Filing # 101678851 E-Filed 01/15/2020 10:24:50 AM
`
`IN THE CIRCUIT COURT OF THE
`17TH JUDICLAL CIRCUIT IN AND FOR
`
`BROWARD COUNTY, FLORIDA
`
`CASE NO. CACE 2014 005235
`
`JANET HIGHSMITH, individually and on
`Behalf of KAYLA KELLY, a minor,
`
`Plaintiff,
`
`VS.
`
`PLANTATION GENERAL HOSPITAL LIMITED
`PARTNERSHIP
`d/b/a
`PLANTATION GENERAL
`
`HOSPITAL, HERMAN M. EPSTEIN, M.D., HERMAN M.
`EPSTEIN, M.D., P.A., JEAN B. REYNOLDS, R.N.,
`DOREL ABRAMOVICI, M.D., SINAI PERINATAL,
`LLC., FLORIDA ATLANTIC ANESTHESLA, INC., NEIL
`P. RAY, M.D., LOUIS TRUJILLO, CSA, ROBERT J.
`BASS, MD. and FEMCARE ASSOCLATES, LLC,
`
`Defendants.
`
`
`/
`
`DEFENDANTS’, PLANTATION GENERAL HOSPITAL LIMITED PARTNERSHIP
`D/B/A PLANTATION GENERAL HOSPITAL and JEAN B. REYNOLDS, R.N.1
`EXPERT WITNESS DISCLOSURE
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`Defendants, PLANTATION GENERAL HOSPITAL LIMITED PARTNERSHIP d/b/a
`
`PLANTATION GENERAL HOSPITAL and JEAN B. REYNOLDS, R.N., by and through their
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`undersigned counsel, and pursuant to the Court’s Order Setting Cause for Jury Trial, files the
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`following Expert Witness Disclosure:
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`1.
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`Elias Chalub, MD.
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`130 Eaton Square
`Mobile, AL 36608
`
`Specialty: Pediatric Neurology
`
`Dates of availability have been requested and will be provided upon receipt.
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`Dr. Chalub is a Pediatric Neurologist who is expected to testify on the issues of
`causation, damages, and life expectancy from the standpoint of his particular
`
`La Cava &Jacobs0n, RA, 4901 NW1 7” Way, Suite 606, Fort Lauderdale, Florida, 33309
`Telephone (754) 301-5060; Facsimile (754) 551-6884
`
`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/15/2020 10:24:50 AM.****
`
`

`

`KELLY, K. V. PLANTATION GENERAL, ET AL.
`CASE NO. CACE 2014 005235
`DIV: 12
`
`expertise. The grounds for Dr. Chalub’s opinions are the medical records produced
`in this action, diagnostic studies, radiographic evidence, depositions taken or to be
`taken in this matter, evaluation of Kayla Kelly and any additional materials and
`information adduced as discovery continues and the expert’s own professional
`training, expertise and experience.
`
`Stephen Durham, Ph.D.
`100 North Tampa Street, Suite 2410
`Tampa, FL 33602
`Specialty: Economist
`
`Dates of availability have been requested and will be provided upon receipt.
`
`Dr. Durham is an Economist who is expected to testify as to damages. This witness
`is further expected to testify regarding his training, background and expertise, and
`any other issue relevant to the case within the Witness’ purview. The grounds for Dr.
`Durham’s opinions are the pleadings, billing records produced in this action,
`depositions taken or to be taken in this matter, and any additional materials and
`information adduced as discovery continues, and the expert’s own professional,
`training, expertise and experience.
`
`Nathan Hirsch, MD
`South Miami OB/GYN
`
`7300 SW 62 Place 3rd Floor
`
`Miami, FL 33143
`
`Specialty: Obstetrics/Gynecology
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`Dates of availability have been requested and will be provided upon receipt.
`
`Dr. Nathan Hirsch is an obstetrician/gynecologist who is expected to testify that the
`physicians and nursing staff at Plantation General Hospital acted within the standard
`of care with regard to the treatment of Janet Highsmith and Kayla Kelly, and that no
`alleged act or omission was a deviation from the standard of care which caused or
`contributed to any injury and/or damages and life expectancy. This witness is further
`expected to testify regarding his training, background and expertise, and any other
`issue relevant to the case within this witness’ purview. The grounds for Dr. Hirsch’s
`opinions are based on the medical records produced in this action, diagnostic studies,
`radiographic evidence, depositions taken or to be taken in this matter, and any
`additional materials and information adduced as discovery continues, and the
`expert’s own professional training, expertise and experience.
`
`La Cava &Jacobs0n, RA, 4901 NW] 7th Way, Suite 606, Fort Lauderdale, Florida, 33309
`Telephone (754) 301-5060; Facsimile (754) 551-6884
`2
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`

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`KELLY, K. V. PLANTATION GENERAL, ET AL.
`CASE NO. CACE 2014 005235
`DIV: 12
`
`Richard Liles, M.D.
`
`HealthSouth Rehabilitation Hospital
`901 Clearwater—Largo Road
`Largo, FL 33770
`Specialty: Physical Medicine and Rehab
`
`Dates of availability have been requested and will be provided upon receipt.
`
`Dr. Liles is a physical medicine and rehab specialist who is expected to testify
`regarding damages, his training, background and expertise, and any other issue
`relevant to this case within this expert’s purview. The grounds for Dr. Liles’
`opinions are the pleadings, depositions taken or to be taken in this matter, the
`medical records, billing records, evaluation of Kayla Kelly and any other materials
`and information adduced as discovery continues, and the expert’s own professional
`training, expertise and experience.
`
`Carolyn Salafia, MD, MS
`Placental Analytics
`187 Overlook Circle
`
`New Rochelle, NY 10804
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`Specialty: Developmental Pathologist/Placental Pathology
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`Dates of availability have been requested and will be provided upon receipt.
`
`Dr. Carolyn Salaf1a is expected to testify regarding the interpretations of various
`placental slides, tissue and/or reports pertaining to the Plaintiffs. This witness further
`is expected to testify regarding her training, background and experience, and any
`other issue involved in this case within this witness’ purview. The grounds for Dr.
`Salafla’s opinions are the medical records, pathology slides, pathology reports,
`depositions taken or to be taken in this matter, any additional materials and
`information adduced as discovery continues, and the expert’s own professional
`training, expertise and experience.
`
`Robert Michael Shavelle, Ph.D.
`1439 17th Avenue
`
`San Francisco, CA 94122-3402
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`Specialty: Life Expectancy
`
`Dates of availability have been requested and will be provided upon receipt.
`
`La Cava &Jacobs0n, RA, 4901 NW] 7th Way, Suite 606, Fort Lauderdale, Florida, 33309
`Telephone (754) 301-5060; Facsimile (754) 551-6884
`3
`
`

`

`KELLY, K. V. PLANTATION GENERAL, ET AL.
`CASE NO. CACE 2014 005235
`DIV: 12
`
`Dr. Shavelle is a life Expectancy expert who is expected to testify as to causation and
`damages. This witness is further expected to testify regarding his training,
`background and expertise, and any other issue relevant to the case within the Witness’
`purview. The grounds for Dr. Shavelle’s opinions are the pleadings, medical records
`produced in this action, depositions taken or to be taken in this matter, and any
`additional materials and information adduced as discovery continues, and the
`expert’s own professional, training, expertise and experience.
`
`Barbara B. Stabile, R.N., MS
`7 Shadow Creek Lane
`
`Ashland, MA 01721
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`Specialty: L&D Nursing
`
`Dates of availability have been requested and will be provided upon receipt
`
`Ms. Barbara Stabile is a Labor & Delivery nurse expected to testify that the nursing
`care and treatment of Janet Highsmith and Kayla Kelly at Plantation General
`Hospital was within the standard of care. The grounds for Nurse Stabile’s opinions
`are the review of hospital records, deposition testimony, and her own professional
`training, experience and expertise.
`
`Avrum Pollock, MD.
`
`614 Ballytore Road
`Wynnewood, PA 19096-2210
`Specialty: Pediatric Neuroradiology
`
`Dates of availability have been requested and will be provided upon receipt
`
`Dr. Avrum Pollock is a Pediatric Neuroradiologist who is expected to testify as to
`causation and damages. This witness is further expected to testify regarding his
`training, background and expertise, and any other issue relevant to the case within
`this witness’ purview. The grounds for Dr. Pollock’s opinions are based on the
`medical records produced in this action, diagnostic studies, radiographic evidence,
`depositions taken or to be taken in this matter, and any additional materials and
`information adduced as discovery continues, and the expert’s own professional
`training, expertise and experience.
`
`La Cava &Jacobs0n, RA, 4901 NW] 7th Way, Suite 606, Fort Lauderdale, Florida, 33309
`Telephone (754) 301-5060; Facsimile (754) 551-6884
`4
`
`

`

`KELLY, K. V. PLANTATION GENERAL, ET AL.
`CASE NO. CACE 2014 005235
`DIV: 12
`
`Jamie Murphy M.D.
`Johns Hopkins University Hospital
`1800 Orleans Street
`
`Baltimore, MD 21287
`
`Specialty: Obstetrical Anesthesia
`
`Dates of availability have been requested and will be provided upon receipt
`
`Dr. Jamie Murphy is a Obstetrical Anesthesiologist who is expected to testify that
`the physicians and nursing staff at Plantation General Hospital acted within the
`standard of care with regard to the treatment of Janet Highsmith and Kayla Kelly,
`and that no alleged act or omission was a deviation from the standard of care which
`caused or contributed to any injury and/or damages and life expectancy. This
`witness is further expected to testify regarding his training, background and
`expertise, and any other issue relevant to the case within this witness’ purview. The
`grounds for Dr. Murphy’s opinions are based on the medical records produced in this
`action, diagnostic studies, radiographic evidence, depositions taken or to be taken in
`this matter, and any additional materials and information adduced as discovery
`continues, and the expert’s own professional training, expertise and experience.
`
`10.
`
`Frank Manning, MD.
`260 Third Street North
`
`Naples, FL 34102
`Specialty: Maternal Fetal Medicine
`
`Dates of availability have been requested and will be provided upon receipt
`
`Dr. Frank Manning is an expert in Maternal Fetal Medicine who is expected to testify
`that the physicians and nursing staff at Plantation General Hospital acted within the
`standard of care with regard to the treatment of Janet Highsmith and Kayla Kelly,
`and that no alleged act or omission was a deviation from the standard of care which
`caused or contributed to any injury and/or damages and life expectancy. This
`witness is further expected to testify regarding his training, background and
`expertise, and any other issue relevant to the case within this witness’ purview. The
`grounds for Dr. Manning’s opinions are based on the medical records produced in
`this action, diagnostic studies, radiographic evidence, depositions taken or to be
`taken in this matter, and any additional materials and information adduced as
`discovery continues, and the expert’s own professional training, expertise and
`experience.
`
`La Cava &Jacobs0n, RA, 4901 NW] 7th Way, Suite 606, Fort Lauderdale, Florida, 33309
`Telephone (754) 301-5060; Facsimile (754) 551-6884
`5
`
`

`

`KELLY, K. V. PLANTATION GENERAL, ET AL.
`CASE NO. CACE 2014 005235
`DIV: 12
`
`11.
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`12.
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`13.
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`14.
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`15.
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`Defendants reserve the right to call each and every expert Witness listed by any
`other party Whether they are still a party to this lawsuit at the time of trial.
`
`Defendants reserve the right to any and all objections to any and all expert Witnesses
`listed by any other party.
`
`Defendants reserve the right to call additional expert Witnesses in specialty relating to
`Plaintiff’ s claims for damages, for rebuttal and/or for impeachment purposes.
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`Defendants further advise all counsel of record that they reserve the right to call any
`and all of Plaintiff’ s treating physicians, including physicians rendering treatment at
`hospitals, clinics or outpatient centers, as expert Witnesses at the time of trial.
`
`The Defendants reserve the right to amend and/or supplement this Expert Witness
`Disclosure upon proper notice to the parties and this Court.
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that a copy ofthe foregoing has been filed and served on all parties on
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`the attached Mailing List via the Court’s Efiling Portal this 15th day of January, 2020.
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`La CAVA & JACOBSON, PA
`Attorneys for PGH and Reynolds, RN
`4901 NW 17th Way, Suite 606
`Fort Lauderdale, FL 33309
`(754)301-5060
`(754)301-6884 fax
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`MStrauss@LaCavaJacobson.com
`MmarrerogQLacavaJacobson. com
`
`Kbrown@lac avaJacobson. com
`
`BY:
`
`/s/Marci L. Strauss
`
`MARCI L. STRAUSS, ESQ.
`FBN: 857025
`
`LOUIS J. LACAVA
`
`FBN: 507880
`
`La Cava &Jacobson, RA, 4901 NW] 7th Way, Suite 606, Fort Lauderdale, Florida, 33309
`Telephone (754) 301-5060; Facsimile (754) 551-6884
`6
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`

`

`KELLY, K. V. PLANTATION GENERAL, ET AL.
`CASE NO. CACE 2014 005235
`DIV: 12
`
`MAILING LIST
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`Maria D. Tejedor, Esq.
`Diez-Arguelles & Tejedor, PA
`505 North Mills Avenue
`
`Orlando, FL 32803
`(407)705-2880
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`mail@theorlandolawyers.com
`
`leah@theorlandolawyers.com
`Attorneys for Plaintiffs
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`Julia M. Ingle, Esq.
`Lubell & Rosen
`
`Museum Plaza, Suite 900
`200 S. Andrews Avenue
`
`Fort Lauderdale, FL 33301
`(954)755—3425
`jmi@lubellrosen.com
`alice
`lubellrosen.com
`
`Attorneys for Defendants, Epstein, MD and MDPA
`
`Jay P. Chimpoulis, Esq.
`Chimpoulis Hunter
`150 S. Pine Island Road, Suite 510
`
`Plantation, FL 33324
`(954)463-0033
`(954)463-9562 fax
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`Jchimpoulis@chl-law.com
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`evalazquez@chl-law.com
`Attorneys for Ray, MD and Sheridan
`
`Louis J. La Cava, Esq.
`Marci L. Strauss, Esq.
`La Cava & Jacobson, PA
`4901 NW 17th Way, Suite 606
`Fort Lauderdale, FL 33309
`(754)301-5060
`(754)301-6884 fax
`MStrausngLaCavaJacobson. corn
`
`Mmarrero@LacavaJacobson. corn
`
`Kbrown@lac avaJacobson. com
`Attorneys for PGH, Reynolds, RN
`
`La Cava &Jacobson, RA, 4901 NW] 7th Way, Suite 606, Fort Lauderdale, Florida, 33309
`Telephone (754) 301-5060; Facsimile (754) 551-6884
`7
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`