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Filing # 140912749 E-Filed 12/23/2021 04:45:04 PM
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
ELIZABETH L. BALZARANO, CASE NO.: 50-2018-CA-15763-XXXX-MB
Individually, and as Personal Representative
of the ESTATE OF MICHELLE L.
BALZARANO,
Plaintiffs,
v.
LIFELINE RECOVERY, LLC d/b/a
LIFELINE RECOVERY SUPPORT
SERVICES, a Foreign Corporation; JOHN
BROGAN; LIFE CHANGES ADDICTION
TREATMENT CENTER OF THE PALM
BEACHES; WARBIRD PROPERTIES, LLC,
d/b/a CAMERON VILLA, LLC, a Florida
Corporation, EMILIO DUBOY, M.D.; and,
JANINE BEATTIE, ARNP,
Defendants.
/
DEFENDANT’S WITNESS AND EXHIBIT LIST
COME NOW Defendant, EMILIO DUBOY, M.D., by and through their undersigned
counsel, and pursuant to this Court’s Order Setting Jury Trial and Directing Pretrial and
Mediation Procedures dated September 15, 2021, hereby file this Witness and Exhibit List as
follows:
DEFENDANT EMILIO DUBOY, M.D.WITNESS LIST
Parties:
Name: Elizabeth L. Balzarano
Liability and damage witness / Plaintiff
Address: c/o Thomas Scolaro and Thomas D. Graham, Esq.
LEESFIELD SCOLARO, P.A.,
264573519v.1
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/23/2021 04:45:04 PM ***Name:
Address:
Name:
Name:
Name:
Name:
Name:
Name:
Name:
264573519v.1
2350 South Dixie Highway,
Miami, Florida 33133
Dominic Williams
Liability and damage witness
c/o Thomas Scolaro and Thomas D. Graham, Esq.
LEESFIELD SCOLARO, P.A.,
2350 South Dixie Highway,
Miami, Florida 33133
Emilio Deboy, M.D.
Liability witness / Defendant
c/o Noelle Sheehan, Esq. & Molly Durso, Esq.
Contact Through Counsel
Corporate Representative of Lifeline Recovery, LLC d/b/a Lifeline
Recovery Support Services
Liability witness / Defendant
Jonathan M. Midwall, Esquire, and Alyssa Tornberg, Esquire
Cole Scott & Kissane, P.A.,
110 Tower, 110 S.E. 6th Street, Suite 2700,
Ft. Lauderdale, Florida 33301
Corporate Representative of Life Changes Addiction Treatment
Center ofthe Palm Beaches
Liability witness / Defendant
Contact through counsel
Corporate Representative of Warbird Properties, LLC, d/b/a
Cameron Villa, LLC
Liability witness / Defendant
Contact through counsel
Janine Beattie, ARNP
Liability witness / Defendant
Jonathan M. Midwall, Esquire, and Alyssa Tornberg, Esquire
Cole Scott & Kissane, P.A.,
110 Tower, 110 S.E. 6th Street, Suite 2700,
Ft. Lauderdale, Florida 33301
Mary M. Coumbe
Liability and damages
208 North Kay Street
Lake Worth, FL 33460
Benjamin CardillaName:
Name:
Name:
Name:
Name:
Name:
Name:
Name:
Name:
Name:
Name:
264573519v.1
Liability and damages
Address unknown
Lori Withworth
Liability and damages
Address unknown
Cami Eldridge
Liability and damages
Address unknown
Casey Floyd
Liability and damages
Address unknown
Martin Mobarek (Life Changes)
Liability and damages
Address unknown
Debbie Martin (Cameron Villa)
Liability and damages
Address unknown
Sean Grant
Liability and damages
Address unknown
Sarah (Roommate)
Liability and damages
Address unknown
Chris Lorenzo (Peer Recovery Specialist)
Liability and damages
Address unknown
Cherie (Mentor)
Liability and damages
Address unknown
Kelsey (Mentor)
Liability and damages
Address unknown
Felipe Diaz (Case Manager)
Liability and damages
Address unknownName: Andrew Huisman (Belmar Police)
Liability and damages
1775 Glendola Road
Wall Township, NJ 07719
Name: Adrienne Johnson (Director of NJ Addiction Triage)
Liability and damages
Address unknown
Name: Nelson (Inspirations)
Liability and damages
Address unknown
Name: Frank Walter (South Florida Recovery Marketing)
Liability and damages
Address unknown
Name: Telby Cavalieri (Probation Officer)
Liability and damages
Address unknown
Expert Witnesses:
1.
Steven A. Fayer, MD, PC {Psychiatry and Neurology}
169 East 74" Street
New York , NY 10021
Phone: (212) 628-6208
Dr. Fayer is a physician who specializes in and is board certified in psychiatry and
neurology. His educational and professional background, training and experience is
detailed in his CV which is provided under separate cover. Dr. Fayer will discuss his review
of materials in this case and his interpretation of the records and events. He will also review
all depositions as taken and may offer further opinions based upon the material reviewed.
Dr. Fayer will discuss the basis for his opinion, his knowledge of applicable standard of
care, and his opinions on standard of care and causation regarding this matter. Dr. Fayer
may discuss Michelle. Balzarano’s history, the interaction between Michelle Balzarano and
various healthcare providers who saw her previously or during the course of events made
the basis of this lawsuit, as well as those who saw Michelle Balzarano during her
subsequent care. His opinions in this case will be based upon a reasonable degree of
medical probability.
Dr. Fayer will also opine that Dr. Duboy was reasonable and met the standard of care when
treating Michelle Balzarano. Dr. Fayer will opine that Dr. Duboy’s care and treatment of
Michele Balzarano was reasonable and appropriate. He will further opine that Michelle
Balzarano’s injuries were not due to any negligence or gross negligence on the part of Dr.
264573519v.1Duboy. He will testify about treatment and medications provided to Michelle Balzarano
while in-patient.
Dr. Fayer may testify regarding the mental impressions and opinions of Plaintiffs’ experts,
and the health care providers of Michelle Balzarano, and will rebut any testimony offered
that Dr. Duboy was negligent or grossly negligent, breached the standard of care and/or
caused or contributed to cause Plaintiffs’ alleged injuries and/or damages. Dr. Fayer will
rebut any testimony offered by Plaintiffs’ experts or health care providers that Dr. Duboy
failed to meet the standard of care or caused any injuries or damages.
Dr. Fayer’s opinions are and will be based on his education, training, experience, Michelle
Balzarano’s medical records, documents produced, depositions, exhibits and attachments
to depositions and any newly discovered evidence, if any.
Defendant incorporates by reference all opinions which may be offered by Dr. Fayer at
the time of his deposition. Dr. Fayer reserves the right to offer additional opinions after
the case has been fully discovered. Dr. Fayer will also offer rebuttal opinions, if
necessary.
2. Discovery is ongoing and Defendants may call any witness deposed or identified in this
cause who has "expert" knowledge.
3. Although not retained experts, Defendants may call at trial the health care providers who
have examined, provided therapy or other services, or who treated Michelle Balzarano.
Such witnesses are expected to testify as to the facts regarding his condition and their care,
treatment and/or therapies rendered to her.
4. All expert witness whose purpose is to impeach the testimony proffered by a fact or expert
witnesses.
5. Any and all expert witnesses listed by any party in this case, not otherwise objected to by
these Defendants.
The Defendant reserves the right to supplement this list to include additional expert witnesses
as discovery continues or for rebuttal purposes.
Treating Physicians and/or Records Custodian of:
1. Life Changes Addiction Treatment Center of The Palm Beaches
900 Osceola Drive, Suite 200
West Palm Beach, FL 33409
264573519v.12. JFK Medical Center
5301 South Congress Avenue
Atlantis, FL 33452
3. Cameron Villas
930 Grace Avenue
Lake Worth, FL 33461
4. Integrity House
103 Lincoln Park
P.O. Box 510
Newark, NJ 07101
5. Walmart Pharmacy
1200 S Pine Island Road
Plantation, FL 3324
6. CVS Pharmacy
Once CVS Drive
Woonsocket, RI 02895
7. Office of the District Medical Examiner
District 15 — State of Florida
3126 Gun Club Road
West Palm Beach, FL 33406
8. Carrier Clinic
252 Co Road 601
Bell Mead, NJ 08502
9. New Hope — Discovery Institute
80 Conover Road
Malboro, NJ 07746
10. Epiphany House
1110 Grand Avenue
Asbury Park, NJ 07712
11. Catholic Charities
238 Neptune Blvd
Neptune, NJ
12. Jersey Shore University Medical Center
Rosa Pavilion
1945 NJ 33
264573519v.1Neptune City, NJ 07753
13. David Moskowitz, MD
1112 Commons Way Bldg F,
Toms River, NJ 08755
14. Monmouth Medical Center
300 2nd Ave,
Long Branch, NJ 07740
15. Turning Point
532 County Rd 523
Whitehouse Station, NJ 08889
16. Blue Cross & Blue Shield of New Jersey
250 Century Pkwy,
Mt Laurel Township, NJ 08054
17. State of New Jersey
Department of Human Services
Division of Medical Assistance and Health Services
P.O. Box 712
Trenton, NJ 08625
18. Any witnesses identified in the pleadings, Answers to the Interrogatories, depositions,
Tesponses to Requests for Admissions and/or items provided in response to Subpoenas,
Notices to Produce, Requests to Produce and/or Consents to Release of Information.
19. All parties to this action.
20. Any and all medical and billing records custodians for healthcare providers who may have
treated Plaintiff who may not have been specifically listed.
21. Medical personnel who performed any x-rays, MRIs or any other diagnostic procedures
for any and all of Plaintiff's treating, consulting and/or examining physicians,
chiropractors, psychiatrists, pain management consultants and counselors or hospitals.
22. Record custodians for Medicare and Medicaid.
23. All witnesses listed by Plaintiffs and Co-Defendants in their witness lists.
24. Appropriate records custodians of all documentary evidence listed in any pretrial Statement
and/or Witness List filed in this cause.
25. Any and all expert witnesses retained by the Plaintiff or Co-Defendants.
26. Any and all persons identified in the Plaintiff's employment records.
264573519v.127. Records Custodians of all Plaintiff's treating or examining physicians, surgeons, therapists,
clinics, hospitals, diagnostic studies, including x-rays and MRI scans and other health care
professionals.
28. Those witnesses necessary for impeachment or rebuttal purposes.
Defendant reserves the right to amend and/or supplement this Witness List with appropriate
notice to opposing counsel, prior to the trial of this matter.
DEFENDANT EMILIO DUBOY, M.D. EXHIBIT LIST
1. Any and all Medical records, including office notes, reports, billing, charts, diagnostic
studies, or other documentation evidencing interaction with the patient and/or patient care
from the following individuals or entities:
264573519v.1
a.
Life Changes Addiction Treatment Center of The Palm Beaches
900 Osceola Drive, Suite 200
West Palm Beach, FL 33409
JFK Medical Center
5301 South Congress Avenue
Atlantis, FL 33452
. Cameron Villas
930 Grace Avenue
Lake Worth, FL 33461
Integrity House
103 Lincoln Park
P.O. Box 510
Newark, NJ 07101
Walmart Pharmacy
1200 S Pine Island Road
Plantation, FL 3324
Office of the District Medical Examiner
District 15 — State of Florida
3126 Gun Club Road
West Palm Beach, FL 33406
CVS Pharmacy
Once CVS Drive
Woonsocket, RI 02895h. Carrier Clinic
252 Co Road 601
Bell Mead, NJ 08502
i New Hope — Discovery Institute
80 Conover Road
Malboro, NJ 07746
j. Epiphany House
1110 Grand Avenue
Asbury Park, NJ 07712
k. Catholic Charities
238 Neptune Blvd
Neptune, NJ
1 Jersey Shore University Medical Center
Rosa Pavilion
1945 NJ 33
Neptune City, NJ 07753
m. David Moskowitz, MD
1112 Commons Way Bldg F,
Toms River, NJ 08755
n. Monmouth Medical Center
300 2nd Ave,
Long Branch, NJ 07740
o. Turning Point
532 County Rd 523
Whitehouse Station, NJ 08889
p. Blue Cross & Blue Shield of New Jersey
250 Century Pkwy,
Mt Laurel Township, NJ 08054
q. State of New Jersey
Department of Human Services
Division of Medical Assistance and Health Services
P.O. Box 712
Trenton, NJ 08625
2. Photographs, drawings or videos of the Plaintiff, including enlargements and demonstrative
aids.
264573519v.120.
21.
22.
All evidence and/or exhibits listed by the Plaintiff or Co-Defendants as well as any
attachments thereto.
All depositions (including videotaped depositions), exhibits to deposition, Answers to
Interrogatories, Responses to Requests to Produce, Responses to Requests for Admissions ,
and items produced to Notices of Production from Non-Parties, Subpoenas Duces Tecum,
consent to Release of information, and affidavits in this matter.
Copies of Plaintiff's health, dental, and mental health records and/or reports; all x-rays and
other diagnostic tests and studies; and statements from any of the Plaintiff's health care
providers or examiners.
Applicable statutes or ordinances
Mortality records.
Charts, diagrams, graphs, models, authoritative texts, articles, treatises to be used by the
Defendant’s expert witnesses or to impeach Plaintiff's witnesses.
Records pertaining to payment of benefits from any collateral sources.
. Any and all documents regarding any liens related to this action.
. Composite of medical bills and other related expenses relevant to the injuries being claimed
in this matter
. Exhibits necessary for impeachment purposes.
. Any and all exhibits to be used for rebuttal purposes.
Diagnostic photos and imaging.
. Any and all pharmaceutical and billing records.
. CV of Defendants
. Any and all certificates, certifications or CVs of any party in this action.
. Any and all certificates, certifications or CVs of any experts in this action.
. Without waiving objections thereto, any and all exhibits listed on Plaintiff's witness and
exhibit lists.
Without waiving objections thereto, any and all exhibits listed on any of Defendant’s
witness and exhibit lists.
All exhibits identified between now and start of trial.
Future depositions and exhibits to future depositions, including expert witness depositions,
to be taken in this action.
264573519v.123. Records, notes and reports generated by any Experts used at trial relating to this case.
24. Demonstrative aids for trial including but not limited to time lines, anatomical and medical
illustrations or models, diagrams or photos.
25. Enlarged copies of medical records, charts, diagrams, reports, articles, exhibits to
depositions or other documents.
26. All pleadings filed in this action.
Defendants reserve the right to amend and or supplement their exhibit disclosure as
additional exhibits become known to Defendants upon proper notice to the other parties, based on
subsequent discovery or for rebuttal purposes.
Defendants reserve any and all objections to any and all exhibits listed by any other party
in this matter.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing was filed with the Clerk of Court via the Florida
Courts E-Filing Portal and a true and correct copy was served via email on December 23, 2021
upon Jonathan M. Midwall, Esquire, and Alyssa Tornberg, Esquire, Cole Scott & Kissane, P.A.,
110 Tower, 110 SE. 6th Street, Suite 2700, Ft. Lauderdale, Florida 33301
Jonathan.Midwall@csklegalcom, Alyssa. Tornberg@csklegalcom (Attorney for Defendant Life
Changes Addition Treatment Center of the Palm Beaches, Jeanine Beattie, ARNP); Thomas
Scolaro and Thomas D. Graham, LEESFIELD SCOLARO, P.A., 2350 South Dixie Highway,
Miami, Florida 33133, scolaro@leesfield.com; graham@leesfield.com (Attorney for Plaintiff);
William McCaughan, Esq, Farrell Patel Jomarron & Lopez, 4300 Biscayne Blvd Suite 305, Miami,
FL 33137, wmccaughan@justice360.com, eservice@justice360.com, (Attorney for John Brogan
and Lifeline Recovery, LLC); Nicole Sauvola, P.A, 13889 Deer Creek Dr, Palm Beach Gardens ,
FL, colelaw36@gmail.com, (Attorney for Defendant Warbird Properties LLC d/b/a Cameron
Villa.
264573519v.1264573519v.1
/s/ Noelle K. Sheehan
NOELLE K. SHEEHAN, ESQUIRE
Florida Bar No.: 0084677
MOLLY J. DURSO, ESQUIRE
Florida Bar No.: 0091029
Wilson Elser Moskowitz Edelman & Dicker, LLP
111 N. Orange Ave., Suite 1200
Orlando, FL 32801
Phone: (407) 203-7599
Fax: (407) 648-1376
Noelle. Sheehan@wilsonelser.com
Molly.Durso@wilsonelser.com
Karla. Velazquez-Suarez@wilsone lser.com
Alejandra. Boscan@wilsonelser.com
Counsel for Defendant Emilio Duboy
Preview
Filing # 140912749 E-Filed 12/23/2021 04:45:04 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA ELIZABETH L. BALZARANO, CASE NO.: 50-2018-CA-15763-XXXX-MB Individually, and as Personal Representative of the ESTATE OF MICHELLE L. BALZARANO, Plaintiffs, v. LIFELINE RECOVERY, LLC d/b/a LIFELINE RECOVERY SUPPORT SERVICES, a Foreign Corporation; JOHN BROGAN; LIFE CHANGES ADDICTION TREATMENT CENTER OF THE PALM BEACHES; WARBIRD PROPERTIES, LLC, d/b/a CAMERON VILLA, LLC, a Florida Corporation, EMILIO DUBOY, M.D.; and, JANINE BEATTIE, ARNP, Defendants. / DEFENDANT’S WITNESS AND EXHIBIT LIST COME NOW Defendant, EMILIO DUBOY, M.D., by and through their undersigned counsel, and pursuant to this Court’s Order Setting Jury Trial and Directing Pretrial and Mediation Procedures dated September 15, 2021, hereby file this Witness and Exhibit List as follows: DEFENDANT EMILIO DUBOY, M.D.WITNESS LIST Parties: Name: Elizabeth L. Balzarano Liability and damage witness / Plaintiff Address: c/o Thomas Scolaro and Thomas D. Graham, Esq. LEESFIELD SCOLARO, P.A., 264573519v.1 *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 12/23/2021 04:45:04 PM ***Name: Address: Name: Name: Name: Name: Name: Name: Name: 264573519v.1 2350 South Dixie Highway, Miami, Florida 33133 Dominic Williams Liability and damage witness c/o Thomas Scolaro and Thomas D. Graham, Esq. LEESFIELD SCOLARO, P.A., 2350 South Dixie Highway, Miami, Florida 33133 Emilio Deboy, M.D. Liability witness / Defendant c/o Noelle Sheehan, Esq. & Molly Durso, Esq. Contact Through Counsel Corporate Representative of Lifeline Recovery, LLC d/b/a Lifeline Recovery Support Services Liability witness / Defendant Jonathan M. Midwall, Esquire, and Alyssa Tornberg, Esquire Cole Scott & Kissane, P.A., 110 Tower, 110 S.E. 6th Street, Suite 2700, Ft. Lauderdale, Florida 33301 Corporate Representative of Life Changes Addiction Treatment Center ofthe Palm Beaches Liability witness / Defendant Contact through counsel Corporate Representative of Warbird Properties, LLC, d/b/a Cameron Villa, LLC Liability witness / Defendant Contact through counsel Janine Beattie, ARNP Liability witness / Defendant Jonathan M. Midwall, Esquire, and Alyssa Tornberg, Esquire Cole Scott & Kissane, P.A., 110 Tower, 110 S.E. 6th Street, Suite 2700, Ft. Lauderdale, Florida 33301 Mary M. Coumbe Liability and damages 208 North Kay Street Lake Worth, FL 33460 Benjamin CardillaName: Name: Name: Name: Name: Name: Name: Name: Name: Name: Name: 264573519v.1 Liability and damages Address unknown Lori Withworth Liability and damages Address unknown Cami Eldridge Liability and damages Address unknown Casey Floyd Liability and damages Address unknown Martin Mobarek (Life Changes) Liability and damages Address unknown Debbie Martin (Cameron Villa) Liability and damages Address unknown Sean Grant Liability and damages Address unknown Sarah (Roommate) Liability and damages Address unknown Chris Lorenzo (Peer Recovery Specialist) Liability and damages Address unknown Cherie (Mentor) Liability and damages Address unknown Kelsey (Mentor) Liability and damages Address unknown Felipe Diaz (Case Manager) Liability and damages Address unknownName: Andrew Huisman (Belmar Police) Liability and damages 1775 Glendola Road Wall Township, NJ 07719 Name: Adrienne Johnson (Director of NJ Addiction Triage) Liability and damages Address unknown Name: Nelson (Inspirations) Liability and damages Address unknown Name: Frank Walter (South Florida Recovery Marketing) Liability and damages Address unknown Name: Telby Cavalieri (Probation Officer) Liability and damages Address unknown Expert Witnesses: 1. Steven A. Fayer, MD, PC {Psychiatry and Neurology} 169 East 74" Street New York , NY 10021 Phone: (212) 628-6208 Dr. Fayer is a physician who specializes in and is board certified in psychiatry and neurology. His educational and professional background, training and experience is detailed in his CV which is provided under separate cover. Dr. Fayer will discuss his review of materials in this case and his interpretation of the records and events. He will also review all depositions as taken and may offer further opinions based upon the material reviewed. Dr. Fayer will discuss the basis for his opinion, his knowledge of applicable standard of care, and his opinions on standard of care and causation regarding this matter. Dr. Fayer may discuss Michelle. Balzarano’s history, the interaction between Michelle Balzarano and various healthcare providers who saw her previously or during the course of events made the basis of this lawsuit, as well as those who saw Michelle Balzarano during her subsequent care. His opinions in this case will be based upon a reasonable degree of medical probability. Dr. Fayer will also opine that Dr. Duboy was reasonable and met the standard of care when treating Michelle Balzarano. Dr. Fayer will opine that Dr. Duboy’s care and treatment of Michele Balzarano was reasonable and appropriate. He will further opine that Michelle Balzarano’s injuries were not due to any negligence or gross negligence on the part of Dr. 264573519v.1Duboy. He will testify about treatment and medications provided to Michelle Balzarano while in-patient. Dr. Fayer may testify regarding the mental impressions and opinions of Plaintiffs’ experts, and the health care providers of Michelle Balzarano, and will rebut any testimony offered that Dr. Duboy was negligent or grossly negligent, breached the standard of care and/or caused or contributed to cause Plaintiffs’ alleged injuries and/or damages. Dr. Fayer will rebut any testimony offered by Plaintiffs’ experts or health care providers that Dr. Duboy failed to meet the standard of care or caused any injuries or damages. Dr. Fayer’s opinions are and will be based on his education, training, experience, Michelle Balzarano’s medical records, documents produced, depositions, exhibits and attachments to depositions and any newly discovered evidence, if any. Defendant incorporates by reference all opinions which may be offered by Dr. Fayer at the time of his deposition. Dr. Fayer reserves the right to offer additional opinions after the case has been fully discovered. Dr. Fayer will also offer rebuttal opinions, if necessary. 2. Discovery is ongoing and Defendants may call any witness deposed or identified in this cause who has "expert" knowledge. 3. Although not retained experts, Defendants may call at trial the health care providers who have examined, provided therapy or other services, or who treated Michelle Balzarano. Such witnesses are expected to testify as to the facts regarding his condition and their care, treatment and/or therapies rendered to her. 4. All expert witness whose purpose is to impeach the testimony proffered by a fact or expert witnesses. 5. Any and all expert witnesses listed by any party in this case, not otherwise objected to by these Defendants. The Defendant reserves the right to supplement this list to include additional expert witnesses as discovery continues or for rebuttal purposes. Treating Physicians and/or Records Custodian of: 1. Life Changes Addiction Treatment Center of The Palm Beaches 900 Osceola Drive, Suite 200 West Palm Beach, FL 33409 264573519v.12. JFK Medical Center 5301 South Congress Avenue Atlantis, FL 33452 3. Cameron Villas 930 Grace Avenue Lake Worth, FL 33461 4. Integrity House 103 Lincoln Park P.O. Box 510 Newark, NJ 07101 5. Walmart Pharmacy 1200 S Pine Island Road Plantation, FL 3324 6. CVS Pharmacy Once CVS Drive Woonsocket, RI 02895 7. Office of the District Medical Examiner District 15 — State of Florida 3126 Gun Club Road West Palm Beach, FL 33406 8. Carrier Clinic 252 Co Road 601 Bell Mead, NJ 08502 9. New Hope — Discovery Institute 80 Conover Road Malboro, NJ 07746 10. Epiphany House 1110 Grand Avenue Asbury Park, NJ 07712 11. Catholic Charities 238 Neptune Blvd Neptune, NJ 12. Jersey Shore University Medical Center Rosa Pavilion 1945 NJ 33 264573519v.1Neptune City, NJ 07753 13. David Moskowitz, MD 1112 Commons Way Bldg F, Toms River, NJ 08755 14. Monmouth Medical Center 300 2nd Ave, Long Branch, NJ 07740 15. Turning Point 532 County Rd 523 Whitehouse Station, NJ 08889 16. Blue Cross & Blue Shield of New Jersey 250 Century Pkwy, Mt Laurel Township, NJ 08054 17. State of New Jersey Department of Human Services Division of Medical Assistance and Health Services P.O. Box 712 Trenton, NJ 08625 18. Any witnesses identified in the pleadings, Answers to the Interrogatories, depositions, Tesponses to Requests for Admissions and/or items provided in response to Subpoenas, Notices to Produce, Requests to Produce and/or Consents to Release of Information. 19. All parties to this action. 20. Any and all medical and billing records custodians for healthcare providers who may have treated Plaintiff who may not have been specifically listed. 21. Medical personnel who performed any x-rays, MRIs or any other diagnostic procedures for any and all of Plaintiff's treating, consulting and/or examining physicians, chiropractors, psychiatrists, pain management consultants and counselors or hospitals. 22. Record custodians for Medicare and Medicaid. 23. All witnesses listed by Plaintiffs and Co-Defendants in their witness lists. 24. Appropriate records custodians of all documentary evidence listed in any pretrial Statement and/or Witness List filed in this cause. 25. Any and all expert witnesses retained by the Plaintiff or Co-Defendants. 26. Any and all persons identified in the Plaintiff's employment records. 264573519v.127. Records Custodians of all Plaintiff's treating or examining physicians, surgeons, therapists, clinics, hospitals, diagnostic studies, including x-rays and MRI scans and other health care professionals. 28. Those witnesses necessary for impeachment or rebuttal purposes. Defendant reserves the right to amend and/or supplement this Witness List with appropriate notice to opposing counsel, prior to the trial of this matter. DEFENDANT EMILIO DUBOY, M.D. EXHIBIT LIST 1. Any and all Medical records, including office notes, reports, billing, charts, diagnostic studies, or other documentation evidencing interaction with the patient and/or patient care from the following individuals or entities: 264573519v.1 a. Life Changes Addiction Treatment Center of The Palm Beaches 900 Osceola Drive, Suite 200 West Palm Beach, FL 33409 JFK Medical Center 5301 South Congress Avenue Atlantis, FL 33452 . Cameron Villas 930 Grace Avenue Lake Worth, FL 33461 Integrity House 103 Lincoln Park P.O. Box 510 Newark, NJ 07101 Walmart Pharmacy 1200 S Pine Island Road Plantation, FL 3324 Office of the District Medical Examiner District 15 — State of Florida 3126 Gun Club Road West Palm Beach, FL 33406 CVS Pharmacy Once CVS Drive Woonsocket, RI 02895h. Carrier Clinic 252 Co Road 601 Bell Mead, NJ 08502 i New Hope — Discovery Institute 80 Conover Road Malboro, NJ 07746 j. Epiphany House 1110 Grand Avenue Asbury Park, NJ 07712 k. Catholic Charities 238 Neptune Blvd Neptune, NJ 1 Jersey Shore University Medical Center Rosa Pavilion 1945 NJ 33 Neptune City, NJ 07753 m. David Moskowitz, MD 1112 Commons Way Bldg F, Toms River, NJ 08755 n. Monmouth Medical Center 300 2nd Ave, Long Branch, NJ 07740 o. Turning Point 532 County Rd 523 Whitehouse Station, NJ 08889 p. Blue Cross & Blue Shield of New Jersey 250 Century Pkwy, Mt Laurel Township, NJ 08054 q. State of New Jersey Department of Human Services Division of Medical Assistance and Health Services P.O. Box 712 Trenton, NJ 08625 2. Photographs, drawings or videos of the Plaintiff, including enlargements and demonstrative aids. 264573519v.120. 21. 22. All evidence and/or exhibits listed by the Plaintiff or Co-Defendants as well as any attachments thereto. All depositions (including videotaped depositions), exhibits to deposition, Answers to Interrogatories, Responses to Requests to Produce, Responses to Requests for Admissions , and items produced to Notices of Production from Non-Parties, Subpoenas Duces Tecum, consent to Release of information, and affidavits in this matter. Copies of Plaintiff's health, dental, and mental health records and/or reports; all x-rays and other diagnostic tests and studies; and statements from any of the Plaintiff's health care providers or examiners. Applicable statutes or ordinances Mortality records. Charts, diagrams, graphs, models, authoritative texts, articles, treatises to be used by the Defendant’s expert witnesses or to impeach Plaintiff's witnesses. Records pertaining to payment of benefits from any collateral sources. . Any and all documents regarding any liens related to this action. . Composite of medical bills and other related expenses relevant to the injuries being claimed in this matter . Exhibits necessary for impeachment purposes. . Any and all exhibits to be used for rebuttal purposes. Diagnostic photos and imaging. . Any and all pharmaceutical and billing records. . CV of Defendants . Any and all certificates, certifications or CVs of any party in this action. . Any and all certificates, certifications or CVs of any experts in this action. . Without waiving objections thereto, any and all exhibits listed on Plaintiff's witness and exhibit lists. Without waiving objections thereto, any and all exhibits listed on any of Defendant’s witness and exhibit lists. All exhibits identified between now and start of trial. Future depositions and exhibits to future depositions, including expert witness depositions, to be taken in this action. 264573519v.123. Records, notes and reports generated by any Experts used at trial relating to this case. 24. Demonstrative aids for trial including but not limited to time lines, anatomical and medical illustrations or models, diagrams or photos. 25. Enlarged copies of medical records, charts, diagrams, reports, articles, exhibits to depositions or other documents. 26. All pleadings filed in this action. Defendants reserve the right to amend and or supplement their exhibit disclosure as additional exhibits become known to Defendants upon proper notice to the other parties, based on subsequent discovery or for rebuttal purposes. Defendants reserve any and all objections to any and all exhibits listed by any other party in this matter. CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing was filed with the Clerk of Court via the Florida Courts E-Filing Portal and a true and correct copy was served via email on December 23, 2021 upon Jonathan M. Midwall, Esquire, and Alyssa Tornberg, Esquire, Cole Scott & Kissane, P.A., 110 Tower, 110 SE. 6th Street, Suite 2700, Ft. Lauderdale, Florida 33301 Jonathan.Midwall@csklegalcom, Alyssa. Tornberg@csklegalcom (Attorney for Defendant Life Changes Addition Treatment Center of the Palm Beaches, Jeanine Beattie, ARNP); Thomas Scolaro and Thomas D. Graham, LEESFIELD SCOLARO, P.A., 2350 South Dixie Highway, Miami, Florida 33133, scolaro@leesfield.com; graham@leesfield.com (Attorney for Plaintiff); William McCaughan, Esq, Farrell Patel Jomarron & Lopez, 4300 Biscayne Blvd Suite 305, Miami, FL 33137, wmccaughan@justice360.com, eservice@justice360.com, (Attorney for John Brogan and Lifeline Recovery, LLC); Nicole Sauvola, P.A, 13889 Deer Creek Dr, Palm Beach Gardens , FL, colelaw36@gmail.com, (Attorney for Defendant Warbird Properties LLC d/b/a Cameron Villa. 264573519v.1264573519v.1 /s/ Noelle K. Sheehan NOELLE K. SHEEHAN, ESQUIRE Florida Bar No.: 0084677 MOLLY J. DURSO, ESQUIRE Florida Bar No.: 0091029 Wilson Elser Moskowitz Edelman & Dicker, LLP 111 N. Orange Ave., Suite 1200 Orlando, FL 32801 Phone: (407) 203-7599 Fax: (407) 648-1376 Noelle. Sheehan@wilsonelser.com Molly.Durso@wilsonelser.com Karla. Velazquez-Suarez@wilsone lser.com Alejandra. Boscan@wilsonelser.com Counsel for Defendant Emilio Duboy