E-FILED IN COUNTY CLERK'S OFFICE PIERCE COUNTY, WASHINGTON March 0 0: AM KEVIN STOCK COUNTY CLERK NO: --0-0 0 The Honorable G. Helen Whitener IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF PIERCE RONALD W. GIESEN, individually, No. --0- vs. Plaintiff, CANDICE L. MOBERG and DAVID C. MOBERG, individually, and the marital community composed thereof, Defendants. DEFENDANTS MOBERG S DISCLOSURE OF POSSIBLE PRIMARY WITNESSES Defendants Moberg submit the following disclosure of possible primary witnesses pursuant to the Order Setting Case Schedule:. Ronald Giesen c/o Thomas M. Adkins South th Place, Suite D Federal Way, WA 0 () 0- LAY WITNESSES Plaintiff Ronald Giesen has knowledge of the facts and circumstances of the subject incident, as well as his physical condition at the scene of the incident, and treatment for his alleged injuries. POSSIBLE PRIMARY WITNESSES - 0 th Avenue, Ste 0 Seattle, WA TEL: (0) -000 FAX: () 0-0
0 0 incident. incident.. David Moberg c/o Mark Conforti Todd A. Bowers & Associates 0 th Avenue, Ste 0 Seattle, WA Defendant David Moberg has knowledge of the facts and circumstances of the subject. Candice Moberg c/o Mark Conforti Todd A. Bowers & Associates 0 th Avenue, Ste 0 Seattle, WA Defendant Candice Moberg has knowledge of the facts and circumstances of the subject. Billing Record Custodian EMEDEX SW st Street Renton, WA 0 () - Camila Knackstedt, O.T. Christine Louie, P.T. Michelle McMullen, O.T. Kyle Mendes, P.T. Outpatient Physical Therapy 00 S 0th Street, Ste Kent, WA 0 () - Phuc Phung, M.D. 0 0th Ave SE Kent, WA 00 () -000. Chad Maloney, PA.c. POSSIBLE PRIMARY WITNESSES - 0 th Avenue, Ste 0 Seattle, WA TEL: (0) -000 FAX: () 0-0
0 0 Erik Novak, M.D. Niket Shrivastava, M.D. Proliance Orthopedic Surgeons 0 Talbot Road S. Suite 00 Renton, WA 0 () -00 Record Custodian Rite Aid Pharmacy 0 00 Southeast th Kent, WA 00 () - Person with Most Knowledge Valley Ambulatory Surgery Center 0 Talbot Road, South, Suite 0 Renton, WA 0 Billing Record Custodian Valley Anesthesia Associates 00 S rd St. Renton, WA 0 () -0 John Bauman, M.D. Jeffrey Fountain, D.O. Valley Diagnostic Imaging Services Olympic Bldg 00 SW rd St Renton, WA 0 () -0 Andrew Homer, M.D. Russell Spies, M.D. Jun Wei-Behr, M.D. Valley Medical Center 00 S rd St Renton, WA 0 () - POSSIBLE PRIMARY WITNESSES - 0 th Avenue, Ste 0 Seattle, WA TEL: (0) -000 FAX: () 0-0
0 0 The above listed health care providers have provided service to Plaintiff Ronald Giesen. These physicians will testify, amongst other things, regarding Plaintiff's physical health and mental health at the time of their treatment of Plaintiff. They will also testify as to the impact, if any, of Plaintiff's treatment, condition, medication, surgical procedures and prognosis before the subject incident upon Plaintiff's pre-existing condition(s) as well as future prognosis.. Any and all employers who may have provided employment to Plaintiff Ronald Giesen and have knowledge of Plaintiff's health and physical condition at or around the time of Plaintiff's employment.. Any and all insurance companies who may have provided service to Plaintiff Ronald Giesen, and have knowledge of Plaintiff's mental and physical health condition on or around the times and dates of their respective service to Plaintiff Ronald Giesen.. Records custodians of any and all of Plaintiff Ronald Giesen's medical, employment, education, insurance, financial, tax, worker s compensation, governmental assistance and other records pertaining to Plaintiff. Plaintiff already has knowledge, or access to, these records, and their respective authors or makers. These records custodians have knowledge of the identity and authenticity of these records, respectively, sufficient to establish a foundation for the admission of these records into evidence at trial. Further, all records custodians identified in discovery may be called as witnesses. Sean Ghidella, M.D. c/o Advanced Medical Group First Avenue Northwest Issaquah, WA 0 () -00 EXPERTS POSSIBLE PRIMARY WITNESSES - 0 th Avenue, Ste 0 Seattle, WA TEL: (0) -000 FAX: () 0-0
0 0 Patrick Bays, D.O. c/o Advanced Medical Group First Avenue Northwest Issaquah, WA 0 () -00 Defendants Moberg may retain either Sean Ghidella, M.D. or Patrick Bays, D.O., doctors of orthopedics. The doctor chosen is expected to review Plaintiff Ronald Giesen s medical records and conduct an independent medical examination of Plaintiff, and give an opinion as to the causal relationship, if any, of any physical complaints of Plaintiff to the accident; the reasonableness, necessity and costs of any treatment for same; and the prognosis for resolution of these alleged injuries and damages. This expert will base his opinion upon a review of Plaintiff health care records, his examination of Plaintiff, and his knowledge and expertise in the field of orthopedics. OTHER WITNESSES Defendants Moberg reserve the option to call or cross-examine any of the witnesses that this Court permits Plaintiff to call during his case. RESERVATION OF RIGHTS. Defendants reserve the right to supplement this list.. Defendants reserve the right to identify and call any and all additional medical providers and/or records custodians whose identities and addresses are unknown to them at present or whose identities are revealed through further discovery.. Defendants reserve the right to call as witnesses any person disclosed by any other party in their primary or additional witness lists as well as persons identified in answers to discovery requests or in depositions including but not limited to family members, friends and associates with factual knowledge. POSSIBLE PRIMARY WITNESSES - 0 th Avenue, Ste 0 Seattle, WA TEL: (0) -000 FAX: () 0-0
0. Defendants reserve the right to name any additional experts deemed necessary to support their defense or rebut any expert witnesses named by any other party in the future.. Defendants reserve the right to call any witnesses necessary to lay a sufficient foundation or authentication for documentary evidence.. Defendants reserve the right to strike any witness they have disclosed and to withdraw any disclosed witness and consider him or her a consulting witness pursuant to Mothershead v. Adams, Wn. App., P. d ().. Defendants reserve the right to retain additional experts to testify in rebuttal to any expert witness identified or presented by any other party.. Defendants reserve the right to supplement this list to include witnesses to rebut or address the testimony of any witness whom any other party in this litigation discloses.. Defendants reserve the right to call any fact witness listed above as an expert witness, as appropriate. 0. Defendants reserve the right to identify additional expert witnesses and to call additional expert witnesses at the time of trial and/or offer additional expert opinions by the above named experts pursuant to Burnet v. Spokane Ambulance, Wn. d, P. d 0 () and Jones v. City Of Seattle, Wn. d,, P. d 0 (0). DATED this nd day of March, 0. 0 By: Mark Conforti, WSBA # Attorney for Defendants Moberg POSSIBLE PRIMARY WITNESSES - 0 th Avenue, Ste 0 Seattle, WA TEL: (0) -000 FAX: () 0-0
0 DECLARATION OF SERVICE I hereby declare under the penalty of perjury under the laws of the State of Washington that I have served a true and correct copy of the foregoing, except where noted, upon the individual(s) listed by the following means: Pierce County Superior Court Clerk 0 Tacoma Avenue S, Room 0 Tacoma, WA 0 [X] E-Filed Thomas M. Adkins Adkins Law, PLLC PO Box Federal Way, WA 0 Tom@ThomasAdkins-law.com [X] E-Service 0 DATED: March, 0 By: Name: Title: Amber Tibbot Legal Secretary POSSIBLE PRIMARY WITNESSES - 0 th Avenue, Ste 0 Seattle, WA TEL: (0) -000 FAX: () 0-0