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`LINDA ROSS, SBN 085563
`JENNIFER ZARICH, SBN 276130
`LAW OFFICES OF LINDA ROSS
`1104 Irwin Street
`San Rafael, California 94901
`Telephone: (415) 563-2400
`Facsimile: (415) 931-0291
`jzarich@lindarosslaw.com
`
`QUINTON B. CUTLIP, SBN 168030
`CUTLIP LAW OFFICE
`106 Merced Dr.
`San Bruno, CA 94066
`Telephone: (415) 350-5196
`cutliplawoffice@gmail.com
`
`Attorneys for Plaintiff
`AWET TEKLE
`
`
`AWET TEKLE aka AWET
`TEKLEHAIMANOT
`
`
`
`
`Plaintiff,
`
`v.
`
`
`
`DAVID HOURIGAN, BACKHOE
`DISPATCH 24-7, VICTORIA FIRE AND
`CASUALTY CO., and DOES 1 to 25,
` Defendants.
`
`ELECTRONICALLY
`F I L E D
`
`Superior Court of California,
`County of San Francisco
`10/05/2020
`Clerk of the Court
`BY: ERNALYN BURA
`Deputy Clerk
`
`CASE NO.: CGC-19-574244
`
`DECLARATION OF COUNSEL IN
`SUPPORT OF PLAINTIFF’S
`OPPOSITION TO DEFENDANTS’ EX
`PARTE APPLICATION FOR AN ORDER
`SHORTENING TIME TO HEAR A
`MOTION TO STRIKE PLAINTIFF’S
`SUPPLEMENTAL EXPERT STEPHEN
`WATSON, P.E.
`
`Date: October 5, 2020
`Time: 11:00 a.m.
`Dept.: 302
`
`
`Trial Date: October 26, 2020
`Complaint Filed: March 4, 2019
`
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`SUPERIOR COURT OF CALIFORNIA
`COUNTY OF SAN FRANCISCO
`
`(Unlimited Civil Jurisdiction)
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`I, Quinton B. Cutlip, declare:
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`1.
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`I am an attorney at law who is duly licensed to practice before the Courts of the
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`State of California. I am an attorney of record for the plaintiff in the above captioned action.
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`
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`2.
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`There are ten (10) expert depositions scheduled in this case between October 5,
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`2020 and October 13, 2020, seven (7) the week of October 5th, and three (3) on October 13,
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`Plaintiff’s Objection and Opposition to Ex Parte Application.
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`2020. Alireza Bagherian, D.C. is scheduled to be deposed on October 7, 2020. Stephen Watson,
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`P.E. is scheduled to be deposed on October 16, 2020.
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`3.
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`Given the expert witness deposition schedule in this case, including seven (7)
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`expert depositions the week of October 5th and three (3) expert depositions on October 13th,
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`Plaintiff will be severely prejudiced if his attorneys have to expend time and effort opposing
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`Defendants’ motion and attending a hearing.
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`4.
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`The document attached, hereto, as Exhibit “A” is a true and correct copy of my
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`declaration in support of Plaintiff’s initial expert disclosures in this case. Plaintiff’s initial expert
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`disclosure says nothing about “accident reconstruction” or “biomechanical engineering.” The
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`comments in the boxes to the left of my discussion in the declaration about Dr. Bagherian were
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`added for purposes of this opposition. This copy of my declaration also does not contain the
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`CVs for the retained experts who are not at issue in defendants’ motion.
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`5.
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`In 27 years of practice, I have never retained a physician or a chiropractor to
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`perform an “accident reconstruction” analysis in a car collision case. This is not to question any
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`physician’s or chiropractor’s credentials to reconstruct accidents. Perhaps one day I will make
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`such a disclosure in a future case, but it did not happen here. Dr. Bagherian was not even present
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`when the vehicles were inspected.
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`6.
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`Dr. Bagherian also was not retained or disclosed to perform what defendants call
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`a “biomechanical engineering” analysis. As a chiropractor, Dr. Bagherian has extensive
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`knowledge about the causes of spinal injuries and of the mechanics and structures of the spines
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`he treats every day. That is a foundation of being a chiropractor. His medical opinions about
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`the nature and extent of Mr. Tekle’s injuries, the cause of his injuries, the progression of his
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`injuries, and the effects of his injuries will undoubtedly be at odds with currently anticipated
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`defense claims that Mr. Tekle was not significantly injured in the collision, based upon alleged
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`defense “accident reconstruction” and “biomechanical engineering” analyses, but that does not
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`Plaintiff’s Objection and Opposition to Ex Parte Application.
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`mean Dr. Bagherian was retained or disclosed for accident reconstruction and biomechanical
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`engineering purposes. As a practicing doctor of chiropractic medicine, he might even criticize
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`alleged “biomechanical engineering” studies that claim injuries he sees all the time in vehicle
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`collision victims could not have been caused by motor vehicle collisions, but that does not mean
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`he was retained or disclosed to perform an accident reconstruction or biomechanical engineering
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`analysis in this case.
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`7.
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`The document attached, hereto, as Exhibit “B” is a true and correct copy of the
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`defendants’ expert disclosure that disclosed Chris Kauderer, BSME (Bachelor of Science
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`Mechanical Engineering) “who will testify regarding his calculations related to speed-time-
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`position; delta V or change of Velocity, vehicle and occupant dynamics, and transfer of force to
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`occupants of the subject accident, as well as related matters within his expertise.” (Exh. “B” pp.
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`3:14-19, emphasis added.) Defendants also disclosed Aaron Souza, Ph.D., who was described as
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`a “biomechanical engineer and bioengineering expert who will testify regarding his review and
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`analysis of plaintiff’s medical records, claimed injuries and the accident reconstruction
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`calculations and his analysis as [sic] nature and impact of the accident forces had Plaintiff’s body
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`and what injuries could result form those forces as well as related matters within his expertise.”
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`8.
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`The March 5, 2017, collision Mr. Hourigan caused was obviously a substantial
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`factor in causing Awet Tekle’s injuries and damages. It seems silly for the defense to claim that
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`the collision did not seriously injure Plaintiff. Upon receiving Defendants’ expert disclosure, I
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`hemmed and hawed about whether to retain an accident reconstruction expert and a
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`biomechanical engineering expert to address the subjects that Messrs. Kauderer and Souza were
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`disclosed to address. I debated whether it would be better in such an obvious case to simply
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`challenge bogus defense accident reconstruction opinions and biomechanical opinions, or
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`whether it would be better to retain an engineer to also address the matters? I intend to move to
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`exclude and/or severely limit Messrs. Kaunderer’s and Souza’s opinions at trial. If my efforts
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`Plaintiff’s Objection and Opposition to Ex Parte Application.
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`3
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`are not successful, I concluded that, given the severity of his continuing injuries, Plaintiff should
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`have his own accident reconstruction andbiomechanical engineering expert to address the
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`defense experts’ opinions. Pursuant to the provisions of Code of Civil Procedure § 2034.280, I
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`decided to make a supplemental disclosure. My declaration in support identified Mr. Watson’s
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`accident reconstruction and biomechanical engineering credentials and mirrored the defendants’
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`disclosures of Messrs, Kauderer’s and Souza’s expected testimony.
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`9.
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`The document attached as Exhibit “C” is a true and correct copy of my
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`declaration in support of Plaintiff’ supplemental expert disclosure.
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`1 did not include the CV of
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`the other supplementally disclosed expert the defense is apparently not challenging.
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`I declare under the penalty of perjury, according to the la 3 of the State of California,
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`that the foregoing is true and correct.
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`Dated: October 4, 2020
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`EXHIBIT “A”
`EXHIBIT “A”
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`LINDA ROSS, SBN 085563
`JENNIFER ZARICH, SBN 276130
`LAW OFFICES OF LINDA ROSS
`1104 Irwin Street
`San Rafael, California 94901
`Telephone: (415) 563-2400
`Facsimile: (415) 931-0291
`jzarich@lindarosslaw.com
`
`QUINTON B. CUTLIP, SBN 168030
`CUTLIP LAW OFFICE
`106 Merced Dr.
`San Bruno, CA 94066
`Telephone: (415) 350-5196
`cutliplawoffice@gmail.com
`
`Attorneys for Plaintiff
`AWET TEKLE aka
`AWET TEKLEHAIMANOT
`
`
`AWET TEKLE aka AWET
`TEKLEHAIMANOT
`
`
`
`
`Plaintiff,
`
`v.
`
`
`
`DAVID HOURIGAN, BACKHOE
`DISPATCH 24-7, and DOES 1 to 25,
` Defendants.
`
`SUPERIOR COURT OF CALIFORNIA
`COUNTY OF SAN FRANCISCO
`(Unlimited Civil Jurisdiction)
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`CASE NO.: CGC-19-574244
`
`DECLARATION OF COUNSEL IN
`SUPPORT OF PLAINTIFF’S
`DISCLOSURE OF EXPERT WITNESSES
`
`[C.C.P. § 2034.010 et seq.]
`
`
`Trial Date: October 26, 2020
`Complaint Filed: March 4, 2019
`
`
`
`
`
`
`
`
`
`I, Quinton Cutlip, declare as follows:
`
`1.
`
`I am an attorney at law duly licensed to practice before all courts of the State of
`
`California, I am an attorney of record for the plaintiff in the above captioned action.
`
`2.
`
`Accompanying this declaration is a list of the people whose expert opinion
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`testimony plaintiff intends to offer at the trial of this action. Plaintiff’s list includes his
`
`Plaintiff’s Expert Disclosure – Declaration of Counsel
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`evaluating and treating physicians and other healthcare providers as non-retained experts,
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`pursuant to Schreiber v. Estate of Kiser, (1999) 22 Cal. 4th 31. Plaintiff reserves the right to
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`supplement this list of treating healthcare providers.
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`3.
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`Plaintiff also lists consultants who have been retained to provide expert opinion
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`testimony at trial. Expert opinion testimony will be offered at trial, either orally or by deposition
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`testimony. The retained experts who are listed below have agreed to testify at trial. Each is or
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`will be sufficiently familiar with the pending action to submit to a meaningful oral deposition
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`concerning the testimony described herein, including his or her opinion(s) and the basis or bases
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`therefore.
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`4.
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`The retained experts are as follows:
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`a.
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`Paul J. Slosar, Jr., M.D.
`SpineCare Medical Group
`San Francisco Spine Institute
`455 Hickey Blvd., # 310
`Daly City, CA 94105
`(650) 985-7500
`
`i.
`
`Dr. Slosar is a licensed physician and orthopedic surgeon. He is a
`diplomate with the National Board of Medical Examiners and the
`American Board of Orthopedic Surgery. He is a charter diplomat
`with the American Board of Spinal Surgery. He is the president of
`SpineCare Medical Group and is the past medical director of the
`Spine Care Institute of San Francisco. He is on the board of
`directors of the American Board of Spine Surgery and The Spinal
`Research Foundation. He is an oral board examiner of the
`American Board of Orthopaedic Surgery and the American Board
`of Spine Surgery. He is an editorial board member of the Spinal
`Research Foundation and a past editorial board member of The
`Spine Journal and Spine Line. A true and correct copy of his
`curriculum vitae is attached, hereto, as Exhibit “A” and
`incorporated herein.
`
`ii.
`
`Dr. Slosar is expected to provide testimony at trial concerning
`causation and damages issues in this litigation from the perspective
`of and spine surgeon and physician. His testimony is expected to
`include, but will not be limited to, testimony about Plaintiff’s
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`Plaintiff’s Expert Disclosure – Declaration of Counsel
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`b.
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`diagnoses, Plaintiff’s past and present medical conditions, the
`evolution/progression of Plaintiff’s condition(s), as well as
`Plaintiff’s healthcare and medical needs – past and future. He is
`also expected to provide testimony concerning Plaintiff’s past and
`future medical treatment and bills. Dr. Slosar may also testify with
`respect to opinions expressed by Defendants’ identified experts
`whose testimony falls within his areas of expertise. He may also
`testify about treatises and literature within his areas of knowledge.
`
`Dr. Slosars’s hourly fee for providing expert testimony is as
`follows: Deposition testimony - $ 925.00 per hour and trial
`testimony in the San Francisco Bay Area - $ 3,750.00 per half day.
`He is charging plaintiff $ 925.00 per hour for his non-testimony
`work in this case.
`
`I have not received any discoverable reports from this expert as of
`this time.
`
`iii.
`
`iv.
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`Alireza Bagherian, DC, CCEP, QME, DAIPM, ABVE/F
`3580 California Street, Suite 102
`San Francisco, CA 94118
`(415) 921-6200
`
`i.
`
`
`ii.
`
`Dr. Bagherian is a licensed chiropractor, a certified Functional
`Capacity Evaluator, a Qualified Medical Examiner, a Fellow of the
`American Board of Disability Analysts, and a Fellow of the
`American Board of Vocational Experts. A true and correct copy of
`his curriculum vitae is attached, hereto, as Exhibit “B” and
`incorporated herein.
`
`Dr. Bagherian is expected to provide testimony regarding
`causation, diagnosis, and damages in this case. He will testify
`within the scope of his areas of expertise with respect to matters
`relating to his functional capacity evaluation of Plaintiff, Plaintiff’s
`injuries, the cause and mechanisms of Plaintiff’s injuries,
`biomedical issues regarding Plaintiff’s injuries, the progression of
`Plaintiff’s condition(s), the extent to which Plaintiff’s injuries
`interfere with Plaintiff’s daily functioning, that is likely connected
`with the collision at issue, and the resulting limitations created by
`those injuries that effect Plaintiff’s daily living and ability to
`perform in the workplace. Dr. Bagherian may also testify with
`respect to opinions expressed by Defendants’ identified experts
`whose testimony falls within Dr. Bagherian’s areas of expertise.
`Dr. Bagherian may also testify about treatises and literature within
`his areas of knowledge.
`
`
`Plaintiff’s Expert Disclosure – Declaration of Counsel
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`c.
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`iii.
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`iv.
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`Dr. Bagherian charges $ 575.00 per hour for providing deposition
`testimony. He charges $ 375.00 per hour for record review,
`research, and literature review. Functional capacity evaluations
`cost $ 3,500.00. Trial testimony is billed at $ 3,500.00 for a half
`day.
`
`I have not received any discoverable reports from this expert as of
`this time.
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`Carol Hyland, M.A., M.S., C.L.C.P., C.D.M.S.
`4120 Canyon Road
`Lafayette, CA 94549
`(925) 283-6702
`
`i.
`
`Carol Hyland is a rehabilitation counselor, a certified disability
`management specialist, and a life care planner. She has a Master
`of Science in Rehabilitation Counseling. She has been certified as
`1) a life-care planner by the International Commission on
`Healthcare Certification, 2) a disability management specialist by
`the Disability Management Specialists Commission, and 3) an
`insurance rehabilitation specialist by the Commission on
`Counselor Certification. She is a member of the California
`Association of Rehabilitation and Reemployment Professionals,
`the National Rehabilitation Association, the International
`Association of Rehabilitation Professionals, and the Workforce
`Development Board of Contra Costa County. She was the district
`administrator for the California State Department of Rehabilitation
`in Concord, CA from August 2003 to July 2012 and the
`Rehabilitation Supervisor for the same department from April 1996
`to August 2003. A true and correct copy of her curriculum vitae
`is attached, hereto, as Exhibit “C” and incorporated herein.
`
`ii.
`
`Ms. Hyland is expected to provide testimony about Plaintiff’s
`damages, harms, and losses with respect to Plaintiff’s ability to
`work in various professions, work capacity, and wage-earning
`potentials. She is also expected to provide testimony about
`Plaintiff’s medical care, including life-care testimony regarding
`injury related care and its costs. Ms. Hyland may also testify with
`respect to opinions expressed by Defendants’ identified experts
`whose testimony falls within her areas of expertise. She may also
`testify about treatises and literature within her areas of knowledge.
`
`
`iii. Ms. Hyland charges $ 575.00 per hour for providing deposition
`testimony. She charges $ 325.00 per hour for vocational
`rehabilitation interviews, lifecare planning, vocational testing,
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`Plaintiff’s Expert Disclosure – Declaration of Counsel
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`market research, and vendor identification and research. Trial
`testimony is billed at $ 2,300.00 per half day.
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`I have not received any discoverable reports from this expert as of
`this time.
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`
`iv.
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`Craig Enos, CPA
`Enos Forensics
`1024 Iron Point Road, Suite 100
`Folsom, CA 95630
`(916) 357-6750
`
`i.
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`ii.
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`Craig Enos is a certified public accountant and the owner of Enos
`Forensics, a forensic accounting firm providing forensic
`accounting services. He has a Masters of Science degree in
`taxation and a Bachelor of Science degree in Business
`Administration (accounting). He is a member of the Forensic and
`Valuation Services section and an instructor in economic
`damages/individuals with the American Institute of Certified
`Public Accountants. He is also a member of the California
`Society of Certified Public Accountants, where he belongs to the
`Forensic Services section and is a member of the State Society’s
`Forensic Services Section Steering Committee and has also been
`served as the chair and treasurer of the organization’s Forensic
`Services Section Economic Damages Section. He is also a
`member of the Association of Certified Fraud Examiners, the
`National Association of Forensic Economics, and the American
`Academy of Economic and Financial Experts. A true and correct
`copy of Mr. Enos’ curriculum vitae is attached, hereto, as Exhibit
`“D” and incorporated herein.
`
`Mr. Enos is expected to testify from an economic and accounting
`perspective about the dollar value of damages, harms, and losses
`that Plaintiff suffered. He will provide testimony about the costs
`of past and future medical expenses, lost wages, and lost earning
`capacity. Mr. Enos may also testify with respect to opinions
`expressed by Defendants’ identified experts whose testimony falls
`within his areas of expertise. He may also testify about treatises
`and literature within his areas of knowledge.
`
`iii. Mr. Enos charges $ 400.00 per hour for analysis as well as for
`deposition and trial testimony.
`
`I have not received any discoverable reports from this expert as of
`this time. As part of attempted settlement negotiations, Plaintiff
`previously provided the defendants with an exhibit created by Mr.
`
`
`iv.
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`Plaintiff’s Expert Disclosure – Declaration of Counsel
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`Enos that was clearly marked “For Settlement Discussion Purposes
`Only.” That exhibit should not be admissible according to
`Evidence Code §§ 350, 352, and 1154.
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`John T. Martin
`P.O. Box 21
`Carmichael, CA 95609
`(916) 871-3289
`
`John Martin is an expert in automotive, truck and heavy equipment
`mechanical and auto body inspection, diagnosis, estimation, repair,
`invoicing, and training. He has directly inspected, diagnosed,
`estimated, and repaired thousands of vehicles. He has also trained
`and managed hundreds of technicians, service advisers,
`management personnel, and repair facilities and dealerships. He
`has over 14 years of experience providing forensic expert
`testimony regarding vehicle damage; collision investigations;
`mechanical failure and damage analysis; and auto body inspection,
`diagnosis, estimation, and repair. A true and correct copy of Mr.
`Martin’s curriculum vitae is attached, hereto, as Exhibit “E” and
`incorporated herein.
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`Mr. Martin is expected to provide testimony regarding the collision
`between the vehicles, including, but not limited to, collision
`forensics, collision assessments, vehicle damage, vehicle repairs,
`collision / repair forces, and crash data retrieval. Mr. Martin may
`also testify with respect to opinions expressed by Defendants’
`identified experts whose testimony falls within his areas of
`expertise. He may also testify about treatises and literature within
`his areas of knowledge.
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`iii. Mr. Martin charges $ 300.00 per hour for deposition and trial
`testimony. He charges $ 250.00 per hour for non-testimonial
`work.
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`I have not received any discoverable reports from this expert as of
`this time.
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`Plaintiff retains the right to make a supplemental disclosure of expert witness
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`5.
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`information, pursuant to Code of Civil Procedure § 2034.280 to disclose any experts who will
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`express an opinion on a subject covered by an expert designated by the defense. Plaintiff also
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`reserves the right to call any of the defendants’ identified experts that Plaintiff’s attorneys deem
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`Plaintiff’s Expert Disclosure – Declaration of Counsel
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`appropriate. Defendants’ retained experts may be examined pursuant to Evidence Code § 776.
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`l
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`I declare under the penalty of perjury, according to the laws of the State of California,
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`that the foregoing is true and correct.
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`Dated: September 9, 2020
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`Plaintiff‘s Expert Disclosure — Declaration of Counsel
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`EXHIBIT “B”
`EXHIBIT “B”
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`

`

`Alireza Bagherian, DC, CCEP, QME, DAIPM, ABVE/F
`3580 California Street, Suite 102  San Francisco, CA 94118  T: (415) 921-6200 F: (415)
`921-6206 drb@synapsehc.com
`
`CURRICULUM VITAE (Updated: 2020)
`
`EDUCATION
`Doctor of Chiropractic, Life Chiropractic College West (Summa Cum Laude), 1997
`Bachelor of Arts, San Francisco State University, 1993
`
`DIPLOMATES
`Diplomate, Academy of Integrative Pain Management, 2005
`
`FELLOWSHIPS
`Fellow, American Board of Vocational Experts, 2017
`Fellow, American Board of Disability Analysts, 2002
`Fellow, Academy of Forensic and Industrial Chiropractic Consultants, 2002
`
`CERTIFICATIONS AND APPOINTMENTS
`Blankenship WorkEval / FCE Certification, 2013
`Human Factors Engineering, 2012
`Certified Forensic Consultant, 2006
`Certified Traffic Accident Reconstructionist, 2006
`Internationally Certified in Impairment and Disability Rating - AMA Guidelines, 5th Edition, 2004
`Certified Functional Capacity Evaluator, 2004
`Certified Manipulation Under Anesthesia, 2002
`Qualified Medical Examiner / Agreed Medical Examiner, 2001
`Certified Industrial Disability Evaluator, 2001
`Advanced Certification in the diagnosis, treatment, and management of motor vehicular cervical
`acceleration/deceleration (CAD) trauma, 2001
`Certified Low Speed Rear Impact Automobile Crash Reconstructionist, 2000
`Certification in advanced diagnosis and clinical management of CAD trauma and whiplash related
`tempromandibular joint disorders, 2000
`Certified Chiropractic Extremity Practitioner, 1998
`
`MEMBERSHIPS AND COMMITTEE ASSIGNMENTS IN SOCIETIES
`Member, American Academy of Forensic Sciences
`Member and Board of Directors, American Board of Vocational Experts
`International Association of Rehabilitation Professionals
`Latino Comp, A Non-Profit Wokers Comp Association
`California Association of Accident Reconstruction Specialists
`Society of Automotive Engineers - Affiliate for 11 years
`
`POSITIONS AND BOARD MEMBERSHIPS
`Board member, American Board of Vocational Experts, 2018
`
`Page 1 of 7
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`

`

`LICENSES
`National Board of Chiropractic Examiners, Number 25120
`National Provider Identifier Number 1376520775
`Qualified Medical Evaluator Number 942016
`
`TEACHING EXPERIENCE
`Irene Gold and Associates Inc., Instructor: National Boards Part IV Professional Review, 1997
`Medlink, Instructor: Impairment and disability rating using the AMA Guides, 5th, Edition, 2005
`
`PUBLICATIONS
`Comparing 2 Whiplash Grading Systems to Predict Clinical Outcomes” Journal of Chiropractic Medicine, 15, 2016 (81-86)
`Co-author, “A Secondary Air Bag System for the Prevention of Hyperextension Injuries to the Cervical Spine,” Life Work,
`Vol. 3, No. 1, 1996 (92-95)
`Co-author, “Treatment of Migraine: A New Era,” Life Work, Vol. 3, No. 1, 1995 (7-8)
`
`RESEARCH PROJECTS
`Long-term Outcome Study of Human Subjects Following MVC and CAD
`Sponsor: The Center for Research into Automotive Safety and Health.
`Principal Investigator: Art Croft, D.C., M.S., M.P.H., F.A.C.O.
`Co-Investigator: Alireza Bagherian, D.C., C.C.E.P., Q.M.E., F.A.F.I.C.C. et al.
`San Diego, CA, August 2004 and February 2005
`
`Cervical Spine Curve Research Study
`Sponsor: The Center for Research into Automotive Safety and Health.
`Principal Investigator: Art Croft, D.C., M.S., M.P.H., F.A.C.O.
`Co-Investigator: Alireza Bagherian, D.C., C.C.E.P., Q.M.E., F.A.F.I.C.C. et al.
`San Francisco, CA 2005
`
`CRASH OBSERVATIONS, PARTICIPATIONS, OCCUPANT & VEHICLE EXAMINATION
`From 2000 to 2006, participated in live crash analysis as an observer, research assistant, and forensic examiner in
`75 vehicle impacts at high and low speeds. Crash vehicles, RID dummies, and live human subjects (male and female)
`were instrumented for velocity measurements and force calculations. Crash tests were recorded by high speed film
`and video at speeds up to 500 frames per second. Participation in crash studies consisted of pre and post-crash
`examination of occupants and vehicles. Crash tests included linear rear-end impacts, offset and angled rear-end
`impacts, broad-side impacts, side-swipe impacts, and high speed head-on/frontal impacts with airbag deployment.
`Low speed crashes involved inspection of the vehicles for property damage including measurement analyses of
`bumper isolator compression. Crash testing also included pedestrian collisions. All data were collected following the
`general theory of SAE (Society of Automotive Engineers).
`
`SPORTS AFFILIATIONS
`Team USA Doctor - Muay-Thai World Cup. Busan, South Korea, 2008
`Team USA Doctor - TAFISA Games & International Olympic Committee. South Korea, 2008
`Attending doctor - “War of the Heroes”, USMF and Fairtex. Santa Clara, CA, 2008
`Team USA Doctor - Muay-Thai World Cup and King Cup, Bangkok, Thailand, 2007
`Attending doctor for Fairtex Smoker Full-Contact Muay-Thai Events. Pre and post-physical examination and
`ringside doctor. San Francisco and Mountain View. 2006-2007
`
`QUALIFIED AS AN EXPERT AND PROVIDED TESTIMONY IN THE FOLLOWING AREAS
`• Injury Biomechanics / Injury Causation
`
` • Functional Capacity Evaluations
`• Occupant Kinematics & Mechanism of Injury
` • Vocational Rehabilitation
`• Accident Reconstruction
`
`
`
` • Impairment & Permanent Disability
`• Human Factors / Risk Factor Analysis
`
` • IME, QME, AME
`• Chiropractic & Medical Care
`
`
`
` • Prognosis & Future Medical Care
`• Medical Records / Reasonableness of care / Standard of Care
`
`
`
`Page 2 of 7
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`

`

`POSTDOCTURAL TRAINING AND CONTINUING EDUCATION
`
`Injury causation, Injury biomechanics, occupant kinematics, human factors
`Accident Reconstruction, accident investigation, crash testing, vehicle inspection
`Disability, impairment, functional capacity evaluation, QME, industrial injuries
`
`X-ray, MRI, CT, diagnostic ultrasound, video fluoroscopy, diagnostics
`
`
`Chiropractic technique, bracing, taping, instrumentation, & related areas
`
`Vocational Rehabilitation, IPEC, Employment Assessment
`
`
`
`
`RELICENSURE AND CONTINUING EDUCATION FACULTY AND GUEST LECTURER
`
`409 hours
`468 hours
`453 hours
`110 hours
`284 hours
` 85 hours
`
`1. California Applicants’ Attorneys Association. The Brain – A Medical & Legal Perspective. Lectured on Cognitive Functional
`Capacity Evaluations, TBI and Injury Biomechanics. Napa Valley, March 2019
`2. The Academy of Forensic & Industrial Chiropractic Consultants. Lumbar Spine Injuries from Rear-end Motor Vehicle
`Crashes, Injury Biomechanics, Causation and Medico-legal Challenges. Orange County, June 2016
`3. Consumer Attorneys of California. Don L. GalineTavel Seminar. Functional Capacity Evaluations, Injury Biomechanics and
`Injury Causation. Maui, November 2014
`4. 18th Annual SRISD Scientific Conference. Injury Biomechanics, Occupant Kinematics, and Functional Capacity Evaluations.
`Coronado Island, San Diego, 2013
`5. California Applicants’ Attorneys Association, Sacramento Chapter. Lectured on Functional Capacity Evaluations, Injury
`Causation, Apportionment and Injury Biomechanics. San Francisco, 2013
`6. American Association of Legal Nurse Consultants, Bay Area Chapter. Lectured on Functional Capacity Evaluations, Injury
`causation, and Injury Biomechanics. San Francisco, 2013
`7. Workers' Comp Educational Seminar through Warbritton & Associates. Lecturer for QME Recertification. The State Bar of
`California / MCLE & Legal Specialization, IEA Training for CPDM / CCMP for Claims Examiners on SB 863 and Functional
`Capacity Evaluations. Oakland, 2012
`8. Saint Francis Memorial Hospital. Lecturer and faculty for QME Recertification Course. FCE and Injury Biomechanics in the
`Industrial Setting, Part I. San Francisco, 2012
`9. Cedars-Sinai Medical Center. FCE Co-Instructor for J-Tech Medical Group. Los Angeles, 2011
`10. Saint Francis Memorial Hospital. Lecturer and faculty for QME Recertification Course. FCE and Injury Biomechanics in the
`Industrial Setting, Part II. San Francisco, 2011
`11. Functional Capacity Evaluation Certification Program. West Hollywood, 2007
`12. Santa Clara Valley Medical Center. Lectured to neurosurgeons and medical residents in the Physical Medicine and
`Rehabilitation Department on Functional Capacity Evaluations, Injury Biomechanics, Medical Causation, Impairment Rating
`and Disability using the AMA Guides. San Jose, 2006
`13. Medlink, Instructor: Impairment and disability rating using the AMA Guides, 5th, Edition, 2005
`14. Irene Gold and Associates Inc., Instructor: National Boards Part IV Professional Review, 1997
`
`LECTURES AND PRESENTATIONS
`
`1. American Board of Vocational Experts - 2019 Annual Conference. Functional Capacity Evaluations in Traumatic Brain Injury
`Cases. Tucson, 2019
`2. CAAA (California Applicants’ Attorneys Association). Lectured on Functional Capacity Evaluations in TBI cases. Napa 2019
`3. American Board of Vocational Experts - 2018 Annual Conference. Evidence-Based Medicine FCEs. Salt Lake City, Utah,
`April 2018
`4. California Self-Insurers Association - 2018 Employer Seminar, Annual Meeting & Educational Conference. Disneyland
`Hotel, Anaheim, March 2018
`5. California Self-Insurers Association. Lectured on Functional Capacity Evaluations, Return to Work Examinations, Injury
`Causation & Vocational Rehabilitation Issues, San Francisco November 2017
`6. JT2 Integrated Resources. Lectured on Functional Capacity Evaluations, Return to Work Examinations, Injury Causation /
`Injury Biomechanics. Oakland, CA, November 2017
`7. Alameda-Contra Costa Trial Lawyers Association. Lectured on Functional Capacity Evaluations, Injury Causation / Injury
`Biomechanics. Oakland, March 2017
`8. Diablo Valley Industrial Claims Association. Lectured to senior claims analysts, claims examiners, nurse case managers,
`physicians, and defense attorneys on Functional Capacity Evaluation and Injury Biomechanics. Walnut Creek, 2012
`
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`Page 3 of 7
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`9. American Association of Legal Nurse Consultants. Bay Area Chapter. Lectured on Functional Capacity Evaluations and Injury
`Biomechanics. San Francisco, 2012
`10. San Francisco Trial Lawyer Lawyers Association. Lectured on Functional Capacity Evaluations.
`San Francisco, 12/2010
`11. California Uninsured Employers Fund. Lectured to s