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Filing # 95704772 E-Filed 09/13/2019 05:19:25 PM
IN THE CIRCUIT COURT OF THE FIFTHTEETH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO: 2018-CA-015498-XXXX-MB
ERROLL INNISS,
Plaintiff,
vs.
THE FLORIDA HIGHWAY PATROL,
A division of FLORIDA DEPARTMENT
OF HIGHWAY SAFETY & MOTOR
VEHICLES, an Agency of the State of
Florida, and TROOPER RICKY LEE
MAYO,
Defendants.
/
DEFENDANTS, THE FLORIDA HIGHWAY PATROL AND TROOPER RICKY LEE
MAYO’S EXHIBIT LIST FOR TRIAL
Come now, Defendants THE FLORIDA HIGHWAY PATROL and RICKY LEE
MAYO, by and through the undersigned counsel and pursuant to the Order Setting Jury
Trial dated August 5, 2019, and files this list of Trial Exhibits as follows:
Exhibit | Exhibit Description Objection | Marked
No.
Medical Records re: Erroll Inniss
Jaimy H. Bensimon, MD PA
Independent Imaging
Jeffrey L. Katzell, MD, PA
JFK Medical Center
Lake Worth Surgical Center
Olympia Medical Center
Dr. Renes Castor
Palm Beach County Fire Rescue
Palms West Hospital
Brett A. Schlifka, DO
Radiology Physician Solutions
Sierra Surgical
Southern Chiropractic Life Center
David Migdal, DC
$0] 20) NO?) 1) BO) OT
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AION:
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 09/13/2019 05:19:25 PM ***CASE NO: 2018-CA-015498
Defendant's Exhibit List for Trial
Page 2 of 3
Exhibit | Exhibit Description Objection | Marked
No.
15. SportsCare Institute
Aka SportsCare of America, PC
16. The Imaging Centers
17. Wellington Regional Medical Center
18. Accident Report
19. Any and all digital imaging studies of plaintiff
20. Medical bills of plaintiff
21. Photographs of plaintiff's injuries
22. Photographs of accident scene and/or vehicles
involved
23. The Florida highway patrol records
24. Employment records of Ricky Mayo
25. All parties responses to _ interrogatories,
responses to request for production and
responses to requests for admissions
26. Exhibits produced at depositions and in response
to requests for production of documents
27. Charts, diagrams, and other demonstrative
evidence.
28. Curriculum Vitae of treating physicians and/or
experts.
29. Blow-ups of selected portions of medical charts,
medical records and diagnostic studies
30. Relevant medical text articles and periodicals.
31. Rebuttal documents and evidence
32. Any and all anatomical diagrams, models,
illustrations, photographs and charts or other
demonstrative aids used by Plaintiff's trial
experts.
33. Any and all anatomical diagrams, models,
illustrations, photographs and charts or other
demonstrative aids used by Defendants’ trial
experts.
34. Any and all documents produced pursuant to any
subpoena duces tecum which any party issued.
35. Any and all applicable ordinances, statutes
and/or cases.
36. Any and all reports prepared by any expert of any
party.
37. Any and all records or documents utilized by any
persons called as a witness in this matter.
38. Any and all records of all parties to this lawsuit
and/or the representatives thereof.CASE NO: 2018-CA-015498
Defendant's Exhibit List for Trial
Page 3 of 3
Exhibit | Exhibit Description Objection | Marked
No.
39. Any and all depositions taken by any party from
the date of the certificate of service herein to the
date of trial.
40. Any and all pleadings or documents filed with this
Court from the certificate of service date herein to
the date of the trial.
This Defendant reserves the right to amend this List of Trial Exhibits pursuant to
the Court's Pretrial Order.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true copy of the foregoing has been furnished by
electronic mail only via the E-Portal to Brett m. Steinberg, Esq. of Steinberg Law, P.A., 10
S.E. 1% Ave, Ste. C, Delray Beach, FL 33444, [melanie@brettsteinberglaw.com,
steinberglawservice@qmail.com] on this 13th day of September, 2019.
BOBO, CIOTOLI, WHITE & RUSSELL, P.A.
Counsel for FLORIDA HIGHWAY PATROL and
TROOPER RICKY LEE MAYO
11641 Kew Gardens Avenue
Suite 101
Palm Beach Gardens, Florida 33410
Tel. No.: 561-684-6600
Fax No.: 561-622-6288
Primary: pleadingsnpb@bobolaw.com
Secondary: dunlap@bobolaw.com
/s/David C. Dunham, Esq.
By:
James L. White, III, Esq.
Florida Bar No.: 0325030
E-mail: white@bobolaw.com
David C. Dunham, Esquire
Florida Bar Number: 0989990
E-mail: dunham@bobolaw.com
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Filing # 95704772 E-Filed 09/13/2019 05:19:25 PM IN THE CIRCUIT COURT OF THE FIFTHTEETH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2018-CA-015498-XXXX-MB ERROLL INNISS, Plaintiff, vs. THE FLORIDA HIGHWAY PATROL, A division of FLORIDA DEPARTMENT OF HIGHWAY SAFETY & MOTOR VEHICLES, an Agency of the State of Florida, and TROOPER RICKY LEE MAYO, Defendants. / DEFENDANTS, THE FLORIDA HIGHWAY PATROL AND TROOPER RICKY LEE MAYO’S EXHIBIT LIST FOR TRIAL Come now, Defendants THE FLORIDA HIGHWAY PATROL and RICKY LEE MAYO, by and through the undersigned counsel and pursuant to the Order Setting Jury Trial dated August 5, 2019, and files this list of Trial Exhibits as follows: Exhibit | Exhibit Description Objection | Marked No. Medical Records re: Erroll Inniss Jaimy H. Bensimon, MD PA Independent Imaging Jeffrey L. Katzell, MD, PA JFK Medical Center Lake Worth Surgical Center Olympia Medical Center Dr. Renes Castor Palm Beach County Fire Rescue Palms West Hospital Brett A. Schlifka, DO Radiology Physician Solutions Sierra Surgical Southern Chiropractic Life Center David Migdal, DC $0] 20) NO?) 1) BO) OT = ° = = afalo AION: *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 09/13/2019 05:19:25 PM ***CASE NO: 2018-CA-015498 Defendant's Exhibit List for Trial Page 2 of 3 Exhibit | Exhibit Description Objection | Marked No. 15. SportsCare Institute Aka SportsCare of America, PC 16. The Imaging Centers 17. Wellington Regional Medical Center 18. Accident Report 19. Any and all digital imaging studies of plaintiff 20. Medical bills of plaintiff 21. Photographs of plaintiff's injuries 22. Photographs of accident scene and/or vehicles involved 23. The Florida highway patrol records 24. Employment records of Ricky Mayo 25. All parties responses to _ interrogatories, responses to request for production and responses to requests for admissions 26. Exhibits produced at depositions and in response to requests for production of documents 27. Charts, diagrams, and other demonstrative evidence. 28. Curriculum Vitae of treating physicians and/or experts. 29. Blow-ups of selected portions of medical charts, medical records and diagnostic studies 30. Relevant medical text articles and periodicals. 31. Rebuttal documents and evidence 32. Any and all anatomical diagrams, models, illustrations, photographs and charts or other demonstrative aids used by Plaintiff's trial experts. 33. Any and all anatomical diagrams, models, illustrations, photographs and charts or other demonstrative aids used by Defendants’ trial experts. 34. Any and all documents produced pursuant to any subpoena duces tecum which any party issued. 35. Any and all applicable ordinances, statutes and/or cases. 36. Any and all reports prepared by any expert of any party. 37. Any and all records or documents utilized by any persons called as a witness in this matter. 38. Any and all records of all parties to this lawsuit and/or the representatives thereof.CASE NO: 2018-CA-015498 Defendant's Exhibit List for Trial Page 3 of 3 Exhibit | Exhibit Description Objection | Marked No. 39. Any and all depositions taken by any party from the date of the certificate of service herein to the date of trial. 40. Any and all pleadings or documents filed with this Court from the certificate of service date herein to the date of the trial. This Defendant reserves the right to amend this List of Trial Exhibits pursuant to the Court's Pretrial Order. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true copy of the foregoing has been furnished by electronic mail only via the E-Portal to Brett m. Steinberg, Esq. of Steinberg Law, P.A., 10 S.E. 1% Ave, Ste. C, Delray Beach, FL 33444, [melanie@brettsteinberglaw.com, steinberglawservice@qmail.com] on this 13th day of September, 2019. BOBO, CIOTOLI, WHITE & RUSSELL, P.A. Counsel for FLORIDA HIGHWAY PATROL and TROOPER RICKY LEE MAYO 11641 Kew Gardens Avenue Suite 101 Palm Beach Gardens, Florida 33410 Tel. No.: 561-684-6600 Fax No.: 561-622-6288 Primary: pleadingsnpb@bobolaw.com Secondary: dunlap@bobolaw.com /s/David C. Dunham, Esq. By: James L. White, III, Esq. Florida Bar No.: 0325030 E-mail: white@bobolaw.com David C. Dunham, Esquire Florida Bar Number: 0989990 E-mail: dunham@bobolaw.com