Interrogatories 3- 213f with Answers from Car Accident Case

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213(f) Interrogatories with Answers

1. Pursuant to Supreme Court Rule 213(f)(1), please state potential lay witnesses who may be called to testify at trial and the subjects that they will testify to and the opinions of each:

ANSWER:

a.) Juan Murillo 296 Heritage Parkway Romeoville, IL 60446

Mr. Murillo will testify as to the facts of the occurrence complained of in the plaintiff's complaint. He will testify as to his observations at the scene of the occurrence before, during and after the occurrence. He will testify as to his observations of the plaintiff's vehicle before, during and after the occurrence. He will testify as to his own actions before, during and after the occurrence. He may testify as to any statements made by the plaintiff at any time. He will also testify as to other matters as generally stated in his discovery deposition.

b.) Jose Sanchez 14638 Central Park Avenue Midlothian, IL 60445

Mr. Sanchez is expected to testify as to his knowledge - of the facts of the occurrence complained of in his complaint. He is expected to testify as to his observations at the scene of the occurrence before, during and after the occurrence. He may testify as to his own actions before, during and after the occurrence. He may testify as to injuries allegedly sustained by him as a result of the occurrence, including the nature, extent and duration of any claimed injury. He is also expected to testify as to other matters as generally stated in his discovery deposition.

c.) Investigating Officer J. Kelly, ID #64

This officer will testify concerning the scene of the occurrence, the officer's investigation of the accident, traffic accident report, diagram of the scene of the occurrence, the location and damage to vehicles and any statements made by the parties, including any statements or lack of statements made by plaintiff regarding pain, injury, or need for medical treatment.

d.) Lisa Nolan 15515 S. Crawford Avenue Markham, IL 60426

Ms. Nolan will testify concerning her knowledge of the facts of the occurrence complained of in the plaintiff's complaint. She will testify as to the business of Reyes Group, Ltd. as well as that business' relationship with Juan Murillo. She will testify as to any contracts and/or agreements with Juan Murillo pertaining to the business of Reyes Group, Ltd.

e.) Records Custodian of Alsip Fire Department P.O. Box 438495 Chicago, IL 60643

A records custodian of Alsip Fire Department will testify as to the authenticity of and establish the necessary foundation to admit the records of Alsip Fire Department.

f.) Records Custodian of Physical Therapy Associates 3849 West 95th Street Evergreen Park, IL 60805 A records custodian of Physical Therapy Associates will testify as to the authenticity of and establish the necessary foundation to admit the records of Physical Therapy Associates.

g.) Records Custodian of St. Francis Hospital & Health Center 12935 South Gregory Blue Island, IL 60406

A records custodian of St Francis Hospital & Health Center will testify as to the authenticity of and establish the necessary foundation to admit the records of St. Francis Hospital & Health Center.

h.) Records Custodian of St. James Hospital 1423 Chicago Road Chicago Heights, IL 60411

A records custodian of St. James Hospital will testify as to the authenticity of and establish the necessary foundation to admit the records of St. James Hospital.

i.) Records Custodian of Blue Island Radiology Consultants 3300 West 127th Street 2nd Floor Blue Island, IL 60406

A records custodian of Blue Island Radiology Consultants will testify as to the authenticity of and establish the necessary foundation to admit the records of Blue Island Radiology Consultants.

j.) Records Custodian of Metro Infectious Disease Consultants a/k/a Metro Primary Care Associates 13755 South Cicero Avenue Crestwood, IL 60445

A records custodian of Metro Infectious Disease Consultants and/or Dr. Asgar will testify as to the authenticity of and establish the necessary foundation to admit the records of Metro Infectious Disease Consultants and/or Dr. Asgar.

k.) Records Custodian of Well Group Health Partners 333 Dixie Highway Chicago Heights, 60411

A records custodian of Well Group Health Partners and/or Drs. Payne and DeRubertis will testify as to the authenticity of and establish the necessary foundation to admit the records of Well Group Health Partners and/or Drs. Payne and DeRubertis.

l.) Records Custodian of Preferred Open MRI 4200 West 63rd Street Chicago, IL 606029

A records custodian of Preferred Open MRI will testify as to the authenticity of and establish the necessary foundation to admit the records of Preferred Open MRI.

m.) Records Custodian of Walgreens Pharmacy

A records custodian of Walgreens Pharmacy will testify as to the authenticity of and establish the necessary foundation to admit the prescriptions and records of Walgreens Pharmacy.

n.) Records Custodian of Vicek's Inc. 1807 Cermak Road Broadview, IL 60155

A records custodian of Vicek's Inc. will testify as to the authenticity of and establish the necessary foundation to admit the records of Vicek's Inc.

o.) Records Custodian of Ruwaldt's Meat Packing 6510 E Ridge Rd Hobart, IN 46342

A records custodian of Ruwaldt's Meat Packing will testify as to the authenticity of and establish the necessary foundation to admit the records of Ruwaldt's Meat Packing.

The defendants reserve the right to supplement and/or amend these disclosures in the future.

2. Pursuant to court Rule 213(f)(2), please state potential independent expert witnesses who may be called to testify at trial and the subjects that they will testify to and the opinions of each:

ANSWER: None at this time.

The defendants reserve the right to supplement and/ or amend these disclosures in the future.

3. Pursuant to Supreme Court Rule 213 (f)(3), please state potential controlled expert witnesses who may be called to testify at trial and the subjects that they will testify to and the opinions of each:

ANSWER:

a.) Thomas Gleason, M.D. Illinois Bone & Joint Institute 55 East Washington Street Suite 1709 Chicago, IL 60602

1. A copy of Dr. Thomas Gleason's Cirriculum Vitae is attached as Exhibit “A”.

2. Dr. Thomas Gleason will testify concerning the subject matter of plaintiff, Jose Luis Sanchez's alleged injuries, medical care and treatment, medical records, diagnostic studies, prognosis, his physical examination of Jose Luis Sanchez, as well as his training and experience in orthopedic medicine and surgery.

3. Dr. Thomas Gleason has reviewed the following records and documents pertaining to plaintiff Jose Luis Sanchez:

i. Alsip Fire Department

ii. Physical Therapy Associates

iii. St. Francis Hospital & Health Center

iv. St. James Hospital

v. Blue Island Radiology Consultants

vi. Metro Infectious Disease Consultants

vii. Well Group Health Partners

viii. Preferred Open MRI

ix. MRI scans of cervical and lumbar spine

x. X-rays of cervical and lumbar spine

xi. Vicek's Inc. and

x. Ruwaldt's Meat Packing

4. Dr. Gleason prepared a report after his review of plaintiff Jose Luis Sanchez's above-mentioned records, diagnostic studies and his examination of said plaintiff. A copy of his six page report dated October 30, 2007 is attached hereto as Exhibit “B”.

5. Dr. Gleason's opinions and conclusions are based on his review of Jose Luis Sanchez's medical records, employment records, radiographic studies, his examination of plaintiff Jose Luis Sanchez, as well has Dr. Gleason's training and experience in the field of orthopedic medicine and surgery.

6. Dr. Gleason is expected to testify consistently with the opinions and conclusions contained in his report, attached as Exhibit “B”, and his discovery depositions, if taken, namely:

i.) That plaintiff Jose Luis Sanchez currently presents with the ability to stand and walk in a normal fashion and has no malady of the back, spine, hips, knees or ankles.

ii.) that plaintiff Jose Luis Sanchez was involved in a motor vehicle accident after which he expressed complaints of pain to the lower back and neck, which could be consistent with a strain and/or a temporary aggravation of a pre-existing condition;

iii.) that plaintiff's neck symptoms had resolved by July 29, 2004 and his back condition was resolved by November 2, 2004, after which, no additional complaints or further treatment would be expected, anticipated or recommended related to the motor vehicle accident of October 20, 2003;

iv.) that plaintiff Jose Luis Sanchez does not require any further orthopaedic evaluation, care or treatment as a result of the October 20, 2003, accident;

v.) that the plaintiff, Jose Luis Sanchez will not require any surgery or additional medical treatment as a result of the occurrence of October 20, 2003;

vi.) that plaintiff Jose Luis Sanchez can return to work and continue with other activities as desired;

vii.) that the automobile accident of October 20, 2003, did not cause any permanent disability or impairment to Jose Luis Sanchez;

viii.) that the automobile accident of October 20, 2003, did not cause a loss of normal life to plaintiff Jose Luis Sanchez;

ix.) that the accident of October 20, 2003, did not cause any injury which currently or in the future would impair the plaintiff, Jose Luis Sanchez's ability to work or perform his normal everyday activities.

x.) Any additional treatment to the neck (after July 29, 2004) and back (after November 2, 2004) would be unrelated to the motor vehicle accident of October 20, 2003.

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