IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
Sally Vitale- Plaintiff v James Sexton- Defendant |
* * * * |
CASE NO.: 05-C-00-1234 |
PLAINTIFF’S DESIGNATION OF EXPERT WITNESSES
Now comes the Plaintiff, Sally
Vitale, by and through her attorneys, Ronald V.
Miller, Jr. and Miller & Zois, LLC, pursuant to Maryland Rule
2-402(e)(1) and this Honorable Court’s Scheduling Order
designates the following individuals and entities as potential
expert witnesses to testify at the trial of this matter:
1. Representatives and doctors from Franklin Square Hospital;
including, Lawanda Summers, M.D., Edward Carter, M.D., are experts
in the field of emergency medical treatment; their representatives
are expected to testify as to the treatment rendered to the Plaintiff
following the auto accident, the fairness, reasonableness, necessity
and causal relationship between the injuries sustained in the
auto accident and their medical treatment rendered. Plaintiff’s
lawyers expect to solicit testimony from these doctors as to the
permanent nature of the personal injuries sustained by the Plaintiff
as a result of this accident; future medical expenses and treatment
which are reasonably expected in occur in the future. The doctors’
opinions are based upon their review of the medical records, treatment
or examination of the Ms. Vitale, history taken from the Plaintiff
and years of experience and medical training. The Plaintiff incorporates
herein by reference all of her medical records attached to the
Plaintiff’s response to request for production of documents.
2. Henry K. Smith, M.D.; Irfan Sarfo, M.D.; Michael D.. Reischer, M.D.; are experts in the field of orthopaedic surgery; pain management; physical therapy and rehabilitation therapy. These doctors are expected to testify as to the treatment rendered to the Plaintiff following the auto accident, the fairness, reasonableness, necessity and causal relationship between the personal injuries sustained in the auto accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this auto accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
3. Representatives and doctors from Sevenson Physical Therapy are experts in the field if medical rehabilitation and physical therapy; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the car accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the car accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this car accident; future medical expenses and treatment which are reasonably expected in occur in the future. These health care provider opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
5. Advanced Radiology; Jeffrey Rose, M.D.; and representatives are experts in the field of interpretation of diagnostic testing; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the personal injuries Ms. Vitale sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify at trial as to the permanent nature of the injuries sustained by the Plaintiff as a result of this auto accident, future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records and bills attached to the Plaintiff’s response to request for production of documents.
6. Rafiq Patel, M.D., is an expert in the field of general medicine
and
orthopaedics; he is expected to testify as to the treatment rendered
to the Plaintiff following the auto accident, the fairness,
reasonableness, necessity and causal relationship between the
injuries sustained in the auto accident and their medical
treatment rendered. Her doctors are also expected to testify as
to the permanent nature of the injuries sustained by the Plaintiff
as a result of this auto accident; future medical expenses
and treatment which are reasonably expected in occur in the future.
The doctors’ opinions are based upon their review of the
medical records, treatment or examination of the Plaintiff, history
taken from the Plaintiff and years of experience and medical training.
The Plaintiff incorporates herein by reference all of her medical
records attached to the Plaintiff’s response to request
for production of documents.
7. Michele T. Cerino, M.D., is an expert in the field of thoracic surgery; she is expected to testify as to the treatment rendered to the Plaintiff following the car accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the automobile accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this automobile accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
8. Representatives and doctors from Harford County Ambulatory Surgical Center are experts in the field of pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the auto accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the automobile accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this automobile accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
9. Representatives and doctors from Chesapeake Medcare Services are experts in the field of pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the automobile accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the auto accident and their medical treatment rendered. Her attorneys are expected to solicit testimony from these doctors as to the permanent nature of the injuries sustained by the Ms. Vitale as a result of this auto accident; future medical expenses and treatment for her personal injuries which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
10. Avraam Karas, M.D., is an expert in the field of thoracic and outlet surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the car automobile accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the automobile accident with Defendant’s truck and their medical treatment rendered. Plaintiff’s doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this car accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
11. Representatives and doctors from Rosen-Hoffberg Rehabilitation and Pain Management Associates are experts in the field of medical rehabilitation, physical therapy, and pain management; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the motor vehicle accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the auto accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this car accident; future medical expenses and treatment which are reasonably expected in occur in the future. These doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff during her treatement and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
12. Representatives and doctors from Upper Chesapeake Medical Center are experts in the field of emergency medicine; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the auto accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the auto accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this auto accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
13. Abdallah J. Helou, M.D., is an expert in the field of orthopedics and thoracic outlet surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the car accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the auto accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this car accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
14. Representatives and doctors from Good Samaritan Hospital are experts in the field of general medicine; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the auto accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the car accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this motor vehicle accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
15. Henry A. Simpson, M.D., is an expert in the field of rehabilitation medicine and electromyography; he is expected to testify as to the treatment rendered to the Plaintiff following the car accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the auto accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this auto accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
16. Mid-Atlantic Neurosurgical Associates, P.A., Agha S. Khan, M.D., and their representatives are experts in the field of orthopedics and neurosurgery; the representatives are expected to testify as to the treatment rendered to the Plaintiff following the car accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the auto accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this auto accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
17. Rakesh K. Mathur, M.D., is an expert in the field of internal medicine, anesthesiology, and critical care; he is expected to testify as to the treatment rendered to the Plaintiff following the auto accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the auto accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
18. Robert E. Johnson, M.D., is an expert in the field of orthopaedic surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this car accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
19. Joel L. McEnroe, M.D., is an expert in the field of orthopaedic surgery; he is expected to testify as to the treatment rendered to the Plaintiff following the car accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and his years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
20. Kevin Travis, M.D., is an expert in the field of orthopaedics; he is expected to testify as to the treatment rendered to the Plaintiff following the car accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the car accident and their medical treatment rendered. Her doctors are also expected to testify as to the permanent nature of the injuries sustained by the Plaintiff as a result of this auto accident; future medical expenses and treatment which are reasonably expected in occur in the future. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents.
21. Larry Strauss is an expert in the field of vocational rehabilitation; he is expected to testify as to the extent of the Plaintiff’s ability to be re-trained in a career suitable to her skills and ability to learn a new trade, and the costs associated with such retraining, loss of earnings capacity and any losses she may incur.
22. Thomas Invico is an expert in the field of economics; he is expected to testify as to the present day value of Sally Vitale’s loss of earning capacity and future lost wages.
Respectfully submitted,
MILLER & ZOIS, LLC
____________________________
Laura
G. Zois
Ronald
V. Miller, Jr.
Empire
Towers, Suite 615
7310
Ritchie Highway
Glen
Burnie, Maryland 21060
(410)553-6000
(410)760-8922
(Fax)
Attorneys
for Plaintiff
Certificate of Service
I hereby certify that a copy of the foregoing Designation of Expert Witnesses was sent via U.S. Mail, first-class, postage prepaid, this 29th day of March, 2006, to:
Neal S. Wadler, Esq.
8600 LaSalle Road
The Oxford Building, Suite 620
Towson, Maryland 21286-5955
See also Food Lion v. McNeill (Analysis of Maryland Case Regarding Expert Designations)
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