Plaintiff’s Designation of Expert Witnesses

ROBERT LEWIS,
Plaintiff,
v.
DISNEY THEATRICAL PRODUCTIONS LTD
d/b/a DISNEY THEATRICAL GROUP, et al.
Defendants.

Case No. 24-C-069-05747

Now comes the Plaintiff, Robert Lewis, by and through her attorney, Laura G. Zois, 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. Jim Custard, M.D., Jose Marks, M.D. and/or representatives of University Doctors at University of Washington Medical Center, Shock Trauma, experts in the field of emergency and general surgery, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
2. Stan Manger, M.D., Stacy Shore, M.D., Clyde Striker, M.D., LeslieAnne Miller, M.D., Karl Schok, M.D. and/or representatives of University Doctors at University of Washington Medical Center, Shock Trauma, experts in the field of Diagnostic Imaging and Interpretation, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
3. Eli Ackler, Richard Chenson, M.D. and/or representatives of University Doctors at University of Washington Medical Center, Shock Trauma, experts in the field of Neurosurgery, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
4. Mark Studeman, M.D., Kyle Wriggle, M.D. and/or representatives of University Doctors at University of Washington Medical Center, Shock Trauma, experts in the field of Orthopaedic Surgery, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
5. Edmond D. Ricardo, M.D., Randall Simmonts, M.D., James Schoemacker, M.D., Ronald P. Klanzic, M.D. and/or representatives of University Doctors at University of Washington Medical Center, Shock Trauma, experts in the field of Plastic Surgery, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
6. Markus Channel, M.D., Bob Cancol, M.D., Michael Malphrey, M.D. and/or representatives of Kennesaw Orthopaedics and Rehabilitation Hospital, experts in the field of Physical Medicine and Rehabilitation, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
7. Andrea Shipley, M.D. and/or representatives of the Trauma Clinic at University of Washington Med
   ical Center, Shock Trauma, experts in the field of Trauma Injuries, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
8. Irene Greenbrier, M.D., an expert in the field of General Medicine, is expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and the medical treatment rendered. His doctor is also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctor is expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctor is also expected to testify that this pre-existing condition made him more susceptible to injury. The doctor’s opinions are based upon her review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
9. Daniel M. Eichenferg, M.D. and/or representatives of Advantage Radiology, experts in the field of Diagnostic Imaging and Interpretation, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
10. MaryKaye C. Gladen, RPT and/or representatives of Healing Fingers, experts in the field of Massage Therapy, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
11. Darnell Wright, DDS and/or representatives of Darnell Wright, DDS, PC, experts in the field of dentistry, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
12. Stewart Grenich, DDS, PA, and/or representatives of Stewart Grenich, experts in the field of dentistry and Temporomandibular Joint Dysfunctions, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
13. Martin P. Rodack, M.D. and/or representatives of Martin P. Rodack, M.D., experts in the field of Psychiatry, are expected to testify as to the treatment rendered to Plaintiff following the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
14. Dr. Edwin Clanten, is an expert in the field of Orthopaedic Surgery, are expected to testify as to the treatment rendered to Plaintiff fo
    llowing the accident, the fairness, reasonableness, necessity and causal relationship between the injuries sustained in the accident and their medical treatment rendered. His doctors are also expected to testify as to the permanent nature of the injuries sustained by Plaintiff as a result of this accident; future medical expenses and treatment which are reasonably expected to occur in the future. Additionally, his doctors are expected to testify that he suffered from a pre-existing condition and this pre-existing condition was exacerbated in the accident. His doctors are also expected to testify that this pre-existing condition made him more susceptible to injury. The doctors’ opinions are based upon their review of the medical records, treatment or examination of Plaintiff, history taken from Plaintiff and years of experience and medical training. Plaintiff incorporates all of his medical records as though fully set forth herein.
15. Marty Glaken, Ph.D., is an expert in the fields of psychology, human factor science, and visual warnings; he is expected to testify as to the deficiencies in the visual warnings allegedly placed on the set cart in question and the human factors and psychological factors surrounding such warnings. Dr. Glaken’s opinions are based upon his review of the facts relevant to this accident, his examination of the evidence available, his education and his years of experience and training. He is expected to produce a written report which will be produced upon completion of additional necessary discovery. His curriculum vitae is attached hereto.
16. Roberto G. Danmiels, PE, Common Engineers & Scientific Study, Inc., is an expert in engineering principles and work place safety. Mr. Danmiels is expected to testify and provide opinions as to the safety of the set cart in question. Mr. Danmiels opinions are based upon his review of the facts relevant to this accident, his examination of the evidence available, his education and his years of experience and training. He is expected to produce a written report which will be produced upon completion of additional necessary discovery. His curriculum vitae is attached hereto.
17. Jackson M. Ganton, Safest Theater Program, is an expert in the field of Theater Safety Management, and is expected to provide opinions as to the safety issues surrounding the set cart in question and the load out that was done on September 17, 2006. Mr. Ganton’s opinions are based upon his review of the facts relevant to this accident, his examination of the evidence available, his education and his years of experience and training. He is expected to produce a written report which will be produced upon completion of additional necessary discovery. His curriculum vitae is attached hereto.
18. Plaintiff reserves the right to elicit expert opinions from any experts called by any other party to this lawsuit and/or to rely on the expert opinions provided by any expert called by any other party to this lawsuit.
19. Plaintiff reserves the right to supplement, revise, or modify its Expert Witness Designation including, but not necessarily limited to, the identification of additional or new experts, based on the production of new evidence, which includes deposition testimony from any experts identified by Defendants.
20. If and when additional or different opinions are provided by Defendant’s experts and/or those opinions are supplemented, amplified, or modified, Plaintiff further reserves their right to supplement, revise, or modify their Expert Witness Designations, including the identification of additional experts.
21. If and when any other party identifies additional experts, Plaintiff further reserves their right to supplement, revise, or modify their Expert Witness Designations, including the identification of additional experts.

Respectfully submitted,
Miller & Zois, LLC

Laura G. Zois
1 South St, #2450
Baltimore, MD 21202
(410) 779-4600
(410) 760-8922 (facsimile)
Attorney for Plaintiff

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