Interrogatories 5-213f1&2 Lay and Expert Witnesses from Car Accident Case

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1. Pursuant to Illinois Supreme Court Rule 213(f)(1), furnish the name and address of each fact witness who will testify at trial, together with the subject on which the witness will testify at trial.

Answer:

Steven Troland 815 E. Oakton, Lot 270 Des Plaines, Illinois 60016

It is expected that said witness will testify to the actions of the parties immediately prior to the motor vehicle accident in question, the results of said motor vehicle accident, the injuries he sustained and continues to suffer, as a result of said accident, his out of pocket expenses. It is further expected that said witness will testify consistently with and regarding the testimony in his discovery deposition taken in this matter. Investigation continues.

Andrew P. Wojcik 707 Austin Park Ridge, Illinois 60068

It is expected that said witness will testify to the actions of the parties immediately prior to the motor vehicle accident in question, the results of said motor vehicle accident, the state of his intoxication at the time of the motor vehicle accident in question, the outcome of his Driving Under the Influence & Driving With a Blood Alcohol Concentration of .08 or Greater case arising from the motor vehicle accident in question. It is further expected that said witness will testify consistently with and regarding the testimony in his discovery deposition taken in this matter. Investigation continues.

Keeper of the Records Cook County Circuit Court Clerk -2nd Municipal Dist. 5600 Old Orchard Road Skokie, Illinois

It is expected that said witness will testify that on or about October 10, 2006, the Defendant entered a plea of guilty to the charge of Driving With a Blood Alcohol Content in Excess of .08 in Complaint Number YJ-458-585. Investigation continues.

Timothy Van Meighen 1004 N. Clifton Park Ridge, Illinois 60068

It is expected that said witness will testify as to the subject matter of his statement to defendant's insurer as set forth in the records received in discovery as well as consistent with the testimony and subject matter addressed in this discovery deposition taken in this matter. Investigation continues.

Officer D. Harris (Star #127)

Officer Thomas Cierniak (Star #144)

Officer W. Christie (Star #124)

Officer M. Baumhardt (Star #117)

Niles Police Department

7000 W. Touhy Ave.

Niles, Illinois 60714

It is expected that said witnesses will testify as to their observations of the accident scene and parties upon their arrival, and actions they took as a result thereof. It is further expected that said witnesses will testify as to any statements made by the parties to the above witnesses. Investigation continues.

Dave Wintercorn

Jim Wintercorn

Wintercorn's Citgo

Prospect & Oakton Streets

Niles, Illinois 60714

If called to testify, said witnesses will testify to their observations as to the accident scene immediately after the accident, as well as the condition of the parties and vehicles involved in said accident. Said witnesses are also expected to testify as to the reduced number of hours that the Plaintiff was able to work after the accident at issue.

Mr. Wintercorn is expected to testify that the Plaintiff worked as an automobile mechanic for him prior to the accident, and further testify that the Plaintiff experienced increased difficulty in focusing after the motor vehicle accident in questions. It is further expected that if called to testify, Mr. Wintercorn will testify that the Plaintiff complained of headaches and dizziness after the accident, and that due to the above, the Plaintiff worked fewer hours than prior to the motor vehicle accident at issue. Investigation continues.

Investigation continues.

2. Pursuant to Illinois Supreme Court Rule 213(f)(2), furnish the name and address of each independent expert witness who will testify at trial, together with the subject on which the witness will testify at trial, and the opinions the party expects to elicit.

Answer:

1. Dr. Ronald Barrera Lutheran General Hospital Emergency Room Department 1775 W. Dempster St. Park Ridge, Illinois 60068

See previously disclosed records and bills. (Bates #'s pp. -5- thorugh -22-; - 26- through -47-)

a. It is expected that this witness will testify to the neurological injuries suffered by the Plaintiff, pain and suffering suffered by the Plainitff, the diagnosis, course of treatment, and that the injuries suffered by the Plaintiff were, within a reasonable degree of medical certainty, caused by the motor vehicle accident described in the pending Complaint. It is further expected that this witness will testify to the normal ongoing effects of said injury, the normal pain and suffering as a result of such an injury, the normal resulting limitations on the activities of an individual who suffers such an injury, the future treatment, therapy and medication that will be required for this_Plaintiff as a result of the injuries suffered as a result of the allegations contained in the pending Complaint. It is further anticipated that, at trial, this Witness will testify consistent with his testimony at his discovery deposition. Finally, it is expected that this witness will testify to the amount of his bills as a result of the services provided and the reasonableness of said bills, as well as the expected cost of future treatment, therapy and medication. Investigation continues.

b. It is expected that this witness will provide the following opinions:

i. That based on a reasonable degree of medical and neurological certainty, this Plaintiff suffered the following injuries as a result of the allegations contained in the pending Complaint:

A. Closed Head Injury;

B. Cerfical Stain;

C. Laceration on forehead;

D. Abrasions on forehead;

.racturenose;

F Short-term memor loss

G. Loss of Consciousness.

ii. That based on a reasonable degree of medical and neurological certainty, this Plaintiff has suffered from extreme pain and discomfort in his head, neck, upper back and shoulders that has caused him to loose sleep, decreased his ability to concentrate and work for long periods of time, decreased his ability for physical exercise, work or exertion, and increased his irritability.

iii. That based on a reasonable degree of medical and neurological certainty, this Plaintiff will continue to suffer from above conditions, symptoms, and limitations through the foreseeable future.

vi. That based on the reasonable fees with other neurologists with similar background and experience in the Cook County area, the medical fees totaling $5,000.00 for services provided on the date of the accident, are fair and reasonable.

vii. any additional opinions stated in this witnesses' medical records and/or discovery deposition.

Investigation continues.

2. Officer D. Harris (Star # 127) Officer Thomas Cierniak (Star #144) Officer W. Christie (Star #124) Officer M. Baumhardt (Star #117) Niles Police Department 7000 W. Touhy Ave. Niles, Illinois 60714 _

See records previously provided (Bates #'s -58- through -86; -105-through - 109-).

a. It is expected that the above witnesses will testify to their investigation, and subsequent arrest of the Defendant for Driving Under the Influence as set forth in the above referenced records obtained from the Niles Police Department. It is further expected that said witnesses will opine that the Defendant was operating his motor vehicle under the influence of alcohol at the time of the accident described in the above referenced records obtained from the Niles Police Department. It is further expected that the above witnesses will testify as to their observations of the Defendant's physical condition, manner of speech, odor, appearance, and ability to balance immediately following the motor vehicle accident. It is further expected that the above witnesses will further testify as to conversations they had with the Defendant after the motor vehicle accident at issue in the instant case. It is further expected that the above witnesses will testify as to conditions of the two motor vehicles involved in the accident at issue, as well as the Plaintiff's physical condition upon their arrival at the scene of the accident. Investigation continues.

b. It is expected that this witness will provide the following opinions:

i. That based on a reasonable degree of certainty, the Defendant was under the influence of alcohol at the time of the motor vehicle accident at issue in the instant case.

ii. any additional opinions contained in said witness' police or investigative records, and/or stated in this witness's discovery deposition.

Investigation continues.

3. Ms. Margo Sims 7500 N. Elmhurst Road, Lot 207 Des Plaines, Illinois 60018

Mail to: P.O. Bo 2382 Des Plaines, IL 60017 (847) 699-5113

If called to testify, Ms. Sims is expected to have knowledge concerning the change in the Plaintiffs mood, personality, memory, social activities, and ability to function independently since the date of the accident. It is further expected that Ms. Sims possesses knowledge concerning the Plaintiff's frequent complaints of headaches and loss of sleep. Investigation continues.

4. Mr. Ed Kleckner Address unknown

If called to testify, said witness is expected to have knowledge concerning the change in the Plaintiffs mood, personality, memory, social activities, and ability to function independently since the date of the accident. It is further expected that this witness possesses knowledge concerning the Plaintiffs frequent complaints of headaches and loss of sleep. Investigation continues.

5. Dave Wintercorn Jim Wintercorn Wintercorn's Citgo Prospect & Oakton Streets Niles, Illinois 60714

If called to testify, Mr. Wintercorn is expected to testify that the Plaintiff worked as an automobile mechanic for him prior to the accident, and further testify that the Plaintiff experienced increased difficulty in focusing after the motor vehicle accident in questions. It is further expected that if called to testify, Mr. Wintercorn will testify that the Plaintiff complained of headaches and dizziness after the accident, and that due to the above, the Plaintiff worked fewer hours than prior to the motor vehicle accident at issue. Investigation continues.

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