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Filing # 117501408 E-Filed 12/02/2020 10:33:05 AM
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT
IN AND FOR ALACHUA COUNTY, FLORIDA
CIVIL DIVISION
GALE ARLEDGE and
TERRANCE ARLEDGE,
her husband,
Plaintiffs, CASE NO: 01-2018-CA-004032
Vv.
13™ STREET HOME SALES, LLC,
Defendant.
/
DEFENDANT’S SECOND AMENDED EXPERT WITNESS DISCLOSURE
The Defendant, 13"' STREET HOME SALES, LLC, by and through undersigned counsel
hereby discloses its expert witnesses as follows:
RETAINED EXPERTS
Michael J. Foley, M.D., F.A.C.R.
Radiographic Consultants, LLC
101 E. Kennedy Blvd.
Ste. 3900
Tampa, FL 33602
Telephone: (813) 229-1208
Dr. Foley is anticipated to testify as to Gale Arledge’s pre-accident and post-accident radiographic
studies. A true and correct copy of Dr. Foley’s CV has been previously provided to the Plaintiff.
Dr. Foley is available for deposition December 2, 2020 at 10:00 am, December 3, 2020 from 10:00
to 3:00 pm, and December 8, 2020, at 3:00 pm.
Donald L. Mellman, M.D., M.P.H., M.B.A., F.A.C.S., F.A.A.N.S., F.A.C.H.E.
Donald L. Mellman, MD. Inc.
11804 Middlebury Dr.
Tampa, FL. 33626
Telephone: (813) 468-2352
Dr. Foley is anticipated to testify as to his physical examination of Gale Arledge and Gale
Arledge’s pre-accident and post-accident medical condition(s). A true and correct copy of his CV
has been previously provided to the Plaintiff. Dr. Mellman is available for deposition December
09, 2020, at 10:00 am, December 11, 2020 at 10:00 am, and December 18, 2020, at 10:00 am.
"2018 CA 004032" 117501408 Filed at Alachua County Clerk 12/02/2020 10:33:09 AM ESTMichael Shahnasarian, Ph.D.
11019 North Dale Mabry Highway
Tampa, FL 33618
Telephone: (813) 265 — 9262
Dr. Shahnasarian is anticipated to testify as to Gale Arledge’s vocational rehabilitation and life
care planning. A true and correct copy of his CV has been previously provided to the Plaintiff.
Dr. Shahnasarian is available for deposition December 8, 2020 at 8:00 am, December 9, 2020 at
8:00 am, and December 10, at 4:00 pm.
Greg A. Zier, AIA, NCARB
Oxley & Brannon Construction Consultants, Inc.
13830 58TH Street North
Suite 403
Clearwater, FL 33760
Telephone: (727) 821-9190
Mr. Zier is a licensed architect and a certified general contractor. His anticipated testimony will
include the relevant building codes for the location wherein the accident occurred and the condition
of the location at the time of the inspection conducted by the Plaintiff’s experts or agents. A true
and correct copy of his CV has been previously provided to the Plaintiff. The Defendant will
provide Mr. Zier’s availability for deposition following Plaintiff's production of the photographs
obtained by the Plaintiff during the inspection of the Plaintiff’s premises.
NON-RETAINED EXPERTS
Tom Bentley, MD
6500 Newberry Road
Gainesville, FL 32605
Telephone: (352) 333-4000
Dr. Bentley provided medical treatment to Gale Arledge prior to the accident at issue in the instant
litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical
condition prior to the injuries allegedly sustained in the incident alleged in the Complaint.
Craig A Kornick, MD
7207 Golden Wings Road,
Suite 100
Jacksonville, FL 32244
Telephone: (904) 389-1010
Dr. Kornick provided medical treatment to Gale Arledge prior to the accident at issue in the instant
litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical
condition prior to the injuries allegedly sustained in the incident alleged in the Complaint. Dr.Komnick is not currently practicing medicine. As such, the Defendant has provided his last known
address herein. Defendant will amend this disclosure once a current address for Dr. Kornick is
located.
Stephen Kramarich, MD
7207 Golden Wings Road,
Suite 100
Jacksonville, FL 32244
Telephone: (904) 389-1010
Dr. Kramarich provided medical treatment to Gale Arledge prior to the accident at issue in the
instant litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her
medical condition prior to the injuries allegedly sustained in the incident alleged in the Complaint.
Samuel E. Adams, MD
6500 Newberry Road
Gainesville, FL 32605
Telephone: (352) 333-4000
Dr. Adams provided medical treatment to Gale Arledge prior to the accident at issue in the instant
litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical
condition prior to the injuries allegedly sustained in the incident alleged in the Complaint.
CE. Zuluaga, DC, PA
Hunter’s Crossing Chiropractic
4631 NW 53rd Ave
Suite 106
Gainesville, FL 32653
Telephone: (352) 378-8500
Dr. Zuluaga provided medical treatment to Gale Arledge prior to the accident at issue in the instant
litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical
condition prior to the injuries allegedly sustained in the incident alleged in the Complaint.
Miguel Dejuk, MD
800 Zeagler Drive
Ste. 210
Palatka, FL 32177
Telephone: (386) 328-8668
Dr. Dejuk provided medical treatment to Gale Arledge prior to and following the accident at issue
in the instant litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and
her medical condition prior to the injuries allegedly sustained in the incident alleged in the
Complaint, as well as her medical condition following the incident alleged in the Complaint.
Kevin Farmer, MDUF Orthopaedics and Sports Medicine Institute
3450 Hull Road
Gainesville, FL 32607
Telephone: (352) 273-7001
Dr. Farmer provided medical treatment to Gale Arledge prior to the accident at issue in the instant
litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical
condition prior to the injuries allegedly sustained in the incident alleged in the Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-served
through the Florida Courts E-filing Portal to: Ian Steiner, Esq., Ronald E. Sholes, P.A., 6850
103 Street, Suite 1, Jacksonville, Florida 32210 at RonSholesPA-Team12-
Eservice@Y ouHurtWeFight.com; Team20-Premises-Eservice@Y ouHurtWeFight.com, this 2nd
day of December 2020.
s/ Carla M. Sabbagh
Michael S. Rywant, Esquire
Florida Bar No.: 240354
Primary email:msrywant@rywantalvarez.com
Secondary: service@rywantalvarez.com
shanley@rywantalvarez.com
Carla M. Sabbagh, Esquire
Florida Bar No.: 72727
Primary email:csabbagh@rywantalvarez.com
Secondary: creneke@rywantlavarez.com
Rywant, Alvarez, Jones, Russo & Guyton, P.A.
2440 S.W. 76" Street Ste. 130
Gainesville, FL 32608
(Tel) 352-333-3700 / (Fax) 352-333-3706
Attomeys for Defendant, 13" Street Home Sales,
LLC
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Filing # 117501408 E-Filed 12/02/2020 10:33:05 AM IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA CIVIL DIVISION GALE ARLEDGE and TERRANCE ARLEDGE, her husband, Plaintiffs, CASE NO: 01-2018-CA-004032 Vv. 13™ STREET HOME SALES, LLC, Defendant. / DEFENDANT’S SECOND AMENDED EXPERT WITNESS DISCLOSURE The Defendant, 13"' STREET HOME SALES, LLC, by and through undersigned counsel hereby discloses its expert witnesses as follows: RETAINED EXPERTS Michael J. Foley, M.D., F.A.C.R. Radiographic Consultants, LLC 101 E. Kennedy Blvd. Ste. 3900 Tampa, FL 33602 Telephone: (813) 229-1208 Dr. Foley is anticipated to testify as to Gale Arledge’s pre-accident and post-accident radiographic studies. A true and correct copy of Dr. Foley’s CV has been previously provided to the Plaintiff. Dr. Foley is available for deposition December 2, 2020 at 10:00 am, December 3, 2020 from 10:00 to 3:00 pm, and December 8, 2020, at 3:00 pm. Donald L. Mellman, M.D., M.P.H., M.B.A., F.A.C.S., F.A.A.N.S., F.A.C.H.E. Donald L. Mellman, MD. Inc. 11804 Middlebury Dr. Tampa, FL. 33626 Telephone: (813) 468-2352 Dr. Foley is anticipated to testify as to his physical examination of Gale Arledge and Gale Arledge’s pre-accident and post-accident medical condition(s). A true and correct copy of his CV has been previously provided to the Plaintiff. Dr. Mellman is available for deposition December 09, 2020, at 10:00 am, December 11, 2020 at 10:00 am, and December 18, 2020, at 10:00 am. "2018 CA 004032" 117501408 Filed at Alachua County Clerk 12/02/2020 10:33:09 AM ESTMichael Shahnasarian, Ph.D. 11019 North Dale Mabry Highway Tampa, FL 33618 Telephone: (813) 265 — 9262 Dr. Shahnasarian is anticipated to testify as to Gale Arledge’s vocational rehabilitation and life care planning. A true and correct copy of his CV has been previously provided to the Plaintiff. Dr. Shahnasarian is available for deposition December 8, 2020 at 8:00 am, December 9, 2020 at 8:00 am, and December 10, at 4:00 pm. Greg A. Zier, AIA, NCARB Oxley & Brannon Construction Consultants, Inc. 13830 58TH Street North Suite 403 Clearwater, FL 33760 Telephone: (727) 821-9190 Mr. Zier is a licensed architect and a certified general contractor. His anticipated testimony will include the relevant building codes for the location wherein the accident occurred and the condition of the location at the time of the inspection conducted by the Plaintiff’s experts or agents. A true and correct copy of his CV has been previously provided to the Plaintiff. The Defendant will provide Mr. Zier’s availability for deposition following Plaintiff's production of the photographs obtained by the Plaintiff during the inspection of the Plaintiff’s premises. NON-RETAINED EXPERTS Tom Bentley, MD 6500 Newberry Road Gainesville, FL 32605 Telephone: (352) 333-4000 Dr. Bentley provided medical treatment to Gale Arledge prior to the accident at issue in the instant litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical condition prior to the injuries allegedly sustained in the incident alleged in the Complaint. Craig A Kornick, MD 7207 Golden Wings Road, Suite 100 Jacksonville, FL 32244 Telephone: (904) 389-1010 Dr. Kornick provided medical treatment to Gale Arledge prior to the accident at issue in the instant litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical condition prior to the injuries allegedly sustained in the incident alleged in the Complaint. Dr.Komnick is not currently practicing medicine. As such, the Defendant has provided his last known address herein. Defendant will amend this disclosure once a current address for Dr. Kornick is located. Stephen Kramarich, MD 7207 Golden Wings Road, Suite 100 Jacksonville, FL 32244 Telephone: (904) 389-1010 Dr. Kramarich provided medical treatment to Gale Arledge prior to the accident at issue in the instant litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical condition prior to the injuries allegedly sustained in the incident alleged in the Complaint. Samuel E. Adams, MD 6500 Newberry Road Gainesville, FL 32605 Telephone: (352) 333-4000 Dr. Adams provided medical treatment to Gale Arledge prior to the accident at issue in the instant litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical condition prior to the injuries allegedly sustained in the incident alleged in the Complaint. CE. Zuluaga, DC, PA Hunter’s Crossing Chiropractic 4631 NW 53rd Ave Suite 106 Gainesville, FL 32653 Telephone: (352) 378-8500 Dr. Zuluaga provided medical treatment to Gale Arledge prior to the accident at issue in the instant litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical condition prior to the injuries allegedly sustained in the incident alleged in the Complaint. Miguel Dejuk, MD 800 Zeagler Drive Ste. 210 Palatka, FL 32177 Telephone: (386) 328-8668 Dr. Dejuk provided medical treatment to Gale Arledge prior to and following the accident at issue in the instant litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical condition prior to the injuries allegedly sustained in the incident alleged in the Complaint, as well as her medical condition following the incident alleged in the Complaint. Kevin Farmer, MDUF Orthopaedics and Sports Medicine Institute 3450 Hull Road Gainesville, FL 32607 Telephone: (352) 273-7001 Dr. Farmer provided medical treatment to Gale Arledge prior to the accident at issue in the instant litigation, and is anticipated to testify as to the treatment rendered to the Plaintiff and her medical condition prior to the injuries allegedly sustained in the incident alleged in the Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-served through the Florida Courts E-filing Portal to: Ian Steiner, Esq., Ronald E. Sholes, P.A., 6850 103 Street, Suite 1, Jacksonville, Florida 32210 at RonSholesPA-Team12- Eservice@Y ouHurtWeFight.com; Team20-Premises-Eservice@Y ouHurtWeFight.com, this 2nd day of December 2020. s/ Carla M. Sabbagh Michael S. Rywant, Esquire Florida Bar No.: 240354 Primary email:msrywant@rywantalvarez.com Secondary: service@rywantalvarez.com shanley@rywantalvarez.com Carla M. Sabbagh, Esquire Florida Bar No.: 72727 Primary email:csabbagh@rywantalvarez.com Secondary: creneke@rywantlavarez.com Rywant, Alvarez, Jones, Russo & Guyton, P.A. 2440 S.W. 76" Street Ste. 130 Gainesville, FL 32608 (Tel) 352-333-3700 / (Fax) 352-333-3706 Attomeys for Defendant, 13" Street Home Sales, LLC