Preview
Filing # 142543279 E-Filed 01/24/2022 04:29:58 PM
IN THE CIRCUIT COURT OF THE 19TH
JUDICIAL CIRCUIT IN AND FOR MARTIN
COUNTY, FLORIDA
CASE NO.: 2019CA000015
FREDERIC CHARLES GREER, III and
MELISSA ANNE GREER, as Husband and
Wife, and FREDERIC CHARLES GREER, III
and MELISSA ANNE GREER, individually
Plaintiffs,
vs.
MARTIN MEMORIAL MEDICAL
CENTER, INC. d/b/a MARTIN MEDICAL
CENTER, a Florida Corporation, KUNAL
CHAUDHRY, M.D. and CARDIOLOGY
ASSOCIATES OF STUART, P.A., a Florida
Corporation
Defendants
/
DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN
MEDICAL CENTER’S, NINTH AMENDED EXPERT WITNESS DISCLOSURE
Defendants, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN
MEDICAL CENTER by and through undersigned counsel hereby files this Ninth Amended
disclosure of the following expert witnesses:
1. Jerome A. Barakos, M.D. - Neuroradiology
California Pacific Medical Center
Third Floor, Department of Radiology
1101 Van Ness Avenue
San Francisco, CA 94109
Dr. Barakos is a Neuroradiology expert who is expected to provide testimony related to
causation and damages on behalf of the Defendant, Martin Memorial Medical Center, Inc.
d/b/a Martin Medical Center.
Dr. Barakos’ opinions are based upon his education, training and experience, as well as his
review of deposition testimony, relevant medical records imaging studies, and pleadings,Greer v Martin Memorial Medical Center, Inc.
Case No.: 2019CA000015
Page 2
Dr. Barakos is expected to testify regarding the timing, nature, and cause of Plaintiff,
Frederic Charles Greer, III’s claimed neurological and cognitive injuries.
Also, see Dr. Barakos deposition taken on April 22, 2021.
Dr. Barakos’ curriculum vitae was previously provided and is attached herewith (MMMC-
006767-0006826).
Dominique Bradford, RN, RCIS, IV, CVN — Cardiac Cath Nursing
27061 Shipwreck Drive
Shelbyville, DE 19775
Nurse Bradford is a nursing expert who is expected to provide testimony related to the
nursing standard of care on behalf of the Defendant, Martin Memorial Medical Center, Inc.
d/b/a Martin Medical Center.
Nurse Bradford’s opinions are based upon her education, training and experience, as well
as her review of relevant medical records, policies and procedures, deposition testimony
and pleadings.
Nurse Bradford is expected to testify that the nurses caring for Plaintiff, Frederic Charles
Greer, III on September 1, 2017, were at all times in compliance with the appropriate
standard of care.
Also, see Nurse Bradford’s deposition taken on March 15, 2021.
A copy of Nurse Bradford’s curriculum vitae was previously produced (MMMC-005970-
005971).
Michael J. Carmichael, M.D. - Cardiothoracic Surgery
8115 Main Street
Bokeelia, FL 33922
Dr. Carmichael is expected to testify on the issues of standard of care, causation and
damages. Specifically, he is expected to testify that the care and treatment did not
contribute to or cause any injuries to the Plaintiff.
Dr. Carmichael’s opinions are based upon his education, training and experience in his field
of expertise, as well as his review of relevant medical records, deposition testimony,
employment records and pleadings.
Also, see Dr. Charmichael’s deposition taken on January 16, 2020.
Dr. Carmichael's curriculum vitae was previously provided and is attached herewith
(MMMC-006752-006766).Greer v Martin Memorial Medical Center, Inc.
Case No.: 2019CA000015
Page 3
4. Stephen Durham, Ph.D. — Economist
100 North Tampa Street, Suite 2410
Tampa, FL 33602
Dr. Durham is an economist who is expected to testify and rebut Plaintiffs’ economic
analysis on behalf of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center.
Dr. Durham’s opinions are based upon his education, training and experience in his field
of expertise, as well as his review of relevant medical records, employment records, income
tax returns, Social Security Administration records, deposition testimony and pleadings.
A copy of Dr. Durham’s curriculum vitae was previously produced (MMMC-005972-
005973).
5. Timothy Fischell, M.D. — Interventional Cardiology
Borgess Heart Institute
1521 Gull Road
Kalamazoo, MI 49048
Dr. Fischell is an International Cardiology expert who is expected to provide testimony
related to standard of care, causation and damages on behalf of the Defendants, Kunal
Chaudhry, M.D. and Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center.
Dr. Fischell’s opinions are based upon his education, training and experience, as well as his
review of relevant medical records and depositions, and his review of medical records,
relevant deposition testimony and pleadings
Dr. Fischell is expected to testify that nothing the employees, servants, agents and/or
apparent agents of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center did
or failed to do caused or contributed to the injuries alleged by the Plaintiff, Frederic Charles
Greer, III.
Also, see Dr. Fischell’s deposition taken on January 22, 2020.
A copy of Dr. Fischell’s Curriculum Vitae was previously produced and is attached
herewith (MMMC-005974-006010).
6. Kim Klancke, M.D. — Internal Medicine, and Cardiovascular Disease
Daytona Heart Group
695 North Clyde Morris Boulevard
Daytona Beach, FL 32114
Dr. Klancke is an expert who is board certified in Internal Medicine, and Cardiovascular
Disease. Dr. Klancke is expected to provide testimony related to standard of care,
causation and damages on behalf of the Defendant, Martin Memorial Medical Center, Inc.
d/b/a Martin Memorial Medical Center.Greer v Martin Memorial Medical Center, Inc.
Case No.: 2019CA000015
Page 4
Dr. Klancke’s opinions are based upon her education, training and experience, as well as
her review of relevant medical records and depositions,
Dr. Klancke is expected to testify that nothing the employees, servants, actual agents and/or
apparent agents of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center did
or failed to do caused or contributed to the injuries alleged by the Plaintiff, Frederic Charles
Greer, III.
Also see Dr. Klancke’s deposition taken on November 15, 2019.
A copy of Dr. Klancke’s Curriculum Vitae was previously produced (MMMC-006011-
006022).
Eric D. Kramer, M.D. — Neurology
140 John F. Kennedy Drive, Suite 140
Atlantis, FL 33462
Dr. Kramer is a neurologist who is expected to provide testimony related to causation and
damages on behalf of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center.
Dr. Kramer is expected to testify that Martin Memorial Medical Center’s care and
treatment of the Plaintiff, Frederic Charles Greer, III, did not cause and/or contribute to
any of his alleged injuries. Moreover, Dr. Kramer is expected to testify on issues relating
to Plaintiffs alleged diagnosis of an anoxic or hypoxic brain injury.
Dr. Kramer is expected to testify base on his opinions on his examination and evaluation
of Mr. Greer, the depositions taken in this case, reports from Plaintiffs’ damages experts,
medical records and other relevant records and documents obtained in this case and
generated through discovery.
A copy of Dr. Kramer’s curriculum vitae was previously produced (MMMC-006023-
006033).
Tomas D. Martin, M.D. — Cardiothoracic Surgery
Division of Thoracic & Cardiovascular Surgery
College of Medicine
Director, University of Florida Aortic Disease Center
P O Box 103720
Gainesville, FL 32610
Dr. Martin is a Cardiothoracic Surgery expert who is expected to provide testimony related
to standard of care, causation and damages on behalf of the Defendant, Martin Memorial
Medical Center, Inc. d/b/a Martin Medical Center.
Based on his education, training and experience, as well as his review of relevant medical
records and depositions, Dr. Martin is expected to testify that nothing the employees,
servants, actual agents and/or apparent agents of Martin Memorial Medical Center, Inc.Greer v Martin Memorial Medical Center, Inc.
Case No.: 2019CA000015
Page 5
d/b/a Martin Medical Center, did or failed to do caused or contributed to the injuries alleged
by the Plaintiff, Frederic Charles Greer, III.
Also, see Dr. Martin’s deposition taken on January 15, 2021.
A copy of Dr. Martin’s curriculum vitae was previously produced (MMMC-006034-
006052).
9. Joel Meyer, M.D. — Neuroradiology
The University of Chicago Pritzker School of Medicine
2650 Ridge Avenue
Evanston, IL 60201
Dr. Meyer is a Neuroradiology expert who is expected to provide testimony related to
causation and damages on behalf of the Defendant, Martin Memorial Medical Center, Inc.
d/b/a Martin Medical Center.
Based on his education, training and experience, as well as his review of relevant medical
records, depositions, and imaging studies, Dr. Meyer is expected to testify regarding the
timing, nature, and cause of Plaintiff, Frederic Charles Greer, III’s claimed neurological
and cognitive injuries.
Also see Dr. Meyer’s deposition taken on February 16, 2021.
A copy of Dr. Meyer’s curriculum vitae was previously produced (MMMC-006053-
006075).
10. Robert F. Padera, M.D., Ph.D. — Cardiac Pathology
Department of Pathology
Brigham and Women’s Hospital
75 Francis St.
Boston, MA 02115
Dr. Padera is a Cardiac Pathology expert who is expected to provide testimony related to
causation and damages on behalf of the Defendant, Martin Memorial Medical Center, Inc.
d/b/a Martin Medical Center.
Based on his education, training and experience, as well as his review of relevant medical
records, depositions, and pathology slides, Dr. Padera is expected to testify regarding the
timing, nature, and cause of Plaintiff, Frederic Charles Greer, III’s claimed cardiac injuries.
Also see Dr. Padera’s deposition taken on February 19, 2021.
A copy of Dr. Padera’s curriculum vitae was previously produced (MMMC-006076-
006111).Greer v Martin Memorial Medical Center, Inc.
Case No.: 2019CA000015
Page 6
11. Harris R. Stutman, M.D. — Clinical Informatics — EPIC
5300 24" Avenue NE, Unit #425
Seattle, WA 98105
Dr. Stutman is a Clinical Informatics expert who is expected to provide testimony related
to the EPIC system on behalf of the Defendant, Martin Memorial Medical Center, Inc.
d/b/a Martin Medical Center. Dr. Stutman is expected to testify regarding the EPIC system
and the electronic medical records, in general, as well as the EPIC records in regard to
Frederic Greer.
Dr. Stutman’s opinions, in part, are based on his education, training and experience, as well
as his review of relevant medical records, depositions, Access Log Report, Audit Trail
Report, Cardiac Cath Event Log, electronic medical records and various motions regarding
the on-site inspection and opposition to same, as well as the hearing transcripts regarding
Plaintiffs’ motion for an on-site inspection.
A copy of Dr. Stutman’s curriculum vitae was previously produced (MMMC-006604-
006609).
12. Ronald B. Tolchin, D.O. — Physiatrist
Baptist Center for Spine Care
8950 North Kendall Drive, Suite 410W
Miami, FL 33176
Dr. Tolchin is a physiatrist who is expected to provide testimony related to causation and
damages on behalf of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center.
Additionally,
Dr. Tolchin is expected to testify consistent with his IME of the Plaintiff, Frederic Charles
Greer, III, which will include, but may not be limited to, Mr. Greer’s functional
capabilities, restrictions, limitations, prognosis, degree of impairment, life expectancy and
necessity of future medical treatment. Dr. Tolchin is further expected to opine on Mr.
Greer’s ability to work in sedentary positions/jobs. Dr. Tolchin is expected to base his
opinions on his IME of Mr. Greer performed on November 8, 2019, the depositions taken
in this case, reports from Plaintiffs’ damages experts, medical records and other relevant
records and documents obtained in this case and generated through discovery, as well as
his education, training and experience.
A copy of Dr. Tolchin’s curriculum vitae was previously produced (MMMC-0061 12-
00061126).Greer v Martin Memorial Medical Center, Inc.
Case No.: 2019CA000015
Page 7
13,
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
RESERVATION OF RIGHT
Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN
MEDICAL CENTER reserves the right to supplement this Expert Witness List with expert
witnesses, as they become known to this Defendant upon proper notice to all parties.
Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN
MEDICAL CENTER reserves the right to call any and all treating physicians and/or other
health care providers as experts in their fields of practice with respect to opinions as to the
pre-existing conditions of Plaintiff, Frederic Charles Greer, III.
Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN
MEDICAL CENTER reserves the right to call any and all experts listed by all the parties
to this action, whether or not they are a party at the time of trial. By listing a Witness,
Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN
MEDICAL CENTER is indicating only that they may call said Witness and by so listing,
waive no other objections to said Witnesses.
All anticipated opinions listed as part of this Expert Witness Disclosure are general areas
of discussion and each witness will be available for deposition in order for the Plaintiff to
explore all aspects of their opinions. This disclosure is not intended to limit the extent or
nature of the opinions of these witnesses at the time of their deposition or at time of trial.
Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN
MEDICAL CENTER adopts and incorporates, as if fully set forth herein, each and every
previously E-filed Expert Witness Disclosures.
Any and all expert witnesses listed by any other party.
Any and all experts deposed in this matter.
Other experts pending further discovery.
Any and all impeachment or rebuttal witnesses that may be developed or may be necessary
to the proper defense of these claims.
Defendant reserves any and all objections to any and all expert witnesses listed by any
other party.
Defendant reserves the right to amend this Expert Witness Disclosure as discovery
continues.Greer v Martin Memorial Medical Center, Inc.
Case No.: 2019CA000015
Page 8
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this 24% day of January 2022, a copy of the foregoing
was served via the Florida E-Filing Portal to the parties on the attached service list.
STEARNS WEAVER MILLER
WEISSLER ALHADEFF & SITTERSON, P.A.
Attorneys for Martin Memorial Medical Center, Inc.
200 East Las Olas Blvd., Suite 2100
Fort Lauderdale, FL 33301
Phone: (954) 462-9500
Fax: (954) 462-956
By:
FBN: 008060
taubin@stearnsweaver.com
MATTHEW S. PODOLNICK, ESQUIRE
FBN: 112126
mpodolnick@stearnsweaver.com
AMANDA L. SPENCER, ESQUIRE
FBN: 1010874
aspencer( @stearnsweaver.comGreer v Martin Memorial Medical Center, Inc.
Case No.: 2019CA000015
Page 9
SERVICE LIST
Peter J. Somera Jr., Esq.
Paul M. Silva, M.D., Esq.
Somera & Silva, LLP
2255 Glades Road, Suite 232W
Boca Raton, FL 33431
Phone: (561) 981-8881
Fax: (561) 981-8887
pleadings@somerasilva.com
litigation@somerasilva.com
Attorneys for Plaintiffs
Geoffrey N. Fieger, Esq.
Fieger Law
19390 West Ten Mile Road
Southfield, MI 48075
Phone: (248) 355-5555
Fax: (248) 355-5148
G.Fieger@Fiegerlaw.com
S.Teal@Fiegerlaw.com
Co-Attorneys for Plaintiffs
Adam Richardson, Esq.
Bard D. Rockenbach, Esq.
Burlington & Rockenbach, P.A.
444 West Railroad Avenue
West Palm Beach, FL 33401
Tel: 561-721-0400
ajr@FLAppellateLaw.com
bdr@FLAppellateLaw.com
fa@FLAppellateLaw.com
Appellate attorneys for Plaintiffs
#9368895 v1
Preview
Filing # 142543279 E-Filed 01/24/2022 04:29:58 PM IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT IN AND FOR MARTIN COUNTY, FLORIDA CASE NO.: 2019CA000015 FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, as Husband and Wife, and FREDERIC CHARLES GREER, III and MELISSA ANNE GREER, individually Plaintiffs, vs. MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER, a Florida Corporation, KUNAL CHAUDHRY, M.D. and CARDIOLOGY ASSOCIATES OF STUART, P.A., a Florida Corporation Defendants / DEFENDANT, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER’S, NINTH AMENDED EXPERT WITNESS DISCLOSURE Defendants, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER by and through undersigned counsel hereby files this Ninth Amended disclosure of the following expert witnesses: 1. Jerome A. Barakos, M.D. - Neuroradiology California Pacific Medical Center Third Floor, Department of Radiology 1101 Van Ness Avenue San Francisco, CA 94109 Dr. Barakos is a Neuroradiology expert who is expected to provide testimony related to causation and damages on behalf of the Defendant, Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Dr. Barakos’ opinions are based upon his education, training and experience, as well as his review of deposition testimony, relevant medical records imaging studies, and pleadings,Greer v Martin Memorial Medical Center, Inc. Case No.: 2019CA000015 Page 2 Dr. Barakos is expected to testify regarding the timing, nature, and cause of Plaintiff, Frederic Charles Greer, III’s claimed neurological and cognitive injuries. Also, see Dr. Barakos deposition taken on April 22, 2021. Dr. Barakos’ curriculum vitae was previously provided and is attached herewith (MMMC- 006767-0006826). Dominique Bradford, RN, RCIS, IV, CVN — Cardiac Cath Nursing 27061 Shipwreck Drive Shelbyville, DE 19775 Nurse Bradford is a nursing expert who is expected to provide testimony related to the nursing standard of care on behalf of the Defendant, Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Nurse Bradford’s opinions are based upon her education, training and experience, as well as her review of relevant medical records, policies and procedures, deposition testimony and pleadings. Nurse Bradford is expected to testify that the nurses caring for Plaintiff, Frederic Charles Greer, III on September 1, 2017, were at all times in compliance with the appropriate standard of care. Also, see Nurse Bradford’s deposition taken on March 15, 2021. A copy of Nurse Bradford’s curriculum vitae was previously produced (MMMC-005970- 005971). Michael J. Carmichael, M.D. - Cardiothoracic Surgery 8115 Main Street Bokeelia, FL 33922 Dr. Carmichael is expected to testify on the issues of standard of care, causation and damages. Specifically, he is expected to testify that the care and treatment did not contribute to or cause any injuries to the Plaintiff. Dr. Carmichael’s opinions are based upon his education, training and experience in his field of expertise, as well as his review of relevant medical records, deposition testimony, employment records and pleadings. Also, see Dr. Charmichael’s deposition taken on January 16, 2020. Dr. Carmichael's curriculum vitae was previously provided and is attached herewith (MMMC-006752-006766).Greer v Martin Memorial Medical Center, Inc. Case No.: 2019CA000015 Page 3 4. Stephen Durham, Ph.D. — Economist 100 North Tampa Street, Suite 2410 Tampa, FL 33602 Dr. Durham is an economist who is expected to testify and rebut Plaintiffs’ economic analysis on behalf of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Dr. Durham’s opinions are based upon his education, training and experience in his field of expertise, as well as his review of relevant medical records, employment records, income tax returns, Social Security Administration records, deposition testimony and pleadings. A copy of Dr. Durham’s curriculum vitae was previously produced (MMMC-005972- 005973). 5. Timothy Fischell, M.D. — Interventional Cardiology Borgess Heart Institute 1521 Gull Road Kalamazoo, MI 49048 Dr. Fischell is an International Cardiology expert who is expected to provide testimony related to standard of care, causation and damages on behalf of the Defendants, Kunal Chaudhry, M.D. and Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Dr. Fischell’s opinions are based upon his education, training and experience, as well as his review of relevant medical records and depositions, and his review of medical records, relevant deposition testimony and pleadings Dr. Fischell is expected to testify that nothing the employees, servants, agents and/or apparent agents of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center did or failed to do caused or contributed to the injuries alleged by the Plaintiff, Frederic Charles Greer, III. Also, see Dr. Fischell’s deposition taken on January 22, 2020. A copy of Dr. Fischell’s Curriculum Vitae was previously produced and is attached herewith (MMMC-005974-006010). 6. Kim Klancke, M.D. — Internal Medicine, and Cardiovascular Disease Daytona Heart Group 695 North Clyde Morris Boulevard Daytona Beach, FL 32114 Dr. Klancke is an expert who is board certified in Internal Medicine, and Cardiovascular Disease. Dr. Klancke is expected to provide testimony related to standard of care, causation and damages on behalf of the Defendant, Martin Memorial Medical Center, Inc. d/b/a Martin Memorial Medical Center.Greer v Martin Memorial Medical Center, Inc. Case No.: 2019CA000015 Page 4 Dr. Klancke’s opinions are based upon her education, training and experience, as well as her review of relevant medical records and depositions, Dr. Klancke is expected to testify that nothing the employees, servants, actual agents and/or apparent agents of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center did or failed to do caused or contributed to the injuries alleged by the Plaintiff, Frederic Charles Greer, III. Also see Dr. Klancke’s deposition taken on November 15, 2019. A copy of Dr. Klancke’s Curriculum Vitae was previously produced (MMMC-006011- 006022). Eric D. Kramer, M.D. — Neurology 140 John F. Kennedy Drive, Suite 140 Atlantis, FL 33462 Dr. Kramer is a neurologist who is expected to provide testimony related to causation and damages on behalf of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Dr. Kramer is expected to testify that Martin Memorial Medical Center’s care and treatment of the Plaintiff, Frederic Charles Greer, III, did not cause and/or contribute to any of his alleged injuries. Moreover, Dr. Kramer is expected to testify on issues relating to Plaintiffs alleged diagnosis of an anoxic or hypoxic brain injury. Dr. Kramer is expected to testify base on his opinions on his examination and evaluation of Mr. Greer, the depositions taken in this case, reports from Plaintiffs’ damages experts, medical records and other relevant records and documents obtained in this case and generated through discovery. A copy of Dr. Kramer’s curriculum vitae was previously produced (MMMC-006023- 006033). Tomas D. Martin, M.D. — Cardiothoracic Surgery Division of Thoracic & Cardiovascular Surgery College of Medicine Director, University of Florida Aortic Disease Center P O Box 103720 Gainesville, FL 32610 Dr. Martin is a Cardiothoracic Surgery expert who is expected to provide testimony related to standard of care, causation and damages on behalf of the Defendant, Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Based on his education, training and experience, as well as his review of relevant medical records and depositions, Dr. Martin is expected to testify that nothing the employees, servants, actual agents and/or apparent agents of Martin Memorial Medical Center, Inc.Greer v Martin Memorial Medical Center, Inc. Case No.: 2019CA000015 Page 5 d/b/a Martin Medical Center, did or failed to do caused or contributed to the injuries alleged by the Plaintiff, Frederic Charles Greer, III. Also, see Dr. Martin’s deposition taken on January 15, 2021. A copy of Dr. Martin’s curriculum vitae was previously produced (MMMC-006034- 006052). 9. Joel Meyer, M.D. — Neuroradiology The University of Chicago Pritzker School of Medicine 2650 Ridge Avenue Evanston, IL 60201 Dr. Meyer is a Neuroradiology expert who is expected to provide testimony related to causation and damages on behalf of the Defendant, Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Based on his education, training and experience, as well as his review of relevant medical records, depositions, and imaging studies, Dr. Meyer is expected to testify regarding the timing, nature, and cause of Plaintiff, Frederic Charles Greer, III’s claimed neurological and cognitive injuries. Also see Dr. Meyer’s deposition taken on February 16, 2021. A copy of Dr. Meyer’s curriculum vitae was previously produced (MMMC-006053- 006075). 10. Robert F. Padera, M.D., Ph.D. — Cardiac Pathology Department of Pathology Brigham and Women’s Hospital 75 Francis St. Boston, MA 02115 Dr. Padera is a Cardiac Pathology expert who is expected to provide testimony related to causation and damages on behalf of the Defendant, Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Based on his education, training and experience, as well as his review of relevant medical records, depositions, and pathology slides, Dr. Padera is expected to testify regarding the timing, nature, and cause of Plaintiff, Frederic Charles Greer, III’s claimed cardiac injuries. Also see Dr. Padera’s deposition taken on February 19, 2021. A copy of Dr. Padera’s curriculum vitae was previously produced (MMMC-006076- 006111).Greer v Martin Memorial Medical Center, Inc. Case No.: 2019CA000015 Page 6 11. Harris R. Stutman, M.D. — Clinical Informatics — EPIC 5300 24" Avenue NE, Unit #425 Seattle, WA 98105 Dr. Stutman is a Clinical Informatics expert who is expected to provide testimony related to the EPIC system on behalf of the Defendant, Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Dr. Stutman is expected to testify regarding the EPIC system and the electronic medical records, in general, as well as the EPIC records in regard to Frederic Greer. Dr. Stutman’s opinions, in part, are based on his education, training and experience, as well as his review of relevant medical records, depositions, Access Log Report, Audit Trail Report, Cardiac Cath Event Log, electronic medical records and various motions regarding the on-site inspection and opposition to same, as well as the hearing transcripts regarding Plaintiffs’ motion for an on-site inspection. A copy of Dr. Stutman’s curriculum vitae was previously produced (MMMC-006604- 006609). 12. Ronald B. Tolchin, D.O. — Physiatrist Baptist Center for Spine Care 8950 North Kendall Drive, Suite 410W Miami, FL 33176 Dr. Tolchin is a physiatrist who is expected to provide testimony related to causation and damages on behalf of Martin Memorial Medical Center, Inc. d/b/a Martin Medical Center. Additionally, Dr. Tolchin is expected to testify consistent with his IME of the Plaintiff, Frederic Charles Greer, III, which will include, but may not be limited to, Mr. Greer’s functional capabilities, restrictions, limitations, prognosis, degree of impairment, life expectancy and necessity of future medical treatment. Dr. Tolchin is further expected to opine on Mr. Greer’s ability to work in sedentary positions/jobs. Dr. Tolchin is expected to base his opinions on his IME of Mr. Greer performed on November 8, 2019, the depositions taken in this case, reports from Plaintiffs’ damages experts, medical records and other relevant records and documents obtained in this case and generated through discovery, as well as his education, training and experience. A copy of Dr. Tolchin’s curriculum vitae was previously produced (MMMC-0061 12- 00061126).Greer v Martin Memorial Medical Center, Inc. Case No.: 2019CA000015 Page 7 13, 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. RESERVATION OF RIGHT Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER reserves the right to supplement this Expert Witness List with expert witnesses, as they become known to this Defendant upon proper notice to all parties. Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER reserves the right to call any and all treating physicians and/or other health care providers as experts in their fields of practice with respect to opinions as to the pre-existing conditions of Plaintiff, Frederic Charles Greer, III. Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER reserves the right to call any and all experts listed by all the parties to this action, whether or not they are a party at the time of trial. By listing a Witness, Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER is indicating only that they may call said Witness and by so listing, waive no other objections to said Witnesses. All anticipated opinions listed as part of this Expert Witness Disclosure are general areas of discussion and each witness will be available for deposition in order for the Plaintiff to explore all aspects of their opinions. This disclosure is not intended to limit the extent or nature of the opinions of these witnesses at the time of their deposition or at time of trial. Defendant, MARTIN MEMORIAL MEDICAL CENTER, INC. d/b/a MARTIN MEDICAL CENTER adopts and incorporates, as if fully set forth herein, each and every previously E-filed Expert Witness Disclosures. Any and all expert witnesses listed by any other party. Any and all experts deposed in this matter. Other experts pending further discovery. Any and all impeachment or rebuttal witnesses that may be developed or may be necessary to the proper defense of these claims. Defendant reserves any and all objections to any and all expert witnesses listed by any other party. Defendant reserves the right to amend this Expert Witness Disclosure as discovery continues.Greer v Martin Memorial Medical Center, Inc. Case No.: 2019CA000015 Page 8 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 24% day of January 2022, a copy of the foregoing was served via the Florida E-Filing Portal to the parties on the attached service list. STEARNS WEAVER MILLER WEISSLER ALHADEFF & SITTERSON, P.A. Attorneys for Martin Memorial Medical Center, Inc. 200 East Las Olas Blvd., Suite 2100 Fort Lauderdale, FL 33301 Phone: (954) 462-9500 Fax: (954) 462-956 By: FBN: 008060 taubin@stearnsweaver.com MATTHEW S. PODOLNICK, ESQUIRE FBN: 112126 mpodolnick@stearnsweaver.com AMANDA L. SPENCER, ESQUIRE FBN: 1010874 aspencer( @stearnsweaver.comGreer v Martin Memorial Medical Center, Inc. Case No.: 2019CA000015 Page 9 SERVICE LIST Peter J. Somera Jr., Esq. Paul M. Silva, M.D., Esq. Somera & Silva, LLP 2255 Glades Road, Suite 232W Boca Raton, FL 33431 Phone: (561) 981-8881 Fax: (561) 981-8887 pleadings@somerasilva.com litigation@somerasilva.com Attorneys for Plaintiffs Geoffrey N. Fieger, Esq. Fieger Law 19390 West Ten Mile Road Southfield, MI 48075 Phone: (248) 355-5555 Fax: (248) 355-5148 G.Fieger@Fiegerlaw.com S.Teal@Fiegerlaw.com Co-Attorneys for Plaintiffs Adam Richardson, Esq. Bard D. Rockenbach, Esq. Burlington & Rockenbach, P.A. 444 West Railroad Avenue West Palm Beach, FL 33401 Tel: 561-721-0400 ajr@FLAppellateLaw.com bdr@FLAppellateLaw.com fa@FLAppellateLaw.com Appellate attorneys for Plaintiffs #9368895 v1