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CAUSE NO.
DESHANNON MUSA IN THE DISTRICT COURT OF
HARRIS COUNTY, TEXAS
NICHOLAS ALEXANDER VICKERY
AND INFRAMARK, LLC JUDICIAL DISTRICT
DESIGNATION OF EXPERTS
TO: Defendant , Nicholas Alexander Vickery and Inframark, LLC, by and through counsel
of record, Troy A. Williams, GERMER, PLLC; 2929 Allen Parkway, Suite 2900; Houston,
Texas 77019
Pursuant to provision of Texas Rule of Civil Procedure 195, Plaintiff hereby designates the
following experts
RETAINED MEDICAL EXPERTS.
The following healthcare providers, and/or the custodian of their records, may testify
regarding the injuries sustained by Plaintiff as a result of the incident made the subject of this suit,
Plaintiff medical diagnosis, prognosis and the reasonable and necessary cost of hospital, doctor and
medical bills for treatment of Plaintiff injuries in the past and in the future.
MEMORIAL VILLAGE EMERGENCY ROOM
(a)(1): expert’s name, address, and telephone number;
Amir Zegar, DO
Troy Metrejean
Can Nguyen
Manal Schoellerman, M.D.
Andrew Martin, M.D.
Memorial Drive, Suite 4
(a)(2): the subject matter on which the expert will testify:
knowledge, skill, training, education, and/or experience as they relate to the
subject matter of this lawsuit;
their qualifications to render an expert opinion;
plaintiff's injuries at issue in this case;
the medical care that he provided and/or prescribed to plaintiff;
the existence, nature and/or extent of, and pain associated with the injuries sustained
by Plaintiff;
the examination and treatment of the injuries sustained by Plaintiff;
o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack
thereof;
o the type, purpose, extent, results, evaluations and/or interpretations of examinations,
treatments, x-rays and MRI’s tests regarding Plaintiff;
o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in
the past, and the reasonable probability and extent of the disabilities and/or
incapacities which Plaintiff may suffer from in the future;
o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
o 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;
o 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;
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical
probability, will need in the future for the injuries sustained by Plaintiff in the subject
collision;
o all those subject matters contained, discussed or disclosed in:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause;
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o All of the above documents are incorporated herein by reference as though set out
verbatim for all purposes.
• (a)(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, employed by, or otherwise
subject to the control of the responding party, documents reflecting such information;
o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary;
o the subject accident did, based on reasonable medical probability, cause all of the
complaints, disabilities, injuries, and/or incapacities of Plaintiff;
o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated
and proximately caused by the incident made the subject of this lawsuit;
o that the medical expenses of Plaintiff were necessitated by the incident which is the
subject of this lawsuit;
o all other impressions and/or opinions that are contained, discussed, and/or disclosed
in the following:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause including the following:
• Medical and Billing Records from Memorial Village Emergency
Room. See Plaintiff’s production (MUSA-000001-MUSA000044).
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o The experts’ opinions are based on the following:
â–ª The medical records of Plaintiff produced in this cause;
â–ª The experts knowledge, skill, training, education, and/or experience as they
relate to the subject matter of this lawsuit;
â–ª The experts time, examinations, and conversations with Plaintiff;
â–ª All depositions taken and hereafter taken in this cause, either by written
questions or orally, and all exhibits thereto;
â–ª The expert reports herein above expressly referred to;
â–ª All witness statements which may be produced in this cause;
â–ª All of the photographs and videotape recordings produced in this cause;
â–ª The Responses to Requests for Disclosure, Responses to Requests for
Production, Answers to Interrogatories, and the Amendments and
Supplements thereto which have been served by each of the parties in this
action;
â–ª The pleadings on file in this action; and
â–ª All documents and tangible things produced in this cause.
ICONIC CHIROPRACTIC
• (a)(1): expert’s name, address, and telephone number;
o Ken Tran, D.C.
o 9555 W Sam Houston Parkway Houston, TX 77099
o 281-829-8587
• (a)(2): the subject matter on which the expert will testify:
o his knowledge, skill, training, education, and/or experience as they relate to the subject
matter of this lawsuit;
o his qualifications to render an expert opinion;
o plaintiff's injuries at issue in this case;
o the medical care that he provided and/or prescribed to plaintiff;
o the existence, nature and/or extent of, and pain associated with the injuries sustained
by Plaintiff;
o the examination and treatment of the injuries sustained by Plaintiff;
o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack
thereof;
o the type, purpose, extent, results, evaluations and/or interpretations of examinations,
treatments, x-rays and MRI’s tests regarding Plaintiff;
o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in
the past, and the reasonable probability and extent of the disabilities and/or
incapacities which Plaintiff may suffer from in the future;
o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
o 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;
o 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;
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical
probability, will need in the future for the injuries sustained by Plaintiff in the subject
collision;
o all those subject matters contained, discussed or disclosed in:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause;
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o All of the above documents are incorporated herein by reference as though set out
verbatim for all purposes.
• (a)(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, employed by, or otherwise
subject to the control of the responding party, documents reflecting such information;
o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary;
o the subject accident did, based on reasonable medical probability, cause all of the
complaints, disabilities, injuries, and/or incapacities of Plaintiff;
o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated
and proximately caused by the incident made the subject of this lawsuit;
o that the medical expenses of Plaintiff were necessitated by the incident which is the
subject of this lawsuit;
o all other impressions and/or opinions that are contained, discussed, and/or disclosed
in the following:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause including the following:
• Medical and Billing Records from Iconic Chiropractic. See Plaintiff’s
production (MUSA-000045-000130).
• Billing Records from Sterling Pharmacy. See Plaintiff’s production
(MUSA000131-MUSA000132)
• Medical and Billing Records from Upright MRI. See Plaintiff’s
production (MUSA000133-MUSA000141)
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o The experts’ opinions are based on the following:
â–ª The medical records of Plaintiff produced in this cause;
â–ª The experts knowledge, skill, training, education, and/or experience as they
relate to the subject matter of this lawsuit;
â–ª The experts time, examinations, and conversations with Plaintiff;
â–ª All depositions taken and hereafter taken in this cause, either by written
questions or orally, and all exhibits thereto;
â–ª The expert reports herein above expressly referred to;
â–ª All witness statements which may be produced in this cause;
â–ª All of the photographs and videotape recordings produced in this cause;
â–ª The Responses to Requests for Disclosure, Responses to Requests for
Production, Answers to Interrogatories, and the Amendments and
Supplements thereto which have been served by each of the parties in this
action;
â–ª The pleadings on file in this action; and
â–ª All documents and tangible things produced in this cause.
UPRIGHT MRI
• (a)(1): expert’s name, address, and telephone number;
o Dr. Jamie Tsai
o 2655 Cordes Drive, Suite 150, Sugar Land, TX 77479
o 281-494-0505
• (a)(2): the subject matter on which the expert will testify:
o his knowledge, skill, training, education, and/or experience as they relate to the subject
matter of this lawsuit;
o his qualifications to render an expert opinion;
o plaintiff's injuries at issue in this case;
o the medical care that he provided and/or prescribed to plaintiff;
o the existence, nature and/or extent of, and pain associated with the injuries sustained
by Plaintiff;
o the examination and treatment of the injuries sustained by Plaintiff;
o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack
thereof;
o the type, purpose, extent, results, evaluations and/or interpretations of examinations,
treatments, x-rays and MRI’s tests regarding Plaintiff;
o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in
the past, and the reasonable probability and extent of the disabilities and/or
incapacities which Plaintiff may suffer from in the future;
o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
o 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;
o 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;
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical
probability, will need in the future for the injuries sustained by Plaintiff in the subject
collision;
o all those subject matters contained, discussed or disclosed in:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause;
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o All of the above documents are incorporated herein by reference as though set out
verbatim for all purposes.
• (a)(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, employed by, or otherwise
subject to the control of the responding party, documents reflecting such information;
o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary;
o the subject accident did, based on reasonable medical probability, cause all of the
complaints, disabilities, injuries, and/or incapacities of Plaintiff;
o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated
and proximately caused by the incident made the subject of this lawsuit;
o that the medical expenses of Plaintiff were necessitated by the incident which is the
subject of this lawsuit;
o all other impressions and/or opinions that are contained, discussed, and/or disclosed
in the following:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause including the following:
• Medical and Billing Records from Upright MRI. See Plaintiff’s
production (MUSA000133-MUSA000141)
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o The experts’ opinions are based on the following:
â–ª The medical records of Plaintiff produced in this cause;
â–ª The experts knowledge, skill, training, education, and/or experience as they
relate to the subject matter of this lawsuit;
â–ª The experts time, examinations, and conversations with Plaintiff;
â–ª All depositions taken and hereafter taken in this cause, either by written
questions or orally, and all exhibits thereto;
â–ª The expert reports herein above expressly referred to;
â–ª All witness statements which may be produced in this cause;
â–ª All of the photographs and videotape recordings produced in this cause;
â–ª The Responses to Requests for Disclosure, Responses to Requests for
Production, Answers to Interrogatories, and the Amendments and
Supplements thereto which have been served by each of the parties in this
action;
â–ª The pleadings on file in this action; and
â–ª All documents and tangible things produced in this cause.
MUNSHI MODERN PAIN
• (a)(1): expert’s name, address, and telephone number;
o Omer F. Munshi, MD
o 5420 West Loop S Ste 1100 Bellaire, TX 77401
o 281-929-0804
• (a)(2): the subject matter on which the expert will testify:
o his knowledge, skill, training, education, and/or experience as they relate to the subject
matter of this lawsuit;
o his qualifications to render an expert opinion;
o plaintiff's injuries at issue in this case;
o the medical care that he provided and/or prescribed to plaintiff;
o the existence, nature and/or extent of, and pain associated with the injuries sustained
by Plaintiff;
o the examination and treatment of the injuries sustained by Plaintiff;
o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack
thereof;
o the type, purpose, extent, results, evaluations and/or interpretations of examinations,
treatments, x-rays and MRI’s tests regarding Plaintiff;
o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in
the past, and the reasonable probability and extent of the disabilities and/or
incapacities which Plaintiff may suffer from in the future;
o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
o 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;
o 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;
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical
probability, will need in the future for the injuries sustained by Plaintiff in the subject
collision;
o all those subject matters contained, discussed or disclosed in:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause;
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o All of the above documents are incorporated herein by reference as though set out
verbatim for all purposes.
• (a)(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, employed by, or otherwise
subject to the control of the responding party, documents reflecting such information;
o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary;
o the subject accident did, based on reasonable medical probability, cause all of the
complaints, disabilities, injuries, and/or incapacities of Plaintiff;
o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated
and proximately caused by the incident made the subject of this lawsuit;
o that the medical expenses of Plaintiff were necessitated by the incident which is the
subject of this lawsuit;
o all other impressions and/or opinions that are contained, discussed, and/or disclosed
in the following:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause including the following:
• Medical and Billing Records from Upright MRI. See Plaintiff’s
production (MUSA000133-MUSA000141)
• Medical and Billing Records from Munshi Modern Pain. See
Plaintiff’s production (MUSA000142-000156)
• Billing Records from Sterling Pharmacy. See Plaintiff’s production
(MUSA000131-MUSA000132)
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o The experts’ opinions are based on the following:
â–ª The medical records of Plaintiff produced in this cause;
â–ª The experts knowledge, skill, training, education, and/or experience as they
relate to the subject matter of this lawsuit;
â–ª The experts time, examinations, and conversations with Plaintiff;
â–ª All depositions taken and hereafter taken in this cause, either by written
questions or orally, and all exhibits thereto;
â–ª The expert reports herein above expressly referred to;
â–ª All witness statements which may be produced in this cause;
â–ª All of the photographs and videotape recordings produced in this cause;
â–ª The Responses to Requests for Disclosure, Responses to Requests for
Production, Answers to Interrogatories, and the Amendments and
Supplements thereto which have been served by each of the parties in this
action;
â–ª The pleadings on file in this action; and
â–ª All documents and tangible things produced in this cause.
OSD SURGERY CENTER
• (a)(1): expert’s name, address, and telephone number;
o Omer Munshi, MD
o 2121 Williams Trace Blvd., Ste. 200 Sugarland TX 77478
o 281-404-3280
• (a)(2): the subject matter on which the expert will testify:
o his knowledge, skill, training, education, and/or experience as they relate to the subject
matter of this lawsuit;
o his qualifications to render an expert opinion;
o plaintiff's injuries at issue in this case;
o the medical care that he provided and/or prescribed to plaintiff;
o the existence, nature and/or extent of, and pain associated with the injuries sustained
by Plaintiff;
o the examination and treatment of the injuries sustained by Plaintiff;
o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack
thereof;
o the type, purpose, extent, results, evaluations and/or interpretations of examinations,
treatments, x-rays and MRI’s tests regarding Plaintiff;
o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries;
o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in
the past, and the reasonable probability and extent of the disabilities and/or
incapacities which Plaintiff may suffer from in the future;
o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities;
o 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;
o 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;
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications prescribed to Plaintiff in the past.
o the reasonableness of the costs associated with, and the necessity of, the medical
services, medical care, and medications that Plaintiff, in reasonable medical
probability, will need in the future for the injuries sustained by Plaintiff in the subject
collision;
o all those subject matters contained, discussed or disclosed in:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause;
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o All of the above documents are incorporated herein by reference as though set out
verbatim for all purposes.
• (a)(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, employed by, or otherwise
subject to the control of the responding party, documents reflecting such information;
o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary;
o the subject accident did, based on reasonable medical probability, cause all of the
complaints, disabilities, injuries, and/or incapacities of Plaintiff;
o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated
and proximately caused by the incident made the subject of this lawsuit;
o that the medical expenses of Plaintiff were necessitated by the incident which is the
subject of this lawsuit;
o all other impressions and/or opinions that are contained, discussed, and/or disclosed
in the following:
â–ª the medical records of Plaintiff which have been and which may hereafter be
produced in this cause including the following:
• Medical and Billing Records from Upright MRI. See Plaintiff’s
production (MUSA000133-MUSA000141)
• Medical and Billing Records from Munshi Modern Pain. See
Plaintiff’s production (MUSA000142-000156)
• Medical and Billing Records from OSD Surgery Center. See
Plaintiff’s production (MUSA000147-MUSA000248)
• Medical and Billing Records from TL Billing Management. See
Plaintiff’s production (MUSA000249-MUSA000256)
• Billing Records from Sterling Pharmacy. See Plaintiff’s production
(MUSA000131-MUSA000132)
â–ª 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;
▪ 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
â–ª all written reports of healthcare providers produced during the course of
discovery in this cause.
o The experts’ opinions are based on the following:
â–ª The medical records of Plaintiff produced in this cause;
â–ª The experts knowledge, skill, training, education, and/or experience as they
relate to the subject matter of this lawsuit;
â–ª The experts time, examinations, and conversations with Plaintiff;
â–ª All depositions taken and hereafter taken in this cause, either by written
questions or orally, and all exhibits thereto;
â–ª The expert reports herein above expressly referred to;
â–ª All witness statements which may be produced in this cause;
â–ª All of the photographs and videotape recordings produced in this cause;
â–ª The Responses to Requests for Disclosure, Responses to Requests for
Production, Answers to Interrogatories, and the Amendments and
Supplements thereto which have been served by each of the parties in this
action;
â–ª The pleadings on file in this action; and
â–ª All documents and tangible things produced in this cause.
ADDITIONAL DISCLOSURES.
Plaintiff also incorporates herein by reference all depositions; depositions on written
questions; documents and exhibits attached to or referenced in all depositions; and all documents
produced by any party hereto in disclosures and/or discovery. Any opinions and bases for opinions
discussed in deposition(s) are incorporated herein.
Plaintiff further refers the Defendants to Plaintiff’s retained and non-retained experts’ files,
reports and supplemental reports; written discovery responses of all parties; pleadings of all parties;
depositions and exhibits thereto; medical and billing records; rebuttal opinions; factual observations
and opinions.
Plaintiff further reserves the right through cross-examination or deposition, to call any expert
witness identified herein by the Defendants.
Plaintiff 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.
Plaintiff 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.
Plaintiff reserves all additional rights that Plaintiff may have regarding expert witnesses and
testimony under the Texas Rules of Civil Procedure, case law and rulings of this Honorable Court.
Plaintiff reserves the right to elicit expert opinion from any of the designated fact witnesses
within any area as to which such person has expertise.
Respectfully submitted,
_____________________
The Law Office of Tarek Fahmy, PLLC
Attorney at Law
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CAUSE NO. DESHANNON MUSA IN THE DISTRICT COURT OF HARRIS COUNTY, TEXAS NICHOLAS ALEXANDER VICKERY AND INFRAMARK, LLC JUDICIAL DISTRICT DESIGNATION OF EXPERTS TO: Defendant , Nicholas Alexander Vickery and Inframark, LLC, by and through counsel of record, Troy A. Williams, GERMER, PLLC; 2929 Allen Parkway, Suite 2900; Houston, Texas 77019 Pursuant to provision of Texas Rule of Civil Procedure 195, Plaintiff hereby designates the following experts RETAINED MEDICAL EXPERTS. The following healthcare providers, and/or the custodian of their records, may testify regarding the injuries sustained by Plaintiff as a result of the incident made the subject of this suit, Plaintiff medical diagnosis, prognosis and the reasonable and necessary cost of hospital, doctor and medical bills for treatment of Plaintiff injuries in the past and in the future. MEMORIAL VILLAGE EMERGENCY ROOM (a)(1): expert’s name, address, and telephone number; Amir Zegar, DO Troy Metrejean Can Nguyen Manal Schoellerman, M.D. Andrew Martin, M.D. Memorial Drive, Suite 4 (a)(2): the subject matter on which the expert will testify: knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; their qualifications to render an expert opinion; plaintiff's injuries at issue in this case; the medical care that he provided and/or prescribed to plaintiff; the existence, nature and/or extent of, and pain associated with the injuries sustained by Plaintiff; the examination and treatment of the injuries sustained by Plaintiff; o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack thereof; o the type, purpose, extent, results, evaluations and/or interpretations of examinations, treatments, x-rays and MRI’s tests regarding Plaintiff; o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or incapacities which Plaintiff may suffer from in the future; o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; o 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; o 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; o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical probability, will need in the future for the injuries sustained by Plaintiff in the subject collision; o all those subject matters contained, discussed or disclosed in: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause; ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o All of the above documents are incorporated herein by reference as though set out verbatim for all purposes. • (a)(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, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary; o the subject accident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and/or incapacities of Plaintiff; o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated and proximately caused by the incident made the subject of this lawsuit; o that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; o all other impressions and/or opinions that are contained, discussed, and/or disclosed in the following: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause including the following: • Medical and Billing Records from Memorial Village Emergency Room. See Plaintiff’s production (MUSA-000001-MUSA000044). ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o The experts’ opinions are based on the following: ▪ The medical records of Plaintiff produced in this cause; ▪ The experts knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; ▪ The experts time, examinations, and conversations with Plaintiff; ▪ 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; ▪ The Responses to Requests for Disclosure, Responses to Requests for Production, 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. ICONIC CHIROPRACTIC • (a)(1): expert’s name, address, and telephone number; o Ken Tran, D.C. o 9555 W Sam Houston Parkway Houston, TX 77099 o 281-829-8587 • (a)(2): the subject matter on which the expert will testify: o his knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; o his qualifications to render an expert opinion; o plaintiff's injuries at issue in this case; o the medical care that he provided and/or prescribed to plaintiff; o the existence, nature and/or extent of, and pain associated with the injuries sustained by Plaintiff; o the examination and treatment of the injuries sustained by Plaintiff; o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack thereof; o the type, purpose, extent, results, evaluations and/or interpretations of examinations, treatments, x-rays and MRI’s tests regarding Plaintiff; o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or incapacities which Plaintiff may suffer from in the future; o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; o 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; o 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; o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical probability, will need in the future for the injuries sustained by Plaintiff in the subject collision; o all those subject matters contained, discussed or disclosed in: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause; ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o All of the above documents are incorporated herein by reference as though set out verbatim for all purposes. • (a)(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, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary; o the subject accident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and/or incapacities of Plaintiff; o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated and proximately caused by the incident made the subject of this lawsuit; o that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; o all other impressions and/or opinions that are contained, discussed, and/or disclosed in the following: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause including the following: • Medical and Billing Records from Iconic Chiropractic. See Plaintiff’s production (MUSA-000045-000130). • Billing Records from Sterling Pharmacy. See Plaintiff’s production (MUSA000131-MUSA000132) • Medical and Billing Records from Upright MRI. See Plaintiff’s production (MUSA000133-MUSA000141) ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o The experts’ opinions are based on the following: ▪ The medical records of Plaintiff produced in this cause; ▪ The experts knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; ▪ The experts time, examinations, and conversations with Plaintiff; ▪ 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; ▪ The Responses to Requests for Disclosure, Responses to Requests for Production, 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. UPRIGHT MRI • (a)(1): expert’s name, address, and telephone number; o Dr. Jamie Tsai o 2655 Cordes Drive, Suite 150, Sugar Land, TX 77479 o 281-494-0505 • (a)(2): the subject matter on which the expert will testify: o his knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; o his qualifications to render an expert opinion; o plaintiff's injuries at issue in this case; o the medical care that he provided and/or prescribed to plaintiff; o the existence, nature and/or extent of, and pain associated with the injuries sustained by Plaintiff; o the examination and treatment of the injuries sustained by Plaintiff; o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack thereof; o the type, purpose, extent, results, evaluations and/or interpretations of examinations, treatments, x-rays and MRI’s tests regarding Plaintiff; o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or incapacities which Plaintiff may suffer from in the future; o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; o 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; o 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; o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical probability, will need in the future for the injuries sustained by Plaintiff in the subject collision; o all those subject matters contained, discussed or disclosed in: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause; ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o All of the above documents are incorporated herein by reference as though set out verbatim for all purposes. • (a)(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, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary; o the subject accident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and/or incapacities of Plaintiff; o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated and proximately caused by the incident made the subject of this lawsuit; o that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; o all other impressions and/or opinions that are contained, discussed, and/or disclosed in the following: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause including the following: • Medical and Billing Records from Upright MRI. See Plaintiff’s production (MUSA000133-MUSA000141) ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o The experts’ opinions are based on the following: ▪ The medical records of Plaintiff produced in this cause; ▪ The experts knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; ▪ The experts time, examinations, and conversations with Plaintiff; ▪ 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; ▪ The Responses to Requests for Disclosure, Responses to Requests for Production, 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. MUNSHI MODERN PAIN • (a)(1): expert’s name, address, and telephone number; o Omer F. Munshi, MD o 5420 West Loop S Ste 1100 Bellaire, TX 77401 o 281-929-0804 • (a)(2): the subject matter on which the expert will testify: o his knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; o his qualifications to render an expert opinion; o plaintiff's injuries at issue in this case; o the medical care that he provided and/or prescribed to plaintiff; o the existence, nature and/or extent of, and pain associated with the injuries sustained by Plaintiff; o the examination and treatment of the injuries sustained by Plaintiff; o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack thereof; o the type, purpose, extent, results, evaluations and/or interpretations of examinations, treatments, x-rays and MRI’s tests regarding Plaintiff; o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or incapacities which Plaintiff may suffer from in the future; o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; o 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; o 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; o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical probability, will need in the future for the injuries sustained by Plaintiff in the subject collision; o all those subject matters contained, discussed or disclosed in: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause; ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o All of the above documents are incorporated herein by reference as though set out verbatim for all purposes. • (a)(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, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary; o the subject accident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and/or incapacities of Plaintiff; o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated and proximately caused by the incident made the subject of this lawsuit; o that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; o all other impressions and/or opinions that are contained, discussed, and/or disclosed in the following: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause including the following: • Medical and Billing Records from Upright MRI. See Plaintiff’s production (MUSA000133-MUSA000141) • Medical and Billing Records from Munshi Modern Pain. See Plaintiff’s production (MUSA000142-000156) • Billing Records from Sterling Pharmacy. See Plaintiff’s production (MUSA000131-MUSA000132) ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o The experts’ opinions are based on the following: ▪ The medical records of Plaintiff produced in this cause; ▪ The experts knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; ▪ The experts time, examinations, and conversations with Plaintiff; ▪ 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; ▪ The Responses to Requests for Disclosure, Responses to Requests for Production, 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. OSD SURGERY CENTER • (a)(1): expert’s name, address, and telephone number; o Omer Munshi, MD o 2121 Williams Trace Blvd., Ste. 200 Sugarland TX 77478 o 281-404-3280 • (a)(2): the subject matter on which the expert will testify: o his knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; o his qualifications to render an expert opinion; o plaintiff's injuries at issue in this case; o the medical care that he provided and/or prescribed to plaintiff; o the existence, nature and/or extent of, and pain associated with the injuries sustained by Plaintiff; o the examination and treatment of the injuries sustained by Plaintiff; o pre-existing injuries to and/or pre-existing medical conditions of Plaintiff, or lack thereof; o the type, purpose, extent, results, evaluations and/or interpretations of examinations, treatments, x-rays and MRI’s tests regarding Plaintiff; o recommendations, diagnosis and prognosis regarding the Plaintiff’s injuries; o the existence, nature and/or extent of the disabilities and/or incapacities of Plaintiff in the past, and the reasonable probability and extent of the disabilities and/or incapacities which Plaintiff may suffer from in the future; o the cause(s) of Plaintiff’s condition(s), injuries, disabilities and/or capacities; o 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; o 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; o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications prescribed to Plaintiff in the past. o the reasonableness of the costs associated with, and the necessity of, the medical services, medical care, and medications that Plaintiff, in reasonable medical probability, will need in the future for the injuries sustained by Plaintiff in the subject collision; o all those subject matters contained, discussed or disclosed in: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause; ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o All of the above documents are incorporated herein by reference as though set out verbatim for all purposes. • (a)(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, employed by, or otherwise subject to the control of the responding party, documents reflecting such information; o the medical care and treatment rendered to Plaintiff was reasonable and/or necessary; o the subject accident did, based on reasonable medical probability, cause all of the complaints, disabilities, injuries, and/or incapacities of Plaintiff; o that any surgical intervention for treatment of Plaintiff’s symptoms was necessitated and proximately caused by the incident made the subject of this lawsuit; o that the medical expenses of Plaintiff were necessitated by the incident which is the subject of this lawsuit; o all other impressions and/or opinions that are contained, discussed, and/or disclosed in the following: ▪ the medical records of Plaintiff which have been and which may hereafter be produced in this cause including the following: • Medical and Billing Records from Upright MRI. See Plaintiff’s production (MUSA000133-MUSA000141) • Medical and Billing Records from Munshi Modern Pain. See Plaintiff’s production (MUSA000142-000156) • Medical and Billing Records from OSD Surgery Center. See Plaintiff’s production (MUSA000147-MUSA000248) • Medical and Billing Records from TL Billing Management. See Plaintiff’s production (MUSA000249-MUSA000256) • Billing Records from Sterling Pharmacy. See Plaintiff’s production (MUSA000131-MUSA000132) ▪ 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; ▪ 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 ▪ all written reports of healthcare providers produced during the course of discovery in this cause. o The experts’ opinions are based on the following: ▪ The medical records of Plaintiff produced in this cause; ▪ The experts knowledge, skill, training, education, and/or experience as they relate to the subject matter of this lawsuit; ▪ The experts time, examinations, and conversations with Plaintiff; ▪ 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; ▪ The Responses to Requests for Disclosure, Responses to Requests for Production, 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. ADDITIONAL DISCLOSURES. Plaintiff also incorporates herein by reference all depositions; depositions on written questions; documents and exhibits attached to or referenced in all depositions; and all documents produced by any party hereto in disclosures and/or discovery. Any opinions and bases for opinions discussed in deposition(s) are incorporated herein. Plaintiff further refers the Defendants to Plaintiff’s retained and non-retained experts’ files, reports and supplemental reports; written discovery responses of all parties; pleadings of all parties; depositions and exhibits thereto; medical and billing records; rebuttal opinions; factual observations and opinions. Plaintiff further reserves the right through cross-examination or deposition, to call any expert witness identified herein by the Defendants. Plaintiff 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. Plaintiff 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. Plaintiff reserves all additional rights that Plaintiff may have regarding expert witnesses and testimony under the Texas Rules of Civil Procedure, case law and rulings of this Honorable Court. Plaintiff reserves the right to elicit expert opinion from any of the designated fact witnesses within any area as to which such person has expertise. Respectfully submitted, _____________________ The Law Office of Tarek Fahmy, PLLC Attorney at Law