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Filing # 59027902 E-Filed 07/14/2017 12:20:16 PM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL
CIRCUIT IN AND FOR JACKSON COUNTY, FLORIDA
KIM BICE and SHAWN BICE as parents and
natural guardians a: minor,
Plaintiffs,
-v- CASE NO.: 16-133-CA
CAROLYN JOHNSON d/b/a JOHNSON RENTALS,
individually, and DUCKY JOHNSON HOUSE
MOVERS, INC., a Florida corporation
Defendants.
PLAINTIFFS’ WITNESS, EXPERT, AND EXHIBIT LIST
The Plaintiffs file this Witness, Expert, and Exhibit List in compliance with the Court’s
Order Setting Pretrial Conference, Jury Trial and. Directing Mediation.
WITNESS LIST
1. Kim Bice
Key Largo, FL 33037
2. Shawn Bice
Key Largo, FL 33037
Key Largo, FL 33037
4. Donald Bice
Grand Ridge, FL 32442
5. Carolyn Johnson
Electronically Filed Jackson Case # 16000133CAAXMX 07/14/2017 11:20:16 AMMarianna, FL 32446
6. Corporate Representative for Carolyn Johnson d/b/a Johnson Rentals
5194 Hwy 90
Marianna, FL 32446
7. Corporate Representative for Ducky Johnson House Movers, Inc.
5194 Hwy 90
Marianna, FL 32446
8. Nicole Johnson
seas ; a.
9. Rebecca Wagner
Marianna, FL 32446
10. Any lay witness disclosed by the Defendants
11. Any and all rebuttal witnesses as may be necessary
12. Any and all impeachment witnesses as may be necessary
13. Any and all records custodians as may be necessary
14, Michael McKenzie, ARNP
Treating nurse practitioner
This witness has retired and Plaintiffs’ counsel are working to obtain his current contact
information.
Michael McKenzie is Plaintiff] | treating nurse practitioner and has not been
retained as an expert by the Plaintiffs in this matter. However, Mr. McKenzie will be asked
to give specialized or expert opinion(s) regarding his education and background as a nurse
practitioner, his treatment of Li
and the specific treatment_provided to
Plinti (thc nature of the specific injuries suffered by Plaintiff, a
his opinions regarding the cause of Plaintiff injuries and future care needed
by Plaintiff| a the permanency of Plaintiff] injuries, the costs of
the past and future care of Plaintift if any, and any other opinions germane to
his treatment of Plaintiff]
15. Dr. Val Dee Sheffield, MD
Treating physician16.
HE h: permanency of Plaintiff]
future care of Plaintiff fany,
of Plaintifi
17.
Jackson County Hospital
4250 Hospital Drive
Marianna, FL 32446
Dr. Sheffield is Plaintiff HE «cating emergency care physician and has not been
retained as an expert by the Plaintiffs in this matter. However, Dr. Sheffield will be asked
to give specialized or expert opinion(s) regarding her education and background as a
physician, her treatment of Plaintiff]
and the specific treatment_provided to
Phin aa the nature of the specific injuries suffered by ini
her opinions regarding the cause of Plaintiff| injuries and future care needed
by — | the permanency of Plaintiff injuries, the costs of
the past and future care of Plaintifi if any, and any other opinions germane to
her treatment of Plainti
Wendy Miller, RN
Treating nurse
UF Health Jacksonville
655 W 8" Street
Jacksonville, FL 32209
Wendy Miller is Plaintiff HE «cating emergency care nurse and has not been
retained as an expert by the Plaintiffs in this matter. However, Ms. Miller will be asked to
give specialized or expert a regarding her education and background as a nurse,
her treatment of Plaintiff and the specific treatment provided to Plainti{/ =i
Hine nature of the specific injuries suffered by i her opinions
regarding the cause of Plaintiff njuries and future care needed by Plaintiff
injuries, the costs of the past and
and any other opinions germane to her treatment
Dr. James Christian Brown, MD
Treating physician
UF Health Shands Hospital
1600 SW Archer Road
Gainesville, FL 32608
Dr. Brown is Plaintifi eating emergency care physician and has not been
retained as an expert by the Plaintiffs in this matter. However, Dr. Brown will be asked to
give specialized or expert opinion(s) regarding his education and background as a
physici i nt of Plaintiff] ee the specific treatment provided t
Plaintiff the nature of the specific injuries suffered by |
his opinions regarding the cause of Plaintiff — injuries and future care needed
by Plaintiff] | the permanency of Plaintiff Taylor Bice’s injuries, the costs of
the past and future care of Phin a any, and any other opinions germane to
3his treatment of Phin
18. Dr. Chris Wade Babl, MD
Treating physician
UF Health Shands Hospital
1600 SW Archer Road
Gainesville, FL 32608
Dr. Babl is Plaintiff HE eating emergency care physician and has not been
retained as an expert by the Plaintiffs in this matter. However, Dr. Babl will be asked to
give specialized or expert opinion(s) regarding his education and background as a
physician, his treatment of Plaintiff ind the specific treatme i
Phin the nature of the specific injuries suffered by Plainti
his opinions regarding the cause of Plaintiff| injuries and future care needed
by >. a permanency of Plaintiff injuries, the costs of
the past and future care inti any, and any other opinions germane to
his treatment of Plainti:
19. Rachel Nettle, ARNP
Treating nurse practitioner
UF Health Shands Hospital
1600 SW Archer Road
Gainesville, FL 32608
Rachel Nettle is Plaintiff P| treating pediatric nurse practitioner and has not
been retained as an expert by the Plaintiffs in this matter. However, Ms. Nettle will be
asked to give specialized or expert opinion(s) regarding her education and background as
a nurse practitioner, her treatment of Pini a and the specific treatment
provided to Plain EE thc nature of the specific injuries suffered by Plaintiff
a opinions regarding the cause of Pi A ie future
care needed by Paint a permanency of Plainti injuries,
the costs of the past and future care o' aT if any, and any other opinions
germane to her treatment of Plaintiff
20. Dr. Stanley Zuba, MD
Treating physician
Florida Keys Pediatrics & Adolescent Center
91550 Overseas Highway Suite 209
Tavernier, FL 33070
Dr. Zuba is Prin treating physician and has not been retained as an
expert by the Plaintiffs in this matter. However, Dr. Zuba will be asked to give
specialized or expert opinion(s) regarding his education and background as a physician,
421.
22.
23.
24.
his treatment of Phin and the specific treatment provided to Plaintiff
F the nature of the specific injuries suffered by Plainti {EE his
opinions regarding the cause of Plainti i id future care needed by
Plaintiff jE the permanency of Plaintiff] injuries, the costs of the
past and future care of Plaintiff if any, and any other opinions germane to
his treatment of Plaintiff]
All treating health care providers at UF Health Shands Hospital
1600 SW Archer Road
Gainesville, FL 32608
Any other attending or treating health care providers as mentioned mi
medical records.
Any experts retained and disclosed as testifying witnesses by the Defendants.
Any expert rebuttal witnesses depending on the testifying experts disclosed by
Defendants and the nature of that testimony.
EXHIBIT LIST
1. All medical bills and records
2. Social Security Administration Mortality Tables
3. All documents produced by either party pursuant to a Request for Production
4. All documents produced by any entity or individual pursuant to a Third Party
Subpoena
5. All deposition transcripts for depositions taken in this case
6. All videotaped depositions taken in this case
7. Any and all documents, items, or things that have been obtained by the Defendants or
Plaintiffs pursuant to a third party/ non-party subpoena8. Any and all other expert exhibits which have not been finalized at this juncture
9, Any and all deposition videos, exhibits, and/or transcripts for any and all experts for
all parties
10. Any and all deposition videos, exhibits, and/or transcripts for any and all witnesses
11. Photographs and videos of injuries re
12. All documents related to the rental property where the subject incident occurred.
13. Any item or thing listed on the Defendants’ witness and exhibit lists
14. Any and all rebuttal evidence
15. Any and all impeachment evidence
Plaintiffs reserve the right to amend their witness, expert, and exhibit list as discovery is
ongoing.
Respectfully submitted the 14" day of July 2017.
SCOTT & WALLACE LLP
/s/ Robert M. Scott
Robert M. Scott
Florida Bar No. 57149
J. Clint Wallace
Florida Bar No. 59590
209 E. Brevard Street
Tallahassee, Florida 32301
Telephone: (850) 222-7777
Facsimile: (850) 222-7778
rscott@scottandwallacelaw.com
ewallace@scottandwallacelaw.com
Attorneys for Kim and Shawn Bice as natural guardians of
a minor, the PlaintiffCERTIFICATE OF SERVICE
I certify that a copy of the foregoing has been e-served on Valerie P. Dray
(Valerie.dray@esklegal.com) and Randall G. Rogers (randall.rogers@ecsklegal.com), and on
Clifford W. Sanborn at csanborn@barronredding.com, sbelli@barronredding.com and
eservice@barronredding.com utilizing the eservice portal on July 14, 2017.
/s/ Robert M. Scott
Robert M. Scott
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Filing # 59027902 E-Filed 07/14/2017 12:20:16 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR JACKSON COUNTY, FLORIDA KIM BICE and SHAWN BICE as parents and natural guardians a: minor, Plaintiffs, -v- CASE NO.: 16-133-CA CAROLYN JOHNSON d/b/a JOHNSON RENTALS, individually, and DUCKY JOHNSON HOUSE MOVERS, INC., a Florida corporation Defendants. PLAINTIFFS’ WITNESS, EXPERT, AND EXHIBIT LIST The Plaintiffs file this Witness, Expert, and Exhibit List in compliance with the Court’s Order Setting Pretrial Conference, Jury Trial and. Directing Mediation. WITNESS LIST 1. Kim Bice Key Largo, FL 33037 2. Shawn Bice Key Largo, FL 33037 Key Largo, FL 33037 4. Donald Bice Grand Ridge, FL 32442 5. Carolyn Johnson Electronically Filed Jackson Case # 16000133CAAXMX 07/14/2017 11:20:16 AMMarianna, FL 32446 6. Corporate Representative for Carolyn Johnson d/b/a Johnson Rentals 5194 Hwy 90 Marianna, FL 32446 7. Corporate Representative for Ducky Johnson House Movers, Inc. 5194 Hwy 90 Marianna, FL 32446 8. Nicole Johnson seas ; a. 9. Rebecca Wagner Marianna, FL 32446 10. Any lay witness disclosed by the Defendants 11. Any and all rebuttal witnesses as may be necessary 12. Any and all impeachment witnesses as may be necessary 13. Any and all records custodians as may be necessary 14, Michael McKenzie, ARNP Treating nurse practitioner This witness has retired and Plaintiffs’ counsel are working to obtain his current contact information. Michael McKenzie is Plaintiff] | treating nurse practitioner and has not been retained as an expert by the Plaintiffs in this matter. However, Mr. McKenzie will be asked to give specialized or expert opinion(s) regarding his education and background as a nurse practitioner, his treatment of Li and the specific treatment_provided to Plinti (thc nature of the specific injuries suffered by Plaintiff, a his opinions regarding the cause of Plaintiff injuries and future care needed by Plaintiff| a the permanency of Plaintiff] injuries, the costs of the past and future care of Plaintift if any, and any other opinions germane to his treatment of Plaintiff] 15. Dr. Val Dee Sheffield, MD Treating physician16. HE h: permanency of Plaintiff] future care of Plaintiff fany, of Plaintifi 17. Jackson County Hospital 4250 Hospital Drive Marianna, FL 32446 Dr. Sheffield is Plaintiff HE «cating emergency care physician and has not been retained as an expert by the Plaintiffs in this matter. However, Dr. Sheffield will be asked to give specialized or expert opinion(s) regarding her education and background as a physician, her treatment of Plaintiff] and the specific treatment_provided to Phin aa the nature of the specific injuries suffered by ini her opinions regarding the cause of Plaintiff| injuries and future care needed by — | the permanency of Plaintiff injuries, the costs of the past and future care of Plaintifi if any, and any other opinions germane to her treatment of Plainti Wendy Miller, RN Treating nurse UF Health Jacksonville 655 W 8" Street Jacksonville, FL 32209 Wendy Miller is Plaintiff HE «cating emergency care nurse and has not been retained as an expert by the Plaintiffs in this matter. However, Ms. Miller will be asked to give specialized or expert a regarding her education and background as a nurse, her treatment of Plaintiff and the specific treatment provided to Plainti{/ =i Hine nature of the specific injuries suffered by i her opinions regarding the cause of Plaintiff njuries and future care needed by Plaintiff injuries, the costs of the past and and any other opinions germane to her treatment Dr. James Christian Brown, MD Treating physician UF Health Shands Hospital 1600 SW Archer Road Gainesville, FL 32608 Dr. Brown is Plaintifi eating emergency care physician and has not been retained as an expert by the Plaintiffs in this matter. However, Dr. Brown will be asked to give specialized or expert opinion(s) regarding his education and background as a physici i nt of Plaintiff] ee the specific treatment provided t Plaintiff the nature of the specific injuries suffered by | his opinions regarding the cause of Plaintiff — injuries and future care needed by Plaintiff] | the permanency of Plaintiff Taylor Bice’s injuries, the costs of the past and future care of Phin a any, and any other opinions germane to 3his treatment of Phin 18. Dr. Chris Wade Babl, MD Treating physician UF Health Shands Hospital 1600 SW Archer Road Gainesville, FL 32608 Dr. Babl is Plaintiff HE eating emergency care physician and has not been retained as an expert by the Plaintiffs in this matter. However, Dr. Babl will be asked to give specialized or expert opinion(s) regarding his education and background as a physician, his treatment of Plaintiff ind the specific treatme i Phin the nature of the specific injuries suffered by Plainti his opinions regarding the cause of Plaintiff| injuries and future care needed by >. a permanency of Plaintiff injuries, the costs of the past and future care inti any, and any other opinions germane to his treatment of Plainti: 19. Rachel Nettle, ARNP Treating nurse practitioner UF Health Shands Hospital 1600 SW Archer Road Gainesville, FL 32608 Rachel Nettle is Plaintiff P| treating pediatric nurse practitioner and has not been retained as an expert by the Plaintiffs in this matter. However, Ms. Nettle will be asked to give specialized or expert opinion(s) regarding her education and background as a nurse practitioner, her treatment of Pini a and the specific treatment provided to Plain EE thc nature of the specific injuries suffered by Plaintiff a opinions regarding the cause of Pi A ie future care needed by Paint a permanency of Plainti injuries, the costs of the past and future care o' aT if any, and any other opinions germane to her treatment of Plaintiff 20. Dr. Stanley Zuba, MD Treating physician Florida Keys Pediatrics & Adolescent Center 91550 Overseas Highway Suite 209 Tavernier, FL 33070 Dr. Zuba is Prin treating physician and has not been retained as an expert by the Plaintiffs in this matter. However, Dr. Zuba will be asked to give specialized or expert opinion(s) regarding his education and background as a physician, 421. 22. 23. 24. his treatment of Phin and the specific treatment provided to Plaintiff F the nature of the specific injuries suffered by Plainti {EE his opinions regarding the cause of Plainti i id future care needed by Plaintiff jE the permanency of Plaintiff] injuries, the costs of the past and future care of Plaintiff if any, and any other opinions germane to his treatment of Plaintiff] All treating health care providers at UF Health Shands Hospital 1600 SW Archer Road Gainesville, FL 32608 Any other attending or treating health care providers as mentioned mi medical records. Any experts retained and disclosed as testifying witnesses by the Defendants. Any expert rebuttal witnesses depending on the testifying experts disclosed by Defendants and the nature of that testimony. EXHIBIT LIST 1. All medical bills and records 2. Social Security Administration Mortality Tables 3. All documents produced by either party pursuant to a Request for Production 4. All documents produced by any entity or individual pursuant to a Third Party Subpoena 5. All deposition transcripts for depositions taken in this case 6. All videotaped depositions taken in this case 7. Any and all documents, items, or things that have been obtained by the Defendants or Plaintiffs pursuant to a third party/ non-party subpoena8. Any and all other expert exhibits which have not been finalized at this juncture 9, Any and all deposition videos, exhibits, and/or transcripts for any and all experts for all parties 10. Any and all deposition videos, exhibits, and/or transcripts for any and all witnesses 11. Photographs and videos of injuries re 12. All documents related to the rental property where the subject incident occurred. 13. Any item or thing listed on the Defendants’ witness and exhibit lists 14. Any and all rebuttal evidence 15. Any and all impeachment evidence Plaintiffs reserve the right to amend their witness, expert, and exhibit list as discovery is ongoing. Respectfully submitted the 14" day of July 2017. SCOTT & WALLACE LLP /s/ Robert M. Scott Robert M. Scott Florida Bar No. 57149 J. Clint Wallace Florida Bar No. 59590 209 E. Brevard Street Tallahassee, Florida 32301 Telephone: (850) 222-7777 Facsimile: (850) 222-7778 rscott@scottandwallacelaw.com ewallace@scottandwallacelaw.com Attorneys for Kim and Shawn Bice as natural guardians of a minor, the PlaintiffCERTIFICATE OF SERVICE I certify that a copy of the foregoing has been e-served on Valerie P. Dray (Valerie.dray@esklegal.com) and Randall G. Rogers (randall.rogers@ecsklegal.com), and on Clifford W. Sanborn at csanborn@barronredding.com, sbelli@barronredding.com and eservice@barronredding.com utilizing the eservice portal on July 14, 2017. /s/ Robert M. Scott Robert M. Scott