, nature and/or extent of, and pain associated with the injuries sus- tained by Plaintiff; the examination and treatment of the injuries sustained by Plaintiff; pre existing injuries to and/or pre existing medical conditions of Plaintiff; the type, purpose, extent, results, evaluations and/or interpretations of examina- tions, treatments, x rays and MRI’s tests regarding Plaintiff; ecommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; the existence, nature and/or extent of the disabilities and/or incapacities of Plain- tiff in the past, and the reasonable probability and extent of the disabilities and/or incapacities which Plaintiff may suffer from in the future; the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; medical care and treatment and medications that have been required by Plaintiff in the past for the treatment of the injuries allegedly sustained by Plaintiff in the subject collision and for rehabilitation from such injuries; hird Designation of Expert Witnesses Page of medical care and treatment and medications that will be required by Plaintiff in the future, if any, for the treatment of the injuries allegedly sustained by Plaintiff in the subject collision and for rehabilitation from such injuries; the reasonableness of the costs, and the necessity of the medical services and medical care and medications rendered to Plaintiff in the past, and that they will in reasonable probability receive in the future, for the injuries sustained by Plain- tiff in the subject collision; all those subject matters contained, discussed or disclosed in: (1) the medical records of Plaintiff which have been and which may here- after be produced in this cause; (2) all medical records affidavits and/or medical billing affidavits which have been served and which may hereafter be served in this cause, and all exhibits thereto; (3) the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and (4) all written reports of healthcare providers produced during the course of discovery in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes. 3. Impressions and Opinions of Non Retained Medical Experts. The general sub- stance of said non retained/non controlled medical experts’ mental impressions and opinions are expected to be, and a brief summary of the basis for them are, as follows: the nature, extent, and severity of Plaintiff’s alleged injuries, incapacities, and disabilities; Plaintiff’s injuries, incapacities, and/or disabilities are the result in whole or in part of the injuries received by the Plaintiff and made the subject of this suit; the medical care and treatment rendered to Plaintiff was reasonable and/or nec- essary; the subject accident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and/or incapacities of Plaintiff; that any surgical intervention for treatment of Plaintiff’s symptoms was neces- sitated and proximately caused by the incident made the subject of this lawsuit; that the medical expenses of the Plaintiff were necessitated by the incident which is the subject of this lawsuit; all other impressions and/or opinions that are contained, discussed, and/or dis- closed in the following: (1) the medical records of Plaintiff which have been and which may here- after be produced in this cause; (2) the medical records affidavits and medical billing affidavits which have been served and which may hereafter be served in this cause and all ex- hibits thereto; hird Designation of Expert Witnesses Page of (3) the depositions on written questions of Plaintiff’s health care providers which have been taken and which may hereafter be taken in this cause, and all exhibits thereto; and (4) all written reports of healthcare providers produced during the course of discovery in this cause. All of said documents are incorporated herein by reference as though set out at length for all purposes. rief Summary of Basis or Impressions And Opinions. The basis for the fore- going impressions and opinions of the above named and/or designated expert witnesses are the experts' education, training and experience and all of the facts shown by and/or contained in: All of the medical records of Plaintiff produced in this cause; All depositions taken and hereafter taken in this cause, either by written ques- tions or orally, and all exhibits thereto; The expert reports herein above expressly referred to; All witness statements which may be produced in this cause; All of the photographs and videotape recordings produced in this cause; The Responses to Requests For Disclosure, Responses to Requests For Produc- tion, Answers to Interrogatories, and the Amendments and Supplements thereto which have been served by each of the parties in this action; The Pleadings on file in this action; and All documents and tangible things produced in this cause. All of which records, reports, documents, depositions, photographs and videotape record- ings are incorporated herein by reference and made a part hereof for all purposes as if set out at length herein. NON RETAINED PEACE OFFICER EXPERT. The following peace officer, and/or the cus- todian of his records, may testify regarding the facts of the wreck made the subject matter of this case, the causation of the wreck, and statements made by the persons involved in the wreck, or witnesses thereto. Please refer to the Texas Peace Officer’s Crash Report and his oral deposition for his mental impressions, opinions, conclusions, and the factual basis for each opinion. Identity of Non Retained Peace Officer. The names of the non retained/non controlled Peace Officer experts and their addresses and telephone numbers are as follows: Officer Twyla F. Kimberlin ID No. 1499 Humble Police Department Its Custodian of Records, Employees, Agents, Representatives and/or Servants hird Designation of Expert Witnesses Page of 310 N. Bender Ave. Humble, Texas 77338 Subject Matters of Non Retained Peace Officer. The subject matters on which said non retained non controlled peace officer will testify are as follows: the facts surrounding the wreck; the cause of the wreck; the results of his accident investigation/recreation of the wreck; the facts obtained during his investigation of this wreck; any observations made by him at the scene of the wreck or during the course of his investigation; the substance of any witness statements taken during the course of his investigation; any analysis of the vehicles involved in this collision; and h. all those subject matters contained, discussed or disclosed in: (1) the Texas Peace Officer’s Report of the wreck made the subject of this suit; (2) the depositions taken in this cause, orally and on written questions; (3) all written reports produced during the course of discovery in this cause; (4) any and all accident reports created by any governmental agency and all at- tachments thereto; (5) any and all pictures taken of the wreck, the vehicles involved in the wreck, or the injuries received in the wreck, including all photographs produced during the course of discovery in this cause; (6) all statements produced during the course of discovery in this cause; (7) any deposition testimony given in this cause by any of the above designated individuals or any individual who also investigated this wreck but who is not specifi- cally identified above. All of which documents are incorporated herein by reference as though set out at length for all purposes. Impressions and Opinions of Non Retained Peace Officer. The general sub- stance of said non retained / non controlled Peace Officer expert mental impressions and opinions are expected to be, and a brief summary of the basis for them are, as follows: the facts of the wreck made the subject of this suit; the identity of the drivers involved in the wreck made the subject of this suit; the causative factors regarding the wreck made the subject of this suit. the extent of the damage to the vehicles involved in the wreck made the subject of this suit; the traffic conditions, terrain, and weather conditions at the time of the wreck made the subject of this suit. f. all other impressions and opinions that are contained, discussed or disclosed in: (1) the Texas Peace Officer’s Crash Report of the wreck made the subject of this suit; (2) the depositions taken in this cause, orally and on written questions; (3) all written reports produced during the course of discovery in this cause; hird Designation of Expert Witnesses Page of (4) any and all accident reports created by any governmental agency and all attach- ments thereto; (5) any and all pictures taken of the wreck, the vehicles involved in the wreck, or the injuries received in the wreck, including all photographs produced during the course of discovery in this cause; (6) all statements produced during the course of discovery in this cause; (7) any deposition testimony given in this cause by any of the above designated individuals or any individual who also investigated this wreck but who is not specifically identified above. All of which documents are incorporated herein by reference as though set out at length for all purposes. rief Summary of Basis for Impressions and Opinions: The basis for the fore- going impressions and opinions of the above named and/or designated expert witness are all of the facts shown by and/or contained in: the Peace Officer’s investigation of the wreck including the scene of the wreck; the vehicles involved; the statements of the drivers and passengers in the vehicles; statements of witnesses to the wreck; emergency medical care rendered to the parties; the Peace Officer’s report and notes pertaining to the wreck made the subject of this suit; all depositions taken and hereafter taken in this cause, either by written questions or orally, and all exhibits thereto; the expert reports herein above expressly referred to; all witness statements which may be produced in this cause; all of the photographs and videotape recordings produced in this cause or obtained by the designated individuals during the course of their investigation; the Responses to Requests or Disclosure, Responses to Requests For Production, Answers to Interrogatories, and the Amendments and Supplements thereto which have been filed by each of the parties to this cause; the Pleadings on file in this cause; all documents and tangible things produced in this cause; All depositions taken and hereafter taken in this cause, either by written questions or orally, and all exhibits thereto; Any and all accident reports created by any governmental agency and all attach- ments thereto; the knowledge and experience of the investigating officer along with any special- ized training received by him and his observations, deductions and calculations performed during her investigation of this wreck. All of which records, reports, documents, depositions, photographs and videotape record- ings are incorporated herein by reference and made a part hereof for all purposes as if set out at length herein. TIONAL DESIGNATIONS. Plaintiff also incorporates herein by reference all depositions; depositions on written questions; documents and exhibits attached to or referenced hird Designation of Expert Witnesses Page 8 of in all depositions; and all documents produced by any party hereto in disclosures and/or discov- ery. Any opinions and bases for opinions discussed in deposition(s) are likewise incorporated herein. Plaintiff further reserves the right through cross examination or deposition, to call any ex- pert witness identified herein by the Defendant. laintiff reserves the right to withdraw the designation of any expert witness and to aver positively that such previously designated expert will not be called as an expert witness at trial and to redesignate same as a consulting expert, who cannot be called by opposing counsel. laintiff reserves the right to elicit any expert testimony and/or lay opinion testimony that would assist the jury in determining material issues of fact and that would not violate the Texas Rules of Civil Procedure. laintiff reserves all additional rights that Plaintiff may have regarding expert witnesses and testimony under the Texas Rules of Civil Procedure, the Texas Rules of Evidence, case law, and the rulings of this Honorable Court. laintiff reserves the right to elicit expert opinion from any of the designated fact witnesses within any area as to which such person has expertise. o the extent necessary, this expert designation should be considered a supplement to any outstanding or future discovery requests served on Plaintiff. his designation shall serve to supplement Plaintiff’s Responses to Defendant’s Request for Disclosures, Answers to Interrogatories, and Responses to Requests for Production propounded to Plaintiff by a party inquiring as to expert witnesses. iscovery in this matter is still ongoing and Plaintiff reserves the right to supplement this esignation if further discovery reveals the need for additional testimony. hird Designation of Expert Witnesses Page 9 of Respectfully submitted, /s/ Joe Jones JOSEPH K. ONES State ar o. 24076466 LOAN IRM FM Houston, exas Phone: -520-8833 Fax: 713-520-9933 E-service: houstonservice@sloanfirm.com ATTORNEYS LAINTIFF I hereby certified that on the to the Texas Rules of Civil Procedure, a true and correct copy of the foregoing document has been served on the follow- ng: Luis abrega Hughes rrellKinchen LP 1221 McKinney, ite Houston, exas lfabrega@hakllp.com Evette Hooper Berchelmann Jason uen teward s ttorney Jones oad, Suite Houston, exas jason@attorneyguss.com Evette.hooper@attorneyguss.com Ryan.berchelmann@attorneyguss.com /s/ Joe Jones JOSEPH K. JONES hird Designation of Expert Witnesses Page of